vvEPA
Region V
United States
Environmental Protection
Agency
Water Division
230 South Dearborn Str
Chicago, Illinois 60604
JANUARY 1983
905R83110
TTTT V '* "ซ&*.
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11 ?.iป*
Final-Generic
WASTEWATER MANAGEMENT IN
RURAL LAKE AREAS
-------
C
VrX
I
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
23O SOUTH DEARBORN ST.
CHICAGO. ILLINOIS 606O4
REPLY TO ATTENTION OF:
5WFI
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS:
The Final Generic Environmental Impact Statement (EIS) for Wastewater Management
in Rural Lake Areas is provided for your information and review. This EIS has
been prepared in compliance with the National Environmental Policy Act of 1969,
and the subsequent regulations prepared by the Council on Environmental Quality
and this Agency.
Upon publication of a notice in the Federal Register, a 30-day period will com-
mence during which this Agency will not take any administrative actions. After
30 days, EPA may take certain administrative actions in accordance with this
Final EIS.
Sincerely yours,
Valdas V. Adamkus
Regional Administrator
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UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
230 SOUTH DEARBORN ST.
CHICAGO, ILLINOIS 60604
REPLY TO ATTENTION OF:
5WFI
Dear Reader:
This Region is completing a five-year effort to develop methods and to analyze
issues involved in wastewater management for unsewered communities. This Final
Generic EIS is one of the principal products of our efforts. We feel that this
document reflects the state-of-the-art of rural wastewater management.
The strength of our results derives in large part from the comments and sugges-
tions made by citizens and officials in the seven case study communities, and
by interested State and Federal officials. An EIS, however, only makes recom-
mendations. It is people at all levels of government, in many private companies,
and in numerous small communities that put these recommendations to work.
Therefore, we are seeking your comments and suggestions on a number of the EIS
recommendations so that we will know which ones are likely to be put to work,
and which ones should be emphasized in our management of the Construction Grants
program.
If you read the EIS, please complete the survey and return it to us at the
address printed on the last page. Attach any other written comments that you
may have in the spaces on the survey form itself.
If enough surveys are returned (10% or more), we will prepare a brief report
summarizing the results. To receive a copy of the report, check off the space
at the top of the next page.
Thank you for your interest in wastewater management and clean water.
Sipcjerely yours,
k i
Chief, Unit
Environmental Impact Section
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. , _, . _T^ , January 1983
Final Generic EIS for I
Wastewater Management in Rural Lake Areas
READER OPINION SURVEY
Name:
Address: j~jl would like a copy of
the Survey Summary
Job Title:
Type of Employer (check any that are applicable) :
Q Local government Q Environmental Q On-site system
D,_ . , protection construction
State government c
D^ , , , I [Public works I I Septic tank service
Federal government ' i ' ' -^
D Private organization D Public health Q Other wastewater -
H0 ., . , [>t^r government construction
Qself-employeed LJ y Hother wastewater -
DL, Equipment supplier ' '
Other: - UJ ^ ฃ manuf a^urer operation
construction DConsultini3
D^/E firm
LjPublic interest group
Qdo
I have a decision-making role in wastewater management for
1 1 ฐ no Q one or [_]more communities.
Ddo
I have a staff or advisory role in wastewater management for
' ' ฐ no LJone or | _ | more communities.
If you are a sanitarian, public health officer, an elected official, or are
otherwise responsible for public health or water quality, do you know the
numbers and types of on-site system failures in the places you are
responsible for?
GNO
LJNo, there are no on-site systems in my area
Oi I don't deal with on-site systems.
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Page 2
If you are not responsible for public health or water quality, do you think the
persons who are responsible in your community know the numbers and types of
failures?
Q]Yes,they do
LJNo, they don't
QJMaybe, but the only existing on-site systems they have time to
inspect are the ones they get complaints about.
[ II don't care
L_]My community is sewered
Comment:
A principle theme of the Generic FIS for Wastewater Management in Rural Lake
Areas is the benefits of increased community roles in monitoring and ntainl <--,in j n<_
on-site systems. Do you have opinions about the types of agencies best suited
to define and implement those roles:
LJHealth officer or health depar tnu-n l
LJ Public works department
LJPrivate firms under contract to county or local government
LJSpecial purpose district
[_JExpanded role for existing sanitary or water and sewer district
|__JDepends on local preferences, state requirements, politics, etc.
Comment:
There are several ways that communities can improve the maintenance that is
provided for on-site and small-scale wastewater facilities. which would you
prefer?
^JRenewable permits requiring verification that an approved
contractor inspected and serviced the system
J__JMaintenance and inspection services provided by management
agency personnel
Maintenance and inspection services provided by contractors to
a management agency
Qpublic education
j^JDepends on how much liability a management agency assumes for
fixing future failures
Gl Other: __ _ __ _
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page 3
Local officials and other community leaders have a variety of reasons for wanting
improved wastewater facilities. Rate the following reasons for their effect in
motivating action in unsewered communities with which you are familiar:
(0=1 really don't have a feelincr for this.
1 = Relevant only in applications for grants and loans.
2 = Useful at public meetings and with the Citizens Advisory Committee.
3 = A responsibility of municipal and county governments requiring
con t i nu ed s tudy.
4 = Might get a project through a referendum.
5 = Hot enough to get re-elected with. )
Circle one Reasons Comments
0
0
0
0
0
1
1
1
1
1
2
2
2
2
2
3
3
3
3
3
4
4
4
4
4
5
5
5
5
5
Protecting the public health
Improving property values
Facilitating industrial development
Avoiding prosecution
Protecting lakes and streams for
recreational use
012345 Facilitating residential development
012345 Facilitating commercial development
012345 Abating odor and visual nuisances
012345 Protecting groundwater quality
012345 Protecting drinking water supplies
012345 Allowing present residents to add
water using appliances or house
extensions
012345 Other:
012345 Other:
New on-site and small-scale technologies can overcome some of the natural
constraints to standard septic tank systems. But they generally require more
maintenance and should be inspected more frequently. Would you support
establishment of management agencies that provide inspection and maintenance
services for the purpose of facilitating development on property not suited for
standard septic tank systems? (Please note that the Generic EIS makes no
recommendation on this issue. )
LJonly where it is technically feasible to sewer if the technologies
don ' t work
Comment :
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Page 4
A number of concepts are presented in the Generic EIS for Wastewater Management
in Rural Lake Areas that would have utility in any unsewered community. Based
on your knowledge of small communities and sanitation without sewers, how useful
do you expect the following concepts to be in planning or managing an optimum
operation alternative:
( 0=1 have no feeling for it, or I didn't understand the EIS
1 = Destined for oblivion
2 = Appropriate only in special cases
3 = Usefulness depends on characteristics of each community
4 = Has merit, but I'd like to see someone try it out first
5 = Ought to be considered in any plan or management program. )
Final EIS
Circle One Page Ref. Comments
012345 Decision Flow Diagram for 31
existing on-site systems
012345 Use of performance data to 28-
decide what to do with 29
existing on-site systems
012345 Sequencing data collection 54-
and alternative development 58
tasks
012345 Early identification of Small 66
Waste Flows districts using
results of the Cost Variability
Study
012345 Use of Average Annual Homeowner 68-
Cost to compare local economic 69
impacts of alternatives
012345 Matching management agency 76-
responsibilities to failure rate, 79
housing density, and sensitivity
of water resources
012345 Management agency liability for ฐฎ~
fixing system failures ฎ1
012345 Public ownership of on-site ฐ^~
systems ฐ^
012345 Sanitary Review Board input to 83-
management agency decisions ฐ^
012345 Construction variances for 84-
non-conforming upgrades 85
012345 Usage variances for continued ^4-
use of non-conforming systems ^5
012345 Reserve fund to pay for future ^2
repairs and upgrades
012345 Concurrent land use and waste- 109-
water facilities planning 112
012345 Environmental Constraints 109-
Evaluation 110
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Page 5
012345 Nomograph for identifying lakes 114-
that are sensitive to nutrients 117
from on-site systems
012345 Simplified easement form 130-
131
Many communities that implement an optimum operation program for on-site systems
will have a few properties where holding tanks or some other expensive facilities
are required. Would you
Qrequire those residents to pay the full cost of operating and
maintaining their facilities?
[^subsidize part of the cost out of user charges or general government
funds ?
Qhave everyone pay the same user charge regardless of the cost for any
one type of system?
[^There's no way residents in my community would ever pay a user charge
for their own on-site system.
Comment:
There are a number of things that regional, state or Federal agencies could do to
help communities achieve the economic and other advantages of Small Waste Flows
management. In light of budget restrictions and the problems in getting new
efforts staffed and funded, how would you rate the following initiatives:
(0=1 don't understand what this initiative involves
1 = No socially redeeming value
2 = Sounds useful, but later
3 = The staff likes it, but they are hesitant to propose it to the head
of the agency
4 = This should have been done already
5-1 don't care how many have been laid off or what the rest are doing.
Get this done. )
pinal
_ Circle one _ Page Ref. _ Comments
012345 Development of a standardized 53-
information system for use in 54
both local record keeping and
regional or state correlations
of on-site system performance
with soil, use, site, design, age,
and maintenance characteristics
012345 Request the US Department of 127-
Labor to change the classification 128
of small waste flows projects from
heavy construction to commercial
or residential
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Page 6
012345 Comprehensive evaluations of 132
state roles in the management of
existing and future on-site systems
012345 Amendment of state regulations 132
for on-site systems that outlines a
process for deciding to abandon,
upgrade, or continue using "as is"
existing on-site systems
012345 State legislation giving local 132
governments explicit authority to
manage on-site systems throughout
their life cycle
012345 Analysis of state laws regarding 132
rights of access for management
agencies to enter private property
012345 Coordination of pilot Small Waste 132
Flows projects in several different
settings to test innovative tech-
nologies and management methods
012345 Municipal Needs Analysis for 133
small communities not participating
in the US EPA Construction Grants
program
012345 Separate state Construction Grants 133
priority lists for small communities
012345 State or regional management and 133-
technical assistance for small 135
communities in planning, designing,
or implementing projects
012345 Training programs for small 136-
system specialists 137
012345 Homeowner education programs 137
and materials
012345 Listings of approved small system
specialists such as installation
contractors, soil testers, designers
survey specialists, inspectors,
management planners, etc.
012345 .Analysis of toxic substances and 144
viruses in wells of selected
communities and correlation with
septic waste disposal
Thank you for your response.
Please fold forms in three sections, staple, and mail to the address printed
on the back of the last page.
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Staple here
Fold
From:
Place
Stamp
Here
Jack Kratzmeyer
U.S. Environmental Protection Agency
Municipal Facilities Branch
Environmental Impact Section (5WFI)
230 South Dearborn Street
Chicago, Illinois 60604
Fold
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FINAL
GENERIC ENVIRONMENTAL IMPACT STATEMENT
for
WASTEWATER MANAGEMENT IN RURAL LAKE AREAS
Prepared by the
United States Environmental Protection Agency
Region V, Chicago, Illinois
and
WAPORA, Incorporated
January, 1983
U.S. Environmental Protection Agency
Region V, Uhnry
230 Suuti; D-.^orn Gtrcet
Chicago, Illinois 60604
Approved by:
Valdas V. Adamkus
Regional Administrator
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U,S. Envlronrrtarrtal Protection Agency
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FINAL ENVIRONMENTAL IMPACT STATEMENT
WASTEWATER MANAGEMENT IN RURAL LAKE AREAS
Prepared by
U.S. Environmental Protection Agency, Region V
for further information, contact:
Mr. Jack Kratzmeyer, Project Monitor
Water Division, LISEPA
230 South Dearborn Street
Chicago, Illinois 60604
312/353-2157
Abstract
This EIS examines the environmental, economic and social costs within Region V
of rural lake wastewater planning especially as funded and managed under the
Clean Water Act. It reviews and analyzes facilities planning and environmental
review methods for rural lake areas.
It uses seven sample projects of this type to present specific recommendations
about development and management of on-site and small scale alternatives to
conventional wastewater treatment. It recommends specific methods to document
project need and water quality impact. It concludes that wherever continued
operation of a substantial percentage of existing systems is feasible, a waste-
water management program based on optimum operation of existing systems will
result in substantial savings in capital and present worth costs.
The EIS offers a complete manual for planning, construction and management of
decentralized rural lake projects with or without Federal or State assistance.
It can be used, and contains specific advice for projects operating under both
old (1977) and new (1981) Construction Grant Amendments. Reasonable use of the
methods outlined here for construction grant applications already in hand will
"esult in an estimated savings exceeding $460 million in Region V alone.
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TABLE OF CONTENTS
Section
Final EIS
Executive Summary
Terminology
List of Tables/Figures
Chapter I: WHAT THIS EIS DOES AND WHY (PURPOSE OF AND NEED FOR ACTION)
A. What it is About (Scope)
B. What does it Wish to Accomplish and How Does it Propose to do it
(Proposed Actions)
C. Why Do These Things Need to be Done (The Need for Action)
Chapter II: SMALL WASTE FLOWS TECHNOLOGIES
A. On-Site Systems
B. Small-Scale Off-Site Treatment
C. Needs Documentation Policies
D. Needs Documentation Methods
E. Designing an Optimum Operation Alternative
F. Cost Analysis
G. Self-Help and Use of Consultants in Needs Documentation,
Facilities Planning, and Detailed Site Analysis
H. Use of Segments in Planning and Implementation
Chapter III: COMMUNITY MANAGEMENT
A. The Need for Management
B. Six Community Management Models
C. Design of Small Waste Flows Management Programs
D. Public Involvement in Agency Design and Operation
E. Use of Variances
F. Access Considerations
G. Implementing Water Conservation Programs
H. Monitoring Groundwater and Surface Water
I. Recovery of Local Costs
J. Broader Responsibilities of Public Agencies Related to Rural Wastewater
Management
K. Personnel
L. Revising the Management Program
Chapter IV: FACILITIES PLANNING TECHNIQUES
A. Planning Area Definition
B. Demography
C. Categorical Exclusions from Environmental Review
D. Land Use and Environmental Constraints
E. Water Resources
F. Financial Impacts
G. Public Participation
Paee
i
iii
xix
xxi
4
10
21
23
34
38
44
54
60
69
70
73
75
77
79
83
84
86
87
88
91
93
94
95
97
99
103
109
109
113
118
121
Chapter V: FUNDING AND ADMINISTERING THE OPTIMUM OPERATION ALTERNATIVE--MITIGATING MEASURES 123
A. Federal Concerns
B. State Concerns
C. Training
D. Does Anyone Want the Small Waste Flows Approach?
125
132
136
137
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TABLE OF CONTENTS--Continued
Section Page
Chapter VI: ENVIRONMENTAL AND SOCIAL CONSEQUENCES OF THE PROPOSED ACTION 139
A. Water Quality Impacts 141
B. Environmentally Sensitive Areas 144
C. Economic Impact 146
D. Land Use 148
E. Resident Privacy and Inconvenience 149
Chapter VII: COMMENTS ON THE DRAFT EIS AND RESPONSES 151
Chapter VIII: COORDINATION 169
List of Recipients
List of Preparers
Index
Bibliography
Appendices
Region V Needs Documentation Guidance and Alternative Construction Grants A-l
Procedures for Small Waste Flows Areas
On-Site Sanitary Inspection Form B-l
Steuben Lake Limited Action Cost Sheets C-l
Otter Tail Limited Action Cost Sheets D-l
Table of Contents for the Technical Reference Document E-l
Deletions from the Draft EIS F-l
Cross-References
Throughout this document cross-reference notes are printed in the margins. These
notes refer either to related sections within the document (e.g., EIS I-C-2) or to sections
of the separately published Technical Reference Document (e.g., TRD II-A). The Table of
Contents for the Technical Reference Document is reproduced in Appendix E.
The issues and the format of this Final EIS are substantially the same as the Draft
EIS. Changes have been made to reflect new law, regulations, and guidance for the
Construction Grants Program. These changes are identified by a cross-reference to relevant
sections of the Clean Water Act (e.g., 201 (1)(2)), new Construction Grants regulations
(e.g., 40 CFR 35.2110), or Construction Grants - 1982, the new program guidance document
(e.g., 6.2). Changes have also been made in response to comments on the Draft EIS and to
incorporate improved discussions of the topics. Cross-references to comments on the Draft
EIS, whether a change was made or not, appear in the margins (e.g., C.26). All changes
from the Draft except editorial and typographical are identified by underlining.
Legend for Cross-References in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published
separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates
change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which
necessitates change in the text
CG 82-6.2. Section of the program guidance document, Construction
Grants - 1982, upon which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed
(see Chapter VII)
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FINAL EIS
The Draft Environmental Impact Statement for Wastewater Management in Rural
Lake Areas (Draft EIS) was distributed to the public and to concerned
agencies in September, 1981. In December 1981, shortly after the end of
the comment period for the Draft EIS, Congress passed Public Law 97-117
amending the Clean Water Act. Also, the U.S. Environmental Protection
Agency has revised the regulations covering the Construction Grants program
and has consolidated applicable guidance documents. Completion of the
Final EIS was deferred until the regulations and guidance were available in
interim final and draft form, respectively.
The following changes in the law, in the regulations, and in program
guidance have had significant effects on what is presented in this
Environmental Impact Statement:
Municipal Wastewater Treatment Construction Grant Amendments of 1981,
Public Law 97-117, enacted December 29, 1981
After December 29, 1981, no grants will be made solely for facilities
planning (Step 1) or for design (Step 2). However, Grants for building
(Step 3) shall include an allowance for facilities planning and design
based on a percentage of total project cost.
States shall reserve a portion of their annual allotment to advance
allowance funds to small communities which would not otherwise be
financially able to complete an application.
Increased funding for alternative and innovative technologies is
continued through fiscal year 1985.
Field testing of alternative and innovative processes or techniques are
grant eligible costs.
Grant applicants are encouraged to develop capital financing plans.
After October 1, 1984, grants will not be made for collector sewers
except that the Governor of a state may elect to use up to 20 percent of
a state's allotment to fund facilities which were previously ineligible,
such as collector sewers.
40 CFR Part 35, Grants for Construction of Treatment Works
A new Subpart I is added in which only items required by statute and
minimum requirements for effective program management are included.
Emphasizes that the need for proposed facilities will be investigated
during facilities planning.
Requires consideration of on-site systems in unsewered communities of
10,000 or less.
Requires analysis of cost impacts of selected alternatives on users.
Subpart E regulations remain in effect for grants approved before May
12, 1982.
Construction Grants - 1982
Guidance for all three steps for the Construction Grants Program is
consolidated in this new document.
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This document and its predecessor, Facilities Planning 1981, cancel and
replace documents (PRM's and POM's) which had the effect of Agency
policy. However, guidance offered in Construction Grants - 1982 and not
duplicated in Subpart I of the regulations is considered now to be
suggestions of good practice, not requirements.
Because of these changes, significant elements of the Draft EIS needed to
be reconsidered and revised, especially needs documentation policy, funding
of field work, and the level of detail required for describing facilities
plan proposed actions. See notes at the end of the Table of Contents
explaining how these and other changes from the Draft EIS are identified.
Since grants approved before May 12, 1982, are still subject to pre-
existing regulations and guidance, parts of the Draft EIS which are deleted
or significantly revised are repeated in Appendix F for ready reference.
11
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EXECUTIVE SUMMARY
What This EIS Does and Why (Purpose of and Need for Action)
This EIS examines a number of Federal actions, especially U.S. EPA review
and approval of facilities plans in unsewered rural lake communities or
parts of them.
Seven earlier EIS's on rural lake sewering projects, comprising 35 lakes in
five states, were the case studies for this EIS. They provided the
identification of issues and much of the analysis and data used here. The
two major findings of these EIS's are:
that wastewater management based on optimum operation of existing on-
site systems differs substantially from either new centralized facili-
ties or new small waste flows facilities, and
ซ that wastewater management based on existing systems allows substantial
savings in capital costs and operation and maintenance expenses,
compared with centralized facilities. This occurs wherever continued
operation of a substantial percentage of systems is feasible, while
still meeting water quality objectives.
The six projects recommended for implementation in the EIS's offered
present worth savings of approximately $44 million or $5,220 per dwelling
unit compared to conventional sewering. If this savings can be achieved
for just the 80,000 additional unsewered dwellings in lake communities, the
total regional present worth savings for lake projects funded through 1985
could be as high as $460 million.
Savings from this recommended wastewater management approach, if applied to
that percentage of dwellings in the Region that might otherwise be sewered,
are estimated to be $1.9 billion or $4,436 per dwelling. These 430
thousand dwellings represent 13% of the 3.3 million dwellings in the Region
now served by on-site systems.
Within Region V there are 1,121 applications for Construction Grants funds
on file from communities under 10,000 population. Of these communities an
estimated 372 include developed lakeshores. Based on past funding
experience, most of these communities will apply for new collector sewers
to serve areas now using on-site systems.
To realize the cost savings of optimum operation alternatives while
achieving water quality goals requires adequate data on the performance of
existing on-site systems. This performance data is almost always lacking.
Surveys conducted indicate a much lower failure rate than would be
predicted from site limitations. Large sums may be spent needlessly if
valid performance data are lacking, or if site suitability is wrongly
evaluted. This demands the collection and objective analysis of
performance data and corollary information such as on-site system design,
usage, maintenance, soils, site constraints, groundwater hydrology, and
surface drainage.
Partly due to the lack of data, on-site systems are blamed for problems
they have not, in fact, caused. On-site wells are more often contaminated
by surface water entering them because of poor construction than by gross
contamination of the aquifer by on-site wastewater systems. Eutrophication
of lakes is also blamed on on-site systems yet precipitation and non-point
sources almost always are far larger sources of limiting nutrients.
111
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This does not mean that on-site systems cause no problems. Indeed, though
the flows are small and the adverse impacts are limited in scale and
severity, the significance of on-site malfunctions is amplified by the very
factor that makes them inexpensivetheir proximity to dwellings. Real
water quality and public health problems with on-site systems need to be
revealed and remedied.
A major factor in the failure of on-site systems is lack of adequate main-
tenance. Many owners simply neglect the routine preventive measures
required by their systems. Few install or even know about the simple flow
reduction devices that could prolong the life of their systems. When their
systems fail, owners are severely limited in the types of repair, upgrad-
ing, or replacement measures they may take. Off-site alternatives are
either too expensive or not implementable by the individual owners.
Public involvement and leadership could resolve many of these problems.
Yet only a limited tradition of public management for private on-site
systems exists beyond initial permitting and inspection of construction.
In response to the opportunties and the obstacles associated with the
optimum operation of existing on-site systems, this EIS proposes and
examines the following actions for implementation by Region V and state
Construction Grants agencies.
1. Encourage community supervision of small waste flows facilities.
2. Develop evaluation methods for optimum operation of existing on-site
systems.
3. Promote collection and analysis of on-site and small-scale system
performance data.
4. Review eligibility regulations.
5. Encourage states to play active roles in rural wastewater management.
6. Recommend facilities planning and impact analysis methodologies.
7. Encourage grantee evaluation and adoption of mitigating measures.
8. Encourage public participation.
9. Encourage grantees' innovation with small waste flows technologies and
community management.
Small Waste Flows Technologies
About 3.3 million on-site systems serve 22% of the population in Region V.
95% of these are septic tank/soil absorption systems or cesspools.
Inadequancies and failures of on-site systems that warrant public funding
for abatement include:
direct discharges,
surface malfunctions,
backups into the household, and
groundwater contamination at a point of use.
The significance of these failures is discussed.
Groundwater contamination is the failure with the greatest possibility for
adverse impacts on public health. Reported failure rates seldom include
groundwater failures. Generally, original sampling is the only means of
quantifying groundwater failures.
iv
-------
Reported failure rates seldom specify type. Also, reports cannot usually
be compared or combined; data collection, interpretation and reporting
methods typically are unique to each survey.
The factors that contribute to failures can be controlled to varying
degrees. Most amenable to control are usage and maintenance of the system
and surface drainage. Other factors such as system design, soil charac-
teristics, and groundwater hydrology can be controlled by upgrading or
replacing the on-site facilities. Some factors can only be overcome by
transporting wastes off-site.
Many options exist for preventing and correcting failures of on-site
systems. Some, listed in the text, are described more fully in the fact
sheets of the accompanying Technical Reference Document.
Field studies of on-site system performance in the Seven Rural Lake EIS's
showed total failure rates (including groundwater failures in several
cases) significantly lower than indicated by the percent of systems not
complying with current design codes. The successful performance of many
subcode systems suggests that code conformance is not the best criteria for
deciding the fate of existing on-site systems. The intent of design codes
is to prevent water quality and public health problems. If that is being
done by subcode systems, then upgrading, replacing, or abandoning the
systems is unjustified.
Similarly, soil type and conventional criteria for soil limitation ratings
(slight, moderate, and severe limitations) are not suitable criteria for
deciding the fate of existing systems. Empirical data relating soil
characteristics to system performance at the local level can be readily
obtained during sanitary surveys and are an integral element of optimum
operation alternatives.
The text contains a decision flow diagram of a recommended sequential
approach to selecting appropriate technologies for individual existing
systems. The sequence is divided into five steps including 1) available
data review and community surveys, 2) on-site sanitary inspection, 3)
identification of problem, 4) detailed site analysis, and 5) technology
selection.
Any community will have some developed properties where sewering is not
economically feasible, and upgrading or replacement of the existing soil
absorption system alone may not solve failures or prevent future failures.
In such cases, consideration should be given to use of one or more of the
following technologies:
flow reduction,
water metering,
segregation of waste streams,
reuse/recycle,
holding tanks, or
effluent plume recovery.
Where local conditions make on-site options infeasible or non-cost-
effective, small scale off-site collection and treatment technologies may
solve existing problems. Collection methods include conventional gravity,
small-diameter gravity, pressure, and vacuum sewers. In lake watersheds
where effluent discharges are discouraged, preferred small scale treatment
technologies are subsurface land application (large drainfields called
cluster systems) and surface land application by irrigation or
infiltration - percolation. Where discharges to surface water are
acceptable, treatment options expand to include use of recirculating sand
filters with surface discharge, land application by overland flow, wetlands
discharge, lagoons, fixed film treatment plants and activated sludge
treatment plants.
-------
All optimum operation alternatives will also include off-site treatment and
disposal of septage and, where generated, holding tank wastes. General
options include land application (may be limited to stabilized septage),
treatment in a wastewater plant and treatment in a separate septage plant.
Aside from selecting appropriate on-site technologies, performance data are
also required to determine the eligibility of collector sewers. The role
of performance data, cost-effectiveness, and "substantial human habitation"
in eligibility determinations for collector sewers is illustrated in a
decision flow diagram in the text. The decision flow diagram is based on
national policy contained in Construction Grants 1982.
Region V's guidance on performance data collection (needs documentation) is
based on national policy, experience gained during preparation of the Seven
Rural Lake EIS's, and input from states in the Region. The current
guidance is Appendix A of this EIS. This guidance integrates needs
documentation activities with the development, costing, selection, and
design of alternatives. Also, decision points are identified at which the
results of needs documentation work can be reviewed, and the scope of
facilities planning revised appropriately. A process diagram shows the
interaction of these two vital activities.
The EIS describes new methods of needs documentation used in the prepara-
tion of the Seven Rural Lake EIS's, some for the first time in Construction
Grants programs. It explains limits to their utility and discusses
eligibility considerations. The needs documentation methods include:
interviews with local officials and contractors,
windshield surveys,
review of soil maps,
preparation of base maps,
aerial photographic interpretation,
septic leachate detection,
mailed questionnaires,
partial sanitary surveys, and
representative sampling of soil and groundwater.
Collection of this data and later detailed site analysis generates
previously unavailable information on system performance and on factors
affecting performance. Future utility of this information will depend on
standardizing data collection and reporting methods, and providing
efficient means of storage and retrieval. This EIS recommends that Region
V, Headquarters, the Office of Research and Development, and other
divisions of U.S. EPA discuss among themselves and with concerned state
agencies ways to accomplish this.
Coordination of needs documentation work with the development and cost
analysis of optimum operation alternatives is critical to the time and cost
efficiency of facilities planning for unsewered areas. Three stages of
alternative development are described. The first is based on technology
assumptions. Available data and information from community surveys are
used to estimate the percentage of on-site systems requiring upgrading,
replacement, or abandonment. Assumptions for the technologies required are
then made and costs are estimated for comparison with sewered alternatives.
Depending on the quality of available data, this first stage of needs
documentation and alternative development may demonstrate which areas
require sewers, which require on-site upgrading, replacement or renovation,
and which require no action.
If the first stage is inconclusive or the data base does not adequately
quantify or identify the causes of on-site system failures, then a second
stage of needs documentation and alternative development may be necessary.
Partial sanitary surveys and representative sampling of soil and ground-
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water provide the basis for more conclusive analysis of failures and
feasible remedies. A major difference in needs documentation work between
the first stage and the second is that private property will have to be
entered to acquire the second stage data.
For parts of communities shown to benefit from optimum operation of on-site
systems, data from either stage one or both stages will usually suffice to
describe proposed facilities for a facilities plan. Subject to state
requirements for greater detail or site-by-site selection of funded
facilities, the minimum elements to describe proposed facilities for an
optimum operation alternative are:
* descriptions of the common type of on-site system failures in the area
with known, on-going failures located on a map of the planning area,
analysis of the site, usage, or design factors which cause the failures
technology selection criteria which relate local problems and their
causes to feasible structural and non-structural solutions
the estimated number of on-site systems requiring upgrading, replacement
or renovation, and
the approximate mix of methods estimated to be required to correct fail-
ures .
The final stage of development for optimum operation alternatives involves
investigations of each on-site system that might require funding, and
selection of specific technologies and their design for individual
properties. These investigations would include at least an interview with
the resident and inspection of the property (on-site sanitary inspection).
Detailed site analysis to verify performance or to refine design parameters
would be conducted as necessary (see Figure II-A-1).
This EIS contains special cost curves developed for preliminary comparison
of on-site, small scale off-site, and centralized alternatives. This level
of analysis can determine the alternatives to consider for a Plan of Study
(Step 1 grant application) and estimate the cost of various technology
assumptions. It can be used for community-wide cost analysis or segment-
by-segment within a community. Alternatively, present worth costs can be
developed at this stage using local unit costs and technology assumptions.
After system selection, more detailed present worth calculations are
possible. Comparison of centralized alternatives with optimum operation
alternatives should include items not common to both. Eligible and
ineligible publicly funded items as well as privately purchased items
should be included for all alternatives.
After the sanitary survey and detailed site analysis, facilities verifica-
tion may depend on micro-scale cost-effectiveness analysis for individual
lots or groups of lots. In particular, comparison of higher risk on-site
systems with holding tanks, cluster systems or other off-site technologies
may require this most detailed level of cost analysis.
Because the cash flow characteristics of centralized alternatives differ
greatly from optimum operation alternatives, an average annual homeowner
cost is described for use in local economic impact analysis. All local
public and private costs committed for the initial year of operation are
divided by the number of dwelling units served.
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Community Management
Governmental concern with the use of on-site systems has reflected
perceived and actual inadequacies of early systems. At present, most
governmental authorities regulate the installation of new systems and can
require upgrading and replacement of failing on-site systems. However, few
authorities have accepted the responsibility for supervising the operation
and maintenance of on-site systems.
The 1977 Clean Water Act recognized the need for continuing supervision of
on-site system operation and maintenance. U.S. EPA Construction Grant
regulations and program guidance which implement the Act require that
before a construction grant for on-site systems may be made, the applicant
must meet several requirements, including:
Certify that such treatment works will be properly operated and
maintained...
Demonstrate the legal, institutional, managerial, and financial
capability to ensure adequate building and operation, maintenance and
replacement of the treatment works
Provide assurance of access to the systems at all reasonable times for
such purposes as inspection, monitoring, building, operation, rehabili-
tation, and replacement.
These and other relevant requirements for the management of funded on-site
facilities are broadly stated so that a wide range of management programs
is possible.
If on-site systems impacted water quality and public health only for the
properties on which they lie, the community would not be concerned with
anything that happens on private property. However, on-site systems can
have off-site impacts. Density of development, failure rates, and sensi-
tivity of water resources may lead to impacts requiring community action.
The EIS describes five general management models reflecting different
degrees of community authority and involvement.
The design of small waste flows management programs reflects existing or
projected community characteristics and potential consequences of program
design decisions. Specific factors are listed in Table 1.
Six steps that may be taken in designing a management program are:
1. inventorying factors affecting the design process,
2. making decisions on system ownership and liability,
3. identifying services to be provided,
4. determining how selected services will be performed,
5. determining who will be responsible for providing services, and
6. implementing the management program.
Three of the steps select, specify procedures, and assign responsibility
for services to be provided. Table 2 lists potential services. They are
more fully described in the Technical Reference Document, Chapter VI-A.
A public management agency need not provide all of the selected services or
even be a new agency. Private contractors and homeowners could provide
several non-regulatory services under agency supervision. Existing
agencies could agree to cooperate in running the management program without
creating a new level of government.
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TABLE 1. FACTORS TO BE CONSIDERED IN THE DESIGN OF SMALL WASTE FLOWS MANAGEMENT PROGRAMS
Existing or Projected Community Characteristics
types of wastewater facilities utilized and proposed,
expertise available to the community,
size of the community or management district and number of systems in use,
available regulatory authority,
community jurisdictional setting,
community attitudes toward growth, and
community attitudes toward public management of private wastewater facilities.
Potential Consequences of Program Design Decisions
costs, including initial costs and economic impact of failures,
environmental impacts, especially impacts on water resources, and
level of risk assumed by various parties.
TABLE 2. POTENTIAL MANAGEMENT PROGRAM SERVICES
Administrative
Staffing
Financial
Permits
Bonding
Certification programs
Service contract supervision
Accept for public management privately installed facilities
Interagency coordination
Training programs
Public education
Enforcement
Property/access acquisition
Technical
System design
Plan review
Soils investigations
System installation
Routine inspection and maintenance
Septage collection and disposal
Pilot studies
Flow reduction program
Water quality monitoring
Planning
Land use planning
Sewer and water planning
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Factors affecting the design of a community's management program are
discussed including:
public involvement in agency design and operation,
use and construction variances,
gaining access to on-site systems,
implementing water conservation programs,
monitoring groundwater and surface water,
recovery of local costs,
personnel, and
revising the management program.
Facilities Planning Techniques
An early task in the Construction Grants process is delineation of
facilities planning area boundaries. There are several factors to be
considered in doing this. For rural areas where the optimum operation
alternatives may be selected, planning areas should be large enough to take
advantage of economies of scale in management program costs.
The Cost Variability Study prepared for this EIS provides environmental and
developmental criteria to identify at an early stage planning areas where
optimum operation may be cost-effective. Table 3 indicates housing
densities below which even extensive (50%) replacement of on-site
facilities will be cost-effective compared
TABLE 3. TRADE-OFF DENSITIES (IN HOMES PER MILE) ABOVE WHICH OFF-SITE FACILITIES ARE
COMPETITIVE. BASED ON 50% REPLACEMENT OF ON-SITE SYSTEMS AT 0% AND 50% GROWTH.
(Revised from the Draft EIS)
Collection Centralized Land Cluster
Scenarios only treatment application system
0% 50% 0% 50% 0% 50% 0% 50%
1 No constraints 45 69 93 125 - - -
8' adc1
2 No constraints -- -- - - ~ ~
16' adc
3 Steep topography 57 81 137 - -
1 pump
4 Flat; 6' to - - - - - - - -
groundwater; peat2
5 Flat; 6' to -- -- - - - -
groundwater
6 Steep topography; 77 113 - 150 - - -
1 pump; 6' to
bedrock
7 Flat 75 109 144 - - -
8 Steep topography; 76 111 - 138 - - -
2' to bedrock; 50%
of houses need
grinder pumps
1 adc = average depth of cut.
2 Imported fill needed to replace 1,000' of peat soil.
Greater than 150 homes per mile.
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to off-site technologies. In general sewering any area already developed
with on-site systems will not be cost-effective if new transmission and
treatment facilities are needed in addition to new house and collector
sewers. Sewering becomes cost-effective at densities below 100 dwellings/
mile of collector sewers where construction problems are minimal, the area
served is near existing sewers, and capacity is available in the existing
sewers and treatment plant. For most rural areas this means the choice
between centralized and optimum operation alternatives will be based on the
ability of on-site systems to remedy water quality and public health
problems, not on present worth comparisons.
Advance planning by grantees can also expedite their facilities planning.
Steps they could take in anticipation of facilities planning include
initiation of public information programs, planning for recreational
resource development, and defining community goals and objectives for land
use and water resources.
Population projections and economic impact analysis for rural communities
are seriously limited by data availability and applicability. There are
several ways to overcome these limitations. A particular problem in rural
lake communities is projection of seasonal populations. In some cases
where population projections or residential economic impact are critical to
decision making, resident surveys or tabulation of local tax or building
permit data may be necessary.
Design codes for on-site systems have served as de facto zoning tools and
have protected some environmentally sensitive areas such as wetlands, steep
slopes and flood plains. They have also occasionally been misused to
actually prevent upgrading of existing systems. Sewers can overcome the
natural constraints that limit on-site systems. New small waste flows
technologies may partially or entirely overcome the same constraints.
Grantees can anticipate these changes by conducting environmentally-based
land use planning before or in conjunction with facilities planning.
Methods for environmental constraints evaluation are recommended that will
be useful in land use evaluations, population projections and environmental
analysis.
Consideration of water resources was consistently one of the weakest
elements in the facilities plans that the Seven Rural Lake EIS's evaluated.
Approaches to evaluating existing problems and future impacts of alterna-
tives are recommended.
Pathogen contamination of drinking waters and primary contact waters by
septic tank effluents is unacceptable and, where detected, must be abated.
Systems should be upgraded, replaced or abandoned as appropriate, provided
there is a reasonable connection between the contamination and on-site
failures. Since relevant data is seldom available, sampling of properly
constructed wells and selected leachate plumes is recommended.
Abandoning on-site systems along shorelines will seldom result in signi-
ficant change in plant productivity within the main body of lakes. A new
graphical analysis technique estimates the concentration of total
phosphorus in a lake due to on-site systems. This first-approximation
analysis requires normally available data on the number of on-site systems,
lake morphometry and lake hydrology. The results can guide subsequent
decisions whether to conduct more intensive modeling and water quality
sampling.
While effects of on-site systems on the trophic status of an entire lake
will usually be minor, localized impacts can be more apparent and of
greater public interest. Localized impacts include nearshore plant growth
stimulated by leachate plumes at their point of emergence and plant growth
stimulated by accumulation of nutrients in embayments or canals. Based on
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observations and analysis during preparation of the Seven Rural Lake EIS's,
preventing nearshore plant growth along open shorelines of a lake will
seldom be a sufficient justification for abandoning on-site systems.
However, abandonment of systems adjacent to particularly sensitive embay-
ments and canals may be justified if the plant growth impedes beneficial
uses of the water, if on-site systems are shown to contribute
substantially to the growth, and if non-point source control measures also
are implemented prior to or along with the construction of off-site
facilities.
Communities applying for U.S. EPA Construction Grants funds must demon-
strate in their facilities plans that they have the necessary financial
resources to insure the adequate construction, operation and maintenance of
proposed facilities. There are several ways to determine municipal fiscal
capabilities.
For residential economic impact analysis, this EIS recommends use of a
parameter that accommodates the very different cash flow characteristics of
centralized and optimum operation alternatives. The "average annual home-
owner's cost" amortizes first-year private and local public capital costs
at appropriate mortgage or bond periods and rates. To the annual debt
repayment are added annual administrative costs, operation and maintenance
costs and reserve fund payments. The community total for the first year is
divided by the number of existing dwelling units. Comparison of this
economic parameter with resident income characteristics provides a useful
means of economic impact analysis.
Assessment of economic impact might also include use of locally available
equipment, material, and labor. Small waste flows technologies can usually
be installed with local inputs whereas much of the equipment and labor for
centralized facilities will be imported from outside the community.
Planning for wastewater facilities in rural and developing communities
provides opportunities for public participation not available normally in
urbanized settings. In particular, the inspection, evaluation, and
construction of on-site facilities will result in numerous contacts between
residents and planning personnel. These contacts can provide a
personalized forum for explaining the purpose and methods of the project.
The contacts can also be a way for citizens to participate in the planning
process.
Disputes between property owners and facilities designers will arise over
the type of facilities to be installed, their cost or disruption to the
property. A method for dealing with such disputes is a sanitary review
board. Analogous to a zoning board, a sanitary review board would be made
up of citizens of the community who would weigh owners' concerns against
public concerns about cost, water quality, and public health.
To organize data and calculations, facilitate service area delineations,
organize field work and allow small scale analysis of socioeconomic,
environmental and land use characteristics, facilities planners may decide
to segment planning areas. Planning areas can be segmented on the basis of
soils classifications, housing or land use patterns, on-site system failure
rates, housing occupancy, or other locally relevant criteria.
Funding and Administering the Optimum Operation AlternativeMitigative
Measures
Growing awareness of the benefits available from small waste flows
management and of the obstacles to realizing those benefits has led to
numerous clarifications of the requirements of the Clean Water Act and
regulations implementing it. The December 1981 amendments to the Act,
recently revised Construction Grants Program Regulations, consolidated
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Program Guidanace, and Region V's "Guidance for Site Specific Needs
Determination and Alternative Planning for Unsewered Areas" clarify many of
these requirements. Several requirements relevant to planning, funding,
and implementing optimum operation alternatives are reviewed in this EIS
including:
On-Site Systems for Seasonal PropertiesDuration of residency is not a
determinant of eligibility where public ownership of on-site systems or
its equivalent are feasible. For on-site upgrading or replacement,
adequate access and public control, documented need and demonstrated
cost-effectiveness will allow efficient distribution of construction
grant funds.
Use of Ordinances for Access--A local or county ordinance that grants
the access (at reasonable times) and control over an on-site treatment
system is sufficient to establish public ownership and thus eligibility.
Field TestingThe 1981 amendments to the Clean Water Act authorize
Federal grants for field testing of innovative and alternative
technologies.
Conventional Water UseFacilitating unrestricted water use does not
justify abandoning on-site treatment systems if water use restrictions
and/or subcode sized drainfield replacements can protect water quality
and public health.
Potential FailuresUpgrading and replacement of existing on-site
systems identified as potential failures because of obvious underdesign
or other reasons are eligible provided they are similar to systems that
have already failed. Similarity is measured by system design, usage,
soil characteristics, site limitations and groundwater hydrology.
Simplified Easements In areas where a legal description of the
properties to be served by an on-site wastewater management district may
already be available, a simple "fill in the blanks" easement may be
adequate to fulfill the access requirements of 40 CFR 35.918-1(h) and
35.2110.
Innovative and Alternative Off-Site FacilitiesFacilities such as
holding tanks, cluster systems, sand filters with surface discharge, or
other small-scale treatment methods will be eligible only if documented
problems cannot be abated by any combination of on-site measures, or if
the present worth of off-site facilities for a dwelling or group of
dwellings is less than the present worth of the appropriate on-site
facilities for the same dwellings.
Objections to the optimum operation alternative include the claim that it
will not result in property value increases that often follow installation
of sewer systems. A theoretical case can be made for including property
value changes in cost-effectiveness analysis since they would represent
monetized social impacts. However, modification of current cost-
effectiveness analysis guidelines to allow inclusion of property value
changes is not practical at this time since there are no data or experi-
ences with which to estimate changes associated with the optimum operation
alternative. In addition, numerous cases exist where high sewer charges
have actually reduced property values.
Small contracting firms with little experience in dealing with U.S. EPA
projects may be discouraged by the Davis-Bacon Act requirements from
bidding on small waste flows projects. This would reduce competition and
possibly increase the cost of projects. To lessen the impacts of the
Davis-Bacon Act on on-site facilities contractors, U.S. EPA can request
that the U.S. Department of Labor establish project wage determinations on
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individual projects until enough data have been collected to establish
general wage guidelines for these types of projects. The Department of
Labor also should be requested to change the classification of small waste
flows projects from heavy construction to commercial or residential
construction. In addition, U.S. EPA and state Construction Grants agencies
can take the initiative to educate smaller businesses on the requirements
of the Davis-Bacon Act.
For many communities, an optimum operation alternative may require changes
in existing state regulatory and institutional requirements. This EIS
recommends that the states in Region V:
Review state policies regarding continued use of existing on-site
systems.
Develop procedural guidance for counties and municipalities to use for
evaluation, upgrading, replacement and repair of existing on-site
systems.
Specify property owners' rights in the continued use of on-site systems
and their responsibilities for repair, upgrading, or replacement with
and without a small waste flows management program.
Either test in court the implied authority of civil divisions to
implement small waste flows management programs or legislate explicit
authority for this purpose.
Review the regulatory and institutional powers of civil divisions to
gain necessary access to private wastewater systems for public manage-
ment.
Review the need for modification of variance criteria and procedures
particularly in regard to existing on-site systems.
Review state policies toward the use of innovative technologies weighing
potential risks against economic savings.
In addition to evaluating obstacles to small waste flows management, state
and regional agencies might provide planning, technical and grant or
financial administration assistance to small communities. Some of the
possibilities are summarized below:
State and regional planning agencies could assist communities in
defining local development goals and wastewater needs. Where local
goals are inconsistent with U.S. EPA goals for Construction Grants
funding, the states may assist communities in finding alternative
funding sources or in a reassessment of goals.
Planning assistance may be provided in identifying rural areas where
wastewater improvements are needed and in delineating facilities
planning area boundaries.
States could establish separate priority lists for small communities.
States could provide technical and grant administration assistance
directly or through contractors.
This EIS calls for a higher level of community management than presently
provided where needed to control the adverse impacts of on-site systems.
This will require additional trained manpower. Attempts to quantify the
necessary increase in personnel have been unsuccessful because relevant
data are not available on the manpower currently working in this field and
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on the number of small waste flows projects that might be implemented.
Training of existing and additional personnel could be provided through
university degree programs, workshops, research and demonstration projects,
on-the-job training and preservice training. Education programs should
also be directed toward homeowners and residents.
The success of small waste flows programs and the actual savings acheived
by them will be determined in large part by grantee's motives for improving
local wastewater facilities. These motives include:
avoiding prosecution,
malfunctioning septic tanks,
residential and commercial growth, and
industrial growth.
Environmental and Social Consequences of the Proposed Actions
The proposed actions will impact groundwater quality, lake water quality,
environmentally sensitive areas, local government finances, present and
future property owner economic burdens, operations of utility contractors
and local equipment suppliers, land use and resident privacy and
inconvenience.
Nitrate and bacterial contamination are the chief concerns related to
septic tank effluent discharges to groundwater. At the housing densities
and in the hydrogeologic settings studied in the Seven Rural Lake EIS's,
contamination of wells by septic tank effluent was not shown to be a
problem. The low density, linear development, and lack of fractured or
channeled bedrock in the study areas appear to preclude well contamination
even in areas of high groundwater. Indeed, high groundwater may actually
protect wells since well screens used in many glacial deposits draw water
from levels deeper than the effluent plumes.
Contamination of groundwater by viruses and toxic substances that may be
discharged with sewage are unresolved concerns. Nevertheless, insufficient
data exists to define either the prevalence or public health implications
of such contamination. Thus, while this EIS gives broad support for the
continued use of on-site systems, it also recognizes the need for better
analysis of this concern than is now possible. Therefore, Region V will
work with the states in the Region to investigate the prevalence of viruses
and toxic substances in wells. As an initital proposal, this EIS
recommends:
sampling of selected, properly protected wells previously found to
exceed bacterial or nitrate standards and suspected of contamination by
nearby on-site systems,
concurrent sampling of suspected wastewater sources, and
because of cost, limitation of sampling to single facilities planning
areas representative of each physiographic province in the region.
In facilities planning areas characterized by linear, single- or double-
tier development in nonfractured and nonchanneled geology, description of
groundwater resources based on available well logs and sampling data
augmented by representative sampling of properly protected on-site wells
will normally suffice for assessing impacts of on-site systems on ground-
water. In other settings, the existence or possibility of adverse impacts
should be assessed by a professional geologist or hydrogeologist.
Bacterial contamination can be identified by available survey and sampling
methods. The most likely routes of bacterial contamination from existing
on-site systems are direct discharges and overland runoff of surface mal-
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functions. Groundwater transport of bacteria to lakes is possible but
appears to be rare. On-site systems in sandy or gravelly soils and very
close to lakeshores are suspect and should be examined as sources of
bacterial contamination. On- and off-site technologies are available to
remedy bacterial contamination of lakes.
Nutrient inputs can increase aquatic productivity of a lake as a whole and
stimulate local plant growth. Localized stimulation may be at the point of
plume emergence or in sensitive parts of lakes such as embayments and
canals.
Nutrient inputs to most lakes from on-site systems are generally small com-
pared to total nutrient loads. The nutrient of primary concern is
phosphorus. Except in small lakes with high lake surface area to watershed
area ratios and with large numbers of nearby on-site systems in sandy
soils, the beneficial impact of sewering on lake trophic status will be
small. Trophic status improvements will seldom be a supportable reason for
abandoning on-site systems.
Accumulation of phosphorus from on-site systems in poorly mixed parts of a
lake can result in nuisance plant growth well in excess of growth in the
main body. Where it can be demonstrated that 1) on-site systems are
substantially contributing to nuisance plant growth, 2) abandonment of
on-site systems is cost-effective, 3) all other nutrient control methods
have been evaluated including non-point source control methods, and 4) the
community will commit to implementing other methods that are practically
and economically feasible, then facilities that allow abandonment of on-
site systems adjacent to such sensitive parts of a lake will be eligible.
Plant growth at the point of effluent emergence into the open waters of a
lake seldom interferes with recreational or other uses of the water.
Availability of suitable substratum, wave action, and fluctuations in lake
level normally control such nearshore plant growth naturally before it
becomes a nuisance. On-site upgrading and replacements may incidentially
reduce this growth, and innovative techniques such as effluent plume
recovery may eliminate it. Abandonment of on-site systems adjacent to the
main body of lakes solely for the purpose of controlling nearshore plant
growth will not be eligible unless the growth impedes beneficial uses of
the water and is shown to be stimulated by wastewater effluent.
Development of several types of environmentally sensitive areas, especially
floodplains, wetlands, and steep slopes, has historically been prevented by
on-site sanitary codes and by the fact that conventional on-site systems
will not operate in them. Various technologies that may be included in an
optimum operation alternative, such as cluster systems, mounds and holding
tanks may overcome the natural constraints and allow development in these
areas as well as in prime agricultural lands, habitat for rare and
endangered species, and historic and archaeologic sites.
This EIS recommends the use of technologies that overcome natural con-
straints only for existing buildings. Approval of future on-site and small
scale technologies is under state and local control. Hopefully, these
governments will be cautious about approving any wastewater systems in
environmentally sensitive areas.
Many state statutes limit the amount of debt that can be incurred by
municipal and county governments. Implementation of the optimum operation
alternative will enable local governments to incur less debt than under
conventional centralized alternatives because of lower capital costs and
local share. The Seven Rural Lake EIS's indicated that publicly financed
local costs were reduced between 89% and 98% under some on-site alterna-
tives. Local governments will be able to finance schools, hospitals, and
other community facilities rather than needlessly expensive wastewater
facilities.
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Operation and maintenance costs will not be reduced in proportion to
capital reductions but will generally be lower than with properly main-
tained conventional facilities. As with conventional centralized facili-
ties, operation and maintenance costs associated with the optimum operation
alternative can be passed directly to users. County and municipal
governments that had previously required property owners to bear all the
costs and responsibilities of on-site systems will incur new administrative
costs. This is due to the increased role of local governments in the
overall management of these systems under the optimum operation alterna-
tive. Because of the flexibility local governments have in the design of
small flows management agencies, they can match their costs to the severity
of local water quality problems.
In unsewered communities where the optimum operation alternative is
feasible, the economic burden on present property owners, as a group, will
be less than it would be if a conventional centralized alternative were
selected. The actual economic burden placed on present property owners may
vary from residence to residence depending on the manner in which capital,
operation and maintenance, reserve fund, and administrative costs are
allocated. How these costs are distributed is a decision that will have to
be made at the local level.
Future property owners served by on-site systems will have to pay the full
capital costs of their systems unless local governments wish to subsidize
them. U.S. EPA policy is not to subsidize future growth through the
Construction Grants program. Future capital costs for on-site systems are
deferred over the 20-year project period and are unlikely to be funded by
local government.
Certain lots may require a very expensive on-site technology. The
individual costs on these lots in the future may equal or exceed the
individual shares of subsidized centralized facilities, if these facilities
were available. In cases where sewered off-lot technologies are selected
over on-site alternatives, the magnitude of economic impacts on future
property owners will be locally determined.
The implementation of small waste flows technologies in rural areas can
positively impact on local utility contractors and equipment suppliers.
Most construction services and equipment for on-site and small-scale
technologies can be locally supplied. In contrast to conventional
centralized facilities where outside firms are typically used, optimum
operation alternatives may lead to the retention of more local, state, and
Federal funds in the rural community. Competition for contracts to
construct and provide supplies for small waste flows systems is likely to
come from non-local firms that have established expertise with these tech-
nologies. The degree to which Construction Grants funds are retained
locally will depend on the ability of local contractors to perform work on
government contracts. In some cases, the project workload and meeting of
Federal contracting regulations, such as the Davis-Bacon Act, may currently
be more than small rural area firms can handle.
Adoption of optimum operation alternatives may restrain the amount, rate,
and density of development in communities within a reasonable commuting
distance of employment centers. Often large lot size requirements are
called for by local sanitary codes to protect the quality of groundwater
used as domestic water supply. These lot size requirements for new
dwellings will probably not change as a result of adopting alternative
on-site treatment technologies since water well to treatment system
separation distances will be retained. The net effect of such constraints
on new development may be adverse or beneficial depending on local com-
munity development objectives.
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Cluster systems that use off-site soils circumvent development controls
based on sanitary codes and soils limitations. Cluster systems may thus
permit considerably higher density residential development. High density
development may be counter to local development objectives. Cluster
systems may permit infilling within existing development areas resulting in
loss of open space buffers between existing development, and into areas
possibly unsuitable for residential development. Multifamily systems could
have a positive impact where planned higher density development permits
conservation of open space in contiguous areas.
The predominant settlement pattern and housing type in the Seven Rural Lake
EIS communities were single-family detached residential units in single-
tier development around lakeshore areas. Other rural areas depending on
on-site technology are also single-family units in small subdivisions or in
dispersed low density patterns. This pattern has been determined by
transportation access to lots and by spatial distribution of suitable
soils. If on-site technologies continue to be used, this development
pattern may lead to a situation where the future options to sewer may be
precluded by the great expense of sewering dispersed homes. Further
dependence upon local sanitary codes may thus severly restrict the amount
and distribution of developable land in lake areas. Such restrictions may
be counter to local development goals as well.
Local access and control over on-site systems, although required by both
the Clean Water Act and common sense, raise concerns about individual
privacy and the sanctity of private property. The establishment of on-site
permit requirements a generation ago raised similar concerns. A poorly
planned, designed or funded version of the optimum operation alternative
might not offer benefits worth the costs that it incurs, whether in money
or privacy. Any transfer of authority to government reduces individual
choices, and may make some residents feel helpless, or more nearly so. For
this reason community authority should be exerted tactfully and sparingly,
balancing public health and water quality needs against any infringement of
privacy.
For many properties, modification of on- and off-site small waste flows
facilities will have as an incidential benefit the removal of practical
restrictions to water use. New or upgraded systems may handle dishwashers,
clothes washers, garbage grinders, and additional occupants, which pre-
viously were avoided or prohibited. Some properties will not be so
unencumbered, such as those on small lots for which existing, subcode, or
innovative facilities will be adequate with minimum water usage and for
which off-site facilities are not affordable.
XVlll
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TERMINOLOGY
During the preparation of this Environmental Impact Statement, new and
existing ideas were synthesized into the concept of rural wastewater
management described here. To make the verbal presentation meaningful yet
consistent, it has been necessary to rely on terms which are new or have
not been adequately defined elsewhere. Readers are encouraged to review
these terms prior to reading the text.
Small Waste Flows - Wastewater streams, typically of domestic sewage,
generated at individual housing units or small commercial, institutional
and industrial sites, and disposed of near the site of generation with a
minimum of flow aggregation in sewers.
Small Waste Flows Technologies - The methods for transporting, treating and
disposing of small waste flows. Includes a variety of on- and off-site
methods.
Small Waste Flows Management - Supervision of all phases in the life cycle
of small waste flows facilities. Includes provision of specified services
by a management agency, delegation and oversight of services provided by
other organizations and by homeowners, and services necessary to maintain
the management agency itself.
Small Waste Flows Facilities - Structures and equipment installed to
transport, treat or dispose of small waste flows.
Small Waste Flow Systems - Combinations of small waste flow facilities
designed to process individual small waste flows.
On-site System - Small waste flows facilities located on the property where
a wastewater stream is generated and operating together as a system to
transport, treat and dispose of that wastewater stream. May also include
systems located nearby but off-site and serving only one building.
Includes non-water consuming facilities such as compost toilets, incinera-
tor toilets, pit privies, chemical toilets and recycling systems but not
other flow reduction devices.
New Construction - Small waste flow systems installed to serve newly
constructed or future buildings.
Replacement - Small waste flows facilities or systems installed to replace
existing facilities or systems that are abandoned. Generally implies that
a new location will be used for the replacement.
Upgrade - To modify the design of existing small waste flows facilities or
systems in order to improve their operation.
Repair - To fix or renovate existing facilities and to replace parts of
facilities such as lengths of pipe, sanitary tees, pumps, etc.
Management Service or Service - The duties that may be included in a
management program. Specifically excluded from this definition are the
methods by which services can be delivered. Also termed "functions" in the
Seven Rural Lake EIS, Technical Reference Documents supporting this EIS and
other literature concerning small waste flows management.
Management Agency - The organization (or multiple organizations operating
under an interagency agreement) responsible for assuring the successful
delivery of selected services.
xix
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Management Program - A plan for providing necessary services in a small
waste flows district. The plan should describe funding, organization of
the management agency, services to be provided, parties who will provide
the services, methods by which selected services will be delivered, and
designation of liability for remedying future failures.
Small Waste Flows Project - The planning, technology selection, system
design, management agency design and construction of an Optimum Operation
alternative.
Small Waste Flows District - The geographic area within which a management
agency has supervisory responsibilities for small waste flow systems.
Optimum Operation Approach - Wastewater management in unsewered communities
that emphasizes the optimum operation of existing on-site systems, use of
other small waste flows technologies as appropriate, and small waste flows
management.
Optimum Operation Alternative - In facilities planning, the description and
cost estimate of new or upgraded small waste flow facilities and associated
management program for a specific small waste flows district.
Technology Assumptions - Estimates, based on available data and community
survey results, of the number of existing systems that require upgrading,
replacement or repair, and the mix of technologies needed to do so. Since
technology assumptions are not necessarily based on on-site sanitary
inspections or site-specific analysis, they are appropriate primarily for
describing and costing preliminary optimum operation alternatives for
comparison with centralized alternatives.
Technology Selection - Identification of the upgrading, replacement or
repair expected for individual systems based on available data, community
survey results, partial sanitary surveys and representative sampling of
soil, groundwater and surface water. Technology selections are tentative
and subject to change pending completion of sanitary surveys and, where
indicated, detailed site analysis.
Facility Verification - Confirmed or revised technology selection for
individual systems based on completion of sanitary surveys and, where
indicated, detailed site analysis. For commonly used facilities, reference
to or incorporation of standard designs and specifications is part of
facility specification. For unique facilities, facility specification
requires individual designs and specifications.
On-site Sanitary Inspection - Patterned interview with a resident followed
by a walk-over inspection of his or her property to collect and record
opinions and data on the location, age, condition, design and use of on-
site wastewater and water supply systems. Sampling of the water supply,
soil borings, or other representative sampling, may be scheduled concur-
rently with the on-site sanitary survey but are not included in the
definition.
Sanitary Survey - An inventory of the location, age, condition, design and
use of on-site systems in all or parts of a community based on available
data and numbers of on-site sanitary inspections. Random sanitary surveys
are designed to fairly estimate the proportion of on-site systems requiring
upgrading, replacement, or repairs. The design of targeted sanitary sur-
veys relies on available data to identify suspected problem areas where
extra attention is given to identifying the causes of local on-site system
failures, that is, to analyze worst case conditions.
Detailed Site Analysis - The sequence of investigations and decisions made
to determine the causes of problems with existing on-site systems and to
develop information for selecting appropriate repairs, replacements or
upgrading.
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I-C-1. Estimated Costs of Centralized and Optimum Operation Alternatives -
Seven Rural Lake EIS's 13
I-C-2. Estimated Total Small Community Projects and Rural lake Projects 18
U.S. EPA Region V - 1980-1985
II-A-1. On-site Wastewater Management Options for Specific Limitations or 28
Constraints
II-B-1. Land Treatment Options and Characteristics 37
II-B-2. Types (and Location) of Previously Investigated Wetlands Systems 39
II-B-3. Surface Water Discharge Options for Small Communities 39
II-F-1. Factors Varied and Technologies Considered in the Cost Variability Study 61
II-F-2. Trade-off Densities (in homes per mile at the end of the 20-year
planning period) Above Which Off-Site Facilities are Competitive 66
III-C-1. Potential Management Program Services 82
III-I-l. Cost Recovery Options 92
IV-A-1. Factors that Determine Limits of the Small Waste Flows Niche 101
IV-B-1. Seven Rural Lake EIS Population Projections (Increase to the Year 2000 104
and Seasonal Population Expressed as Percentages)
IV-B-2. Recreation Demand in the North-Central Region of the United States 105
IV-B-1. Estimates of Personnel Involved in Regulation of On-Site Systems 136
LIST OF FIGURES
I-C-1. Monthly Cost of Gravity Sewers 11
I-C-1. Involvement of Small Communities in the Construction Grants Program 17
II-A-1. Decision Flow Diagram for Existing On-site Systems 31
II-B-1. Septage Treatment and Disposal 35
II-C-1. Collection Sewer Eligibility - Decision Flow Diagram Based on PRM 78-9 41
II-C-2. Detailed Site Analysis 42
II-F-1. Cost-effectiveness Curves for On-site Small Scale and Centralized
Treatment Alternatives for Scenario 1; 50% Growth 63
II-F-2. Cost-effectiveness Curves for On-site Small Scale and Centralized
Treatment Alternatives for Scenario 4; 0% Growth 64
IV-E-1. Lake Phosphorus Concentration Due to On-site Systems 115
IV-E-2. Relationship Between Areal Water Load, Q, and Phosphorus Retention, R 116
V-A-1. Sample Sewer Easement and Right of Way Form 131
VII-1. Effect of Varying Discount Rates on Cost-effectiveness Curves for
On-site Small Scale and Centralized Treatment Alternatives for
Scenario 1; 50% Growth 158
VII-2. Effects of Varying Discount Rates on Cost-effectiveness Curves for
On-site Small Scale and Centralized treatment Alternatives for
Scenario 4; 0% Growth 159
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Chapter I
What This EIS Does And Why
(Purpose Of And Need For Action)
Failing Absorption Field
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CHAPTER I
WHAT THIS EIS DOES AND WHY (PURPOSE OF AND NEED FOR ACTION)
A. WHAT IS IT ABOUT (SCOPE)
The Federal actions examined in this Environmental Impact Statement (EIS)
are the review and approval of facilities plans by U.S. EPA Region V for
Construction Grants activities in unsewered communities. The topics
evaluated here apply to those rural and developing areas where responsible
governments must solve existing water quality and public health problems
by:
centralized approachesinstalling new sewers and centralized treatment
facilitiesor
small waste flows technologies and managementoptimizing the operation
of existing on-site systems and construction of new small scale
treatment facilities where appropriate.
EIS I-C-4 This EIS emphasizes unsewered lake communities because of their large
number and environmental significance within the Region. Issues, alter-
TRD X-A natives, and methods unique to them are, therefore, given as much attention
as topics that are generally applicable to any unsewered community. This
emphasizes, for examples, treatment facilities that do not discharge to
surface waters, consideration of seasonal users, and lake eutrophication
modeling.
Many topics discussed in this EIS respond to problems and opportunities
addressed during preparation of seven individual EIS's for rural lake
projects. This series, "Alternative Waste Treatment Systems for Rural Lake
Projects," began July 20, 1977 with seven Notices of Intent. The projects
and dates of completion or most recent U.S. EPA action include:
Case Study Number 1: Crystal Lake Area Sewage Disposal Authority,
Benzie County, Michigan (Final EIS July, 1980);
Case Study Number 2: Green Lake Sanitary Sewer and Water District,
Kandiyohi County, Minnesota (Final EIS December, 1980);
Case Study Number 3: Springvale-Bear Creek Sewage Disposal Authority,
Emmet County, Michigan (Final EIS December, 1980);
Legend for Cross-references in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change
in the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
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Case Study Number 4: Steuben Lakes Regional Waste District, Steuben
County, Indiana (Final EIS January, 1981);
Case Study Number 5: Otter Tail County Board of Commissioners, Otter
Tail County, Minnesota (Final EIS November, 1980);
Case Study Number 6: Salem Utility District No. 2, Kenosha County,
Wisconsin (Preliminary Draft EIS sent to applicant and the state, EIS
preparation terminated July 1979); and
Case Study Number 7: Williams County Commissioners, Nettle Lake Area,
Williams County, Ohio (Final EIS published September 1982).
These Seven Rural Lake EIS's were specifically intended to evaluate the
feasibility, cost-effectiveness, and environmental impacts of alternative
wastewater collection and treatment systems. The alternative systems were
compared to centralized systems that had been proposed in Step 1 Facilities
Plans. Varying modular combinations of the two were also considered. To
date, Final EIS's have been published for six of the case studies.
The first five EIS's recommended that grantees optimize the operation of
existing on-site systems, replace or upgrade failing on-site systems with
conventional or alternative on-site systems, and, where necessary,
construct new subsurface land discharge systems for groups of buildings
having problems with on-site treatment. The seventh case study, recom-
mended an optimum operation alternative consisting of replacement or
upgrading of malfunctioning systems and, where necessary in certain flood
prone areas, use of chemical toilets, composting toilets, or vault privies
and export of human excreta off-site. The EIS for the sixth case study was
terminated at the Preliminary Draft stage because of a decision to proceed
with state funding; the project, utilizing significant portions of EIS
work, is being constructed.
One major finding of the Seven Rural Lake EIS's is that wastewater manage-
ment based on optimum operation of existing on-site systems differs
substantially from that based on either new centralized facilities or new
small waste flows (on-site and small-scale) facilities. Another finding is
that wastewater management based on existing systems allows substantial
capital, operation, and maintenance savings compared to new centralized
facilities wherever continued use of a substantial percentage of existing
systems is feasible. Water quality objectives can still be met while
realizing this cost savings.
B. WHAT DOES IT WISH TO ACCOMPLISH AND HOW DOES IT PROPOSE TO DO IT
(PROPOSED ACTIONS)
These Draft EIS and this Final EIS have three objectives:
1. to encourage active assessment of water quality and public health
problems in unsewered areas,
2. to encourage evaluation of the optimum operation of existing facilities
and other low-cost alternatives to correct those problems, and
3. to enable grantees to recognize situations in which the optimum
operation approach is appropriate.
40 CFR 35.2030 These objectives are consistent with present regulations implementing the
Clean Water Act, especially 40 CFR 35.2030, which states in part:
A completed facilities plan must include:...(3) A cost-effectiveness
analysis of the feasible conventional, innovative, and alternative
wastewater treatment works, processes and techniques capable of meeting
the applicable Federal, State, and local effluent, water quality and
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public health requirements....A cost-effectiveness analysis must
include:...(iii) an evaluation of improved effluent quality attainable
by upgrading the operation and maintenance and efficiency of existing
facilities as an alternative or supplement to construction of new
facilities.
EIS I-C-2-a As will be seen subsequently in an analysis of costs, these objectives are
also consistent with present or future limitations on Federal allocations
of Construction Grants funds.
In regard to grantee acceptance, it is recognized that optimum operation of
existing on-site facilities will not always satisfy a common local objec-
tive of providing reserve capacity for future growth. The costs of
reserve capacity are eligible for Construction Grants funding of conven
CWA 204(a)(5) tional sewers and treatment plants if the grant is awarded before October
CWA 204(c) 1, 1984. However, provision of reserve capacity is not an objective of the
40 CFR 35.2123 Construction Grants program. The absence or reserve capacity in optimum
operation alternatives will not be grounds for finding conventional alter-
natives to be cost-effective.
Specific initiatives that comprise Region V's proposed actions are
discussed in the following sections.
1. ENCOURAGE COMMUNITY SUPERVISION OF SMALL WASTE FLOWS FACILITIES
TRD XV-A Within Region V, state and local laws require that most new on-site systems
be approved and permitted prior to installation. This requirement applies
regardless of proximity to existing development or type of water resources
that may be impacted. Protection of nearby residents' health and of water
quality are sought through design guidelines that must be met as a condi-
tion of permit issuance. The guidelines are, for most sites, conservative
enough to protect public health and water quality even if future residents
use water liberally and fail to provide the minimum maintenance expected.
Communities also provide enforcement services when systems fail. Typi-
cally, this involves responding to complaints from owners or neighbors and
encouraging owners to make suitable repairs.
EIS III-A-2 New construction requirements and enforcement services do not adequately
protect water quality and public health in all areas, however, particularly
where present housing densities are high, malfunction rates are high, or
groundwater and surface water resources are sensitive to drainfield
leachate. Communities may require additional measures to protect their
interests. The traditional community response to the need for additional
measures is to install sewers and treatment plants, if possible. The more
direct response, controlling the source of the problem, may not be consi-
EIS III dered seriously. Control may require community supervision over one or
more of the factors that together determine successful on-site system
operation. These factors and examples of means for modifying or control-
TRD I ling them for existing systems are:
EIS II-A-2-bSec Factors Determining On-site
System Performance Example Control Measures
system design expand drainfield size; upgrade system
with dosing, additional settling capa-
city, aerobic treatment; convert to
alternate design such as shallow place-
ment, mounds, evapotranspiration, or
alternating drainfields
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system usage
TRD V-A
maintenance
soil characteristics
site constraints
(size and shape of lot;
relationship to other lots;
location of house, well)
groundwater hydrology
surface drainage
install flow reduction devices; limit
occupancy; prohibit garbage grinders;
separate black water treatment; recycle
laundry and bath water; public education;
measure water consumption
renewable permits contingent on proof of
periodic inspection and maintenance;
public provision of maintenance services;
required maintenance contracts between
building occupant or owner and private
firm; public education
change system design and/or usage; move
drainfield; import soil fill
evaluate system performance as it is
affected by these constraints; evaluate
design and usage modifications as means
of overcoming site characteristics;
acquire land off-site for wastewater
disposal where necessary
install curtain drains, French drains,
or drainage ditches, septic leachate
recovery for irrigation
disconnect roof drain connections to
wastewater system; divert runoff away
from septic tank and drainfield, mound
soil over drainfield
EIS III-A-2
Many of these control measures have not been conclusively tested, largely
because of the curious position that local governments find themselves in
when they try to assess these measures. First, state and county govern-
ments place certain technical limitations on what may be done, providing no
regulatory outlet for possible successful exceptions. Second, governments
have historically been reluctant to intrude in any way on private property.
Third, budget constraints make it easy to justify doing nothing.
The lack of testing has produced a high degree of design conservatism among
engineering consultants and sanitarians, the principal sources of profes-
sional advice available to local governments. This conservatism is self-
perpetuating; until the control measures are tested, engineers and sani-
tarians will continue to recommend traditional wastewater systems.
Because of the new data and experience discussed in this EIS, U.S. EPA
Region V strongly encourages state governments in the Region and those
local governments contemplating new sewer projects to evaluate their
opportunities for dealing directly with on-site system problems and to test
the reasons typically given for not seizing those opportunities. In par-
ticular, the Region recommends increased community supervision of design,
usage, and maintenance for existing on-site systems when necessary for the
common good. U.S. EPA further recommends that the degree of supervision be
determined by local housing density, rate and type of failure, and sensi-
tivity of water resources to failures.
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2. DEVELOP EVALUATION METHODS FOR OPTIMUM OPERATION OF EXISTING ON-SITE
SYSTEMS
This second Proposed Action has been partially accomplished in the pre-
TRD II-D-G paration of this EIS and the Seven Rural Lake EIS's. Two new evaluation
methods, aerial photographic surveys and septic leachate detection, as well
EIS Il-D as a simple, effective form of sanitary survey were given their first
full-scale applications during these studies. Evaluation of optimum opera-
EIS II-E tion of existing on-site systems is addressed throughout this EIS and the
Technical Reference Document. Some of the topics, such as Construction
Grant sequences for unsewered areas and eligibility of cost items, are
applicable only if a community applies for Construction Grants funding.
The majority of topics are relevant apart from any question of Federal
funding.
As state and local organizations gain experience in applying these methods,
improvements and new methods will doubtless be developed. U.S. EPA will
help disseminate information on new and improved evaluation methods through
the U.S. EPA Small Wastewater Flows Clearinghouse, West Virginia Univer-
sity, Morgantown, West Virginia 26506, and through the Small Waste Flows
Coordinator in Region V's Chicago offices, Mr. Alfred E. Krause,
312/353-2126.
3. PROMOTE COLLECTION AND ANALYSIS OF ON-SITE AND SMALL-SCALE SYSTEM
PERFORMANCE DATA
EIS I-C-5 A nearly universal obstacle to informed decisions for wastewater management
in unsewered areas is lack of adequate local data on the design, use, and
water quality impacts of existing conventional on-site systems. The
situation is, of course, even worse for innovative systems.
EIS II-C Some performance data is necessary to support Construction Grant appli-
cations for any unsewered areas. The need for performance data is even
greater if the optimum operation approach is proposed. If sewers are pro-
posed, the need for them must be documented. This requirement was stated
in Program Requirements Memorandum 78-9:
New collector sewers should be funded only when the systems in use (e.g.
septic tanks or raw discharges from homes) for disposal of wastes from
the existing population are creating a public health problem, contami-
nating groundwater, or violating the point source discharge requirements
of the Act. Specific documentation of the nature and extent of health,
groundwater and discharge problems must be provided in the facility plan
. A community survey of individual disposal systems is recommended
for this purpose.
Additional guidance on documentation of need was provided by Program
Requirements Memorandum 79-8:
Facility planning in some small communities with unusual or inconsistent
geologic features or other unusual conditions may require house-to-house
investigations to provide basic information vital to an accurate cost-
effectiveness analysis for each particular problem area. One uniform
solution to all the water pollution problems in a planning area is not
likely and may not be desirable. This extensive and time-consuming
engineering work will normally result in higher planning costs, which
are expected to be justified by the considerable construction and opera-
tion and maintenance cost savings of small systems over conventional
collection and treatment works.
Though house-to-house visits are necessary in some areas, sufficient
augmenting information may be available from the local sanitarian, geo-
logist, Soil Conservation Service representative or other source to
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permit preparation of the cost-effective analysis. Other sources
include aerial photography and boat-carried leachate-sensing equipment
which can be helpful in locating failing systems. Detailed engineering
investigation, including soil profile examination, percolation tests,
etc., on each and every occupied lot should rarely be necessary during
facility planning.
(NOTE: PRM's 78-9 and 79-8 were canceled in 1981. The guidance dis-
cussed here is continued, however, in almost the same form in the new
program guidance, Construction Grants, - 1982.)
Applying these policies during preparation of the Seven Rural Lake EIS's,
TRD XVI-D Region V in cooperation with states in the Region developed additional
guidance on the collection and use of performance data titled "Region V
Guidance--Site-Specific Needs Determination and Alternative Planning for
Unsewered Areas." It is Appendix A in this EIS. This guidance recommends
phasing of data collection with decisions on alternative development and
selection, ensuring timely data collection and avoiding unnecessary or
redundant work.
The Region V Guidance also emphasizes performance as the relevant criterion
for need. Though this seems obvious, facilities plans and state policies
often rely on nonconformance with current design codes as the criterion for
need. Use of nonconformance alone as a criterion would result in the aban-
donment of many older systems, even though they may have many more years of
use remaining.
EIS II-D The Region V Guidance and this EIS cite several data collection methods.
The data apply particularly to local problems but they also help us to
understand how on-site systems work and affect our water resources. So
that performance data collected with Construction Grants funds can thus
improve the state of the art, Region V will promote development of stand-
EIS II-D-3 ardized on-site data formats and of data storage and retrieval systems.
Discussions with Headquarters and other offices in U.S. EPA and with state
201 agencies are planned.
4. REVIEW ELIGIBILITY REGULATIONS
EIS V-A-1 This EIS addresses a number of questions regarding grant eligibility raised
during preparation of the Seven Rural Lake EIS's. Proposed eligibility
guidelines are presented.
5. ENCOURAGE STATES TO PLAY ACTIVE ROLES IN RURAL WASTEWATER MANAGEMENT
TRD XV-A The evolution of state regulatory authority over on-site systems has not
included explicit means or intent for evaluating and improving on-site
system performance. Published regulations clearly define the design of new
conventional on-site systems. However, inadequate existing systems are
usually only discovered by the homeowner or neighbor after total failure.
Repairs on existing systems are limited to those that the local sanitarian
can persuade owners to make and usually consist of the same type of system
that has already failed. States have legal and social obligations to
define and ensure adequate sanitation. They are also bound by the poli-
tical constraint that adequate sanitation be available at a reasonable
cost. With some exceptions, the states have not clearly resolved the
technical, legal, financial, and administrative problems associated with
existing on-site systems. The number of non-cost-effective proposals for
new sewer construction in rural areas testifies to this.
This EIS does not suggest that ready answers exist for every problem. How-
ever, a number of possibilities are discussed, primarily from local govern-
EIS V-B ment's point of view. Many of the possibilities require enabling legisla-
tion or regulations for which states retain authority. This EIS encourages
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the states within Region V to evaluate comprehensively their roles in the
TRD XV-A management of existing as well as new on-site systems and to provide loca-
lities with the necessary legal and information resources to provide their
delegated management services. The states within Region V do not have to
look extensively beyond the Region to find excellent examples of what can
be done in this field.
6. RECOMMEND FACILITIES PLANNING AND IMPACT ANALYSIS METHODOLOGIES
EIS II-E-F This EIS and its Technical Reference Document use experience from the Seven
Rural Lake EIS's to show several different ways to make planning decisions
EIS IV for unsewered areas. It can help in making these decisions whether or not
they are part of a Construction Grants facilities plan. There are no
TRD X-XIV mandatory rural facilities planning methods; grantees and consultants are
free to choose the best method for satisfying state and Federal planning
requirements.
7. ENCOURAGE CONSIDERATION AND USE OF MITIGATIVE MEASURES
EIS I-C-2 No wastewater facilities are completely free of potential adverse impacts.
For rural communities, the most prevalent adverse impact of constructing
EIS IV-F new sewers and treatment facilities will be economic. Economic impacts can
be avoided by implementing less costly alternatives, such as the optimum
operation alternative, where feasible. Optimum operation may itself have
potential adverse impacts, particularly on land use, groundwater quality,
lake water quality, municipal finances, and homeowner finances. These
impacts can be avoided during facilities planning or mitigated during and
after construction. Other problems, such as non-point source pollution,
may not be addressed by any wastewater management efforts.
EIS VI This EIS will later discuss potential adverse impacts of the optimum opera-
tion alternative and ways to limit them. These mitigating measures can
often both reduce impacts and save money; either of these is sufficient to
recommend their consideration and use by the grantee.
8. ENCOURAGE PUBLIC PARTICIPATION
EIS III-D Experience shows the public's interest in wastewater control projects is at
IV-G least as great in rural lake areas as in any other type of community. This
TRD XIV-A high level of interest is matched by a high level of awareness of and
appreciation for local natural and social resources. We are recommending
an approach to wastewater management that necessarily involves residents to
a greater degree than do conventional sewered approaches.
In one sense this entire document is intended as an aid to public partici-
pation. Not just engineers and planners, but local officials and residents
themselves need to understand enough of wastewater planning so that they
can judge their own problems and needs. Intelligent and alert citizens can
exercise a greater and more lasting degree of quality control than any
state or Federal reviewer.
This document talks about ways to use the advice of an informed public in
Construction Grants Program projects, especially those using the optimum
operation alternative. By understanding the public's concern, consultants
and officials can speed the progress of a project. Sometimes they may
learn enough to improve, revise, or cancel it.
9. ENCOURAGE CREATIVE USES OF SMALL WASTE FLOWS TECHNOLOGY AND COMMUNITY
MANAGEMENT
This document is intended to be a beginning not an end to discussions of
small waste flows systems and community management. On parts of these
matters, it offers new ideas and "state of the art" knowledge. We
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intended, however, to spur debate, analysis, and experimentation concerning
alternative means of rural wastewater management. Our greatest hope is
that within a short time this EIS will be obsolete because inventive
consultants, demanding local officials, and alert involved citizens will
have gone far beyond even our methods toward protection of public health
and water quality at affordable costs.
C. WHY DO THESE THINGS NEED TO BE DONE (THE NEED FOR ACTION)
1. HISTORICAL BACKGROUND
Septic tank/soil absorption systems were not constructed in really great
numbers until after World War II. Pre-war rural electrification programs
set the stage for suburbanization and rural development. Returning
veterans, Federal home loan guarantee programs, rapid economic growth, and
other factors contributed to rapid development outside of sewered urban
areas.
At that time, public control over septic tank system installation was non-
existent or only advisory. In response to frequent failures of these
post-war systems, many sewers have been built. Some local and state
governments sought ways to prevent failures through standardized design
requirements, site evaluations, and permitting requirements. By 1957, the
Taft Research Institute of the U.S. Public Health Service had studied
septic tank system failures and recommended standard design requirements
(U.S. Public Health Service, 1957). These design requirements still form
TRD XV-A the basis for many state regulations.
During the 1960s and early 1970s, state and local governments formulated
and implemented procedures for preconstruction approval of septic tank
systems. These procedures and the standard design requirements greatly
reduce the occurrence of surface malfunctions and plumbing backups for new
systems. However, old and new systems that are overloaded or not main-
tained continue to fail. A third type of failure, groundwater contamina-
tion, has also been recognized as a potential problem.
Relying on such failures, municipalities and facilities planners continue
to propose new sewers. This is done without exhausting means for improving
the performance of existing systems.
Training and education programs in on-site wastewater management have,
until the last several years, been rudimentary. Those programs available
TRD V primarily reached public health sanitarians and system installers, not the
consulting engineering community that now plans facilities for our rural
communities. U.S. EPA is working to improve the availability of training
and education programs through technology transfer seminars, the Small
Waste Flows Clearinghouse, support of other organizations' programs, and
preparation of this EIS and the seven previously mentioned case studies.
2. PROBLEMS WITH CONVENTIONAL COLLECTION AND TREATMENT FACILITIES IN RURAL
AREAS
Three main problems with construction of new collection and treatment
facilities in rural communities are high cost, uncertain performance, and
adverse environmental impacts. While these obviously will not rule out new
sewers in all rural and developing communities, they must be seriously
considered.
a. Costs
The collection system is chiefly responsible for the high costs of conven-
tional sewerage facilities for small communities. Typically, 80% or more
of the total capital cost of wastewater facilities for newly sewered rural
10
-------
areas is spent for sewers. Figure I-C-1 indicates that the costs per
residence for gravity sewers increase exponentially as population density
decreases.
o
f 30
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I 20
en
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Co3t($/month) =
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Source: Dearth 1977
l I I i I
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POPULATION DENSITY
(persons/acre)
12
FIGURE I-C-1. MONTHLY COST OF GRAVITY SEWERS
Source: Dearth, 1977
This cost/density relationship arises from:
greater length of sewer pipe per dwelling in lower density areas,
more problems with grade, resulting in more lift stations or excessively
deep sewers,
regulations or criteria that set 8 inches as the smallest allowable
sewer pipe diameter, and
inability of small communities to spread capital costs among larger
populations sewered previously.
New centralized facilities are capital intensive. The private capital (the
money a homeowner pays directly to contractors) required for plumbing
changes and house sewers may cost $1,000-$5,000. In some rural areas the
homeowner may also have to install indoor plumbing and a new room for a
bathroom. The property owner will also pay a part of the municipality's
share of publicly-owned facilities. The property owner's part may be paid
as soon as the project is built in the form of a hook-up charge or frontage
fee. Charges of $2,000 per connection are not unusual. The public capital
may also be recovered from property owner's over a period of time as
installment payments on municipal bonds.
Like all wastewater facilities, centralized systems have operation, main-
tenance and replacement costs. Such costs incurred by municipalities for
Federally-funded facilites must recover the costs through user charges.
11
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Per household user charges for new centralized wastewater systems are
highest in the smallest communities. An examination of 687 user charge
systems approved by Region V through September 1980 revealed that all 10
communities with annual user charges over $200 had populations of 10,000 or
less. Of the 17 communities charging $150 to $200 per year, 14 had
populations of 10,000 or less. (Only communities that are building
collection sewers and interceptors are included in this analysis.)
Table I-C-1 presents cost data developed for the Seven Rural Lake EIS's
comparing centralized alternatives with optimum operation alternatives.
The potential present worth savings from optimum operation alternatives for
the seven communities totaled $50.9 million or $4,943 per dwelling unit
equivalent. Not all of the potential present worth savings will be rea-
lized. One community has withdrawn its application for Construction Grants
funding using only part of the EIS recommendations in a state funded
project. Other communities, having seen the actual level of water quality
and public health problems, are hesitant to build all parts of even the
optimum operation approach.
EIS IV-F-2 Estimated reductions in average annual homeowner costs due to adoption of
optimum operation approaches ranged from 58% to 90%, averaging 82% or about
$405 per year per house. The estimated homeowner costs include all local
costs, whether privately or publicly financed, with initial capital costs,
including house sewers, amortized over a 30-year period. Therefore, while
the average annual homeowner costs for the centralized alternatives appear
extraordinarily high compared to most user charges, they include real costs
to the homeowner that he or she would usually pay as hook-up charges,
frontage fees, taxes, or direct payments to private contractors.
The most dramatic cost reduction was for publicly financed local capital
costs, the part of the projects typically financed by bonds or loans to
municipalities. Because of lower total capital costs, limitations on col-
lector sewer eligibility, higher Federal and state shares for alternative
facilities, and deferred capital for future on-site systems, local capital
was reduced between 89% and 98%.
b. Performance
In newly sewered areas, particularly around rural lakes, only occasionally
is there a realistic quantified assessment of the water quality impact of
the on-site treatment to be replaced. Experience in the Seven Rural Lake
EIS's suggests that the costs and impacts of sewering may sometimes achieve
no discernible water quality improvement, or that reduction of non-point
source pollution may produce a much greater water quality improvement at a
lower cost.
It is conventional engineering wisdom that centralized wastewater treatment
facilities, if properly designed and maintained, will provide more reliable
and controllable treatment than on-site or small-scale facilities. There
certainly are enough decrepit package aeration plants, weed-infested
lagoons, and bubbling on-site systems to support this comparison. However,
statistics on the performance of U.S. EPA-funded, recently constructed
central treatment plants indicate that the "properly designed and main-
tained" assumption cannot be taken for granted. An EPA-funded study of
treatment plant performance (Energy and Environmental Analysis, Inc., 1978)
found that 53% of the plants were in significant or serious violation of
their National Pollution Discharge Elimination System permits during the
spring of 1977.
The problems that arise with centralized and small waste flows approaches
are not the fault of the technologies involved, but result from the ways
these technologies are selected, designed, built, and operatedin a word,
management. Throwing money into centralized collection and treatment
12
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facilities does not solve the problem of inadequate management. It only
creates a need for different management procedures.
c. Environmental Impact
In many rural and developing communities, installation of sewers will have
minor environmental impact. However, the primary and secondary impacts of
sewer construction that might occur could outweigh the benefits of
centralization.
EIS VI-B-1 Primary environmental and social impacts in rural areas occur as results of
VI-B-6 sewer construction or of the development supported by sewers. Examples are
VI-B-7 disruption of archaeologic sites, development in floodplains, destruction
of wildlife habitat, and increased non-point source pollution.
EIS IV-D Some environmentally sensitive areas are protected from development only by
the fact that on-site systems will not operate in them. Sewers can
EIS VI-B-2 overcome the natural constraints to development in such areas and, in lieu
VI-B-5 of protective laws and enforcement, may result in permanent environmental
damage. In Region V, possibly the most common encroachment of this type is
on fresh water wetlands. Steep slopes, vulnerable to erosion, are common
in the southern parts of Ohio, Indiana, and Illinois, around many glacial
lakes, and in other parts of Region V.
Sewers can overcome these natural constraints resulting in greatly
increased erosion and non-point source pollution during both sewer
construction and subsequent development in these areas. Elevated rates of
erosion and non-point source pollution will continue for the life of the
development. In some cases this non-point source pollution can actually
offset water quality benefits associated with sewering.
EIS VI-B-3 Other valuable natural resources may be encroached on because of the
growth-inducement effects of sewers. Installation of interceptor or col-
lector sewers through sparsely developed or undeveloped tracts provides
incentive to develop that land. This effect is enhanced when municipal-
ities must actively encourage development in order to pay off debts
incurred in financing the sewers. Of particular concern in Region V is
such encroachment on prime agricultural lands.
TRD XI While these impacts are not unique to sewer construction, they commonly are
caused by it. Careful planning and implementation of mitigating measures,
including not building the sewers, must be considered when sensitive or
valuable resources are present.
3. POTENTIAL SAVINGS
EIS I-C-4 The monetary savings that can result from small waste flows management were
summarized above for the seven rural lake communities previously studied by
U.S. EPA Region V. For the six projects that may be implemented as recom-
mended, present worth savings totaled approximately $44 million or $5,220
per dwelling unit. There are, perhaps, 80,000 additional dwellings in
unsewered lake communities for which Construction Grants activities are
planned or in progress based on a review of Region V's project files. If
the same cost savings can be achieved for these dwellings as are possible
in the six EIS communities, the total regional present worth savings for
lake projects funded through 1985 could be as high as $460 million.
TRD X-A The Seven Rural Lake EIS's considered a total of 10,306 dwelling unit
equivalents presently served by on-site systems. There are approximately
TRD X-E 3.3 million on-site systems in Region V. Not all of these, of course,
require improved management or upgraded systems. Even fewer are so densely
located that sewering would even be considered. In order to derive an
order-of-magnitude estimate for potential savings resulting from optimum
operation, the following five steps were taken:
14
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1. The number of residential on-site systems in the Region was estimated
for three categories:
urban - 536,300
rural non-farm = 2,036,600
rural farm = 759,300
3,332,200
2. It was assumed that a negligible part of the rural farm systems would
require either optimum operation or sewering. This leaves a total of
2,572,900 systems.
3. For the urban and rural non-farm categories, the systems were allocated
to density groups of <25, 25-50, 50-75, 75-100, and 100+ dwellings per
mile of potential collection sewer. Depending on lot configuration and
development pattern, average lot sizes would range from eight acres down
to one-quarter acre for the range of densities considered.
4. The total (urban plus rural non-farm) number of residences within each
density group was partitioned into need classes:
sewer,
sewer or optimum operation,
optimum operation,
no action.
5. Present worth costs for sewering were compared to the present worth
costs of optimum operation for the second need class: sewer or optimum
operation.
The nominal present worth savings within Region V, estimated by this
procedure, is $1.9 billion. This represents an average $4,436 savings per
dwelling for the 430 thousand dwellings estimated to be in the "sewer or
optimum operation" needs class. This needs class, as estimated, is 13% of
all on-site systems in the Region and 17% of non-farm on-site systems.
The estimates summarized here are presented in more detail in Technical
TRD X-E Reference Document Chapter X-E, "On-site Systems in Region V and Potential
Cost Avoidance from Adoption of Optimum Operation Alternatives."
The reader should recognize that this estimate is dependent on assumptions
in Steps 3 through 5 which cannot at present be fully verified with hard
data. It is felt, however, that possible errors in these assumptions will
not have as much effect on the estimate as will external factors,
especially local and state initiatives, or the lack thereof, to improve
rural sanitation.
4. NUMBER OF POTENTIAL RURAL AND RURAL LAKE PROJECTS IN REGION V
TRD X-A Specific terms are applied to the various sized communities discussed in
this section. A "small community" as used here is any place with a
population of 10,000 or less. A "place" may be unincorporated or incor-
porated. Unincorporated places are defined as closely settled population
centers that have no corporate boundaries, contain a population of at least
1,000, and have a definite nucleus of residences (U.S. Bureau of the
Census, 1978). In Region V states, incorporated places include cities,
towns, and villages.
The Bureau of the Census defines "urban population" as all persons living
in places of 2,500 population or more, or in specifically defined, urban
areas in and surrounding cities of 50,000 or more population. "Rural
population" is everyone else.
15
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Unsewered development certainly exists in some urban places of over 10,000
population. If proposed for Construction Grants funding of collector
sewers, such areas will have to meet the same criteria as unsewered parts
of smaller communities. However, this is unlikely to be the major focus of
facilities planning in large communities. When estimating potential
numbers of facilities plans, the focus is on communities of less than
10,000 since relatively larger proportions of their areas will be
unsewered.
Figure I-C-2 shows by 2,500 population size brackets the total number of
places less than 10,000 population in Region V as of 1977. Any of these
places, plus an unknown number of smaller settlements that do not qualify
as places, may benefit from adoption of the wastewater management approach
described here.
Figure I-C-2 also shows the number of approved user charge systems and
total number of applications in process or on priority lists. User charge
systems are normally submitted to U.S. EPA near the end of Step 3 in the
Construction Grants process. This is a fairly accurate estimate of the
number of communities that have completed construction of wastewater
facilities.
TRD X-A The next block in each size bracket includes number of projects that are on
the states' 5-year priority lists (1980-1985) or are receiving funds for
Steps 1, 2, or 3. A single user charge system or project may cover only a
part of a place or may include more than one place. The degree of overlap
is not known. Table I-C-2 shows the number of small community projects on
priority lists or receiving Grant funds by state and by community size and
shows the estimated number of lake projects by state.
The remaining places may be placed on state priority lists after 1985.
Potential post-1985 candidates far outnumber small communities already
involved in the Construction Grants process. The majority, 89%, are rural
places of less than 2,500 population.
The number of places on priority lists or designated as potential candi-
dates is large but will be reduced to an unknown extent because many
communities can manage their wastewater facilities without Federal grant
assistance. This is an ultimate objective of the Construction Grants
program, and, to the degree that communities are already managing on their
own, the program will succeed that much more quickly.
The number of future projects can be reduced further by joint applications
from several small communities. In addition to reducing administration
time and costs, this would also provide desirable economies of scale in
small waste flows management and manpower costs.
5. LACK OF INFORMATION ON SMALL SYSTEM PERFORMANCE AND COSTS
The low amount and quality of information about on-site systems is a
reflection of existing management of such systems. The public interest in
adequate performance has traditionally been outweighed by the desire of
individuals for privacy. As a result, on-site systems are seldom inspected
after construction, and community-wide surveys are nearly nonexistent.
Community surveys generally are not encouraged or funded unless an epidemic
or an absolutely unacceptable failure rate already exists. The result is a
very bad reputation and a body of literature that primarily reports the
worst cases.
16
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3,000
2,500
CO
o 2,000
<ฃ
O.
U-
o
CD
1,500
1,000
500
3,426
,066
291
TOTAL PLACES
PLACES ON 5 YEAR STATE
PRIORTY LISTS, RECEIVING
CONSTRUCTION GRANTS FUNDS
OR SUBSTANTIALLY FINISHED
WITH CONSTRUCTION GRANTS
PLACES SUBSTANTIALLY
FINISHED WITH CONSTRUCTION
GRANTS (USER CHARGE SYSTEM
HAS BEEN APPROVED)
483
297
96
Y///////////////.
208
143
56
140
98
40
0-
2,500
2,500-
5,000
5,000-
7,500
7,500-
10,000
POPULATION
FIGURE I-C-2. INVOLVEMENT OF SMALL COMMUNITIES IN THE
CONSTRUCTION GRANTS PROGRAM
17
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TABLE I-C-2. ESTIMATED TOTAL SMALL COMMUNITY PROJECTS AND RURAL LAKE PROJECTS U.S. EPA
REGION V - 1980 - 1985*
State
Total projects
Lake projects
Illinois
0-2,500
2,501-5,000
5,001-10,000
Indiana
0-2,500
2,501-5,000
5,001-10,000
Michigan
0-2,500
2,501-5,000
5,001-10,000
Minnesota
0-2,500
2,501-5,000
5,001-10,000
Ohio
0-2,500
2,501-5,000
5,000-10,000
Wisconsin
0-2,500
2,501-5,000
5,001-10,000
240
177
122
276
143
163
156
48
36
117
29
31
66
29
27
232
35
9
76
36
31
128
24
11
48
40
68
120
Region V
0-2,500
2,501-5,000
5,001-10,000
1,121
775
201
145
372
* The table is based on data from Region V project files. 25% of project files for com-
munities under 10,000 population were randomly selected to provide data for these
estimates.
What results are obtained when surveys are conducted just to monitor per-
formance and not to document situations that are already out of hand? In
many cases, such as Fairfax County, Virginia, Glastonbury, Connecticut, and
the Seven Rural Lake communities, performance has been much better than is
usually expected.
Considerable discrepancy exists between perceived performance and docu-
mented performance. Two possible sources of bias are the homeowner's
perspective and the sanitarian's perspective. Although homeowners seldom
err by reporting failures that have not occurred, they do, either knowingly
or out of ignorance, fail to report problems during surveys or censuses.
The level of underreporting is never quantified. In contrast to home-
owners, sanitarians, engineers and municipal officials are professionally
concerned with failures for various reasons and tend to overemphasize their
18
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prevalence and significance. Consider, for instance, the effects on a
sanitarian's attitude toward installed systems when he is asked to inspect
only failing systems. His negative attitude toward the failing systems,
the other systems he has permitted, and all the ones he must permit in the
future, is amplified by the personal hardship and inconvenience of the
owners, and by the implied or open recriminations that owners heap on the
sanitarian. Municipal officials also do not hear about the systems that
work; they hear about the few that do not work. As evidenced by facilities
plans prepared for the communities studied in the Seven Rural Lake EIS's,
engineers uncritically accept opinion and fragmentary data regarding on-
site system performance.
EIS II-A-2 On-site system failure rates undoubtably vary greatly from community to
community. The Seven Rural Lake EIS's showed that failure rates are not
directly predictable from site suitability criteria such as lot size, depth
to groundwater and soil type. The EIS's showed that lake shores, a setting
conventionally thought to be very sensitive to septic tank systems, do not,
in fact, have unusually high failure rates.
EIS II-A-3-c Community-wide performance data is almost always lacking and surveys that
have been conducted indicate a much lower failure rate than predicted from
site limitations, yet there are suspected sources of bias from the two
groups closest to the problem; homeowners and sanitarians. At the same
time, large sums of money may be needlessly spent if valid performance data
is lacking or if site suitability is erroneously evaluated. This situation
demands the collection and objective analysis of performance data and
corollary information such as design, usage, maintenance, soils, site
constraints, groundwater hydrology, and surface drainage.
Other types of information are also lacking. Many technology and manage-
ment alternatives discussed in this EIS have not been extensively applied
and evaluated. Cost data, while based on a great deal of literature and
direct quotes, have rarely been confirmed in small waste flows projects on
a community scale.
If on-site systems are as hazardous as many responsible people believe, and
if appropriate management can in many cases control problems of on-site
systems with sizable cost savings, answering these questions about per-
formance, costs, and management not only would be justified in the name of
public health and welfare, but also could save billions of dollars.
6. IMPACTS OF ON-SITE SYSTEMS
TRD XII The high cost of sewering requires that any decision to sewer takes into
account the actual quantitative role of existing systems in water quality
problems. An informed decision requires evaluation of pollution sources
beside wastewater, the cost of reducing or ending these other sources, and
the comparative speed with which wastewater and other pollution sources can
be abated. Existing systems are by no means the only cause of water
pollution.
Consider, for example, well contamination. When an on-site well exhibits
indicator bacteria, septic tanks and drainfields are the prime suspects.
For local officials documenting the need for new wastewater or water supply
facilities, they are often the only suspects. But hasty conclusions can
result in expensive measures that do not solve the actual cause of
contamination. In many cases, poor design or poor condition of the well
itself allows surface runoff into the well.
Similarly, on-site systems may be suspected of increasing phosphorus con-
tributions to lakes, thus hastening eutrophication. There is evidence that
septic leachate can stimulate plant growth near the point where the
leachate plume enters a lake. This impact can be pronounced on very small
19
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lakes or embayments with still waters and many shoreline dwellings. How-
ever, on larger bodies of water, wave action seems to control such local
plant growth. Lacking demonstrated bacterial contamination from these
plumes, the impact of concern is phosphorus loading to the lake as a whole.
TRD II-G Phosphorus control strategies that include agricultural, silvicultural,
horticultural, and urban non-point source controls may potentially be more
cost-effective than elimination of on-site systems.
TRD II-A On-site systems are not always harmless. Their very proximity to human
dwellings amplifies the importance of their small flows and limited adverse
impact. It is most important, however, that decisions about their water
quality and public health problems be based on actual performance and not
opinion.
7. TWO LEVELS OF NEED FOR ACTION
The environmental and economic reasons for seriously considering optimum
operation alternatives have been briefly mentioned previously. More
specific information on the needs and methods to address them are presented
in greater detail in the remainder of this EIS and in the supporting
Technical Reference Document.
The recommendation to evaluate optimum operation alternatives generates
secondary needs such as the need for improved data collection as noted.
Most of the proposed actions, in fact, respond to these secondary needs,
the needs that must be met to achieve the environmental and economic
benefits of optimum operation: public participation, community supervi-
sion, state initiatives, facilities planning methodologies, and mitigating
measures.
20
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Chapter II
Small Waste Flows Technologies
SMALL-DIAMETER GRAVITY SEVERS
SEPTIC TANk LIGUIF TO TREATMENT
LAGOOW, LANr
APPLICATION
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WATERLESS TOILET;? 3IN
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ABSORPTION
WITH
EVATOTRANSFICATlON
SEP
P K./ST/ M E
THE SMALL COMMUNITY AND TYPICAL USES OF ALTERNATIVE
WASTEWATER SYSTEMS
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CHAPTER II
SMALL WASTE FLOWS TECHNOLOGIES
A. ON-SITE SYSTEMS
1. ON-SITE SYSTEMS IN REGION V
TRD X-E In the six states of U.S. EPA Region V, approximately 3.3 million on-site
wastewater treatment systems were in place in 1979. These systems served
approximately 22% of the population in the Region, ranging from 4% of urban
residents (places greater than 2500 population), to 66% of rural non-farm
residents, and 99% of farm residents. The predominant type of on-site
system is the septic tank-soil absorption system. Cesspools are also
common in this area but typically serve only buildings that are more than
20 years old. Of all the on-site systems in Region V, 3.2 million or 95%
are either septic tank-soil absorption systems or cesspools. The remaining
systems are chemical toilets or pit privies.
There are great variations in design, construction and quality of these
systems. These have been caused in part by the early absence of regulatory
codes, continuing changes in them, and a frequent lack of enforcement.
Together these have made possible the occasional treatment atrocity:
direct untreated discharge of lakes, 55 gallon drums with axe holes, or
buried automobiles. More recently installed systems include advanced
treatment technologies, such as mounds, shallow placement, dosing, and
electro-osmosis.
When septic tanks systems were beginning to replace pit privies, few local
jurisdictions had standards for siting, designing, installing, and
operating septic tank systems. As knowledge of these systems increased and
early systems failed, regulatory codes were developed. These codes have
changed through the years as experience and research have dictated. As a
result, older systems do not satisfy existing codes.
Regardless of the standards in effect at the time of construction, some
septic tank-soil absorption systems will eventually fail. Factors that
contribute to the failure of on-site systems are discussed in the following
section.
Legend for Cross-references in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change
in the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
23
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2. FAILURES OF ON-SITE SYSTEMS
a. Types of Failures
Failures of on-site systems that are significant enough to warrant public
funding for abatement include:
direct discharges,
surface malfunctions,
backups into the household plumbing, and
contamination of groundwater at an actual or potential point of use.
Direct discharge of raw domestic wastewater or septic tank effluent to the
ground surface, to drainage ditches or to waterways is not a system failure
as such, but lack of a system, and not accepted practice. Depending on the
source of wastewater, direct discharges can pose the most severe public
health and water quality impacts of all types of failure due to the absence
of any treatment by soil or other effective methods. Because of the threat
and difficulties of monitoring, health authorities generally ban direct
discharges whether the discharge contains human waste or just kitchen or
laundry waste. Abatement of direct discharges by cost-effective means will
generally be expected in a community receiving Construction Grants aid.
However, individual exceptions may be justified where the wastewater source
or the conditions under which it is discharged create minor impacts and the
cost of abatement is unreasonable.
Surface malfunctions of soil absorption systems typically are due to
inadequate hydraulic capacity. Wastewater flows in excess of design, soil
clogging, impermeable soils, and pipe clogging or collapse can contribute
to this type of failure. Surface malfunctions can range from seasonal
dampness of the ground to short-circuiting of the soil absorption systems
through channels eroded through the soil. Although a minor malfunction is
often the precursor of more severe problems, this is not always the case.
Intermittent surface malfunctions or "weeping" of mound systems may occur
for long periods without creating anything more than a nuisance. Such
minor surface malfunctions may be included in failure statistics when esti-
mating facilities required for optimum operation alternatives in facilities
planning. However, later decisions to abandon such on-site systems should
be supported by information regarding the severity of the problem and the
feasibility of other remedies.
Backups in household plumbing can be caused by any of the factors that
cause surface malfunctions. In addition, clogging of the plumbing itself
will also cause backups. As contrasted to the other types of malfunctions,
the only way to quantify backups is by interview with residents. Resi-
dents' descriptions of the frequency of backups may be the basis for a
preliminary diagnosis. Non-recurring backups or backups that were remedied
by plumbing maintenance should not be considered as system failures.
However, on some sites, plumbing backups may be the only evidence of
inadequacy in the on-site system.
EIS IV-E-1 Contamination of groundwater is at once the most difficult failure on which
VI-A-1 to obtain reliable data, and the one with the most severe potential public
health impacts. Virtually all standard soil absorption systems and many
alternative on-site technologies discharge to groundwater, thereby contami-
nating it to some degree. Whether the contamination is significant, how-
ever, depends on the use of the affected groundwater, the contaminants
discharged, and their concentrations at points of use.
"Points of use" include:
for unconfined aquifers, all locations around an on-site system beyond
the state's minimum separation distance to wells,
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for confined aquifers, the same except that perched groundwater tables
with no aquifer potential are not points of use,
any existing water supply well, and
zones of groundwater discharge to primary contact surface waters or to
surface waters used for drinking water.
Where local sampling indicates that drinking water standards are exceeded
at distances greater than states' mimimum separation distances, then
locally applicable separation distances should be incorporated into this
definition.
For aquifers and wells, traditional contaminants of concern are bacterial
pathogen indicators (total or fecal coliform bacteria) and nitrates.
Failures of individual wells do not indicate wholesale contamination of the
source aquifer.
Water quality standards for untreated drinking water are well established,
but standards for groundwater discharges to surface waters are not. Sooner
or later, the states in Region V will need to develop such standards.
b. Frequencies of Failures
Reliable data on the various types of failure are very scarce. Most
locales have neither surveys nor more specific analysis of on-site system
performance. Health department complaint and repair records are usually
the only data available. Such information would be useful, but it is
seldom compiled, analyzed or published. While there is no comprehensive
information on the subject, some data exist to broadly describe frequencies
of on-site system failures. The failure most likely to be noticed by
residents, and, therefore, the one most likely to be reported during a
survey, is a plumbing backup.
The 1977 Census of Housing (U.S. Department of Commerce, 1979) reports that
1.6% of surveyed occupants in the north central United States served by
on-site systems reported breakdowns where the systems were unusable one or
more times for six consecutive hours or longer during the 90-day period
preceding the survey. These breakdowns included not only system failures
but also clogged pipes and failures of the water supplies.
By contrast, occupants served by public sewer reported an 0.8% breakdown
rate. For on-site systems, reported breakdowns were highest in urban
areas, 2.8%, lowest on farms, 1.0%, and the same as the overall on-site
breakdown rate in rural, non-farm dwelling, 1.6%. (It is also interesting
to note that the water supply failure rate, 2.5%, and the flush toilet
failure rate due to problems inside the building, 1.6%, were higher than
the combined sewer/on-site sewage disposal failure rate of 1.0%.)
Sanitary surveys conducted for the Seven Rural Lake EISs indicated that
recurrent backups were more frequent in the five communities surveyed than
the census region's average (Peters and Krause, 1980). Rates varied from
2% to 20%. In all five communities the recurrent backup rates were higher
than the rates of surface malfunction, which ranged from 0% to 8%.
Reports on failures of on-site systems seldom specify the type. It is
suspected, however, that "failure" most often refers to surface malfunc-
tions. Surface malfunctions present the greatest nuisance to neighbors,
and are usually more identifiable than direct discharges, which tend to be
well concealed. Surface malfunction rates are best quantified by aerial
survey or on-site sanitary inspection. This information is not yet widely
available. The next best source of data for surface malfunctions is
probably public health department complaint and repair records.
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In support of an EIS on mound systems, Wisconsin Department of Health and
Social Services (1979) cites a 1967 survey of eight lake areas. The
percent of dwellings with sewage discharges to the ground surface ranged
from 3.7 to 44% with an average of 14.6%. It is not stated to what extent
the survey areas were selected based on previously recognized problems.
Combined with direct discharges, the total "failure" rate was 22%. There
is a gross discrepancy between these figures and the rate of issuance for
repair permits. The EIS states that approximately 2042 repair permits were
issued in 1975 within 66 of the state's 72 counties. This is only 0.45% of
the on-site systems that the EIS estimated to be in place then. This
discrepancy strongly suggests that:
Failure rates vary widely from one locale to another. While the state
or regional rates may be low, specific communities or parts of communi-
ties may have substantially higher than average rates.
Many failures remain undetected and unrepaired. The traditionally
passive role that local health officials take in regard to on-site
system performance likely results in underestimation of even the easily
detectable failures.
Depending on the length of time failures are allowed to persist, one-
time surveys probably count more failures than actually start in any
given year. Use of survey statistics to estimate an annual failure rate
is not, therefore, justified in most instances. At the same time, the
survey statistics probably do not reflect a cumulative failure rate
since some proportion of past failures will have been repaired.
Failure rates for groundwater contamination by on-site systems are, and
will continue to be, uncertain. However, in contrast to the other types of
failures for which little epidemiological evidence exists linking them with
actual public health problems, groundwater contamination by on-site systems
is a recognized source of disease. Keswick and Gerba (1980) cite Craun's
data (1979) that 42% of the 264 outbreaks of waterborne disease between
1946 and 1977 were due to "overflow from septic tanks and cesspools..."
Many unreported illnesses no doubt occur and are not investigated because
too few people are involved to indicate the source of pathogens. Woodward
et aJL (1961) report nitrate concentrations in water wells in 39 Minnesota
unsewered villages and metropolitan suburbs. 47.5% (30,000) of 63,000
wells showed significant concentrations of nitrate. 10.6% exceeded the
drinking water quality standard of 10 mg/1 NCL-N. Other studies document
additional examples of aquifer contamination by on-site systems.
In most of the groundwater studies, however, the areas were densely
developed and/or were underlain by channeled or fissured bedrock. Thus,
while it is known that serious groundwater problems can be caused by on-
site systems, there is usually no way to assess the potential locally other
than by sampling programs.
c. Causes of Surface Failures and Plumbing Backups
EIS I-B-1 Causes of surface failures and backup problems for existing systems can be
divided into two categories: those easy to control and those more
difficult (or impossible) to control. Those easy to control include:
system usage,
maintenance, and
surface drainage.
System usage includes number of occupants, daily per capita flow, and use
of garbage disposals. These can be controlled by installing water meters
and flow reduction devices, limiting occupancy, and prohibiting garbage
disposals. Maintenance problems can be controlled by 1) a renewable permit
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system contingent upon proof of periodic inspection and maintenance, 2)
public maintenance services, 3) required maintenance contracts, or 4)
public education. Surface drainage problems can be controlled by diverting
runoff away from on-site systems, disconnecting roof and foundations
drains, or mounding soil over soil absorption systems.
Causes of surface failures and plumbing backups that are more difficult to
control include:
system design,
soil characteristics,
site characteristics (size and shape of lot, relationship to other lots,
relative location of house and well),
groundwater hydrology, and
system age.
Most of these can be controlled by a major modification to the existing
system. Examples of possible controls include: upgrading or expanding the
system, changing the system design, using a different area of the lot,
transporting wastewater off-site for treatment, and installing artificial
drains.
d. Factors Contributing to Failures Resulting in Groundwater Contamination
Groundwater contamination from on-site systems is usually due to some type
of soil or geological characteristic. Examples of such include very
permeable sand layers, creviced limestone, or other formation that allows
partially treated effluent to bypass soil layers and enter the groundwater.
Controls for these types of failures are limited to alternative designs,
such as mounds, that overcome the particular limitations to on-site
treatment and to changing the characteristics of wastewater such as
reducing nitrogen loads with composting toilets or off-site disposal of
toilet wastes.
e. Effects of Failures
TRD II-A The most important effect of on-site system failure is contamination of
water supplies. Pollutants from failing on-site systems can enter surface
waters from groundwater plumes or when storm water runoff washes ponded
effluent into the water body. Detrimental effects of contaminated surface
waters include slightly increased algal growth and, more important,
contamination of drinking water supplies. High levels of bacteria,
viruses, and nitrates in drinking water can cause various types of disease
and illness.
Another effect is the nuisance that results from effluent ponding. This is
more noticeable in areas of higher density or when the absorption system is
close to residences.
3. AVAILABLE ALTERNATIVE ON-SITE OPTIONS
a. For Overcoming Site Limitations
TRD I Table II-A-1 lists dozens of options for on-site facilities that may be
considered for the specific site limitations or constraints given. These
can be considered for replacing, upgrading, or repairing failing on-site
facilities or for construction of systems for new buildings. (U.S. EPA,
1980b; U.S. EPA, 1980c).
b. For Existing Systems Not in Compliance with Codes
TRD VII-A Existing systems not complying with current regulatory codes should be
investigated to determine their performance. The investigation should
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TABLE II-A-1.
ON-SITE WASTEWATER MANAGEMENT OPTIONS FOR SPECIFIC LIMITATIONS FOR
CONSTRAINTS
Limitation/constraint
On-site option
None
High groundwater or shallow
depth to bedrock
Slowly permeable soil
Hydraulic, organic, or soilds
overload
Grease or scum clogging
Clogging of absorption field
Highly permeable soil
Sloped site
Subsurface disposal not
possible (for example, rock
outcrops, floodplains, steep
slopes)
Conventional septic tank/soil absorption system
Elevated sand mounds
Shallow placement system
Evapotranspiration system
Artificial drainage
Buried sand filters
Oversized soil absorption system
Seepage pits
Electro-osmosis
Pressure distribution
Evapotranspiration system
Flow reduction
Waste stream segregation; chemical biological,
or incineration toilets
Multiple septic tansk or chambers
Septic solids retainer
Septic tank baffles
Large diameter tubing
Grease trap
Septic tank baffles
Alternating drainfields H^O- treatment
Septic tank baffles
Multiple septic tanks or chambers
Gravity or mechanical dosing
Pressure distribution
Oversized soil absorption systems
Serial distribution
Discharging Options:
fixed film reactors, intermittent or
recirculating sand filters, lagoons, aerobic
unit
Disinfection Options:
Sodium or calcium hypochlorite, iodine,
ultraviolet light, ozone
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EIS III-E determine if any system failures such as plumbing backups, surface ponding,
II-D-3 or groundwater contamination have occurred. If the investigation concludes
that no significant past malfunctions have occurred and the likelihood of
future system failure is small, the subcode system should not be upgraded
just to comply with the regulations. The intent of the code is to prevent
groundwater contamination and other public health problems. If this intent
is being met (even with a "sub-standard" system), the cost to upgrade the
system would not be justified. Records of such investigations should be
made and stored so that, if and when the systems fail, the upgrade can be
designed without completely repeating the investigations.
c. Use of Soils Data
TRD III-A Of the several factors that determine on-site system performance, soil
characteristics are most amenable to evaluation prior to issuance of con-
struction permits. Regulatory agencies justifiably consider evaluation of
soil characteristics to be a key element in on-site system management.
EIS II-D-1 Soil characteristics can be used along with other information to explain
the performance of existing on-site sewage disposal systems and to predict
the performance of future systems. Explanations and predictions may be
based on either hypothetical or empirical relationships between soil char-
acteristics and system performance. An example of a hypothetical relation-
ship is correlation of percolation rates with surface malfunctions, e.g.,
malfunctions can be expected in soils with rates greater than 60 minutes
per inch. An example of an empirical relationship is the survey result
that 45 out of 100 on-site systems in slowly permeable soils are failing,
that the soils for 40 of the 45 are also poorly drained, and that 4 out of
the 5 remaining systems receive very high seasonal use.
Reliance on hypothetical relationships is appropriate for planning-level
decisions and, where supported by on-site soil inspection, for site-
specific decisions on undeveloped properties. On-site system design codes
and U.S. Soil Conservation Service soil limitation ratings are examples of
accepted use of hypothetical relationships. Design codes typically
incorporate soil criteria such as percolation rate, depth to groundwater,
and depth to bedrock to guide decisions to allow or reject applications to
install on-site systems. U.S. Soil Conservation Service soil limitation
ratings rely on a comprehensive list of hypothetical relationships to
classify specific soils as having slight, moderate, or severe limitations
for on-site systems.
The U.S. Soil Conservation Service is improving the use of hypothetical
relationships by developing and evaluating soil potential ratings. In
contrast to soil limitation ratings, soil potential ratings consider the
feasibility and cost-effectiveness of techniques that may overcome
unfavorable site characteristics.
Site-specific decisions to abandon or continue to use existing on-site
systems need not rely on hypothetical relationships. Performance and the
factors, including soil characteristics, that determine performance can be
directly measured. This empirical information may or may not confirm
accepted hypothetical relationships. It may indicate that factors other
than soil characteristics determine on-site system performance.
Collected at a sufficient number of sites and analyzed for locally
distinctive trends, data on performance and the factors that affect it will
provide a factual basis for making cost-effective decisions for both
existing and, at local option, future on-site systems. The policies and
procedures recommended in this EIS emphasize reliance on empirical infor-
mation for decisions on the disposition of existing on-site systems.
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4. SITE ANALYSIS AND TECHNOLOGY SELECTION FOR INDIVIDUAL PROPERTIES
TKD II-J In communities served by on-site systems, problems with existing systems
must be identified and appropriate remedies sought. A systematic approach
to evaluating individual on-site systems, determining causes of failures,
and selecting the appropriate technology to correct failures is presented
EIS II-D-1 in Figure II-A-1. The decision flow diagram is divided into the following
sections: 1) available data review and community surveys, 2) on-site
sanitary inspection, 3) identification of problem, 4) detailed site
analysis, and 5) technology selection.
The first step includes reviewing existing or easily obtainable data (for
more detail see description of Phase I needs documentation studies in
Appendix A, Region V GuidanceSite-Specific Needs Determination and
Alternative Plannning for Unsewered Areas and the needs documentation flow
chart, Figure II-C-2). Data for this step can usually be obtained without
going on-site and are useful for preliminary identification of problems.
The on-site sanitary inspection involves talking with individual homeowners
about their on-site systems and inspecting their property. The information
generated is useful for identifying problems with individual systems.
After specific problems are identified, the detailed site analysis section
of the decision flow diagram suggests various tests and inspections to
determine the source of the problem and to provide enough background
information to select the most appropriate technology.
The decision flow diagram provides for systems that do not meet current
codes. A septic tank slightly smaller than current requirements need not be
replaced if it is in satisfactory condition and working well.
The decision flow diagram cannot account for all situations that may be
encountered in the field and should, therefore, be used as a guide along
with common sense to determine a specific solution for each on-site waste-
water treatment system problem. The intent of the decision flow diagram is
to show that specific evaluation procedures beyond the on-site sanitary
inspection are not required on every lot. Procedures, especially expensive
ones in the detailed site analysis, should be performed only when justified
by previous findings.
CWA 201 (1)(1) This decision flow diagram is appropriate for single properties. Following
this diagram for all developed properties in a community could result in
waste of time and money where centralized solutions prove to be cost-
effective. To prevent this waste, sequencing of needs documentation work
with increasingly specific alternative development steps on a community-
wide basis is recommended. A subsequent process diagram (Figure II-C-2)
shows a possible sequence of these activities for a complex planning
situation.
5. OPTIONS FOR THE DIFFICULT SYSTEM
TRD I Some on-site wastewater problems are harder to solve than others. An
isolated section of a community with very low density might have severe
site limitations resulting in high failure rates. Sewering is not eco-
EIS VI-E-2 nomically feasible and alternative on-site options are limited. In such
cases, consideration should be given to one or more of these technologies:
flow reduction,
water metering,
segregation of wastes,
reuse/recycle,
holding tanks, or
effluent plume recovery.
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31
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NOTES
1. If, through previous experience, the cause of the problem can be identified at this point, the
detailed site analysis can be bypassed.
2. State standards for minimum setback distances should be used unless a hydrogeologic (or other)
reason exists to use a larger distance.
3. In using contaminated wells as a criterion for delineating sewer service areas, only data from
protected wells should be used.
4. Odors can come from a properly functioning septic tank/soil absorption system. Relocation of vent
may solve the problem.
5. Shoreline scan should be repeated to ensure that plumes are located properly.
6. Well samples should be taken at least twice to ensure reliability of conclusions.
7. If house drains are likely to be clogged, snaking drains may solve problem. Note: monitoring of
water meter is required after installation.
8. Septic tank and sewer inspection to include: excavation; pumping; inspection for size, structural
integrity, outlet and baffle condition; rodding house and effluent sewers; measuring distance and
direction to SAS using snake and metal detector.
9. If septic tank and/or sewers (to and from septic tank) need replacement and additional work on
drainfield is required, follow "no" route and investigate other factors before replacing septic
tank and/or sewers. This process will avoid replacement of septic tank/sewers when entire system
is not functional.
10. Other tests may be substituted if they distinguish between wastewater and non-wastewater sources
of well contamination.
11. This procedure is limited to digging and inspecting test pits in the drainfield, excavation and
repair of distribution boxes and broken header lines, snaking distribution lines to remove
obstructions, and soil borings through drainfield laterals, pits or trenches.
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a. Flow Reduction
EIS V-A-4-a Where the feasibility of retaining on-site systems depends on substantial
reductions in wastewater flows, highly effective and perhaps expensive flow
TRD II-L reduction devices should be considered. Since toilet use, bathing and
clothes washers are the greatest water users in most residences, these
TRD IV-D should be emphasized in achieving reductions in flow. Waterless toilets
(composting, chemical, incinerating or oil-recycle) or very low flow
toilets (air assisted or vacuum) can reduce total residential wastewater
flows by 30%. Water for showering can be reduced 90% or more by conver-
sion, where feasible, to air assisted showers. The water and energy sav-
C.3. ings from air-assisted showers would be lost, however, if occupants take
tub baths instead; baths generally require more water than even the most
wasteful shower. Water for washing clothes can be reduced by replacing
top-loading with front-loading washing machines. Use of these devices
together can reduce residential wastewater flows by 63% without changes in
life style (Baker, 1980).
The expense of this maximum flow reduction approach may be justified when
holding tanks are used or when the need for expensive off-site facilities
would be avoided. Where need and economics do not justify maximum flow
reduction, minimum flow reduction, the use of relatively inexpensive flow
reduction devices, can still save the homeowner money and possibly prolong
the useful life of his or her on-site system.
Economically, the most attractive devices are low flow shower heads.
Heating water is one of the highest utility costs in most residences. The
energy savings due to low flow shower heads will pay for new shower heads
in a very short time. Other inexpensive devices include toilet tank
modifications, faucet aerators, and pressure reducing values. The total
flow reduction achievable with minimum flow reduction varies. As an
example, a combination of a dual flush device (a toilet tank modification)
and a low flow shower head may reduce total water use approximately 10%
(Cohen and Wallman, 1974).
b. Water Metering
EIS V-A-4-a Water metering can determine whether water use is excessive and suggest a
proper course of action for hydraulically overloaded systems. If metering
indicates a low to moderate water usage, other sources of hydraulic
overloading should be investigated such as foundation or roof drains, air
conditioner condensate, or storm water. Where municipalities assume
liability for on-site systems or grant restricted use variances, metering
may be required to insure operability of systems.
c. Segregation of Wastes
Depending on the characteristics of wastewater from individual homes,
segregating black water (toilet and sometimes garbage disposal waste) from
the remaining waste stream can eliminate significant quantities of
pollutants, especially nitrates. Waste segregation reduces the hydraulic
and organic load to the treatment system, allowing existing treatment
systems to operate satisfactorily even if undersized, subject to high
groundwater, or subject to some other site limitation. Toilet wastes can
be segregated by composting toilets, incineration toilets, or low flow
toilets used with holding tanks.
d. Reuse/Recycle
The reuse of treated wastewater for other household uses is a relatively
new idea. The options available vary from using treated gray water for
toilet flushing to a proprietary system that recycles the entire wasteflow
for potable reuse. Depending on the percentage of wastewater recycled,
33
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these systems could be used to overcome any site limitation. The main
problems with recycle systems are the lack of long-term operations data,
the possible lack of user acceptance, and the relatively high cost of the
more effective devices.
e. Holding Tanks
EIS V-A-4-d Holding tanks are used to store wastewater (total waste flow or segregated
stream) on-site until it is pumped and hauled off-site for treatment and
disposal. Because of the massively high cost of pumping, holding tanks are
used only 1) when no other option is feasible, 2) in combination with waste
stream segregation, or 3) for seasonal residences. Serious application of
flow reduction devices is an economic necessity with any waste stream that
discharges to a holding tank.
f. Effluent Plume Recovery
Groundwater plume recovery systems are constructed by locating the
groundwater plume downstream from the on-site system and pumping the
treated effluent into a lawn irrigation system. The wastewater receives
further treatment by the soil and also irrigates the lawn. This technique
has not been field tested. Careful attention must be given to odors, public
health problems, wet seasons, and freezing of irrigation pipes. A likely
situation for use would be for seasonal residences with adequate land
available. The chief application of this technique would be for on-site
systems on lakeshores where plumes are stimulating aquatic nearshore plant
growth.
g. Limitations
EIS I-B-1 Most of the options discussed for difficult systems cannot solve existing
failures alone but must be used in combination with each other or with
other technologies for satisfactory results. For example, water conser-
vation and metering may be used in conjunction with flow segregation and a
septic tank/shallow placement soil absorption system in order to solve a
particular on-site problem satisfactorily. However, economic constraints
may prevent combinations of several technologies. Costs for overcoming
site limitations may be prohibitive. Another drawback to some of these
options is the lack of field data with which to assess their performance
and reliability. Systems such as effluent plume recovery, complete
recycle, and certain proprietary services for flow reduction and waste
segregation should be tried on an experimental basis for typical failing
systems in the community and monitored for results. Communities can then
choose the option or options that appear best suited to individual
problems.
B. SMALL-SCALE OFF-SITE TREATMENT
1. SEPTAGE DISPOSAL
TRD I Septage from homes is transported either to a treatment system or to an
ultimate disposal point as shown in Figure II-B-1. The three major cate-
gories of treatment and disposal are (1) direct land application, (2)
treatment at a separate septage facility, and (3) addition to a sewage
treatment plant. Application of septage to the land is by far the most
commonly used means of septage disposal. Of the total septage generated,
it is estimated that 60 to 90% is disposed on land. Septage disposal on
land can include surface spreading, subsurface injection, spray irrigation,
trench and fill, sanitary landfills, and lagooning. Septage pumped from
septic tanks is either directly disposed of on land or is treated prior to
land disposal.
34
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Separate septage treatment facilities generally are regional facilities in
areas with high densities of septic tank systems. Only a small portion
(approximately 1%) of the total septage generated nationally is treated in
separate septage treatment facilities. The process types currently in
operation include chemical precipitation, high-dosage chlorine oxidation,
multistage aerobic/facultative lagoons, and composting.
Disposal of septage at wastewater treatment plants is estimated to account
for up to 25% of the total septage generated. In most cases, the septage
is added to the liquid stream. In some instances, however, septage is
handled as a sludge and is processed either alone or in combination with
sewage treatment plant sludge (Cooper and Rezek, 1977; U.S. EPA, 1979a).
2. COLLECTION SYSTEMS
TRD IV-A When off-site treatment is cost-effective or when site constraints prohibit
the use of on-site systems, consideration must be given to collection of
wastewater and its transport to a treatment site. The most common methods
of collection are conventional gravity, small-diameter gravity, pressure,
and vacuum sewers. Topography, depth to bedrock, depth to groundwater and
housing density are the major factors that determine the relative costs of
these methods in a given setting.
EIS II-F-1 Conventional sewers are usually made of clay but can also be made of
plastic, cast iron, concrete, or asbestos cement. A variation of con-
ventional gravity sewers is small-diameter sewers. These 4- or 6-inch
diameter sewers can be made of the same material as conventional sewers.
Used with septic tanks at each house to remove coarse solids, small-
diameter sewers can be laid at slighter grade and require fewer lift
stations than larger sewers carrying raw sewage. Other advantages of
small-diameter sewers include 1) fewer manholes, 2) use of cleanouts in
place of some manholes, 3) lower cost of the smaller sized pipe, and 4)
less chance of clogging. Use of small diameter gravity sewers to convey
effluent is a recognized technology under several regional model sanitary
codes.
Two types of pressure sewers are available: grinder pump pressure sewers
and septic tank effluent pump (STEP) sewers. The grinder pump does not
require a septic tank at each house as the STEP system does. Both systems
transport wastewater under pressure to a treatment facility or to an area
where gravity sewers are utilized. Infiltration and inflow common in con-
ventional sewers are nonexistant in pressure sewers. Other advantages of
pressurized sewer systems include 1) smaller sized pipes, 2) easier instal-
lation (a downhill grade is not necessary), 3) and lower costs than conven-
tional sewers, especially in areas of steep slopes or shallow bedrock.
However, the lower cost of the sewers is offset by pumping units and
electricity costs. Density of development, therefore, is a factor in
economic comparisons between gravity and pressure sewers.
Vacuum sewers have the same advantages over conventional sewers that
pressure sewers have. The main difference between vacuum sewers and
pressure sewers is that wastewater is transported by a central vacuum pump
instead of many individual pressure pumps located at individual residences.
Neither pressure sewers nor vacuum sewers depend on gravity; therefore,
detrimental impacts of disturbing streambeds and low-lying wetlands during
construction can be more readily avoided. Generally, the costs (capital
and operation and maintenance) for pressure sewers are lower than the costs
for vacuum sewers (U.S. EPA, 1980b; U.S. EPA, 1977a).
3. TREATMENT METHODS
TRD I Wastewater treatment technologies for off-site treatment can be grouped in
three categories according to method of effluent discharge: 1) land appli-
36
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TRD II-K
cation (surface and subsurface), 2) wetland discharge, and 3) surface water
discharge.
Off-site subsurface disposal systems for several buildings are known as
cluster systems. Pretreatment by septic tanks is required for cluster
systems. The septic tanks can be located at individual houses (prior to
collection) or off-site, after collection and transportation. Cluster
systems resemble individual subsurface disposal systems in design and
construction but are sized for the flow from more than one household. To
ensure proper distribution, cluster systems usually employ some form of
dosing. Alternating drainfields are often used to allow drainfield resting
and provide emergency backup.
The predominant surface land application processes are shown in Table
II-B-1 along with characteristics of each process.
When considering the type of land application process to use, design
factors such as those following should be considered (U.S. EPA, 1977b; U.S.
EPA, 1976a):
wastewater characteristics,
climatic conditions (water balance),
soil characteristics,
land area required,
existing and surrounding land use,
preapplication treatment,
surface and groundwater hydrology,
vegetative cover,
treatment efficiency, and
ultimate disposal.
TABLE II-B-1. LAND TREATMENT OPTIONS AND CHARACTERISTICS
Irrigation
Predominant land application method
Indirect or no surface water discharge
Uses wastewater for production of marketable crops
Groundwater recharge
Typical land requirement of 100 to 200 wet acres/mgd
Moderately slow to moderately rapid soil permeability
Infiltration-Percolation
Overland Flow
Indirect or no surface water discharge
After infiltration, renovated effluent can be recovered
(underdrains or pumped withdrawal) or allowed to recharge
groundwater
High-rate systems require 3 to 6 wet acres/mgd
Low-rate systems require 20 to 60 wet acres/mgd
Rapid soil permeability (sands, loamy sands)
Ultimate disposal of runoff is required
Land requirements typically range from 25 to 110 wet acres/mgd
Generally does not provide the BOD and SS removals that irrigation
and infiltration-percolation do
Slow soil permeability (clays, silts, and soils with impermeable
barriers)
37
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Wastewater treatment can be accomplished by natural or artificial wetlands.
Table II-B-2 lists the typical systems that have been investigated for
artificial and natural wetlands. Prior to selecting natural wetland
application as a treatment alternative, an inventory of available wetland
sites should be made. Site characteristics (hydrogeological, biological,
etc.) must be investigated in detail if preliminary planning stages indi-
cate that wetlands discharge is a competitive option. Reliable design
criteria have not been developed that can be applied as "rules of thumb"
for sizing and estimating performance of wetland treatment systems. Pilot
scale testing should be conducted to determine the site-specific criteria
(Tchobanoglous and Gulp, 1979). U.S. EPA Region V is preparing a Generic
EIS on wetlands discharges.
Surface water discharges are often not considered for lake areas when such
discharges are likely to add to the nutrient level of the lake. In some
instances, however, surface water discharges are necessary, such as when
soils are unsuitable either for on-site systems or for land application.
In these cases, the selection of treatment facilities for small communities
should be governed by the simplicity of the treatment process and low
operation and maintenance requirements, in addition to such usual con-
straints as required effluent quality. Examples of simple treatment
systems for surface discharge are listed in Table II-B-3.
C. NEEDS DOCUMENTATION POLICIES
Discovery, understanding, and appropriate response to actual problems are
the essence of good sanitary engineering practice. They are equally
valuable to projects being designed or built with or without State or
Federal assistance.
CWA 201 (1)(1) Many elements of the following discussion specifically relate to the
Construction Grants Program and to policies and guidance in effect before
May, 1982. Although no longer required, they offer an outline of prudent
practice likely to result in a savings of time and effort. The elimination
of Step 1 funding means that new applicants for Federal funding are as free
to simplify and improvise as those planning no application.
1. NATIONAL
EIS I-B-3
In the first years of the current Construction Grants program under P.L.
92-500, detailed analysis of need for facility construction was seldom pro-
vided in Step 1 facilities plans. There were enough obviously severe water
quality problems to fill up state priority lists. The priority lists re-
flected needs recognized by the states. Primary treatment, no treatment,
and raw sewage overflows did not require analysis; they required action.
Undoubtedly, many auxiliary facilities, such as interceptor and collector
sewers for which the need was not so obvious, also were funded. The
largest and most severe problems have now been addressed by the Construc-
tion Grants program. Some have been resolved, and others are well on their
way to resolution.
Projects being considered for initial Step 1 funding in the middle 1970s,
however, did not display such obvious needs or were smaller than earlier
projects. Proposed auxiliary facilities began to represent much greater
proportions of the total project. In some projects, the costs of new
sewers represented more than 80% of total project costs. The need for
these expenditures was typically documented by about the same level of
analysis as for earlier projects.
U.S. EPA Headquarters responded to this situation by distributing Program
Requirements Memorandum, PRM 77-8, later superceded by PRM 78-9, which
established criteria for eligibility of collector sewers, the publicly
owned laterals that typically are the point of connection for privately
38
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TABLE II-B-2. TYPES (AND LOCATION) OF PREVIOUSLY INVESTIGATED WETLAND SYSTEMS
Natural Wetlands
Peatlands (Michigan, Wisconsin)
Cattail marshes (Wisconsin)
Freshwater tidal marsh (New Jersey)
Lacustrine Marsh (Hamilton, Ontario, Canada)
Swamplands (Hay River, Canada)
Wetlands, general (Massachusetts, Florida)
Cypress domes (Florida)
Artifical Wetlands
Meadow-marsh-pond system (New York)
Ponds with reeds or rushes (Germany, Holland)
Peat filled trench systems (Finland)
Peat filter (Minnesota)
Marsh pond system (California)
TABLE II-B-3. SURFACE WATER DISCHARGE OPTIONS FOR SMALL COMMUNITIES
Lagoons
Facultative
Aerobic
Anaerobic
With or without sand filters
Fixed Film Reactors
Rotating biological contactors
Trickling filters (various media, various rates)
Activated Sludge
Oxidation ditch
Package type (complete mix, contact stabilization, extended
aeration)
39
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EIS I-B-3
CWA 201(1) (1)
CWA 201(1)(2)
CWA 216
owned house sewers. These criteria and their sequence of application in
eligibility decisions are presented in Figure II-C-1 as interpreted from
PRM 78-9 and modified by recent guidance, Construction Grants - 1982. The
crux of this decision flow diagram is that a need must be documented for a
gravity collector sewer to be eligible. Then, if the need is demonstrated,
it must be shown that the sewer is the cost-effective means to satisfy the
need.
U.S. EPA Headquarters subsequently issued PRM 79-8, which provides guidance
for considering small wastewater systems. The important part of this
guidance relevant to needs documentation was discussed in Section I.E.3 of
this EIS. Briefly stated, the policy is that field work required to
document the actual type and frequency of problems with on-site systems is
eligible, but that the field work in Step 1 facilities planning should be
limited to what is reasonably required to prepare a cost-effectiveness
analysis.
The 1981 Amendments to the Clean Water Act eliminated grants for planning
and design. An allowance procedure was authorized to replace grants as a
means for defraying the cost of these activities. The changes in the Act
and its implementing regulations have alleviated these previous concerns
about eligibility of specific needs documentation tasks. However, the
fundamental principles of demonstrating need for proposed facilities and
selecting cost-effective solutions to remedy identified public health and
water quality problems have been reaffirmed. U.S. EPA's concern now is to
assist applicants in meeting these goals as expeditiously as possible.
2. REGION V
CWA 201(1)(1)
Region V's guidance on needs documentation is based on national policy,
experience gained during preparation of the Seven Rural Lake EIS's, and
input from states in the region. A copy of Region V's guidance is attached
as Appendix A. A key feature of this guidance is sequencing of needs
documentation activities with alternative development, costing, selection,
and design. Also, decision points are identified at which the results of
needs documentation work can be reviewed. The scope of facilities planning
can then be adjusted appropriately.
Region V's guidance was in effect prior to passage of the 1981 Amendments
to the Clean Water Act and prior to preparation of the May 12, 1982,
interimfinal regulations implementing the Act. Nevertheless, the guidance
reflects good practice and has not been altered in substance by changes to
the Act and regulations except that references to grant eligibility of
specific tasks and their acceptable timing in Step 1 and Step 2 are no
longer appropriate.
The accompanying process diagram (Figure II-C-2) shows how needs documenta-
tion and alternative development tasks can be sequenced for a complex
planning situation. Sequencing of these tasks can prevent wasted time and
money spent on field work where centralized solutions might prove to be
cost-effective. Sequencing also provides check points where the scope of
upcoming tasks can be modified to reflect recently acquired data. Addi-
tional discussion of sequencing and more examples of how it can be applied
are available in Technical Reference Document XVI.D.
"Alternative
Construction Grants Procedures for Small Waste Flow Areas" reproduced in
Appendix A of this Final EIS. Chapters III-V discuss the other two
important aspects of such an optimum operation alternative: community
management and the mechanics of the grant program itself. Taken together,
these chapters constitute a road map for planning the management and design
of optimum operation alternatives.
40
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D. NEEDS DOCUMENTATION METHODS
As discussed in Section II-C, participation of the U.S. EPA in the funding
of new wastewater management facilities is contingent upon the documenta-
tion of their need. Needs documentation efforts in Region V's unsewered
areas involve the collection and analysis of available or easily obtainable
data (Phase I), and on-site investigations and representative sampling
necessary to define adequately the type and extent of water quality and
public health problems, determine their causes, and predict remedial
measures (Phase II).
At each stage of needs documentation, individual sites can receive
preliminary assignments to the "need," "no-need," or "inconclusive"
categories.
As Figure II-C-2 shows, these assignments may be reviewed or revised as
data collection proceeds. The purposes of the Phase I and Phase II work
are four-fold:
To reliably estimate the need for any action,
To delineate areas requiring no action, optimum operation of existing
on-site systems, small-scale off-site systems or centralized sewers and
treatment,
To support estimates of on-site measures necessary to construct an
optimum operation alternative,
To effectively organize data acquisition, avoiding duplication of on-
site work and excavations.
Recommended methods by which need may be documented include:
gathering and analysis of available data,
aerial photographic interpretation,
septic leachate detection,
mailed questionnaires,
eutrophication modeling
nearshore plant surveys
partial sanitary surveys, and
representative samplings.
With the exception of mailed questionnaires, all of these methods were used
during the preparation of Region V's Seven Rural Lake EIS's.
1. PHASE I: EXISTING DATA AND DATA COLLECTION
Phase I of needs documentation involves collection of existing data, and
development of general areawide data at moderate cost. Some of the methods
of data collection described here may be valuable in more than one part of
the needs documentation and planning process. Septic leachate detection is
useful not only for lakeshore plume detection but also for detection of
marginal contamination of drinking water wells as part of Phase II
representative sampling. Aerial photography is useful for a whole variety
of planning and design purposes.
At the end of Phase I it should be clear whether no action, centralized
collection and treatment or some form of the optimum operation alternative
is necessary. Within the optimum operation alternative, need or the lack
of it will already be clear for many sites. The information that makes
this possible is also vital to the early stages of alternative design
(alternative screening, technology assumptions, and cost curve analysis as
described in Section II-E).
44
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a. Gathering and Analysis of Available Data
The use of available data can provide a rapid and inexpensive means of
defining the need for improved wastewater management facilities on an
areawide basis. Relevant data assessment efforts include:
Review of local well and septic tank permit records maintained by public
health agencies. Repair permits for septic tank systems can provide
valuable data on the types, frequencies, and causes of system failures,
as well as historical solutions to on-site system problems. Review of
records containing information on the bacteriological quality of private
water supply systems can provide information on the location of wells
that may have been contaminated by on-site sewage treatment systems.
Interviews with sanitarians, soil scientists, septic tank installers and
haulers, well drillers, and zoning officers. Information gathered during
these interviews can identify the location of on-site system problems
(surface malfunctions, sewage backups,illicit discharges, etc.) and
pinpoint areas in need of further investigation during Phase II. System
problems attributed to poor site conditions or inadequate maintenance
practices can be identified through discussion with these officials and
contractors.
Windshield surveys. An automobile tour of the entire community in the
company of local sanitarians, soil scientists, or other knowledgeable
persons (see interviews above) can provide first-hand observation and
interpretation of site conditions and on-lot system practices. This
information will help the applicant's small waste flows specialist
develop a strategy and cost estimate for Phase II field investigations.
TRD III-A Review of soil maps. General and detailed soil maps may be available to
EIS II-A-3-c the small waste flows specialist for use as a guide to planning needs
documentation efforts. They do not by themselves document need. Soil
surveys are published by the U.S. Department of Agriculture Soil
Conservation Service in cooperation with state agricultural experiment
stations. General soil maps, with map units consisting usually of soil
associations drawn at a scale of 1 inch to the mile or less, can be used
for preliminary determinations of the potential suitability of on-site
systems on a community-wide basis. Detailed soil maps, which delineate
soil series, soil complexes, and undifferentiated units at a scale of
approximately 4 inches to the mile, and soil interpretation data enable
the applicant to estimate what percentage of lots can be expected to be
served satisfactorily by on-site systems. It is emphasized that neither
detailed soil maps nor soil limitation ratings contained in the soil
surveys provide a documentation of need. However, they are particularly
useful in planning site-specific field investigations of on-site system
suitability.
TRD XI-B Preparation of base maps. A recommended final step in the gathering and
analysis of available data involves the preparation of a base map. This
EIS IV-D-1 synthesizes information collected and facilitates its use in subsequent
needs documentation efforts. Synthesized data could include soil and
groundwater conditions, land use, and age and density of housing. U.S.
Geological Survey 7.5 minute maps (1:24,000), Soil Conservation Service
soil maps (1:15,840), or local tax maps can be used to prepare planning
area base maps at low cost. Maps that illustrate the location of indi-
vidual buildings are particularly useful. Overlays can be prepared that
delineate:
developed areas obviously requiring centralized facilities.
individual buildings with obvious problems, and
developed areas with indirect evidence of problems.
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Review of Available Water Quality and Eutrophication Modeling. Existing
data may include water quality or eutrophication modeling from any of a
variety of sources such as the National Eutrophication Survey and
various state and 208 surveys. These may be valuable in making
preliminary estimates about the relative role of on-site systems and
non-point pollution sources, so that efforts may be concentrated in
those areas yielding the greatest water quality improvement. It is very
important, however, to know the assumptions made in development of the
model and how they may be modified by actual on-site system performance.
b. Aerial Photographic Interpretation
TRD II-F Properly acquired and interpreted aerial photography can provide data on
surface malfunctions of on-site systems. With this technique, a community
survey can be made rapidly and at relatively low cost without intruding on
private property. Aerial photography detection of surface malfunctions is
a 3-step process involving acquisition of the photography, identification
of suspected malfunctions by an experienced photo interpreter, and field
checking of the suspected malfunctions.
Optimum coverage, resolution, and signature recognition can be achieved
using fine grained color infrared film flown to a scale of approximately
1:8000 (1 inch = 1667 feet). Other image types can be acquired in conjunc-
tion with the color infrared film, such as true color, thermal infrared, or
thermal scans. However, experienced photo interpreters (Evans, 1981) feel
that color infrared film will be adequate. Both true color and color
infrared film were acquired and used comparatively for identifying surface
malfunctions during preparation of the Seven Rural Lake EISs.
Timing of the flight is an important consideration in remote sensing of
surface malfunctions. These failures can best be detected when groundwater
elevations are highest and foliage is minimal. Therefore, best results for
permanent residences are obtained during spring or late winter when the
ground is not snow covered. Tree cover present during the remainder of the
year can limit detection of surface malfunctions. In cases where aerial
photographs must be taken during summer months, such as in communities with
seasonal populations, the subsequent interpretation and field checking
phases must be conducted more cautiously. Also, flights can be completed
with substantial overlap of photos affording stereoscopic analysis of
on-lot features. Interpreters can actually see under some taller trees.
Suspected malfunctions should be identified from the photography by an
experienced photo interpreter. The experience is needed to distinguish
valid signatures from those of unrelated phenomena such as shade, natural
vegetation and wet soils, and artificial surface drainage features.
Surface manifestations of surface malfunctions include:
conspicuously lush vegetation,
dead vegetation (especially grass),
standing wastewater or seepage, and
dark soil indicating excessive accumulation of organic matter.
EIS IV-G The suspected malfunctions should be field checked. The ideal person to do
this is the photo interpreter although others may perform this task. By
inspection and, if feasible, by interview with the residents, the suspected
malfunctions are reclassified as:
confirmed malfunctions - standing wastewater from an on-site system is
visible on the land surface,
marginal malfunctions - accumulation of excess organic matter or the
presence of dead vegetation indicate that wastewater had surfaced in the
past, or
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irrelevant signatures - visible surface or vegetative features which
mimic the visual characteristics of malfunctions but are not caused by
wastewater.
TRD X-B Aerial photography acquired for this purpose can be used for other purposes
XI-B during facilities planning such as:
house counts,
* land use, vegetation and wetlands analysis, and
layout of wastewater collection and transmission facilities.
To accomplish the last purpose, precision flights are necessary to overcome
resolution problems that can result from the normal tilting of the airplane
during photo missions. No special preflight measures (establishment of
reference points, etc.) are required. Available maps can serve as a guide
on precision flight missions. Precise photo missions enhance the three-
dimensional effect already characteristic of aerial photographs, thereby
enabling facilities planners to complete detailed design of wastewater
collection and- transmission facilities. These data supplement those
contained on USGS topographic maps. The cost of precision flights can be
expected to be approximately 50% greater than normal photographic missions.
The decision to make a precision flight should be based on the likelihood
of large portions of the facilities planning area requiring centralized
collection and treatment. Otherwise the extra cost cannot be justified.
c. Septic Leachate Detection
TRD II-D&E Currently available septic leachate detectors can be used to locate ground-
water inflows or surface runoff conveying domestic wastewater into lakes.
The operational theory of the detector depends on the assumptions that
fluorescent organic materials are present in wastewater and that inorganic
chemicals will be present in wastewater at higher concentrations than in
ambient groundwater or surface water. Detection of both increasing
fluorescence and increasing conductivity in water drawn by pump from a
shoreline provides tentative evidence of the presence of domestic waste-
water. Because of the high sensity of their fluorometers, currently
available detectors can rapidly locate groundwater effluent plumes and
wastewater in surface runoff where wastewater is otherwise undetectable.
This tool proved to be invaluable in studies that addressed the impacts of
on-site systems on lakes studied for the Seven Rural Lake EIS's.
The septic leachate detector is subject to certain limitations that must be
recognized in its use and in interpretation of the data it generates. The
most significant limitation is that it cannot quantify the strength of
wastewater in a sample or body of water. The organic and inorganic para-
meters that it monitors can be transported through soil and water quite
independently of other wastewater constituents. Even the fluorescence and
conductivity are recorded in relative, not quantitative, units. In order
EIS IV-E-1 to quantify the concentrations of nutrients, bacterial, or other wastewater
constituents, flow through the meter can be subsampled or samples can be
collected by conventional means for later analysis. The advantage of the
detector is that it permits collection of samples in suspected effluent
plumes so that random sampling is avoided.
Aside from the limit on quantification, septic leachate detector surveys
are subject to false positives and false negatives. Most of these
potential errors are due to the dynamic nature of the natural systems
involved and to variability in wastewater characteristics. False positives
can be caused by:
Naturally fluorescent decay products from dead vegetation. Swamps,
marshes and peat deposits can leach tannins, lignins and other organic
compounds that fluoresce in the detection range of the fluorometer. The
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conductivity measurements provided by the detector are intended to
differentiate such signals, but in practice dilution may eliminate
detectable conductivity changes expected from wastewaters, thus making a
wastewater plume appear to be the same as natural decay products.
Sediment or air drawn through the detector can cause dramatic changes in
the monitor readings. This is usually noted by the operator and
recorded on the recorder tape.
Eddy currents carrying large wastewater or bog plumes can appear to be
individual plumes from on-site systems.
The more serious errors are false negatives since they may indicate no
problem where actual problems might exist. Notable false negatives are:
As mentioned above, high dilution of wastewater in lake or groundwater
may reduce conductivity differences to the level of normal background
variations.
The absence of conductivity differences will cause the detector to
electronicly mask fluorescence signals that are detected.
Mixing of lake water by wind and waves can disperse leachate very
rapidly so that normally strong effluent plumes can be missed al-
together. The time it takes for leachate to accumulate along a
shoreline to detectable concentrations is dependent on several, so far
unstudied, factors.
Fluctuations in lake level can slow or even reverse normal groundwater
flow, temporarily eliminating leachate emergence at a shoreline.
Groundwater recharge by rainfall, snowmelt or irrigation will also
affect the dynamics of leachate movement.
Seasonal use of dwellings may result in only periodic emergence of
leachate at a shoreline.
Due to these factors, the data generated by septic leachate detectors has
to be carefully interpreted before it can be considered to be useful
information. Interpretation is aided by supplementary data collected or
recorded before, during, and after the shoreline scan as noted:
Before
watershed boundaries
groundwater aquifer characteristics
groundwater flow as determined by meters or other methods
soil types
wetlands and other sources of organic decay products in the watershed
locations of surface malfunctions identified by aerial photography
interpretation
information on design, usage, and performance of onsite systems if
available
changes in lake elevation.
weather conditions - especially wind, speed and direction, and recent
rainfall
lake stratification and surface currents
observed non-wastewater sources of fluorescence or conductivity such as
culverts, drainage ditches, salt storage areas, landfills, abundant
organic material in near-shore sediments
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observed direct discharges
likely proximity of on-site systems near shoreline
operational mishaps such as stirred up sediments, air drawn through
meter and engine backwash
sensitivity and zero adjustments for fluorescence and conductivity
channels
frequent notation of visual meter readings
location, time, and conditions of water sample collection.
After
water sample analysis results.
Because of the possibilities for error and the many factors influencing the
result of septic leachate detection, the validity of surveys rests heavily
on the experience, knowledge, and judgment of the surveyor. Until addi-
tional evaluation is made of the factors influencing survey results, septic
leachate surveys will be eligible for Construction Grants funding only
when:
1) the person in charge is experienced in operation and maintenance of the
detector model being used. At least two weeks of field experience is
necessary assisting someone who is already expert with the model,
2) the person in charge is present during any shoreline scans that are
reported,
3) data is interpreted by a person who has a professional background in
limnology, and
4) approximate wind speed and direction are noted during the survey and
reported.
Septic leachate detectors should prove to be valuable monitoring tools for
communities managing shoreline on-site systems. Purchase of detectors will
be eligible for Construction Grants funding. Grantees will be required to
show that comparable instruments are not available on a timely basis from
other nearby grantees. Funded instruments will be made available to other
grantees.
d. Mailed Questionnaires
Mailed questionnaires enable the applicant to exchange information with the
community that will be affected by the results of the needs documentation
effort. The objectives of this method are to:
Inform affected residents of the
- objectives and scope of facilities planning effort,
- importance of needs documentation to facilities planning,
- needs documentation results to date,
- importance of public response to the questionnaire and how
questionnaire data will affect planning efforts, and
- other opportunities available for public participation;
Obtain information on
- the nature and extent of existing pollution and public health problems
as recognized by local residents,
- private wastewater management systems including type, age, location on
property, maintenance records, proximity to private water supply and
surface water bodies,
- lot size,
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- dwelling use (number of bedrooms, permanent or seasonal status),
- private wells including type, construction, location, depth, etc.,
and
- water use in the home;
Determine willingness of residents to allow follow-up surveys and site
investigations.
The questionnaire should be as general as possible and should be prepared
with an awareness that responses are going to be only as good as 1)
residents' knowledge of their own property, 2) their understanding of the
questions being asked, and 3) their willingness to exchange information.
Because their response to the questionnaire could lead to replacement or
renovation of their systems at significant cost, residents may feel it is
in their best interests not to divulge information about their sewage
disposal systems. A concise explanation of the questionnaire's purpose may
improve public cooperation and participation in this impersonal yet com-
prehensive survey of community need.
e. Eutrophication Modeling
For developed lakeshores, needs documentation may include modeling of the
EIS IV-E-2 impact of on-site systems on lake eutrophication potential. A preliminary
estimate can be made with a procedure described in Chapter IV-E-2. The
procedure uses basic hydrological and morphological data for lakes. Based
on the outcome of this estimate, development of more detailed nutrient
budgets may be justified, possibly supplemented by collection of water
quality data to resolve major uncertainties.
f. Nearshore Plant Surveys
Septic tank effluents transported to lakes by groundwater can stimulate
growth of attached and floating plants along lakeshores. Where natural
factors do not control this 'growth and it prevents recreational use of the
water, abandonment of on-site systems might be justified. Surveys that
determine the location and density of nearshore plant growth are a
legitimate needs documentation method. Aerial photography taken during the
growing season can guide such surveys. Nearshore plant surveys are best
conducted along with septic leachate detector or partial sanitary surveys
(see Chapter II-D-2-a) since total cost would be minimized. Results can be
correlated with known locations of effluent plumes and other treatment
problems.
2. PHASE II: DATA COLLECTION AND COMPARISON
If Phase I does not adequately quantify or identify the causes of on-site
system failures, then a second phase of needs documentation and alternative
development may be necessary. The Phase II data collection and subsequent
analysis allows needs documentation to proceed further greatly reducing the
number of "inconclusive" lots. It does this by surveys of selected sites
(both by interview and representative soil and groundwater sampling). Its
aim is not necessarily to do these things for all inconclusive sites but to
study enough of them that reasonable conclusions about systems not studied
may be drawn from those that have been.
Phase II data collection, like that of Phase I, affects not only needs
documentation but actual alternative design. It makes possible a
preliminary system selection for each dwelling in the study area. As with
needs documentation, not every site receives an interview, survey and
sampling, but only those providing sufficient conclusions about the sites
not studied. This is discussed at length in Section II-E.
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a. Sanitary Surveys
TRD II-G Phase I needs documentation efforts will have involved the gathering and
analysis of available or easily obtainable data regarding the type, extent,
and frequency of on-site system malfunctions. Phase I data will have been
used to categorize developed lots within the facilities planning area into
one of three groups: those with obvious problems, no problems, or incon-
clusive problems. Field work in Phase I will have been limited to rapid,
community-wide surveys requiring little or no access to private property.
If available data does not document the causes of system failures, only
hypothetical statements can be made about continued performance of existing
on-site systems.
Sanitary surveys and concurrent representative samplings are field investi-
gative efforts (Phase II) that develop the empirical data necessary for
performance explanation or prediction relevant to existing and future
systems, respectively. The primary objectives of such efforts are to:
reclassify surveyed lots from the "inconclusive" category to "obvious
problem," "no problem," or "potential problem,"3 and
develop requisite information to predict appropriate technologies and
attendant costs for responding to community wastewater management
problems.
Survey design may be either random or targeted. The intent of a random
survey is to obtain as accurate an estimate of failure rate as possible
with a limited number of on-site sanitary inspections. Random surveys are
appropriate where Phase I needs data are incomplete or where most developed
lots remain in the "inconclusive" category. Any bias in the selection of
properties to be inspected must be noted. Such bias must be accounted for
when projecting survey results to uninspected systems in the same segment
or community. As a rule of thumb, random surveys may include 20% of
properties in each segment. (Guidance that is statistically more valid
should be developed by U.S. EPA or the states after a number of small waste
flow projects are completed and the correlation between number of systems
inspected and accuracy of the survey statistics is analyzed.)
Targeted surveys are indicated where the types and frequencies of failures
are adequately estimated from Phase I information but where evidence of
causal connections between poor performance and site, design, and usage
characteristics is sought. With this survey design, properties are
selected for inspection if they have "obvious problems" or if they are
suspected of having problems based on age or known site limitations.
Within a community, sanitary surveys may be designed segment-by-segment to
be random or targeted as appropriate. It is emphasized that statistics on
failures and potential remedies obtained during random surveys are not
interchangeable with statistics from targeted survey areas and vice versa.
Causal relationships between system performance and characteristics of the
site, system design or system usage established by surveys may be meaning-
ful community-wide, however.
EIS II-A-4 Formats for on-site sanitary inspections should be sufficiently general to
be used on either a random or targeted basis. At a minimum, inspections
should involve for each building:
Potential problems are systems that do not yet exhibit direct evidence of failure but
that can reasonably be expected to fail in the future as predicted by the failures of
similar systems.
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an interview with the resident to determine age of the building and
sewage disposal system, design and location of the sewage disposal
system, system maintenance, occupancy of the building, water-using
appliances, use of water conservation devices, and problems with the
wastewater system;
an inspection of the property, preferably in the company of the
resident, noting location and condition (if possible) of well, septic
tank, soil absorption system, pit privies, and other sanitary facili-
ties; lot dimensions; slope; roof and surface drainage; evidence of past
and present malfunctions; and other relevant information such as algae
growth in shoreline areas; and
preliminary conclusions on maintenance, repairs, applicable water
conservation methods, and types and location of replacement facilities
or upgrading measures for existing wastewater systems.
The effectiveness of partial sanitary surveys may be limited by the
unavailability of properly trained personnel. Optimally, the surveyor
should be a sanitarian, engineer, soil scientist, or other professional
knowledgeable of on-site systems, their uses, and their limitations. In
the absence of these persons, nonprofessional personnel could be trained in
a relatively short period to be competent in the conduct of sanitary
surveys. It should be impressed upon these personnel that straightforward-
ness with the public and objectivity in survey data interpretation is just
as important in sanitary surveys as is knowledge of public health, soil
science, and sanitary engineering.
An example of the sanitary survey form used by U.S. EPA during its prepara-
tion of the Seven Rural Lake EIS's is included in Appendix B.
b. Representative Samplings
TRD II-C Representative samplings are intended to enhance the conclusiveness of
Phase II field investigations. Representative sampling conducted in sup-
port of partial sanitary surveys can identify previously unrecognized but
documentable water quality and public health problems, thereby verifying
the number of "obvious problem" lots. Representative sampling may involve
one or more of the following parameters:
Seasonally or permanently high water table. Selected lots suspected
during Phase I of having seasonally or permanently high groundwater
elevations should be augered to a depth of five or six feet to resolve
the uncertainty.
Where a seasonally high water table is suggested and sampling has to be
conducted during dry weather, soil mottling may offer an indication of
high groundwater elevations. In this case, a soil scientist with
knowledge of local soils should be involved.
TRD II-H Groundwater flow. In areas served by on-site systems, the safety of
private well water supplies, small springs, and surface waters may
depend on the direction and velocity of groundwater flow. This informa-
tion is not likely to be available during Phase I. Phase II efforts
will generally be limited to evaluation of well logs and other available
data and to rapid surveys in lakeshore areas. More intensive work may
be useful in some communities.
EIS II-A-2-a Well water contamination. Where contamination by on-site systems of
IV-E-1 aquifers used for drinking water is suspected, sampling of existing
VI-A-1 wells is encouraged. Parameters that may be analyzed include nitrates,
chlorides, fecal coliforms, surfactants, and whiteners. Samples should
only be taken from wells that are properly protected from surface runoff
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and other sources unrelated to wastewater. Sampling must be accompanied
by inspection of the well.
EIS IV-E-1 Shallow groundwater contamination. Groundwater pathways to surface
water bodies and unconfined aquifers may be sampled in areas where
drainfield to water table distances are less than state standards.
Soil permeability. Soil augering to a depth of a selected number of
feet should be conducted by a qualified soil scientist on or near lots
suspected of having very slow or very rapid permeability. Percolation
tests will not usually be necessary.
The value of representative samplings data can be increased through extra-
polation to similar areas within the community. For example, well logs and
soil borings contain valuable information about soil materials and water
table elevations. Following interpretation by soil scientists and hydro-
geologists, these data can be related to specific soil map units, thereby
supporting predictions for all areas containing the same map units.
TRD XVI-D The scope of representative sampling should depend on the conclusiveness of
prior decisions to adopt the optimum operation approach. If it is clear
prior to Phase II that this approach will be adopted, sampling at a level
equivalent to detailed site analysis should be considered. If the decision
has not been made, then the scope should be limited to sampling that will
evaluate typical performance problems, not all of the problems revealed by
the sanitary survey.
3. RETENTION AND FUTURE ANALYSIS OF NEEDS DOCUMENTATION DATA
Data describing the type, extent, and frequency of water quality and public
health problems associated with on-site systems are collected continually
at the local level by sanitarians, soil scientists, and engineers. When
augmented by empirical soils and performance information, this needs
documentation data base provides an invaluable tool for evaluating the
cause of on-site system failures and for predicting future system per-
formance. As such, this data base enables local officials to make informed
decisions on technology selection and system permitting. Obviously, this
suggests that needs documentation data collected during Phase I and Phase
II should be retained for future decision-making. Available soils and per-
formance data could be assessed and tabulated for inclusion in an empirical
data base during the winter months when field investigation efforts and
therefore time and personnel constraints are minimal.
EIS II-A-3-c The economic justification for the collection and use of empirical soils
and needs documentation data at the local level should be based on 1) a
moderate to high level of need based on density of development, on-site
system failure rate, and sensitivity of water resources and 2) the fact
that cost savings from optimum operation of existing systems far outweigh
the costs associated with data collection. The optimum operation approach
is based upon the collection and use of empirical information. It is
frequently more cost-effective than construction of new centralized
facilities that do not require this information.
EIS I-B-3 To maximize the utility of needs documentation and empirical data for
future decision-making, this EIS recommends that a standardized information
system be developed that will facilitate statistical correlation of soil
characteristics, other determinants of performance (system age, design,
maintenance, etc), and on-site system performance itself for use by local,
regional, and state governments in Region V. The objectives of this effort
would be two-fold. First, retention and tabulation of empirical/needs
documentation data are essential to the long term success and low cost of
optimum operation alternatives. A standardized format and local storage of
the data (by fire numbers, segments, etc.) could facilitate extrapolation
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of information from one area to another within the community. Second, use
of the same standardized system by state governments would enable empirical
needs documentation data to be extrapolated from one county or region to
another. As discussed in Section I-B-3, transferability of needs data
would enable state officials to manage information gaps that may include
small waste flows state of the art, costs, and management techniques.
This EIS recommends that Region V, Headquarters, the Office of Research and
Development, and other divisions of U.S. EPA discuss among themselves and
with concerned state agencies in Region V the best means of developing and
utilizing standard formats for the collection, analysis, storage, and
retrieval of needs documentation data developed with Construction Grants
funds.
E. DESIGNING AN OPTIMUM OPERATION ALTERNATIVE
EIS I-A The Seven Rural Lake EIS's recommended (wholly or in part) optimum
operation of existing on-site systems, upgrading or replacement of failing
systems, and construction of cluster systems where on-site remedies are not
workable or cost-effective. The varied range of project sizes, water
quality problems, and site conditions suggests that these methods should
work well in the great majority of unsewered rural lake areas. They can
usually offer a substantial savings in operation and maintenance, as well
as capital costs, over new centralized facilities, while normally providing
comparable public health and water quality benefits.
For these reasons, Figure II-C-2 and this section concentrate heavily on
community development of an optimum operation alternative. They do not
specifically discuss the steps for development of centralized alternatives
that may proceed in concert with it. However, the principles of needs
documentation, sequencing, and system selection reflected in Figure II-C-2
and the Region V Needs Documentation Guidance (Appendix A) will, if dili-
gently followed, lead just as surely to a conventional system or a modular
combination of centralized and small waste flow technologies if that is
what is needed, feasible, and cost-effective.
The sequence of data collection steps shown in Figure II-C-2 and discussed
in Section II-D was designed to support increasingly detailed steps in the
screening and development of optimum operation alternatives. The sequence
of data collection steps and parallel alternatives development steps are:
Data Collection Alternative Development
Phase I Needs Documentation Technology Assumption
Phase II Needs Documentation System Selection
Detailed Site Analysis Facilities Verification
The purpose of sequencing these efforts is to build decision points into
the planning process. If at various points, "no action" or centralized
alternatives are demonstrated to be better than optimum operation,
subsequent planning efforts can be redirected as appropriate. If at an
early stage of needs documentation it becomes clear that the optimum
operation approach is appropriate, then the sequence is further simplified.
These and other factors will modify the actual sequences of steps taken in
a given community. Such factors are discussed and examples of modified
sequences are presented in Technical Reference Document XVI-D, "Alterna-
tive Construction Grants Procedures for Small Waste Flow Areas" reproduced
in Appendix A.
With or without Federal funding the approach outlined here will save time
and effort. In general, the development, costing and evaluation of alter-
natives proceed at a pace only slightly behind that of needs documentation,
and at a comparable level of detail.
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The following sections discuss the alternative development tasks as they
relate to the key data collection steps.
1. PHASE I
The areawide information obtained during Phase I of needs documentation is
also instrumental to the early phases of alternative development. Before
the end of Phase I it should be clear: (1) whether any action is needed,
(2) how segments should be delineated, (3) whether centralized or small
waste flow approaches are needed, and (4) which approach is likely to cost
more.
EIS II-F-3 Phase I data should suffice to make a general assessment of the need, cost,
II-F-1 and feasibility of centralized and small waste flows approaches. The
costing techniques need not be detailed since on-site technology selection
for each residence would not yet take place. Decisions to proceed with
development of optimum operation alternatives will usually be based on the
feasibility of continued use of existing systems since cost comparisons at
low and moderate housing densities will nearly always favor continued use.
a. Segment Delineation
EIS II-H After a review of existing data suggests the need for some response (see
II-D), delineation of segments is the first task of alternative develop-
ment. Unless existing data is extremely limited, this can be done from
available data and community surveys that do not require access to
individual lots.
This task uses information such as:
housing density
failure rates (and kinds of failures) for existing systems
soil types
groundwater conditions
types of systems in use
and other relevant information to divide the study area into segments with
similar characteristics.
Segmentation begins alternative development by organizing site-specific
data. It should at least divide existing sewered areas and those that
obviously require sewers from those areas where the performance and density
of existing on-site systems warrant consideration of the optimum operation
alternative.
b. Screening Alternatives by Segment
Once the segments are defined and Phase I data collection (see II-D) is
completed, it becomes possible to screen alternatives by segment. The
intent of this task is to:
exclude from further planning those segments with limited need, and
recognize specific conditions common to individual segments, such as
housing density, types of facilities in use, nature of water quality
problems, and lake trophic conditions (see Chapter IV-E-2), which
require continuing attention as decisions are made.
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c. Technology Assumptions
Available data and Phase I data collection may not support accurate cost-
effectiveness analysis. Nevertheless, this is an appropriate time to make
a rough determination of those segments that must have off-site treatment,
those that require small waste flows management, and those that are suited
for "no action." To do this, the least detailed type of alternative
description, technology assumptions, will suffice. For optimum operation
alternatives, technology assumption is an informed estimate of the overall
number and types of replacement and upgraded facilities by segment or by
similar groups of segments. This can be done by an appropriate match of
on-site technologies to segment conditions and problems.
First, the overall rate of replacement and upgrading is estimated as indi-
cated by Phase I data. Because this data is not detailed, the estimate
should be somewhat higher than actually documented. Estimates can be made
for individual segments or groups of segments where some action is indi-
cated by the data.
Next, a mix of replacement and upgrade technologies is assumed as indicated
by the types of failures documented and by conditions in the segments. At
this stage the accuracy of the mix is not critical nor is the selection of
specific technologies for individual sites. The intent of technology
assumptions is to prepare a basis for preliminary cost comparisons between
sewered and small waste flow approaches.
d. Cost Analysis
PHASE II
After the technology assumptions are made, two different sources of data
for cost comparisons are available: the cost relationships developed in
the Cost Variability Study (see Sections II-F-1 and F-2) or locally
developed cost data. A cost comparison of sewered and small waste flows
technologies will produce a preliminary indication of which will be more
cost-effective, focus attention on serious need areas, and guide the plan-
ning of Phase II data collection. Absolute accuracy of cost analysis at
this point is not critical since any segment for which sewering is not
incontestably cost-effective should be included in Phase II data collec-
tion.
Phase II takes the project through completion of all remaining facilities
planning, including development of a proposed action. If properly
developed, Phase II data will allow more precise selection and costing of
necessary facilities, especially for the optimum operation alternative.
As Phase II data acquisition proceeds, it becomes increasingly possible to
estimate both needs and possible remedies, until by the completion of
facilities planning we also have a preliminary treatment recommendation for
surveyed sites. Phase II data collection efforts should seek information
to assess the reasons for existing system failure as well as to recommend
appropriate solutions.
Systems Selection
After Phase II needs documentation work and the reclassification of
developed lots, the measures needed to remedy failures become increasingly
clear. New information generated during the partial sanitary survey and
representative sampling should improve the facilities planner's under-
standing of the nature and cause of specific on-site system problems. With
this improved understanding, the planner should review and modify his
technology assumptions. In addition, preliminary treatment recommendations
might be made for surveyed properties. In cases where Phase I and Phase II
56
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data are particularly comprehensive, preliminary treatment recommendations
might be possible for most or all properties in the optimum operation
service area. Preliminary treatment recommendations should be contingent
EIS II-A-4 on detailed site analysis such as described in Section II-A-4.
At a minimum, systems selection should document:
descriptions of the common type of on-site system failures in the area
with known, on-going failures located on a map of the planning area,
analysis of the site, usage, or design factors which cause the failures,
technology selection criteria which relate local problems and their
causes to feasible structureal and non-structural solutions,
the estimated number of on-site systems requiring upgrading, replacement
or renovation, and
* the approximate mix of methods estimated to be required to correct
failures.
b. Alternative Description
System selection is the core of a final optimum operation alternative.
Other elements need to be added:
EIS II-B-1 Septage Disposal. Estimated quantities of septage, feasible treatment
TRD I methods, final disposal sites, and collection equipment must be
described.
EIS III-C-3 Administration, Operation and Maintenance. The management services
TRD VI-A necessary for the successful long-term performance of selected systems
need to be identified on a preliminary basis. Both necessary and
elective services should be included regardless of whether provided by
the applicant or by others.
EIS II-F-3 Present Worth. All direct costs for the alternative over the 20-year
design period will be estimated and converted to their present worth.
EIS II-F-4 Average Annual Homeowner Cost. See Section II-F-4.
EIS III-B-4 Detailed Service Area Delineations. The potential service areas
delineated on the basis of Phase I information may be refined to reflect
Phase II decisions. If some services will be provided to some small
waste flow segments but not others, these differences may be described
and shown graphically as different service areas.
c. Proposed Action Description
Selection of one alternative to be the facilities plan's proposed action
involves environmental assessment, public review, coordination with grant
and regulatory agencies and, finally, a decision by the applicant.
If an optimum operation alternative is selected for part or all of the
planning areas, three items will be needed in addition to those included at
the final alternative stage:
Applicants capabilities. The applicant must certify that funded
facilities will be properly operated and maintained. To do this it
should:
40 CFR 35.2104 - Demonstrate the legal, institutional, managerial and financial
capability to ensure adequate building and operation, maintenance and
replacement of the facilities.
57
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40 CFR 35.2110 - Provide assurance of access to on-site systems at all reasonable
times for such purposes as inspection, monitoring, building,
operation, rehabilitation, and replacement.
40 CFR 35.2106 - Submit a draft plan of operation that addresses development of an
operation and maintenance program and manual, an emergency operating
program, personnel training, a budget for operation and maintenance,
operational reports, and laboratory testing needs.
t Availability of Cluster System Sites. If small scale off-site treatment
appears to be necessary, the availability of potential treatment sites
should be investigated. Where the need for sites is contingent on
detailed site analysis of existing on-site systems, availability does
not have to be conclusively demonstrated at this point.
EIS III-I Proposed User Charges. The "average annual homeowner costs" estimated
for final alternatives include private costs and do not recognize dif-
TRD VIII-B ferent user classes. Based on decisions made for the management pro-
gram, the publicly-funded parts of the proposed action's average annual
homeowner cost should be allocated as the applicant desires. The method
of user charge recovery and the estimated amounts that users will pay
will be described in the final facilities plan. A user charge system
40 CFR 35.2140 will have to be developed which is adequate to produce revenues re-
quired for the operation, maintenance and replacement of funded
facilities. The user charge system must also include an adequate
financial management system that will accurately account for revenues
generated by the user charge system and expenditures for operation and
maintenance, including replacement.
Individual states may require that treatment recommendations be made on a
preliminary basis for each property in optimum operation service areas.
This EIS suggests that any preliminary treatment recommendation be based on
EIS II-D-2-a available data and on on-site sanitary inspection (see Section II-D-2-a) at
a minimum.
3. FACILITIES VERIFICATION AND DESIGN
The next step, facilities verfication, transforms these tentative facili-
ties plan technology selections into actual house-by-house recommendations.
For a Construction Grants project it allows Step 3 funding and actual
bidding, or actual bidding for a self-help project. It includes the
selection of type, locations and design parameters for all on-and-off-site
treatment facilities. It is modified only by last-minute changes due to
completely unforeseen factors that might turn up during actual construc-
tion.
This level of certainty requires hard information. The sanitary survey of
developed properties must be completed. There will be detailed site
analysis for systems with direct discharges, documented failures, surface
malfunctions, recurrent backups, groundwater contamination, or potential
"roblems (unacceptable design or similarity withfailed systems). Figure
I-A-1 shows how this work is shaped by the type of problem indicated.
This data will probably allow final cost comparisons of particular facili-
ties for individual homes or groups of homes. Where on-site facilites will
work well, little comparison is needed. Marginal on-site systems with a
high risk of poor performance will require more detailed comparison; this
will weigh administrative, monitoring, and replacement costs against
savings resulting from~staying withHTgher risk facilities. Careful cost
compaTison will also be needed where the choice is between a few high cost
on-site facilities and widespread off-site treatment.
58
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In practice most on-site facilities can be designed in the field at con-
clusion of the detailed site analysis just described. The site or
neighborhood cost-effectiveness analysis reviews these individual field
decisioas from a community perspective, seeking economies in management
services and facilities costs.
Off-site facilities design will usually require more site work. Because
the need to go off-site may have been clear since the end of facilities
planning, this additional work may have already been completed. In some
special cases the need to go off-site will not be clear until the comple-
tion of the facilities verification studies.
Off-site facilities and non-standard on-site facilities likely will require
design drawings and specifications that take time for preparation, review
and regulatory approval. In contrast, conventional on-site facilities can
be described by standard design packages. With standard design packages,
review and approval may be accomplished quickly through concurrence by
local health officials. Where much of a project consists of standard
on-site facilities, grantees and state grant administrators may wish to
establish a separate track for their bid document preparation and construc-
tion.
4. BID DOCUMENTS FOR COMBINED STEP 2 AND 3 GRANTS
Proposed actions based on the optimum operation alternative will qualify in
many communities for single grants to cover both design and construction
costs. Combined Step 2 and 3 grants are intended to simplify and speed up
CWA 203(a) the grants process for small communities. Communities of 25,000 or less
population are eligible to receive combined grants if the costs of decision
plus construction will be less than $8 million, and the grant is for an
entire project, not just a part of the overall project.
Typically, design, bid document preparation, contract award and construc-
tion are separate steps completed in this sequence. When on-site facili-
ties are to be constructed, however, disruption of property and intrusion
on privacy might be minimized by following facilities verification (design)
immediately with construction. This would also speed up abatement of
failures. To accomplish this, bid documentation preparation and contract
award would have to precede facilities verification. For this to work,
contractors would submit unit prices and quantity discounts for typical
facilities. Payment to contractors would be based on their quotations. In
addition to the bidders' experience and capabilities, selection of contrac-
tors could be based on their total estimated price and unit price bids, for
the mix of facilities included in the optimum operation alternative.
This method of contracting would be aided by the development of standard
design packages for a wide range of technologies.
5. BID DOCUMENTS FOR SEPARATE STEP 2 AND STEP 3 GRANTS
CWA 203(a) Communities over 25,000 population or projects with design and construction
costing more than $8 million will not qualify for combined grants. The
parts of their projects using the optimum operation alternative will have
to follow traditional grant and procurement procedures. Applicants may be
able to speed up abatement of failures by segmenting centralized from small
waste flow portions of a project so that each part may proceed at its own
rate. (The use of the word "segmenting" here is different from its use in
regard to identifying parts of a community for environmental contraints
evaluation, needs documentation and alternative development.)
59
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F. COST ANALYSIS
1. COST VARIABILITY STUDY
TRD IV-A Facilities plans for small communities will consider alternatives ranging
from on-site upgrading and repair to small-scale collection and treatment
to centralized collection and treatment. Many of the technologies to be
considered are alternative or innovative. Rules of thumb regarding cost
competitiveness between these technologies and conventional centralized
technologies have not been developed because so few cost-effectiveness
comparisons between them have been completed.
To provide facilities planners with some of these rules of thumb, the
present worths of on-site, small-scale and centralized approaches have been
estimated, presented in cost curves and compared graphically. A large
number of present worth estimates were generated, reflecting the influence
of key factors on the cost competition between different technologies. The
factors that were varied in this exercise are listed in Table II-F-1.
Density of development, expressed as number of residences per mile of
potential collector sewer, was selected to be the independent variable on
all cost curves. Environmental factors were associated in reasonable
combinations in eight scenarios. The effects of growth were studied by
preparing all analyses at 0% and 50% growth over a two-year period.
Results are expressed as present worth per household at the end of the
C.11.&12. 20-year design period. 1980 costs were used in this analysis (Engineering
News Record Index = 3260^. The discount rate used for the present worth
TRD IV-A calculations was 7-1/8%, the Water Resources Council recommended rate at
the time of the analysis (1980). Other design and cost assumptions are
reported in Technical Reference Document IV-A.
The technologies evaluated are also listed in Table II-F-1. The present
worth cost of each technology was calculated at each of four densities, for
each of eight scenarios, at 0% growth and at 50% growth. A mix of upgrade
and replacement technologies was selected for on-site systems appropriate
to the constraints incorporated into each scenario. On-site replacement/
upgrade rates of 10%, 20% and 50% were costed separately for each scenario.
The mixes incorporate increasingly elaborate and costly technologies as the
rate of replacement increases, reflecting an assumed relationship between
failure rates and environmental conditions.
The per house present worth costs are presented in cost curve graphs and in
tabular format in Technical Reference Document Chapter IV-A. The cost
curves are presented in three combinations:
technology curves - each sewered technology and on-site technology mix
is portrayed on a graph with eight curves, one for each scenario;
scenario curves - for each scenario, curves are included representing
the on-site technology mixes and competitive sewer/treatment combina-
tions;
cost-effectiveness curves - also based on scenarios, only the cost-
effective means of collection, centralized sewering and treatment, land
application and small-scale sewering, cluster collection and treatment,
10% on-site treatment, 20% on-site treatment and 50% on-site treatment
are shown.
The technology curves show the cost consequences of environmental con-
straints on specific technologies. Given local information on the
topography, groundwater conditions, depth to bedrock and on-site system
failure rates, the facilities planner can make preliminary judgments on
which environmental constraints should be reflected in subsequent cost-
effectiveness analysis.
60
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TABLE II-F-1. FACTORS VARIED AND TECHNOLOGIES CONSIDERED IN THE COST VARIABILITY STUDY
Environmental Factors
Topography
Average Depth of Groundwater
Average Depth of Bedrock
Soil Unstable
Developmental Factors
Growth Rate
Housing Density
Technologies
Collection Only (assumes
collection system and
treatment facilities are
in place nearby)
Centralized Treatment
(transport and treatment costs
derived from engineering studies
for Seven Rural Lake EIS's)
Small-scale Land Application
Cluster Systems
Values
Flat
Optimal (8' average depth of cut)
Rough (16' average depth of cut)
Rough (necessitates one pump and force main)
Rough (necessitates one pump and force main; 50% of houses
require grinder pumps)
Below deepest sewer
6' below ground surface (with flat topography only)
Below deepest sewer
2' below ground surface
6' feet below ground surface
Not a problem
Imported fill needed to replace 1,000' of peat soil
0% in 20 years
50% in 20 years
25, 50, 75, 100 houses per mile of potential sewer for 0%
growth rate
39, 75, 113, 150 houses per mile of potential sewer for
50% growth rate
Conventional Gravity Sewers
Small Diameter Gravity Sewers
Pressure Sewers with Septic Tank Effluent Pumps
Pressure Sewers with Grinder Pumps
Four sewering methods
Spray Irrigation
Overland Flow
Rapid Infiltration
Four Sewering Methods
Four Sewering Methods
61
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The scenario curves and the cost-effectiveness curves can be used to
identify cost-effective technologies given local environmental constraints
and housing densities and assuming that one of the scenarios fairly
represents local constraints.
Two of the cost-effectiveness curves are presented in Figures II-F-1 and
II-F-2 to illustrate the considerable effect that density, growth rate, and
environmental constraints cumulatively can have on cost competition between
the major technology options.
Intersections between lines represent trade-off points between technolo-
gies. The densities below trade-off points can be referred to as trade-off
densities.
Figure II-F-1 represents conditions favorable to conventional gravity
sewers: high growth rate, no constraints due to groundwater, bedrock or
unstable soil, and favorable topography allowing a minimal average depth of
excavation. Several points can be drawn from this graph:
Small diameter and conventional gravity sewers are highly competitive
throughout the density range with conventional gravity sewers becoming
cost-effective above 65 homes/mile.
Because of economies of scale, centralized treatment is highly prefer-
able to cluster systems at higher densities and still competitive at low
densities. [However, cluster systems may still be an important element
of small waste flows alternatives that are cost-effective compared to
sewering in a community-wide comparison.]
Rapid infiltration, the least expensive of the three land application
methods evaluated, is still more expensive than cluster systems or
centralized treatment. Convergance of the rapid infiltration curve with
cluster and centralized curves at low density is due to the finding that
very small scale land application systems (surface application) are
impractical at flows below 20,000 or 30,000 gallons per day. It was
assumed that a sufficient number of nearby one-mile segments would
discharge to a single land application site, thereby providing economies
of scale at lower densities not achievable with other sewered tech-
nologies .
Only centralized treatment/collection and collection only are competi-
tive with replacement/upgrading of on-site systems at or below 50%
replacement levels.
Collection only is cost-effective compared to 50% replacement throughout
the range of densities and becomes competitive with 20% replacement at
100 homes/ mile. This comparison is biased somewhat in favor of col-
lection because operation and maintenance costs for treatment and trans-
port of the wastes were not included. The low costs for collection only
are achievable only where the area in question is adjacent to existing
sewered areas having existing transport and treatment capacity for the
20-year design period.
Whereas Figure II-F-1 reflects conditions that are favorable for sewering,
Figure II-F-2 reflects conditions that are adverse: no growth, groundwater
at 6' depth in porous soils, flat topography, and peat soils underlying
1,000' of the one-mile segment. This is a setting typical of many lake-
shores. Comparisons with Figure II-F-1 include:
The cost-effective sewering method throughout the density range is
pressure sewers.
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COST-EFFECTIVENESS CURVES
Scenario 1
50% Growth
20,000
18,000
16,000
o
I
V)
O
O
14,000
12,000
o: 10,000
O
kl
liJ 8,000
oc
0-
uj
O 6,000
CM
4.0OO
2,000
A - Collector Sewers
B - Collection/Tranamission/Treatment
C - Colleccion/Tranarcission/Land Application $ Rapid Infiltration
D - Collectlon/Transmission/Cluster Systems
Collection Components of Systems:
AI...DI - Conventional Gravity Sewers
A2><>D2 * Small Diameter Gravity Sewers with Septic Tanks
A3...D3 - Pressure Sewers with Septic Tank Effluent Funps
A^...D4 Pressure Sewers with Grinder Pumps
E On-Site Systems
ฃ5 10X Replacement Level
E$ 20Z Replacement Level
ฃ7 - 501 Replacement Level
-A31* Trade-Off Between Collection Component
I
I
38
75
113
150
FUTURE
25 50 75
HOUSES/MILE OF COLLECTOR SEWER
100
PRESENT
FIGURE II-F-1.
COST-EFFECTIVENESS CURVES FOR ON-SITE
SMALL SCALE AND CENTRALIZED TREATMENT
ALTERNATIVES FOR SCENARIO 1; 50% GROWTH
63
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COST-EFFECTIVENESS CURVES
Scenario 4
0% Growth
20,000
18,000
16,000
o
^v
CO
cr
O
O
12,000
tE 10,000
O
LL)
CO
uj
cr
o.
CJ
8,000
6,000
4,000
2,000
A - Collector Sewers
B * Collection/Transmission/Treatment
C * Collection/Transmission/Land Application
D * Collection/Transmission/Cluster Systems
Rapid Infiltration
Collection Components of Systems:
AI-..DI - Conventional Gravity Sewers
A2-..D2 * Small Diameter Gravity Sewers with Septic Tanks
A3... 03 - Pressure Sewers with Septic Tank Effluent Pumps
A^...D^ - Pressure Sewers with Grinder Pumps
E - On- Site Systems
ฃ5 - 10 Z Replacement Level
E$ - 20Z Replacement Level
ฃ7 - SOX Replacement Level
Trade-Off Between Collection Component
j_
25 50 75
HOUSES/MILE OF COLLECTOR SEWER
100
FIGURE II-F-2.
COST-EFFECTIVENESS CURVES FOR ON-SITE
SMALL SCALE AND CENTRALIZED TREATMENT
ALTERNATIVES FOR SCENARIO 4; 0% GROWTH
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At no point is sewering competitive with on-site replacement/upgrading.
(This is also true at 50% growth for this scenario although the
difference in present worth is reduced.)
The ranking of off-site treatment methods is the same as in Figure
IV-F-1 since it was assumed that conditions at the treatment sites were
unaffected by conditions in the collection area.
Decisions to sewer or not will be determined ultimately by two analyses:
the feasibility of abating failures of on-site systems by replacement or
upgrading, and cost-effectiveness comparisons. Worst case comparisons
favoring sewers can be made by examining the trade-off densities at which
the most costly on-site technologies (50% replacement) equal the most cost-
effective sewering technologies for each scenario. Table II-F-2 shows the
trade-off densities for the eight scenarios and the several treatment
options considered in the cost variability study at 0% and 50% growth.
The trade-off densities shown in Table II-F-2 for complete collection,
transport and treatment systems are high enough that the decision to sewer
may be made on the basis of on-site feasibility as well as cost. At lower
growth rates and lower replacement rates, on-site feasibility will
increasingly become the determining factor in this decision.
Cost-effectiveness will likely remain the decisive factor in sewering
decisions when existing sewer systems are nearby. Except where constraints
to sewering are severe, the results indicate that sewering in this case
will be cheaper than high rates of on-site replacement and upgrading. The
cost preference for sewers, however, changes rapidly as replacement rates
decline. Even for the most favorable scenario for sewering, on-site
replacement rates below 15% will still be cost-effective at high housing
densities.
Broad conclusions drawn from the cost variabilility study include:
Average depth of cut, depth to groundwater and depth to bedrock can be
decisive factors in cost-effectiveness comparisons between sewering and
on-site upgrading and replacement. Where these constraints might be
expected, cost analysis must include costs of measures to overcome them.
Where extension of existing sewer systems is being compared to on-site
solutions, costs to overcome constraints to sewering become relatively
more important. Field inventories of these constraints and determina-
tion of local excavation, blasting and dewatering costs may be necessary
for preparation of valid cost-effective analysis.
Rate of replacement for on-site systems is much more significant to
cost-effectiveness than the mix of technologies except where a large
proportion of very expensive replacements are necessary. At low
densities or where constraints to sewering exist or when expensive
replacement systems do not appear to be necessary, cost-effectiveness
analysis will not depend on an exact prediction of the on-site facili-
ties required.
Where existing sewer systems are not available nearby, decisions to
EIS V-A-4-d sewer or not will be based primarily on the feasibility of abating
on-site system failures with on-site methods. Analysis of successes of
prior repairs and pilot studies of innovative technologies are,
therefore, going to be more productive in facilities planning than
accurate determinations of the mix of replacement technologies.
65
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2. COST CURVE ANALYSIS
EIS IV-H
TABLE II-F-2.
The relationships between environmental constraints, development variables
and technologies developed by the cost variability study can be used
qualitatively or quantitatively in facilities planning for unsewered areas.
Some of the qualitative conclusions that can be drawn from the cost curves
are listed above. Review of the 132 graphs and accompanying tables in
Chapter IV-A of the Technical Reference Document will suggest numerous
other conclusions.
The cost curves might also be used to make preliminary decisions on what
alternatives to consider (in the Plans of Study accompanying applications
for Step 1 grants) and on preliminary service area delineations (with input
from available needs documentation data and community surveys). To do
this, the developed parts of the facilities planning area are segmented.
The environmental and developmental characteristics of each segment and
proximity to existing collection systems are noted. Depending on the
accuracy of environmental and developmental information available and
appropriateness of the scenarios to local conditions, the curves can help
make decisions to sewer or not in cases where cost differences are great
enough that improved data would not change the conclusions. Use of the
curves can also indicate what types of data would most improve subsequent
detailed cost-effectiveness analysis.
TRADE-OFF DENSITIES (IN HOMES PER MILE) ABOVE WHICH OFF-SITE FACILITIES ARE
COMPETITIVE. BASED ON 50% REPLACEMENT OF ON-SITE SYSTEMS AT 0% AND 50%
GROWTH.
(Revised from the Draft EIS)
Scenarios
Collection
only
0% 50%
Centralized
treatment
0% 50%
Land
application
0% 50%
Cluster
system
0% 50%
1 No constraints 45 69
8' adc1
2 No constraints
16' adc
3 Steep topography 57 81
1 pump
4 Flat; 6' to -
groundwater; peat2
5 Flat; 6' to -
groundwater
6 Steep topography; 77 113
1 pump; 6' to
bedrock
7 Flat 75 109
8 Steep topography; 76 111
2' to bedrock; 50%
of houses need
grinder pumps
93
125
137
150
144
138
1 adc = average depth of cut.
2 Imported fill needed to replace 1,000' of peat soil.
Greater than 150 homes per mile.
66
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Use of the cost curves beyond very preliminary analysis is not warranted
for the following reasons:
Unit costs were based on the best data available. Some units costs such
as cost per house for detailed site analysis are based on educated
judgment but are not yet backed by experience. Other unit costs are
subject to local and regional variability which was not analyzed for its
effect on the results.
The curves have not been tested yet by applying them to actual situa-
tions, then comparing the costs to detailed cost-effectiveness estimates
or bid data.
Not all variables which may significantly affect the outcome of cost
comparisons have been studied. Most cost-imposing factors have been
incorporated in the present worth estimates (with the notable exception
of O&M for transport and treatment in the "collection only" curves) but
only the factors designated have been varied.
3. COST-EFFECTIVENESS ANALYSIS
The main consideration in performing a cost-effectiveness analysis for com-
binations of centralized and small waste flows options is the inclusion of
all costs such that alternatives are comparable. Costs that are common to
all alternatives can usually be omitted from the cost analysis without
affecting the results. For example, in comparing one centralized alterna-
tive to another, costs of items such as collection sewers, transmission
lines, and house sewers do not affect the outcome of the analysis and can
therefore be omitted. However, when a small waste flows alternative is
incorporated into the analysis, the omitted costs are no longer common to
all alternatives and must, therefore, be included. Examples of costs that
should not be omitted from an analysis comparing centralized to small waste
flows alternatives include the following:
Design
- detailed site analysis and facilities verifications for optimum
operation alternatives
- hydrogeologic studies for cluster and land application facilities
- design and specifications for conventional facilities
- evaluating and permitting future on-site systems
Installation
- flow reduction devices
- house sewers and connections
- house plumbing modifications
- monitoring wells
- future on-site systems
Abandonment
- on-site systems
- obsolete treatment plants (include any salvage benefits)
Operation
- monitoring program
- on-site system inspection
- energy savings from flow reduction program
- income from crop production in land application alternatives
EIS II-E Several levels of cost-effectiveness analysis may be useful during planning
and design of optimum operation alternatives. The first level is repre-
sented by cost curves such as those illustrated in Section 2 above. Cost
curve information will be useful in estimating the scope of facilities
planning for description in the applicants Plan of Study and will aid the
67
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delineation of centralized and small waste flows service areas early in
facilities planning.
An intermediate level of analysis would be appropriate, using local costs
for specific facilities and first-cut technology assumptions based on Phase
I needs documentation. The accuracy of such present worth estimates is to
a large degree dependent on the quality and comprehensiveness of Phase I
data. However, the validity at this level of analysis of present worth
comparisons between centralized and optimum operation alternatives is also
dependent on the relative magnitude of the costs. If the difference in
cost is great, the ranking of alternatives by cost-effectiveness will
probably not be altered by additional data collection or more detailed cost
estimation. An example of this level of cost analysis for an optimum
operation alternative is presented in Appendix C.
Phase II needs documentation work will provide more detailed information,
particularly for estimating work and costs for the detailed site analysis,
mix of facilities, and operation and maintenance requirements. This level
of analysis will suffice for optimum operation alternatives recommended in
facilities plans as part or all of Proposed Actions. System selections
made on a preliminary basis (subject to detailed site analysis) for each
developed lot should agree with the assumptions of this cost analysis. The
format may be similiar to that of the intermediate level analysis as
reflected in the example in Appendix D.
EIS V-A-4-d To this point, cost analysis will generally apply to major service areas
and entire communities. Completion of the sanitary survey and detailed
site analyses will be followed by micro-scale decisions on exactly which
facilities will be appropriate for individual lots or groups of lots. When
high risk on-site systems are compared to holding tanks, cluster systems or
other off-site technologies, micro-scale cost-effectiveness analysis will
sometimes be necessary.
Finally, applications for Step 3 construction funds will be accompanied by
detailed cost estimates to accompany bid documents. The expected costs of
the required management program should also be detailed at this time.
Costs of wastewater facilities for future growth must be included in cost-
effectiveness analyses. Future costs are estimated from population projec-
tions derived for planning areas. The costs of both centralized and
optimum operation alternatives should be based on these projections even
though an optimum operation alternative may restrict growth below the
projected level.
Although use of cost curves and general costs found in the literature are
usually sufficient for preliminary planning, local costs should be used for
more detailed comparisons when possible. Construction costs of on-site
systems are particularly subject to variations caused by geographic price
differences, labor and material costs, and varying haul distances for
materials such as stone. To achieve accurate cost estimates (and hence
cost-effectiveness analyses) local cost data should be used when possible.
For alternative on-site systems that have never been constructed in a
particular area, local septic system contractors might provide estimates if
presented with plans and a schedule of materials.
4. AVERAGE ANNUAL HOMEOWNER COST
Conventional centralized alternatives have very different cash flow charac-
teristics from optimum operation alternatives. Centralized facilities
involve a large capital outlay at the beginning of a wastewater facilities
project. After the centralized system begins operation, new capital costs
are minimal and operation and maintenance costs rise slightly as flows
increase and the facilities become older. In contrast, optimum operation
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alternatives involve much smaller initial capital costs to upgrade or
replace existing malfunctioning on-site systems. Additional capital costs
are incurred throughout the project life for construction of new and
replacement systems.
EIS IV-F-2 Given the diverse cash flow characteristics between optimum operation and
centralized alternatives and the need to compare their local costs, a para-
meter termed the "average annual homeowner cost" is recommended for use by
facilities planners. In essence, all local costs, both public and private,
in the initial year of operation are divided by the number of residences or
dwelling unit equivalents served by an alternative in the initial year.
The initial year's costs should include:
local shares of Step 2 design and Step 3 construction costs amortized at
current municipal bond interest rates;
total private costs for flow reduction devices, house sewers, plumbing
changes, etc. amortized at current mortgage interest rates;
the first year's operation, maintenance, and administration costs, and
annual reserve fund assessment (often calculated as 10 to 20% of annual
debt payment on the local share of public costs).
EIS II-C-1 The eligibility of alternatives' components for U.S. EPA grants determines
V-A in part the magnitude of the average annual homeowner cost. The facilities
planner should make preliminary judgments on the eligibility for Federal
assistance of capital costs for facilities in each alternative. This
judgement is based on a review of current U.S. EPA eligibility guidelines
and results of needs documentation studies.
EIS I-C-2-a The average annual homeowner cost for alternatives with new sewers will be
much higher in many cases than user charges typically levied, owing to the
fact that private costs for house sewers and plumbing changes never appear
in user charges. Nor do the often expensive frontage and hook-up fees
charged to newly sewered users appear. These fees go to retire local
capital costs, thereby lowering user charges. Private costs and initial
capital recovery charges are real costs to the homeowner and must be
reasonably reflected in economic impact analysis, even if they are not
included in actual user charges,
EIS IV-F-2 The average annual homeowner cost can be compared to median family income,
individual family income, and expressed willingness to pay in order to
address economic impacts of various alternatives on local residents.
TRD IV-A The cost statistics for the community's proposed alternative that make up
this economic parameter should be presented individually so that normative
EIS III-I judgments can be made by local decision-makers on the distribution of the
local costs.
G. SELF-HELP AND USE OF CONSULTANTS IN NEEDS DOCUMENTATION, FACILITIES
PLANNING, AND DETAILED SITE ANALYSIS (New Section)
While the total costs are lower than for centralized alternatives, the
proportion of personnel costs to total costs for the optimum operation
alternative will be higher. Cost conscious communities will, therefore,
concentrate on controlling personnel costs as well as equipment and con-
struction costs. The question of who will do a task right for the least
cost can be expected to come up repeatedly. An opportune time to begin
answering this question is during negotiations with your facilties planning
consultant on his scope of work for needs documentation.
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Some needs documentation tasks require equipment or expertise that few
communities will have. Examples are septic leachate surveys, aerial
photographic interpretation, and geohydrologic analysis. Even your
facilities planner may have to subcontract such tasks. But much of the
cost for needs documentation and, later, detailed site analysis will be for
the less specialized tasks of inspection, water sample collection, record
review, base map preparation and data compilation. If an optimum operation
alternative is implemented, these are tasks which will be performed
routinely in the future. The sooner that the capacity to perform them is
developed, the better. Building inspectors, sanitarians, planners, zoning
officials and clerks already publicly employed may be able to perform much
of the work either with advise from the facility planner or under his
technical supervision. Part-time employees might also be hired for
temporary but intensive efforts such as sanitary surveys.
Regarding facilities planning, accepted practice is for communities to
contract with consulting firms which then prepare the necessary documents
and grant application forms. Consulting firms that have working knowledge
of Construction Grants program requirements in addition to the necessary
planning, engineering and environmental expertise can prepare these docu-
ments and forms in a time period and at a cost that most small communities
cannot match with available personnel.
This is not to say that facilities planning should be left entirely to a
consulting firm. Obviously, community officials and the public will
provide information and opinions that should guide the consultants. But
communities can play active roles that will make the selected action more
of a local product. Community involvement in needs documentation has been
EIS IV-D-2 discussed in this section. As discussed in Section IV-D-2 officials may
want to examine land use implications of various sewered and unsewered
alternatives or even develop land use plans to complement their investment
in wastewater facilities. Community offices may also be the best source of
economic and demographic information necessary for preliminary designs and
cost analysis of wastewater alternatives.
Communities that select the optimum operation alternative may want to take
a more active role in the design phase than is normally taken with conven-
tional centralized facilities. The key task in designing optimum operation
EIS II-E-3 alternatives is detailed site analysis. (See Section II-E-3) Both the
experience of dealing with individual sites and the sense of which facili-
ties will operate locally that are acquired during detailed site analysis
will be invaluable for local decision-making long after the consultant has
completed his work. Involvement of the individuals who will have long-term
responsibilities for managing on-site systems should be seriously con-
sidered.
H. USE OF SEGMENTS IN PLANNING AND IMPLEMENTATION
TRD IX-C Segmenting a planning area involves systematically dividing the area into
subsections according to specific criteria. Planning areas can be divided
EIS II-F-2 into segments on the basis of soils classifications or suitability for
on-site treatment; housing and land use patterns or neighborhoods; on-site
system failure rates; or housing occupancy status (permanent or seasonal).
The purpose of segmenting an area is:
to organize data and calculations (for use in developing alternatives),
to make the project more understandable,
to facilitate and schedule subsequent work such as sanitary surveys and
detailed site analyses, and
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to evaluate specifically differing socioeconomic, environmental, and
land use characteristics.
The use of segmentation during facilities planning allows a more detailed
study of individual areas than would be possible by studying the area as a
unit. Proper segmentation also provides an appropriate level of data
aggregation when details of house by house information gathering are not
required, such as during the preliminary planning stages (alternatives
development). Additionally, segments ready to proceed with the design step
would not have to await state approval of the remainder of the study area.
Contracts can be awarded for individual segments or for groups of segments
ready for construction. The use of segments, however, does not permit the
omission of the detailed site work that must be done prior to facilities
verification. The only short-cutting advantage is that individual segments
would not have to wait for other areas that are not yet prepared to proceed
to the next step.
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Chapter III
Community Management
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CHAPTER III
COMMUNITY MANAGEMENT
"Community management" refers to the management of small waste flows
systems by a centralized authority. These may include on-site systems,
small cluster systems with subsurface disposal and other small-scale
technologies. They can be managed by a wide variety of public or private
entities or a combination of these entities. Public entities may include
state, regional, or local agencies and nonprofit organizations; private
entities may include private homeowner associations and private contrac-
tors .
In this chapter, the term "management agency" refers to the authority
responsible for managing the systems. A management agency need not be an
autonomous agency with the single purpose of managing these systems. It
may in fact be charged with other duties and may share management responsi-
bility through agreements with other agencies. The term "management
program" in this chpater refers to the broad range of services needed to
ensure the proper design, installation, and operation and maintenance of
the small waste flows systems.
A. THE NEED FOR MANAGEMENT
1. PAST AND PRESENT MANAGEMENT PRACTICES
As discussed in Section I-C-1, governmental concern with the use of on-site
systems has increased in response to perceived and actual inadequancies of
early systems. Most governmental authorities now regulate the installation
of new systems and can require upgrading and replacement of failing on-site
systems. Few authorities, however, have accepted supervisory responsi-
bility for operation and maintenance of on-site systems.
The value of small waste flows systems as a long-term rather than short-
term alternative to centralized collection treatment began to be recognized
in the 1970's. As a result, communities preparing facilities plans after
September 30, 1978, were required to provide an analysis of the use of
innovative and alternative wastewater processes and techniques that could
solve a community's wastewater needs (PRM 78-9, U.S. EPA, 1978a). Included
as alternative processes are individual and other on-site treatment systems
with subsurface disposal units (drainfields).
Legend for Cross-References in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change in
the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
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The 1977 Clean Water Act amendments recognized the need for continuing
supervision of the operation and maintenance of on-site systems. U.S. EPA
Construction Grant Regulations (U.S. EPA, 1978a; U.S. EPA, 1979b), which
implement that act, require that before a construction grant for private
wastewater systems may be made, the applicant must meet a number of
requirements, including:
certifying that a public body will be responsible for the proper instal-
lation, operation, and maintenance of the funded systems;
establishing a comprehensive program for regulation and inspection of
on-site systems that will include periodic testing of existing potable
water wells and, where a substantial number of on-site systems exists,
more extensive monitoring of aquifers; and
obtaining assurance of unlimited access to each individual system at all
reasonable teams for inspection, monitoring, construction, maintenance,
operation, rehabilitation, and replacement.
PRM 79-8 extended these requirements to grants for publicly owned systems.
40 CFR 35.2206 These policies are continued in recent regulations and guidelines imple-
40 CFR 35.2110 menting the Clean Water Act.
2. COMMUNITIY OBLIGATIONS FOR MANAGEMENT OF PRIVATE WASTEWATER SYSTEMS
Communities have obligations to protect public health and water resources
from the adverse impacts of malfunctioning private wastewater systems.
Depending on the type and frequency of malfunctions, community obligations
may outweigh individuals' rights to constant privacy and absolute posses-
sion of private property.
In the most severe cases, the community may require abandonment of
privately owned systems. The economic feasibility of most sanitary
district expansion is based on their statutory authority to require
property owners to abandon existing on-site systems and hookup to new
sewers. Under existing state and local law this can often be done even
without demonstrating need.
For less severe cases, central community management is a way to minimize
this intrusion, avoiding higher costs, landscaping damage, and abandonment
of potentially satisfactory facilities. The degree of central management
needed is a reflection of the problem itself, and the interference with
privacy and property is no greater than that required for maintenance of
public health.
Where the public health and water quality impacts of existing on-site
systems are acceptable under present management practices, no changes
should be necessary in management or in individuals' privacy or property.
This is in stark contrast to sewering, where all systems in a given area
must connect, whether or not they are working well.
EIS II-C-D Proper assessment of system problems (both type and severity) is the key to
determining community obligations while minimizing or eliminating intru-
sion. Overestimation of systems' adverse impacts may lead to overregula-
tion, increased community costs and reduced community support for man-
agement programs. Underestimation of the problems or of management methods
needed to deal with them may perpetuate problems to the detriment of the
entire community.
EIS II-D The previous chapter discussed ways to measure the impacts of existing
on-site systems. On-site system density, failure rate, and the vulner-
ability of the affected water resources can all affect the level of manage-
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merit needed. When houses are far apart, the probability of a system
malfunction harming other residents may be too low for community concern.
However, when houses are closer together, the potential for public health
and groundwater impacts is greater. At high densities, even with no
apparent system malfunctions, impacts on groundwater quality by nitrates
and other chemical constituents may be of concern to the community.
The significance of failures relates directly to density. Among denser
populations, the potential for adverse impacts is greater. Even where the
failure rate is low, densely developed communities have an interest in
aggressively preventing future failures. Failures occurring in sparsely
settled areas may pose only a marginal threat to the common good. Some
individual failures such as plumbing backups are of interest to the general
public since disease contracted by one individual can spread to affect
many.
Water resources vulnerable to on-site systems include recreational lakes,
water supply reservoirs, groundwater aquifers, and other water bodies. The
vulnerability of these water resources and their usage by the public will
determine threats to the community posed by on-site system problems. Where
a eutrophic lake is receiving a small amount of nutrient input from on-site
systems, the community obligation to abate the input may be absent. How-
ever, when a lake is oligotrophic or is used as a water supply, the com-
munity may have to recognize a greater obligation.
Community involvement with existing on-site systems should be limited to
assessment of water quality and public health impacts, requiring remedial
action where unacceptable impacts exist and implementing management
programs to deal with future impacts. Community obligations associated
with future wastewater systems should be to regulate their design, instal-
lation, and operation and maintenance, in order to limit their potential to
affect public health and the environment.
B. FIVE COMMUNITY MANAGEMENT MODELS
The following five models reflect increasing levels of community obligation
for the management of private wastewater systems. When community obliga-
tion is low, community management may be limited to initial installation.
Increasing community obligations may require management of all phases of
system life, including installation, operation and maintenance, failure,
renovation and, ultimately, abandonment. Abandonment represents the
maximum intervention that a community may take in managing individual
systems and should only be taken when community obligations for protecting
public health and water resources cannot be satisfied in any other way.
1. STATUS QUO ALTERNATIVE
Where community obligation for the regulation of private systems is low be-
cause of a low density of systems, lack of problems with the existing
systems, and/or lack of sensitive water resources, a community management
program may be minimal. Such a program is usually limited to management
agency approval of permits, inspection of system installations, and
investigation of complaints concerning failures of on-site systems. Man-
agement programs such as this are currently in general use throughout
Region V.
Under this approach, the homeowner is completely liable for system opera-
tion and maintenance, including necessary system repairs. The management
agency does not conduct routine inspections to monitor system performance,
finance system repairs, consider the use of off-site treatment, or permit
the use of experimental on-site designs.
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This approach is normally adequate for rural land areas where scattered
development, farms, and large tract subdivisions predominate. Construction
Grants funding eligibility, however, requires both identified community
need and a higher level of community management than this alternative
offers.
2. OWNER VOLUNTEER
Certain communities may have limited areas of high density, high failure
rates, or sensitive water resources, which may raise community obligations
for the private systems. In addition to the management program outlined
under the status quo model, the community management agency may survey the
likely impact areas to identify specific problems. Homeowners would be
notified of necessary repairs for their systems, and the community
management agency may offer technical and possibly financial assistance to
facilitate the repairs.
If a significant enough problem area is identified, the homeowners could
receive Construction Grants funds for repair of their systems. The
community management agency could apply for and distribute the funds to
homeowners whose systems qualify for assistance.
The homeowner would retain both responsibility for system operation and
maintenance and liability for system repair. The community management
agency's role would be limited to education and technical assistance. For
Construction Grant recipients, the community management agency must also
insure proper operation and maintenance of the systems. At a minimum this
could be accomplished by homeowners periodically providing proof that the
system is being properly maintained (that is, by providing pumping records)
or by direct inspection and monitoring by the management agency.
3. UNIVERSAL COMMUNITY MANAGEMENT
As system density, failure rate, and sensitivity of water resources
increase, community obligations for managing private systems shift from
voluntary owner participation to universal community management. Under
this approach, all wastewater facilities in a community or section of a
community would be included in a management program. Wastewater facilities
may include on-site systems, cluster systems, other small-scale facilities,
or combinations of these small waste flows technologies. Cluster systems
and other off-site facilities would only be utilized where difficulties in
the use of on-site alternatives require the community to explore all
feasible solutions to meeting the community wastewater needs.
The community management agency would assume all of the management
responsibilities common to the preceding two models. The management agency
would also conduct well water sampling and appropriate monitoring of water
resources impacted by the wastewater systems. Depending on the type of
wastewater facilities utilized, the level of risk assumed by the management
agency, and other factors, the management agency could assume responsi-
bility for performing system operation and maintenance and liability for
system repairs.
The community management agency could apply for and distribute Construction
Grants funds to property owners for repair of qualified private systems if
the owners retain liability. Alternatively, the agency could contract
directly with installation firms and recover the local share of the
construction costs from owners immediately or as part of periodic user
charges. In any case, owners would be assessed periodic fees to cover the
costs of management services actually provided.
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4. COMBINED MANAGEMENT APPROACHES
Sections of a given community may have different wastewater and management
needs based on system density, failure rate, and sensitivity of water re-
sources. Centralized wastewater facilities may be in place or required in
certain areas, and small waste flows systems may be appropriate for other
areas. Owing to varying levels of community obligations, both voluntary
and universal management zones may also be present. A management agency
should develop specific approaches for each section of the community based
on both the projected types of wastewater facilities and community
obligations for regulating the private systems. By so doing, the agency
can ensure that the program meets each given area's needs.
A possible objection to this approach is the diversity of skills that may
be needed. However, there may be sufficient overlap in skills so that
agency staff can be maintained at a reasonable number. For instance,
sewage treatment plant operators may be able to inspect and repair on-site
dosing pump and STEP units. Laboratory personnel can collect and analyze
groundwater and surface water samples as well as treatment plant effluent
samples. The community may group property owners by type of wastewater
system and achieve economies of scale in providing services that would not
be achieved by private contractors providing services to owners
individually.
Under a multizone management approach, homeowners would be responsible for
paying annual fees to support the management services received. Responsi-
bility for operation and maintenance and liability for system failure may
vary within each zone.
5. COMPREHENSIVE WATER QUALITY MANAGEMENT
Where the sensitivity of water resources is the paramount concern,
prevention and control of water pollution need not be restricted to
wastewater facilities. The management program in these communities would
consist of universal community management of the wastewater facilities and
be expanded to identify and control other sources of water pollution.
Additional management agency responsibilities may include pollution control
assessment and control activities such as:
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 lake and its tributaries,
research into the chemical, hydrological and biological dynamics of the
lake, and
coordination with other local, state, and Federal agencies on pollution
control activities and funding.
Communities with such a high interest in the control of water pollution are
also likely to assume direct responsibility for system operation and main-
tenance and liability for correcting system failures.
C. DESIGN OF SMALL WASTE FLOWS MANAGEMENT PROGRAMS
TRD VI-H The process by which a community develops a management program involves six
major steps:
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1. inventorying factors affecting the design process,
2. making decisions on system ownership and liability,
3. identifying services to be provided,
4. determining how selected services will be performed,
5. determining who will be responsible for providing services, and
6. implementing the management program.
Each is discussed in the following sections.
1. INVENTORYING FACTORS AFFECTING THE DESIGN PROCESS
Communities face many choices in designing a management program. The
factors influencing the community decisions are of two types. "First-order
factors" need to be identified and considered before program design
decisions are made. They are existing or projected community charac-
teristics. First-order factors include:
types of wastewater facilities utilized and proposed,
expertise available to the community,
size of the community or management district and number of systems in
use,
available regulatory authority,
community jurisdictional setting,
community attitudes toward growth, and
* community attitudes toward public management of private wastewater
facilities.
"Second-order factors" are potential consequences of program design
decisions. These factors include:
costs, including initial costs and economic impact of failures,
environmental impacts, especially impacts on water resources, and
level of risk assumed by various parties.
The ultimate success of a management program will be measured by these
second-order factors.
Most of these factors will directly or indirectly affect decisions for the
remaining program design steps.
2. MAKING DECISIONS ON SYSTEM OWNERSHIP AND LIABILITY
TRD VI-B Wastewater facilities may be owned by the individual user, by a community
management agency, or by a private organization. User ownership of
facilities generally is limited to those located upon his or her property.
For off-site systems that serve more than one homeowner, community or
private organization ownership is most likely.
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Liability involves acceptance of the responsibility for consequences of
facility failure. Assumption of liability may involve making necessary
repairs and, possibly, paying damages to parties injured by facility
failure. Historically, communities have accepted all liability for the
failure of centralized collection and treatment systems, with the exception
of house connections and plumbing blockages. The liability for individual
system failures has traditionally remained with the system owner. With
community management of small waste flows systems, there may be advantages
to reassignment of the liability for system failure. The assignment of
liability to either individuals or a public agency is a matter of choice
for the community and its residents.
A community may assign ownership and liability separately for the waste-
water systems. For instance, a management agency may agree to replace,
upgrade, or repair privately owned small waste flows facilities that
malfunction after Construction Grants projects are completed. In return
EIS III-I for accepting this liability, the agency requires that owners pay a reserve
fund charge along with other user charges. The reserve fund charge is, in
essence, comparable to an insurance premium.
A possible objection to management agencies assuming liability for future
malfunctions is that the economic incentive for owners to use their systems
judiciously is removed. This possibility will be weighed against the
impacts of prolonged failures should owners not be financially able to make
EIS III-E repairs quickly. A resolution of this trade-off may be agency assumption
of liability on condition that use variances are issued and complied with
or that user charges are based on metered water use with rapidly increasing
rates above a predetermined limit.
3. IDENTIFYING SERVICES TO BE PROVIDED
TRD VI-A The range of services that a management agency could perform in managing
small waste flows systems varies greatly within the limitation of state
guidelines. For Construction Grants grantees, Federal guidelines may also
influence local discretion. Services chosen should be those needed to
fulfill community obligations without superfluous regulation, authorities,
manpower, or investments. Although a few services are essential to all
management programs, many are optional, and their incorporation into a man-
agement program is left to community discretion.
Table III-C-1 lists administrative, technical and planning services that a
community might select.
4. DETERMINING HOW SELECTED SERVICES WILL BE PERFORMED
It is an artificial distinction to separate selection of services from the
definition of how they should be performed and the designation of parties
and persons to perform them. In practice, these three design steps will be
taken in sequence, and perhaps repeated, each step directly influencing the
others.
Taken by itself, this step defines specific practices by which the services
will be provided. For instance, for water quality monitoring, the decision
must be made whether to include non-point source and surface water monitor-
ing. Then the groundwater monitoring plan, and other monitoring as de-
EIS III-I cided, must be designed. This step would also develop the user charge
system and make decisions on financing the local share. For plan review
services, specific policies on experimental or innovative systems may be
established or existing standards and procedures may be confirmed.
5. DETERMINING WHO WILL BE RESPONSIBLE FOR PROVIDING SERVICES
Generally there are three groups who could provide the services selected
and detailed in the two prior steps:
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TABLE III-C-1. POTENTIAL MANAGEMENT PROGRAM SERVICES
Administrative
Technical
Planning
Staffing
Financial
Permits
Bonding
Certification programs
Service contract supervision
Accept for public management privately installed facilities
Interagency coordination
Training programs
Public education
Enforcement
Property/access acquisition
System design
Plan review
Soils investigations
System installation
Routine inspection and maintenance
Septage collection and disposal
Pilot studies
Flow reduction program
Water quality monitoring
Land use planning
Sewer and water planning
the public management agency (includes assistance from regional and
state organizations),
property owners or occupants, and
private organizations such as contractors, consultants, development
companies, private utilities, and private community associations.
Some communities may control services by providing them directly, but
others may provide those services that only the designated regulatory body
can provide (as permit issuance and enforcement), supervising the services
assigned to owners or private organizations. Assignment of service
responsibilities should account for the skills and regulatory authority
needed to successfully provide the service as well as the costs for dif-
ferent parties to provide them and the risks attendant on poor performance.
TRD VI-C
EIS IV-A-3
The public management agency need not be a new or single-purpose organi-
zation. Personnel with appropriate expertise may already be available in
agencies with necessary authority to provide public management services. A
combination of interagency agreements, supplemental training of existing
personnel and new hires will be an adequate basis for agency development in
many communities. Other communities may, for various administrative or
legal reasons, find it more suitable to establish a new operating agency.
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6. IMPLEMENTING THE MANAGEMENT PROGRAM
The last step in the design process is implementation of the management
program. The specifics of this step will vary widely depending on
decisions made in the design process. Examples of implementation
procedures are:
drafting and adopting county or municipal ordinances establishing the
agency or providing it with needed authorities,
EIS III-K hiring new personnel,
notifying potential contractors and consultants of performance criteria
and contract requirements for operating within the management district,
drafting and adopting interagency agreements,
EIS III-D creating a sanitary review board, and
EIS IV-G informing property owners about their responsibilities for specific
services.
D. PUBLIC INVOLVEMENT IN AGENCY DESIGN AND OPERATION
Public attitudes toward community growth and public management of private
wastewater facilities must be considered in agency design decisions.
EIS IV-D-2 The use of small waste flows systems in some settings will directly impact
community growth. Unlike centralized systems, small waste flows systems do
not provide impetus for growth. While this may be desirable in many rural
areas, other areas seek the growth facilitated by centralized sewers for
economic and other reasons.
EIS VI-B On the other hand, the use of alternative small waste flows systems
facilities may permit the development of land formerly considered
undevelopable. This may lead to scattered rural development and/or the
development of enviromentally sensitive property, which may be contrary to
public desires. Such development may be controlled by effective land use
planning if the problem is recognized.
Community understanding of public management of private wastewater faci-
lities will be limited in many rural areas. Where community management is
desirable, the public must be educated about its benefits if the program is
to be successful.
The public will be directly involved in agency design and operation when
individual homeowners are affected by management agency policy and
decisions. Homeowners may be required to perform necessary maintenance, to
repair, replace, and upgrade failed systems and to pay user fees to the
management agency. These requirements may meet with considerable opposi-
tion unless an effective public education program is initiated to inform
homeowners about their role in the community management programs. Home-
owners should be notified and kept informed of their responsibilities and
obligations to the management agency.
EIS IV-G To involve the public more directly in agency design and operation, a
Sanitary Review Board of community residents could be established. The
board would ensure that the management agency's technical and economic
decisions are consistent with citizen interests. The powers and duties of
the board could be structured to reflect citizen interest. The board might
maintain autonomous control over management agency decisions and personnel,
or it could serve as an advisory body to the agency. Where the board is
given autonomous authority, it may be desirable for the administrator of
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the management agency to be a member of the board to ensure that technical
matters are properly understood and considered. The board could also act
as an appeals body to hear and decide on objections to agency decisions.
This function is similar to that performed by zoning and other boards.
E. USE OF VARIANCES
TRD VII-A-B Variances might be granted where practical or physical constraints prohibit
literal compliance with the regulations. All states in Region V currently
allow construction variances for the new construction of on-site systems
where conditions prevent conformity to code. Variances may also be granted
for existing systems.
In any small waste flows district with existing on-site systems, many
systems may not conform to current regulatory standards for site condi-
tions, system design, or distances from wells or surface waters. Some
systems can be upgraded easily and inexpensively to conform with current
codes. In many situations, however, upgrading may be unfeasible or
impracticable because of site limitations and/or costs. From an economic
viewpoint, it would clearly be desirable to continue to utilize a system
for its full, useful life, as measured by absence of adverse public health
or water quality impacts rather than by conformity to code.
Many study results have indicated the viability of existing on-site
systems, including those which may not be in conformance with existing code
requirements. Data developed during the study of alternative waste treat-
ment systems for the Seven Rural Lake Projects indicated that many noncon-
forming systems operate satisfactorily and cause no adverse impacts. In
these seven studies, although up to 90% of the systems were nonconforming,
failure rates represented by system backups, surface ponding, elevated well
nitrate levels and well coliform levels, combined, ranged from a low of 8%
to a high of 27%. Many of the problems identified were the result of poor
system maintenance and could be corrected with minimal cost and effort.
TRD II-D Chemical analysis was also performed on effluent plumes entering the lakes
from groundwater. This indicated that even when drainfields or dry wells
were actually in groundwater, water quality standards were met at adjacent
shorelines in nearly all cases. Bacteriological and nutrient levels at the
shorelines were comparable to those found in the center of the lake. The
studies indicated that the natural assimilative capacity of soil/ground-
water/surface water systems is greater than had previously been expected,
and that actual public health and water quality problems caused by on-site
systems were not as extensive as nonconformity with sanitary codes might
indicate.
1. CONSTRUCTION VARIANCES
TRD XV-A
Region V states currently allow variances for new construction of on-site
systems where either practical or physical constraints make literal
compliance with the regulations infeasible. Presumably, such variances
could also be granted where upgrading is necessary for existing systems.
This type of variance may be considered as a construction variance since it
allows construction which is nonconforming to the regulations.
Generally, existing nonconforming systems are considered "grandfathered"
systems and they are permitted to operate until problems arise. Correction
is then normally required to bring the systems into conformance, if
possible. If not, construction variances may be required.
2. USAGE VARIANCES
In most cases, existing nonconforming systems are not inspected. The
governing body may have little or no knowledge of system design or
construction and takes no liability for the system's performance. Qiffi-
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culties arise, however, when nonconforming systems are inspected during a
sanitary survey. The governing body then becomes cognizant of the
nonconforming systems, and their liability for system performance may
change. For example, if the governing body allows continued use of
nonconforming systems with no structural changes, a court may rule, upon
subsequent system failure, that the governing body was negligent in not
requiring these systems to be upgraded, since the government was cognizant
of the systems' nonconformity. The inspection and the lack of required
upgrading may be considered tantamount to permitting the systems.
EIS III-C-2 To prevent this type of liability problem, a second type of variance,
termed a "usage variance," may be granted. Usage variances are granted to
those systems considered to have additional useful life, and which are not
now causing, and generally have a slight potential for causing, public
health or water quality problems. By issuing a usage variance, the
governing body is legally recognizing that a nonconforming system exists.
At the same time, the governing body notifies the system owner of the
system's nonconformity, of his or her liability in case of system failure,
and of maintenance and flow reduction measures that may be required. This
process results in a clear record between the governing body, system owner,
and other interested parties concerning the continued use of the system and
liability in case of system failure. Provided that the governing body has
the power to grant such variances and that the justification for each
variance has been documented, the governing body would be within its
discretion in deciding to grant such variances, and not liable for legal
action in the case of system failure.
3. ISSUING VARIANCES
Construction or usage variances may be conditional, requiring periodic
monitoring of system performance and renewal of the variances based upon
satisfactory system performance. Conditions could also limit building
occupancy or require the use of flow reduction devices.
Decisions to grant variances should be made on a well-documented, case-by-
case basis. Construction variances should be restricted to those situa-
tions where compliance with regulations is impracticable or unfeasible and
where, based on data concerning similar systems, soil conditions, and other
information, the proposed construction can be reasonably expected to
perform adequately and cause no adverse impacts. Usage variances should be
limited to situations where site-specific performance data can be obtained
concerning existing system performance.
TRD VII-B The variances granted should directly relate to the financial resources and
staff expertise available to the governing body. Where financial resources
allow performance monitoring and employment of experienced personnel to
minimize errors, the governing body may be more liberal in the types of
variances allowed. Sufficient financial resources to correct future
failures where variances have been granted for high risk sites would also
be desirable. Where financial resources and experienced staff will be
limited, more conservative variance guidelines may be considered. Although
costs may be incurred when corrections must be made to systems previously
granted variances, they are expected to be substantially less than the
costs of making unnecessary system repairs for code conformance or of
totally abandoning useful systems when no variances are allowed.
The use of variance procedures may alter a community's decisions in
designing its management agency. When variances are utilized, the manage-
ment agency accepts a higher risk of system failure in order to achieve a
lower overall cost to the community by allowing continued use of existing
systems. When it accepts this higher level of risk, the management agency
may also elect to assume liability for system repairs. Assumption of
liability, in turn, affects decisions on user charge systems.
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F. ACCESS CONSIDERATIONS
TRD VIII-A U.S. EPA Construction Grants regulations (U.S. EPA, 1982) implementing the
40 CFR 35.2110 1981 amendments to the Clean Water Act require in Section 35.2110 that
applicants for privately owned individual systems shall provide assurance
of access to the systems at all reasonable times for such purposes as
inspection, monitoring, building, operation, rehabilitation, and replace-
ment. Access is also a consideration during facilities planning surveys
and detailed site analysis.
When the individual systems are on private property, the community must
obtain the legal authority to enter such property. The three ways that a
community can legally gain access to private property for inspection of an
individual wastewater system are:
1. by gaining the permission of the property owners,
2. by the acquisition of deeded rights, and
3. by a statutory grant of authority from the state legislature.
Each of these alternatives will be individually discussed.
1. BY OWNER'S PERMISSION
The easiest way to gain access to private property for purposes of
inspection is with the owner's permission. This can be oral or written.
There are several problems with this approach if a community requires
guaranteed and long-term access. Bare permission by the owner can always
be revoked. Moreover, when the property changes hands, the permission
granted by the previous owner is of no legal standing. In some instances,
the property owners may be difficult to locate, and a minority of property
owners can be expected to refuse to grant permission under any circum-
stances. For these reasons, a community eventually may need more binding
legal authority to enter property. Owner's permission will usually suffice
for community surveys during facilities planning, however.
2. ACQUISITION OF DEEDED RIGHTS
The acquisition of deeded rights may involve the community in obtaining
easements, easements in gross, or outright ownership of the individual
wastewater systems. Easements confer a legal right, formally conveyed by
deed or other witnessed and notarized writing and filed with land records,
which conveys to one property owner the right to use the land of an
adjacent property owner for a specified purpose. As applied to individual
wastewater systems with no physical connection to agency-owned property,
such a conventional easement may not be possible. The right to enter the
property of another, unrelated to the ownership of adjoining land, is
sometimes called an easement in gross. However, easements in gross are
sometimes held to expire upon a change of land ownership.
Property law relating to easements is highly formal, technical, and
specific to a given state. Communities needing to acquire easements should
consult first with local property attorneys and state or county agencies.
3. STATUTORY GRANTS OF AUTHORITY
In general, there are three types of statutes that confer rights of entry
on municipal officials in connection with wastewater treatment systems:
1. statutes to abate or prevent nuisances,
2. statutes requiring licenses or permits, and
3. statutes establishing special wastewater management districts for small
waste flows systems.
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Statutes that confer the right to enter and inspect private property are
commonly based on the community's right to prevent and abate nuisances.
Since individual wastewater systems are traditionally considered to be
nuisances per se^ when so constructed or maintained as to threaten or injure
the health of others, communities can regulate and take actions necessary
to assure compliance with their requirements for the construction and
maintenance of private wastewater systems.
Statutes requiring licenses or permits can be utilized to require owners to
obtain renewable permits for the continued use of their wastewater system.
With such requirements courts often imply, if they do not state expressly,
that entry and inspection are necessary prerequisites for the renewal of
the permits.
Statutes granting communities the right to form on-site wastewater manage-
ment districts have also granted communities access rights once the manage-
ment district is formed. To minimize problems arising with utilization of
such blanket authority, the degree of intrusiveness of any inspection
program should be minimized consistent with maintaining the effectiveness
of the district. Public education should be part of any inspection
program, and homeowners should be notified prior to inspection.
Under the U.S. EPA Facility Requirements Division Memorandum of July 8,
1980, access by statutory grants continued to be considered equivalent to
public ownership or easement in satisfying requirements of 40 CFR 35.2110.
Some state statutes granting this access limit it only to certain classes
of municipalities.
G. IMPLEMENTING WATER CONSERVATION PROGRAMS
TRD VIII-D Rural unsewered areas may be supplied with water by individual wells or by
a community distribution system. Homeowners supplied by public systems
often use more water than those with individual systems. The chances for
hydraulically overloading on-site wastewater systems is subsequently
greater for those served by a public water system. Methods for implement-
ing water conservation programs in these areas include:
rate structure changes (increases in price),
use restrictions,
changes in plumbing codes,
public education, and
community subsidized distribution of flow reduction devices.
For rural areas served by individual wells, pricing schemes, use restric-
tions, and legal limits on amount of water used are not usually feasible.
Water conservation programs for unsewered areas with individual water
supplies must therefore rely on 1) changes in plumbing codes, 2) public
education, 3) community subsidized water conservation devices, or 4)
on-site system permits requiring the installation of flow reduction
devices. Combinations of these methods should be considered when planning
a water conservation program.
Plumbing codes can require that plumbing fixtures used for new construction
and retrofit applications be of the low-flow type. This method would
gradually result in most residences using water conservation devices.
While gradual replacement will achieve 20-year design goals with centra-
lized wastewater facilities, more rapid methods for implementing water
conservation programs may be needed to achieve water quality and public
health goals with small waste flows facilities.
Public education can focus on the following economic benefits of flow
reduction:
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reduced well water pumping,
reduced water treatment (where treatment is necessary),
reduced energy costs for heating water, and
prolonged life of on-site wastewater treatment system.
Public education should be used in conjunction with other methods of imple-
menting water conservation programs to achieve the maximum benefit of each
method.
Communities can subsidize the purchase and installation of flow reduction
devices. This practice provides homeowners with a readily available means
to conserve water and fosters good public relations at the same time.
Distribution and installation of water reduction devices should be followed
up to determine public acceptance and utility of the devices in saving
water. Follow-up studies can determine the best devices for future distri-
bution. Another method includes a requirement in the permit issued for
on-site treatment systems stating that flow reduction devices will be
installed. Such restrictions could be written into permits for new systems
as well as those for upgrading or replacing failed systems.
H. MONITORING GROUNDWATER AMD SURFACE WATER
TRD VIII-C The success of pollution control programs cannot be taken for granted.
There are many causes of unsatisfactory performance for any facility.
Generally, the more complex the program or the greater the number of
facilities, the greater the probability of failure. Early, thorough
consideration of the causes of failure may prevent many potential failures.
However, failures may still occur. Depending on the value of impacted
resources, long-term monitoring may be necessary to complement structural
elements of a selected pollution control program. Groundwater and surface
water monitoring approaches are discussed below as they would be applied in
small waste flows management.
1. GROUNDWATER
Nearly all on-site and many small-scale wastewater technologies discharge
effluents to the soil. Except in rare instances, the treated effluents
then enter groundwater. Effluent impacts on receiving groundwaters and the
resulting impairment of the groundwater's potential use are not easily
predicted. Consequently, both facilities planning and long-term opera-
tional success depend on sample collection and laboratory analysis.
EIS II-D-2-b Groundwater sampling programs for facilities planning are discussed in
IV-E-1 Chapters II-D-2 and IV-E-1. Information developed for planning will help
define the need for and methods of long-term groundwater monitoring.
Three types of groundwater monitoring strategies may be needed: potable
well sampling, aquifer sampling, and shallow groundwater sampling.
a. Potable Well Sampling
Most dwellings served by on-site systems in Region V also have on-site well
water supplies. These wells are usually the point closest to on-site
wastewater systems at which groundwater quality is a concern.
The following suggestions may be useful in developing local monitoring
programs.
On-site wells within 50 feet of drain fields, within 100 feet and down
gradient from drain fields in unconfined aquifers, or penetrating un-
confined fractured or channeled aquifers could be sampled annually.
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Sand point wells and other shallow wells down gradient from drain fields
could be sampled every 2 to 5 years or when the on-site system is
inspected every 3 years.
Wells not at risk need not be monitored. Examples are properly located
wells cased and grouted down to a known, continuous confining layer;
wells known to be substantially upgradient from wastewater disposal
systems; and wells that have tested satisfactorily over extended periods
of time.
Private wells serving more than one dwelling could be sampled as sug-
gested for on-site wells except where water withdrawal may be sufficient
to alter natural groundwater flow patterns. These could be sampled
annually unless a hydrogeologist demonstrates why more or less frequent
sampling is appropriate.
Public water supplies should be sampled as required by state regulatory
agencies.
At a minimum, sample analysis should include nitrate-nitrogen and fecal
coliform bacteria. Where improperly protected wells (wells with inadequate
seals, casing, or grouting) must be sampled, analysis is also recommended
for non-naturally occurring constituents of domestic wastewater, such as
brighteners or surfactants. This analysis will help determine the source
of contamination.
When samples are positive for bacteria or show unexpectedly high nitrate
concentrations, provisions should be made for confirmatory sampling within
a short time.
b. Aquifer Sampling
Sampling of aquifers will be necessary in addition to potable well sampling
when large numbers of on-site systems are present in a groundwater shed or
when wastewater from multiple dwellings or dwelling unit equivalents is
land disposed at a single site.
Accumulations of nitrates in an aquifer down gradient from on-site systems
are unlikely to affect public health unless a number of systems are lined
up in the direction of groundwater flow. While the boundaries of ground-
water sheds and flow vectors within them are difficult to delineate, it is
safe to assume that single or double tiers of development will not result
in hazardous accumulations of nitrates. Therefore, strip developments
along roads or lakeshores should seldom be causes for aquifer monitoring.
On-site well monitoring will suffice. For more intensive development, the
need for and design of aquifer monitoring programs should be determined on
a case-by-case basis by qualified hydrogeologists.
Monitoring programs for cluster systems, rapid infiltration, or slow rate
TRD II-K land application should be developed in concert with detailed design of
III-B of the system itself. Hydrogeologic studies conducted for site evaluation
and system design will provide information required for development of the
monitoring program. A minimum system size above which aquifer monitoring
should be required is not recommended here. State regulatory agencies are
encouraged to address this topic.
c. Shallow Groundwater Sampling
On-site systems along stream banks and lake shores and larger land disposal
systems located further away may contribute pathogenic organisms and
phosphorus by effluent transport in groundwater. Although unacceptable
discharges of this type should have been discovered and remedied during the
Construction Grants process or similar work, continued surveillance of
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suspect systems may be advisable. The need for and design of a shallow
groundwater monitoring program should be based on results of prior
sampling, uses of the impacted surface waters, possible temporal changes in
the discharges, results of septic leachate scans, and requests for this
service from property owners.
2. SURFACE WATERS
Two types of surface water monitoring may be advisable in rural communities
that rely on the optimum operation approach: effluent surveys and non-
point source monitoring.
a. Effluent Surveys
EIS II-D-l-c In lake communities, periodic septic leachate surveys would identify future
groundwater failures of on-site systems and improve understanding of
factors influencing effluent plume movement. As with septic leachate
surveys conducted during facilities planning, a capability for collecting,
storing, and analyzing selected samples is desirable.
Because the state of the art in leachate detection is still developing, and
because of uncertainties regarding presently available instrumentation,
shoreline septic leachate surveys will not be required at this time in
monitoring programs. Purchase of currently available instrumentation will
be eligible for Construction Grants funding until superior equipment is
developed. Grantees will be required to show that comparable instruments
are not available on a timely basis from other nearby grantees. Funded
instruments will be made available to other grantees.
Where leachates from cluster systems, rapid infiltration systems, or slow
rate land application systems are expected to emerge in streams or lakes,
monitoring of the leachate may be required depending on proximity of the
systems to surface waters, use of the surface waters, and results of
aquifer monitoring. Appropriate monitoring methods should be specified
during detailed design of the systems. The need to implement some
monitoring programs may be conditional on results of aquifer monitoring.
b. Non-point Source Monitoring
Grantees will not be required to monitor non-point sources of pollution.
However, Construction Grants-funded laboratory facilities may be used for
sample analysis. In comparing the cost-effectiveness of constructing a
local laboratory with joint use of other municipal laboratories, or
contracting with private laboratories, the projected number and type of
samples can include those generated by a non-point source monitoring
program that the grantee implements prior to or concurrent with Step 3 of
Construction Grants activities.
c. Nearshore Plant Surveys (New Section)
C.21. For portions of lakes for which off-site treatment facilities are funded to
reduce nuisance nearshore plant growth, periodic surveys may be required to
evaluate the effectiveness of the facilities and accompanying non-point
source control measures.
Where on-site systems are retained along shorelines, plant surveys
conducted with septic leachate detectors may help identify systems that
are overloaded or that are not providing adequate treatment for other
reasons.
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I. RECOVERY OF LOCAL COSTS
1. DEFINITIONS
TRD VIII-B The local costs of a project will generally be allocated to users of the
system. The local costs consist of private capital costs, public capital
costs (local share of capital), interest on public debt, costs of operation
and maintenance, administration and the reserve fund. With the exception
of private costs, communities have a great deal of flexibility in determin-
ing how local costs are allocated and recovered.
Private capital costs will be borne directly by the users. That is, the
users will contract for or purchase items related to the project. Examples
of private cost items include house sewers, necessary plumbing modifica-
tions, and flow reduction devices. The payment of these costs is agreed
upon by the user and contractor or supplier. Communities are not involved
in the payment and recovery of private capital costs.
The community is involved directly, however, in the recovery of public
capital costs, interest on debt, operation and maintenance costs, and
reserve fund costs. These costs are usually recovered through a user
40 CFR 35.2030 charge system. Construction Grant regulations, 40 CFR 35.2030, require
that facilities plans present cost information on total capital costs, and
annual operation, maintenance and replacement costs, as well as estimated
annual or monthly costs to residential and industrial users.
Public capital costs need not be part of an approved user charge system.
Instead, users may be required to pay capital costs at the beginning of the
project. Other sources of funds might also be used such as general
revenues. However, most communities do include capital costs and interest
on public debt in their user charge systems. For centralized facilities
and cluster systems, capital costs and interest can be recovered from both
present and future owners. Public capital costs for on-site systems are
recovered from present users only. Future users of on-site systems will
not be subsidized, and all their capital costs will be private costs in the
absence of a local government subsidy.
Operation and maintenance costs, if the project receives grant funds, must
be allocated on the basis of each user's proportionate use of the system.
In the case of on-site technologies, some operation and maintenance costs
may be paid by users directly to private contractors such as septic tank
pumpers and haulers. Operation and maintenance costs which are incurred by
a public agency, however, must be recovered from users. Construction Grant
40 CFR 35.2140 regulations specify two methods for recovering these costs: (1) actual use
and (2) ad valorem taxes. It is doubtful that communities would already
have ad valorem taxes for unsewered areas, so this choice is not available
for use with optimum operation alternatives. With the actual use method,
each user or user group pays its proportionate share of operation and
maintenance.
Proportionate share as implied by Construction Grant regulations (40 CFR
35.2140) is based on wastewater loading which would encompass flow and
strength. However, most costs of operating on-site and small scale treat-
EIS III-C ment facilities are related to services required (see Section III-C),
therefore, to type of treatment facilities, site conditions and system age
as well as wastewater loading. A user charge system which keys on allocat-
ing costs of services instead of wastewater characteristics, moreover,
would better satisfy the stated goal of the regulations: "...that each
user which discharges pollutants to the system that cause an increase in
the cost of managing the effluent or sludge from the treatment works shall
pay for such increased cost."
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Administration costs for an optimum operation alternative with a strong
public role can be a substantial part of on-going costs. Normally
considered a type of operation cost, they are distinguished here because of
their relative size and importance. Some costs of administrative services
may be collected from contractors as license, certification, or inspection
fees but would be paid ultimately by users.
A reserve fund is not required but is encouraged by U.S. EPA. The reserve
fund can provide for replacement of equipment and future expansion of
centralized facilities. For on-site systems, the reserve fund can replace
systems that may fail in the future. The reserve fund reflects the
liability a community is willing to assume for on-site systems. If the
community assumes no liability for future failures of wastewater systems, a
reserve fund is not necessary. Payments into the reserve fund generally
are low when the failure rate for systems is low. Greater payments are
required for a relatively high failure rate. Reserve fund charges can be
levied from different user groups at varying rates.
2. COST RECOVERY OPTIONS (New Section)
Table III-I-l presents the major options that communities may want to
consider when allocating local costs of an optimum operation alternative.
In selecting options, the topics discussed below might be considered.
TABLE III-I-l. COST RECOVERY OPTIONS
Initial Assessments
Continuing Payments
Contractor
Owner payment Average Bill Average Bill payment to
to contractors within user individual within user individual management
or suppliers groups user groups user agency
Private Capital
Public Capital
Interest on Debt
Administration
Operation and
maintenance
Replacement
Private vs. Public
To keep user charges and initial assessments to a minimum, such costs as
capital for facilities not eligible for grant funding, charges for some
operation and maintenance services, and expenses for replacing systems that
fail in the future could remain the responsibility of property owners.
While low user charges are attractive politically, they may result in false
economies if owners neglect to purchase needed facilities and services.
Initial Assessments vs. Continuing Payments
Another device used to keep user charges down is an initial assessment.
Initial assessments reduce both the capital that has to be recovered and
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interest on debt. With sewered facilities, these assessments take the form
of connection charges, front-footage fees or fees based on property value.
Similar assessments can be made with on-site and small-scale facilities.
For many of these facilities, the entire local share may he very small
after Federal and state grants so that collecting the local share as
initial assessments might not be a financial burden for owners and could
avoid long-term public indebtedness.
c. Averaging Costs within User Groups vs. Billing Individual Users
With centralized collection and treatment systems, user groups are
typically identified as residential, commercial, small industrial, large
industrial, etc. These distinctions are valid also with on-site and small-
scale systems but additional distinctions are also valid. Examples are
type of facilities, age of facilities, and history of failures. Please
note, however, that neither past nor present Construction Grant regulations
consider allocation of O&M costs on any other basis than wastewater charac-
teristics and ad valorem taxes.
The case for charging by user groups in conjunction with an optimum opera-
tion alternative is based on the concept of efficiency. That is, it can
contribute to meeting the goals of a project at the least overall cost. In
particular, billing by user group would be less expensive than assessing
cost property-by-property. In the extreme case, an unsewered community may
recognize only one user group such as "residences served by on-site
systems" so that all public costs would be averaged to each residence.
Another benefit of billing by user groups is that those owners who required
periodic expensive maintenance or repair could see their costs averaged.
The work would be more likely to get done in a timely manner.
The benefit of avoiding occasional, high expenses could be achieved with
individual user billing if the management agency would amortize the expense
over a period of time, in essence, create a loan program for expense over a
predetermined amount. This would lessen the impact of an owner having to
come up with the cash all at one time. The problem would, therefore, more
likely be remedied quickly. Of course, billing costs would increase even
more.
The individual user billing option is the most equitable method. That is,
each owner pays for what he gets. Knowing that other owners are not going
to subsidize his costs, an owner is encouraged to keep his costs down by
using his system wisely. To the degree that owners behave this way,
individual user billing is both equitable and efficient.
Nevertheless, individual user billing can be unnecessarily burdensome and
very inefficient with owners who must use high cost systems such as holding
tanks or water recycle systems. The annual costs of routine holding tank
pumping can exceed even the highest sewer use charges. This penalizes, in
a sense, the few owners with high cost systems who would have been better
off if everyone had helped pay for a sewer. And the cost may induce them
to dispose of sewage in a hazardous manner. In such cases, averaging some
or all of these owners' costs over all user groups may be justified.
J. BROADER RESPONSIBILITIES OF PUBLIC AGENCIES RELATED TO RURAL WASTEWATER
MANAGEMENT
Public agencies managing small waste flows systems may already possess or
may assume responsibilities in addition to those related to wastewater
management. Assumption of multiple responsibilities may be particularly
attractive in small communities with few paid personnel. In such communi-
ties, the small waste flows systems alone may not justify full-time posi-
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tions, making multiple responsibilities more efficient. Examples of
broader responsibilities that may be assumed by a wastewater management
agency are discussed below.
EIS III-C-1-5 Many rural communities lack any form of land use planning, the only land
use restrictions relating to the suitability of a given site for on-site
TKD VI-A wastewater disposal. These restrictions may be altered through approval of
XI-A innovative on-site systems or adoption of performance-based design
standards by a management agency. If this occurs, the community may desire
EIS IV-D-2 to develop appropriate land use designations. The management agency could
be designed to provide this service.
EIS III-H-1 The use of private water systems is predominant in rural communities. In
addition to ensuring adequate wastewater disposal, the management agency
could ensure safe and adequate water supply. The agency can accomplish
this by routinely inspecting and monitoring individual wells and/or
community water supplies and by providing public education related to water
supply management.
TRD X-D Section 201(f) of the Clean Water Act of 1977 states that the administrator
shall encourage waste treatment management that combines open space and
EIS IV-A-3 recreational considerations with such management. A community management
agency could coordinate the use of wastewater management district proper-
TRD XI-C ties for recreational use, such as the use of a community drainfield for
picnic or park land. The management agency could also manage recreational
facilities not part of the management district.
TRD II-C In communities with particularly sensitive water resources, the management
XII-G agency could investigate and monitor sources of pollution unrelated to the
wastewater facilities. In many rural areas, the management agency may be
the only public body involved in pollution control; therefore, assumption
EIS III-H-2-b of broader responsibilities in this area could be of great community
benefit.
K. PERSONNEL
A broad range of skills and expertise may be required by the management
agency. Typical job titles that may be involved in some aspect of waste-
TRD VI-D water management include:
system designer,
clerk,
administrator,
inspector,
attorney,
equipment operator,
plumber,
small waste flows contractor,
laboratory technician,
water resource scientist,
soil scientist,
laborer,
environmental planner, and
wastewater system operator.
Although the list of job classification is long, one person could provide a
number of skills. It is not necessary to employ one person to fill each
position. Customary job titles such as engineer and sanitarian are not
listed as such, in order to define more clearly the types of personnel
needed and to avoid limiting personnel to these disciplines. Sanitarians
and engineers could, however, fill many of the job classifications.
The task of defining and fulfilling management agency personnel needs
required five steps:
1. assess skills and skill levels rewquired by the management agency,
2. estimate the level of effort required by skill,
3. inventory available personnel and define their sill levels,
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4. select personnel to meet management agency needs and acquire their
services through interagency agreements, hiring, or contracts, and
TKD VI-F 5. seek training programs to fill any remaining gaps in expertise required
by the management agency.
A community planning a management program should consider hiring key
personnel early in the process. These personnel, such as an administrator
experienced with small waste flows technologies, would be invaluable in
assisting the community in the design process, then later administering
operation, maintenance and repair services.
The search for personnel who may assist the management agency should not be
TRD XV-C limited to the local area. All sources of potential assistance should be
evaluated, including state, regional and other municipal personnel, U.S.
Soil Conservice Service personnel, utility company workers, private con-
EIS V-B-2 tractors, and consultants. State and regional agencies can provide many
types of assistance, including:
direct technical assistance,
assistance to local communities in grant application and administration,
preparation of community wastewater needs analysis,
identifying the local feasibility of small waste flows technology and
management,
review and upgrading of local and state regulations,
dissemination of information on small waste flows technology and
management, and
preparation of manpower inventories for local small waste flows
programs.
In many rural communities, economies of scale in management may be realized
by sharing personnel with other communities, or by a regional agency
furnishing assistance on a shared time basis.
The community management agency should ensure that private contractors and
consultants hired to perform management agency services are experienced in
the utilization and management of small waste flows systems. Without
experienced assistance, the community may not fully realize the benefits of
the optimum operation approach.
L. REVISING THE MANAGEMENT PROGRAM
After the management program has been implemented, documentation of the
performance of the program as a whole and of each of its component parts is
important to long-term success and economy. Periodic review of this
information, and evaluation and revision of the management program, should
be an ongoing process.
The intitial implementation of a management program in a community cannot
be expected to result in an ideal program. This is particularly true since
community management of small waste flows systems as broadly defined in
this EIS will be a totally new management approach for many communities.
As the program is implemented, unforeseen problems with the system are
likely to develop. Certain seemingly prudent management practices may
appear otherwise in actual operation.
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The agency should encourage feedback on its management program by solicit-
ing and being receptive to community and public comments on the program.
The agency should develop minimum requirements for periodic evaluation of
the successes and problems in the management program and of necessary
revisions to the program to make it operate more effectively.
Provisions for revision of the management program should be flexible enough
to allow constructive improvement in the program without altering the
community's original commitment ot the management of the small waste flows
systems. Where this commitment is questioned, the community's original
analysis of the need for a management program may have been wrong. If
Construction Grants funds have been received for the individual systems,
continuity in the management program must be assured by the community or by
state or regional agencies.
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Chapter IV
Facilities Planning Techniques
WALKER
TOTEM POLE
12
LAKE
HACKBURY,
HAVEN
LOCATION PLAN
Legend
NO INFORMATION AVAILABLE
ฎ UPGRADING REQUIRED
A SYSTEM REQUIRES NO UPGRADING
BUSINESS OR RESORT
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CHAPTER IV
FACILITIES PLANNING TECHNIQUES
Chapter II, sections D through F, discusses some of the most important
aspects of facilities planning: needs documentation and alternatives
development. This chapter discusses additional planning methods of
importance to rural wastewater facilities planning.
Definition of planning area, assessment of water quality impacts, and
calculation of current and future population and land use impacts, are
sometimes technically difficult and even controversial subjects. If
properly explored, however, they allow realistic assessment of project
value and whether it will do more harm than good. Such information is of
great value to the project whatever the Federal or State role may be.
Indeed it may be of greatest value for the community that must plan and
implement a wastewater system using only its own resources.
A. PLANNING AREA DEFINITION
1. APPROACHES FOR DEFINING PLANNING AREA BOUNDARIES
TRD IX-B The wastewater treatment needs and facilities planning area for your com-
CG 82-5.0 munity were identified during the water quality management planning pro-
cess based in part on effluent limitations in your NPDES permit, applicable
groundwater criteria and State requirements. You should review this infor-
mation to ensure that the planning area is large enough to take advantage
of economies of scale and efficiencies possible in regional planning, or
decentralized or individual systems. The planning area will also be
sufficient to ensure that the most cost-effective means of achieving the
established water quality goals can be implemented, and that an adequate
evaluation of environmental effects can be made.
When states and applicants decided on facilities planning area boundaries,
several factors might have been considered:
local growth and development objectives,
geographic, geologic and hydrogeologic conditions
Legend for Cross-References in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change in
the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
99
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wastewater treatment needs,
housing density and identified public health problems,
sensitivity of local water resources to on-site system failure,
availability of data (both socioeconomic and natural environment), and
cooperation of local municipalities, and other political constraints.
Three basic approaches can be taken to delineate planning areas:
1. the jurisdictional approach,
2. the environmental approach, and
3. the development approach.
Each of these approaches has advantages and disadvantages for facilities
planning in unsewered areas.
The jurisdictional approach delineates facilities planning areas based on
county boundaries, municipal boundaries, or census count boundaries (census
tract or minor civil division). This approach maximizes the applicability
of published population and economic data, including census data, popula-
tion (existing and projected), income characteristics, employment patterns,
and land use plans. This approach may also have possible management
advantages in that existing governmental structures can handle implementa-
tion of the facilities plan proposed action and can facilitate the
formation of a small waste flows management district to maintain facili-
ties. Additionally, finance mechanisms may be easier to implement at this
level.
This approach has drawbacks, however. It could lead to conflicts between
jurisdictions resulting from lack of cooperation, which in turn could limit
the range of alternatives that could be implemented. Environmental impact
evaluation may not be comprehensive at this level. This approach may
exclude small outlying problem areas and could preclude evaluation of
cost-effective alternatives.
Based on previous work for the Seven Rural Lake EIS's, the jurisdictional
approach will be difficult to utilize in some large lake areas in U.S. EPA
Region V because these areas generally traverse several municipal
boundaries.
The environmental approach considers the watershed or lake drainage basin
as the principal unit of delineation for facilities planning. Point and
non-point sources of pollution can be comprehensively addressed at this
level. This unit of evaluation takes into account the sensitivity of water
resources to septic tank failures. Data for natural resources may be more
readily available at this level. Disadvantages of the approach may include
the problem of municipal boundary crossover. In addition, the approach may
not adequately consider local growth objectives. Applicability of
published demographic data may also be difficult.
The development approach to study area delineation would utilize both the
existing development areas, which are designated for future residential,
commercial, and industrial growth, and the undeveloped waterfront areas to
establish planning area boundaries. These development areas would include
growth areas defined in local municipal comprehensive land use plans and
zoning ordinances. This approach would include all areas that are expected
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to increase in population during the planning period. Formally adopted
growth objectives would thus be adequately addressed in this approach.
However, several problems may arise with this approach, including dif-
ficulty in applying socioeconomic and environmental data. This approach
may not adequately address the major sources of water quality problems or
septic tank failures.
2. IDENTIFICATION OF PLANNING AREAS WHERE OPTIMUM OPERATION ALTERNATIVES
SHOULD BE CONSIDERED
The optimum operation approach fills a niche between sewering and doing
nothing. The niche can be described in terms of development density,
number of on-site system failures, sensitivity of water resources,
feasibility of abating failures on-site and cost-effectiveness. Table
IV-A-1 relates these factors to the limits of the optimum operation niche
in a general way.
In the very early stages of facilities planning, that is, in defining
facility planning area boundaries and preparing Plans of Study, conclusive
EIS II-F-2 information regarding these factors may not be available. However,
preliminary information can be gathered from an inspection of topographic
maps or aerial photographs (development density), interviews with local
health officials or natural resource personnel (number of on-site system
failures, sensitivity of water resources, and feasibility of abating
failures on-site), and use of cost curves (cost-effectiveness).
TABLE IV-A-1. FACTORS THAT DETERMINE LIMITS OF THE SMALL WASTE FLOWS NICHE
Development
Density
Number of
On-site System
Failures
Sensitivity of
Water Resources
Feasibility of
Abating Failures
On-Site
Do Nothing x x x
vs. These three factors together determine a
Small Water community's obligation to improve waste-
Flows water management in unsewered areas.
Cost-
Effectiveness
Small Waste
Flows
vs.
Sewering
x x
Primary determinants of cost-
effectiveness comparisons.
May preclude
successful use
of the optimum
operation alter-
native in parts
or all of a com-
munity.
x
Will incor-
porate many
unlisted fac-
tors such as
environmental
constraints
to sewer con-
struction,
mix of on-
site and
small scale
systems re-
quired, local
management
options,
growth rate.
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If delineation of facilities planning area boundaries or decisions to
consider optimum operation alternatives have to be based on housing density
alone, it is recommended that any unsewered areas developed at 10 to 125
houses (or dwelling unit equivalents) per mile of road be designated as
potential parts of a small waste flows district. Below 10 houses per mile,
water quality and public health problems caused by on-site failures will
rarely be cause for public concern (although facilities planners should
look for exceptions during needs documentation work). Above 125 houses/
mile, sewering to either small-scale or centralized off-site facilities
will become increasingly cost-effective for solving water quality or public
health problems.
3. ADVANCE PLANNING TO SAVE TIME AND EFFORT
A number of advance steps may be taken to circumvent significant conflicts
and provide creative input to the facilities planning process. These steps
consider non-water quality goals that nevertheless have considerable
influence over the facilities planning process. These include critical
aspects such as initiation of public participation efforts, planning of
recreational resource development, and definition of community development
goals and objectives. Municipal officials have often complained of the
length of time required to complete the facilities planning process. If
local interests were to devote energies to the resolution of these issues
prior to planning, considerable time would likely be saved in the facili-
ties planning process. Advance planning would permit a locality to deal
with non-water quality issues in a way that would help avoid controversy,
minimize the impacts of proposed facilities, and maximize the potential
benefits of the planning process.
TRD XIV-A Almost every one of the Seven Rural Lake EIS's was prepared in the midst of
significant public controversy about the facilities plan. Because of the
complexity of- the facilities planning process, early contact with the
citizens of the area is a necessity. For any given alternative, some
segments of the population will feel harmed and others helped. Those that
perceive themselves harmed may form coalitions and even bring litigation
based on only a partial understanding of a project. A public information/
education program would respond early to concerns raised by the public and
would explain what facilities planning is, how it proceeds, how wastewater
projects affect the community, and how the public can provide input.
TRD X-D The facilities planning process offers opportunities to analyze the need
for recreation resources in an area and to maximize recreation potential.
Section 201 (g)(6) of the Clean Water Act, requires applicants to evaluate
the recreation and open space opportunities achievable with their proposed
facilities as part of overall planning for wastewater treatment facilities
in. A preliminary study area evaluation of existing facilities and
activities can be accomplished at little expense with assistance from local
homeowner associations, 4-H clubs, senior citizens groups, or others. In
the case of the optimum operation alternative, certain forms of treatment,
especially cluster systems, may offer some recreational potential.
EIS IV-D New forms of wastewater treatment that overcome unfavorable site conditions
VI-D may induce residential development in patterns and densities unanticipated
at the local level. To mitigate these impacts, land use planning and the
TRD XI-A&B adoption of growth management controls should be considered before begin
ning facilities planning. In areas without adopted plans and ordinances,
this type of effort would establish community development goals and
objectives relating to residential, recreational, commercial, and indus-
trial development. Formally adopted land use plans most often take into
account the character of a community and its natural resource base, and
establish both conservation and development priorities. Such a program
backed by an updated zoning ordinance with environmental performance
standards will provide facilities planners with specific guidance on the
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likely amount and spatial distribution of growth for which wastewater
treatment must be provided. A comprehensive plan would also have undergone
EIS III-D public scrutiny and taken into account points of public controversy that
would otherwise hinder the facilities planning process. An adopted
comprehensive land use plan would thus significantly expedite facilities
planning.
Facilities plan applications are sometimes made by local public work
departments with little coordination with other functional departments.
Advance planning functions may be carried out by county or municipal
planning departments, local recreation agencies, and local public health
officials. Frequently, regional planning commissions or councils of
government have both experience and technical expertise that can be
utilized in a particular study area. These organizations may have
conducted 208 plans for the area and may have public participation mailing
lists and data on land use and population, as well as on sensitive
environmental areas. Thorough coordination and advance planning by these
agencies could greatly expedite the planning process and prevent signifi-
cant controversy.
B. DEMOGRAPHY
Accurate demographic information and projections play an important role in
determining project need, designing workable alternatives, and assessing
CG 82-5.5.1 project impact. Section 5.5.1, "Population and Land Use Projections" in
Construction Grants - 1982 repeats relevant requirements and offers
guidance on projecting future populations. Accurate information is just as
important for the community that must plan and build its facilities alone.
1. RECREATIONAL DEMAND IN LAKESHORE AREAS
TRD X-C Recreation lot sales and second-home development have been a significant
market force in the United States in recent years. Rising levels of dis-
posable income, ready mobility, and increased leisure time have led to an
increase in the purchase of second homes. This has been true particularly
in areas near inland lakes and rivers and areas accessible to major
employment centers (Marans and Wellman, 1977).
However, the future of second-home development is uncertain. The housing
recession and oil shortage between 1973 and 1975 resulted in a significant
downturn in second-home development (American Society of Planning
Officials, 1976). If this experience is extrapolated to current condi-
tions, the availability of gasoline for leisure travel and prevailing
interest rates may curtail this type of development.
TRD X-B The late 1960s through the mid-1970s, however, showed a steady climb in
this type of development. Data from the Seven Rural Lake EIS project areas
showed an increase in dwelling units between 1970 and 1975 of 12.4% on
Crooked/Pickerel Lakes, 12.5% on Otter Tail Lake, and 15% on Crystal Lake.
Table IV-B-1 shows the increase in total population projected for each of
the Seven Rural Lake EIS communities to the year 2000 and the percentage of
the increase accounted for by seasonal (second-home) residents. Population
growth ranges run from a low of 1.6% at Nettle Lake, Ohio, to a high of
33.5% at Crooked/Pickerel Lakes, Michigan. As these data show, rural lake
areas are projected to experience fairly rapid rates of growth, comprised
to a large extent of seasonal residents.
The overwhelming attraction for second-home development is accessibility to
lakes and rivers and the recreation opportunities that they afford (Marans
and Wellman, 1977). In Michigan, 55% of second homes are on inland lakes,
21% on the Great Lakes, and 10% on rivers or streams; of the total, 89% are
within a 5-minute walk of some body of water (ASPO, 1976).
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TABLE IV-B-1. SEVEN RURAL LAKE EIS POPULATION PROJECTIONS (INCREASE TO THE YEAR 2000 AND
SEASONAL POPULATION EXPRESSED AS PERCENTAGES)
Study area
Crooked/Pickerel Lakes, Michigan
Crystal Lake, Michigan
Otter Tail Lake, Minnesota
Nettle Lake, Ohio
Steuben Lakes, Indiana
Green Lake, Minnesota
Salem Utility District, Wisconsin
Population
(% increase)
33.5
31.8
16.0
1.6
27.0
18.0
31.5
Seasonal
(% of increase)
47.7
46.0
76.0
88.0
68.0
43.0
27.6
Travel distance is a significant factor in the location of second homes.
Data from a study conducted in northern Michigan indicate that the distance
traveled to recreation homes averaged 250 miles (Marans and Wellman, 1977).
Other studies state that accessibility is the key factor in second-home
development, with natural amenities second (ASPO, 1976). This latter study
indicates that most second homes in the United States are within 100 miles
of the primary home.
However, lakefront access for recreation is deemed a critical factor by
recreation home residents. The settlement pattern in five of the Seven
Rural Lake EIS study areas was single-tier development along the banks of
the major surface water bodies with direct access to those resources. In
these study areas, public access in the form of public beaches or boat
ramps is limited. Nettle Lake has no public facilities. On Crooked/
Pickerel Lakes only 2% of the shoreline is available, on Green Lake 2.9%,
and in the Salem Utility District only 960 feet are in public access
facilities. These limitations could severely curtail the incidence of
second-tier residential development where little or no direct access to
lakefront recreation is available.
Ragatz (1980) has projected demand for recreation properties in the north-
central region of the United States to the year 1985. He cautions that
these projections are based upon scant data and market statistics that have
varied significantly in recent years. Table IV-B-2 shows these projections
for recreation lots, single- family recreation homes, and resort condomi-
niums. The number of households owning recreational properties is expected
to increase by 21%, the number of households owning single-family vacation
homes will increase by 14.2%, and the number of households owing resort
condominums will increase by 32%.
Based upon data from the 1973 to 1975 housing recession, the rate of devel-
opment in this market is influenced by major shifts in the economy.
Sources agree that the future of the market will depend on the price and
availability of gasoline as well as the availability of mortgage money and
the prevailing interest rates. Possible shifts in the market could occur
that would encourage more intensive lakeside development in areas closer to
major employment centers.
2. PROBLEMS IN ESTIMATING PERMANENT AND SEASONAL POPULATIONS OF SMALL
SERVICE AREAS
TRD X-B The estimation of population levels within a proposed wastewater management
service area is important in the design of a wastewater treatment system
and in the evaluation of impacts induced by a proposed system. Relevant
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TABLE IV-B-2. RECREATION DEMAND IN THE NORTH-CENTRAL REGION OF THE UNITED STATES
1980 1985
Total number of households
Number of households owning recreational properties
Number of households owning single family vacation homes
Number of households owning resort condominiums
20,500,000
1,827,200
1,107,600
163,200
22,000,000
2,318,400
1,290,200
240,000
data are frequently available for permanent population; however, the
application of these data to small rural service areas may prove difficult.
The data may be outdated; they most often contain no information on
seasonal population; analytical methods to derive the data are often based
on assumptions unsuitable for wastewater treatment planning and design; or
the data base is unacceptable for use at the small area level. Frequently,
the required data are not even available for small rural service areas
where no formal planning exists. In addition, many factors that influence
rural area population dynamics, such as current dwelling unit permits,
housing occupancy rates, or dwelling unit conversions, are largely
undocumented.
A recurring problem in rural areas that include some type of natural
recreational resource (that is, lakes, mountains, rivers) is the determi-
nation of permanent versus seasonal population. In many of the rural
service areas where such resources exist, seasonal residents (normally
summer) comprise a major portion of the total population. Even though the
annual volume of wastewater that seasonal residents generate is less than
for permanent residents, the treatment level and peak flow capacity of
central treatment plants are not reduced. Consequently, the determination
of a permanent versus seasonal population breakdown is an important
consideration for calculating design flows for conventional treatment
systems.
The U.S. Department of Commerce, Bureau of the Census, is the major source
of demographic data. However, census data have several limitations that
restrict their use for small rural planning areas. Since the census is
taken at 10-year intervals, the data quickly become outdated. The data are
usually reported on the township level, and townships are generally
considerably larger than facilities planning boundaries. More important,
though, is the total lack of information differentiating seasonal versus
permanent population data.
The amount and type of population information available from the state
agencies vary. Population estimates at the county and sometimes township
level are prepared annually in conjunction with the Census Bureau. Again,
these types of information apply to larger areas than are associated with
many rural facilities planning areas.
Regional planning or 208 water quality agencies will have population data
for facilities planning areas. There are a number of drawbacks to using
these data. Figures from Federal or statewide projections are often not
sensitive to population dynamics on the local level. In practice, popula-
tion projections assigned to facilities planning areas are seldom compiled
for areas smaller than the township level. They may not, therefore,
contain information relevant to small facilities planning areas; and they
reflect scant data on seasonal population. Also, these data often do not
differentiate between the population to be served by planned facilities and
the total population of the facilities planning area. Oversized facilities
can be the result.
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Municipal and county planning departments or other local government offices
may be able to provide pertinent data concerning rural area populations.
Tax rolls, utility connections, special school censuses, and building
permits can be used to determine the current number of dwelling units,
permanent and seasonal composition, recent growth trends, and other charac-
teristics of a given area. Such data are usually not published, and
personal examination of office records is required to gather information
specific to a facilities planning area.
State and private universities represent valuable sources for local demo-
graphic information. Universities with programs in urban and regional
planning, urban studies, geography, or similar programs frequently conduct
field studies that involve small towns and rural areas. These studies may
contain useful data on the size and characteristics of local population,
but may be difficult to obtain because they are often not published.
Contacts with appropriate university personnel are usually required to
determine if such studies have been performed and are available.
EIS II-D-l-a Windshield surveys and aerial photo interpretation provide reliable and
readily available methods for determining the number of housing units in
a rural planning area. Housing unit data and local occupancy rates can
provide the basis for current population estimates. In some rural areas,
the windshield survey method may prove inaccurate because not all housing
units are visible from public roads. These surveys should be used in
conjunction with aerial photos for greater accuracy. It is also difficult
to differentiate seasonal from permanent residences without some primary
evidence such as a snow-plowed drive. Further, these surveys do not
provide information on vacancy rates or average household size.
EIS II-D-3 There is no straightforward or easy method to determine the percentage of
the population that is seasonal. For estimates of the existing population,
house-by-house surveys provide the most reliable figures but are also
expensive and time-consuming to obtain. However, if house-to-house survey
methods are needed for other purposes anyway (such as sanitary surveys),
then the incremental cost for population and occupancy data would be
negligible. Local post offices and utilities can indicate which dwelling
units are receiving mail or using various utility services on a year-round
basis. The use of this information eliminates the need for house-to-house
surveys except for some possible follow-up cross-check surveys.
The method most commonly used in the Seven Rural Lake EIS's was an analysis
of the property tax rolls. The property tax rolls indicate the home
address of the owner of each residence, identifying those dwelling units
that are owner-occupied. While it cannot be fully determined which units
are seasonally occupied and which are rented to permanent residents, a
fairly accurate delineation of permanent versus seasonal units can be made.
Discussions with local realtors may further refine this delineation.
Application of permanent and seasonal household size figures to this
dwelling unit delineation will then define the permanent versus seasonal
population breakdown.
3. POPULATION PROJECTION METHODOLOGIES FOR SMALL SERVICE AREAS
TRD X-B Population projection techniques normally rely on one or more of six
different types of models:
1. mathematical,
2. economic-employment,
3. cohort analysis,
4. component,
5. ratio/share, and
6. land use.
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TRD X-B Beyond these projection models, various disaggregation techniques may also
be used to distribute the population totals to smaller subareas within a
study area. These various projection and disaggregation techniques each
have certain limitations, and some techniques are more applicable to
smaller areas. Often, a combination of techniques is required to develop
projections for a particular area. Models such as economic-employment,
cohort analysis, or component methods are seldom feasible in rural areas
because they rely on data from areas much larger than these facilities
planning areas.
Mathematical projection models assume that the components that charac-
terized past population change will continue for some period into the
future. This extrapolation of historical trends requires relatively little
data and consequently is simple to apply. However, such projections do not
explain the reasons for past growth nor do they account for possible future
changes that may affect future growth. In addition, they are normally more
accurate for larger areas since the changes from past trends are more
likely to average out over a larger area. As a result, these types of
projections should only be used for short-term projections.
The ratio/share models use population projections available for a larger
area and allocate a portion of the change to the area under evaluation.
This type of projection assumes that the population change in a particular
area depends on the amount of change in the larger region. The ratio of
regional growth to local growth may be chosen from one point in time or as
an annual average ratio from several periods.
EIS IV-D-1 Land use models project population on the basis of available land and
expected population density. This type of projection reverses the process
TRD XI-B of projecting population growth first and then determining what land area
will be required. Instead, it begins with the amount of developable land
available and then determines how many people can be accommodated at full
capacity. In order to determine the amount of developable land, an
environmental constraint evaluation may be performed that incorporates
information on land use, environmental resources, and economic factors.
This evaluation defines the amount of developable land under existing land
use laws and regulations and determines the number and distribution of
potential dwelling units and population equivalents. Facilities planning,
need area, and service area boundaries must be carefully delineated so that
only land being served is analyzed for total population to receive waste-
water treatment service.
The population projection methods discussed previously are applicable to
small rural planning areas in varying degrees. Data requirements, assump-
tions, and the projection outputs may limit the usefulness of many of these
projection techniques for small rural planning areas. During the prepara-
tion of the Seven Rural Lake EIS's, several different or a combination of
projection techniques were utilized. Most of these projection methods
relied at least in part on land use models and land holding capacity
analysis. This combination seems to fit the requirements of small rural
planning areas, given the data normally available for such areas. Only
rarely will data be available to use more sophisticated projection
techniques that result in somewhat more reliable projections.
4. ESTIMATING ECONOMIC CHARACTERISTICS OF RESIDENTS
EIS VI-C-3 The decennial census is the most comprehensive available source of informa-
tion for population characteristics. The Census of Population is currently
conducted at the beginning of each decade and serves as the basis for a
series of related topics. Data typically presented at the state, Standard
Metropolitan Statistical Area, city, county, and township levels include
permanent population characteristics, income levels, employment patterns,
and information on commercial and industrial trade. The data on household
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size, population levels, and vacancy rates are particularly important in
wastewater management planning for small, rural areas.
More current information on population and per capita income is found in
the Current Population Reports, Series P-25, Population Estimates and
Projections, which is issued annually. The estimates are dated two years
preceding the report date and include estimates of per capita income dated
four years preceding the report date. These data do not describe charac-
teristics of the seasonal population and are detailed only to the township
or county level.
Economic data are available from the economic censuses published by the
Census Bureau every five years. This census series is comprised of
individual reports on retail trade, wholesale trade, selected service
industries, manufacturers, agriculture, transportation, and mineral
industries. Each report includes information on employment levels, wages,
sales, size of firms, number of firms, and a level of production. The
results are released in the form of printed reports and computer tapes.
Their use in small rural areas is limited by the size of the reporting
areas, which often include only county, state, and major incorporated
areas.
State government agencies and departments can often provide other data such
as income levels, retail sales, employment data, and local government
finances. The availability and source of these data vary from state to
state. However, when such data are available, they may often be more
current and relevant to small rural areas than Census Bureau data.
Regional planning and development agencies are often responsible for
preparing demographic studies, comprehensive plans, economic studies, and
community facility reports for the small villages and rural settlements
within their jurisdiction. Information obtained in these types of reports
can be useful in establishing baseline economic conditions as well as
economic projections. Many regional planning agencies and councils of
government are also designated as economic development coordinators for the
regions requiring that an Overall Economic Development Plan (OEDP) be
submitted annually to the U.S. Economic Development Administration (EDA).
This plan normally includes information on demography, economic base,
income levels, and public works projects.
Municipal and county planning departments or other local government offices
may be able to provide economic data on rural area populations. Often
township or county comprehensive land use plans will contain information on
local per capita income, unemployment rates, and commercial and industrial
statistics. Considerable information is usually available on housing con-
struction, vacancy rates, and property values. Local property tax roles,
already mentioned as a source of population data, may be useful as an
assessment of relative housing values.
Housing values taken from property tax roles may be the only economic data
obtainable for seasonal residents. If economic impacts of wastewater
alternatives on seasonal residents will be decisive for alternative
selection, a special economic survey may be necessary. Data requested
could either be household income or a maximum amount the respondent is
willing to pay. Data can be collected by mailed questionnaire or door-to-
door survey, possibly in conjunction with needs documentation surveys.
Other sources of information are local real estate agents, homeowner
associations, chambers of commerce, utilities, and other community groups.
Discussions with local real estate agents can yield information about
housing vacancy rates, housing stock, property values, and second-home
construction. Real estate agents may also be aware of planned developments
and future market activity in the area. Local homeowner/ community groups,
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on the other hand, may be able to provide information regarding housing
vacancy rates and shifts from seasonal to permanent occupancy.
C. CATEGORICAL EXCLUSIONS FROM ENVIRONMENTAL REVIEW (New Section)
In March 1982, U.S. EPA published procedures for granting categorical
exclusions from detailed environmental review requirements for certain
Construction Grants projects (47 FR 9827-9831). Categorical exclusions are
intended to apply to actions that are small scale, minor, and routine.
Generally, environmental information documents and environmental assess-
ments or environmental impacts statements will not be required for excluded
actions.
Communities proposing to construct small on-site facilities are eligible
for categorical exclusions. Actions that directly or indirectly involve
the extension of new collection systems or that create new discharges to
surface or groundwaters will not be eligible for an exclusion.
The time and money saved by exclusions will depend on how early in the
planning process that a community decides to upgrade existing wastewater
facilities. State and Federal review officials are expected to determine
as early as possible whether a project is eligible for an exclusion. But
to make this determination, he or she must receive a brief description of
the proposed action. In complex situations, where the choice between new
centralized facilities and continued use of existing facilities requires
significant environmental analysis anyway, the actual savings in time and
money may be small. However, for a great many small communities, continued
use of existing facilities with necessary upgrading and improved management
will be the clear early choice. These communities can then devote a larger
portion of available funds to finding, analyzing, and solving wastewater
problems.
The availability of categorical exclusions should not become an excuse for
avoiding all environmental analysis. As discussed in the next two sections
and throughout Chapter VI, the continued use of on-site systems can have
adverse effects on the human and natural environment in some settings.
Communities are urged to remain attentive to the possibility of such
effects and to assess them in a timely manner. Otherwise the categorical
exclusion may be revoked and the full environmental review process
reinstituted.
D. LAND USE AND ENVIRONMENTAL CONSTRAINTS
1. NONSEWER DEVELOPMENT CONSTRAINTS
TRD XI-A One of the major findings of the Seven Rural Lake EIS's was that signi-
ficant differences in population growth, land use conversion, and environ-
mental impact would result from sewering versus not sewering the rural lake
communities. The decision of whether or not to sewer has significant
implications for a community's future. However, many rural communities
rely on limited planning tools that fail to recognize important environ-
mental and economic resources. They rely heavily on general soil limita-
tions for on-site systems to justify low density land use zones. This has
served to limit the amount of vacant developable land in these areas. It
is, therefore, in the best interests of rural communities to examine land
use potentials carefully as a critical element of their decision-making for
wastewater treatment facilities. This is particularly true for rural lake
communities because of the high incidence of environmentally sensitive
resources.
TRD XI-B An environmental constraints methodology uses information on land use,
environmental resources, and economic factors in the design and evaluation
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of wastewater management alternatives. The process involves an inventory
and mapping of natural and man-made factors in the study area, followed by
interpretation of the degree of constraint on future development caused by
these factors. This will allow compilation of data into a form permitting
facilities planners to view areas where no residential development may
occur, where limited development may occur, and the amount and spatial
distribution of land where residential development is likely to take place.
Interpretation of development limitations should be based upon local zoning
and subdivision ordinances, on-site wastewater sanitary codes, state laws,
and Federal laws and regulations.
EIS II-D-l-a The process requires preparation of a base map of the study area and
overlays of inventory information at the same scale. The base map should
show the planning area boundaries, minor civil divisions, transit systems,
and surface water bodies. The overlays of inventory factors that present
constraints include such characteristics and resources as physiography,
geology, soils conditions, water resources (including wetlands and
floodplain areas), sensitive areas such as historic and archaeologic sites,
existing land use patterns as well as future land use information derived
from local comprehensive plans, zoning ordinances, and subdivision
regulations.
All of this information is inventoried as part of the environmental
assessment process in planning for wastewater treatment facilities. The
information should be compiled in narrative and graphic form for interpre-
tation of those factors that would constrain land development. For all
factors examined, the statutory or regulatory basis for constraining the
use must be stated to remove subjective judgments.
The constraints mapping process should result in a single map that shows
portions of the study area where prohibitive constraints allow no devel-
opment to occur, where restrictive constraints permit limited development,
where qualified constraints reflect policy recommendations, and remaining
areas of vacant unrestricted, developable acreage. This map should next be
overlaid with existing zoning maps to determine the maximum number of
TRD IX-B dwelling units permitted per acre. Planimetric measurement or a grid cell
overlay of the amount of developable land in each of these districts
indicates the total acreage in each category. The amount of land being
scrutinized in a given unit of analysis must be carefully considered. The
larger a facilities planning area, the greater the population that can be
accommodated. In the Seven Rural Lake EIS's, single-tier development was
the predominant settlement pattern and was the basis of delineation for
proposed service areas. The constraints evaluation was thus conducted on
land areas within 300 feet of the lakeshore. In other rural planning
areas, service area boundaries should be closely defined in order to
evaluate the extent of an area's growth potential. This may be
accomplished by consultation with local municipal officials or area
residents.
EIS VI-D Once the number of dwelling units permitted in the area is calculated, the
average number of persons per seasonal and permanent dwelling unit derived
from census or other survey data may be multiplied to determine the total
population carrying capacity. This calculation should provide a basic
upper limit population figure to compare against projections derived from
other demographic sources. This figure will not only aid projection, but
will also aid in understanding area trends. An analysis of the environ-
mental constraints of an area will facilitate a deeper understanding of the
types of impacts that a wastewater management system may generate.
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2. THE INTERRELATIONSHIP BETWEEN SMALL WASTE FLOWS FACILITIES PLANNING AND
LAND USE
TRD XI-A In rural and developing areas, the enforcement of on-site sanitary codes,
beginning anywhere from 1945 to the end of the 1960s, has served as a form
of land use control (Wisconsin Department of Health and Social Services,
1979; Twichell, 1978). These codes have limited residential development in
wetland areas, on soils with a seasonal high water table, including flood-
plain areas, on steeply sloping areas, and in locations with shallow depth
to bedrock because these areas are considered unsuitable for on-site waste-
water treatment. Sanitary codes have thus served as a form of de facto
zoning, resulting in large lot sizes and a settlement pattern based on
suitable soils. The codes have minimized development in some environ-
mentally sensitive areas that would otherwise be unprotected.
Please note that this use of sanitary policy for land use control can have
harmful effects. In some states where repair and upgrading of existing
systems is considered "new construction," codes have been interpreted to
prohibit any upgrading or repair of existing systems. Individual
sanitarians have been unwilling to approve repairs or upgrading, to avoid
any precedent that might allow further lakeshore development. This not
only uses sanitary policy to rule out improvements in sanitation, but
forces some residents to think of sewering as the only method that allows
community growth. Sanitary and land use policy interact closely, but it is
nearly always preferable to consider each openly on its own merits; codes
and standards in sanitation should not be used as a crutch to compensate
for the absence of goals in land use planning.
EIS VI-B The introduction of new forms of wastewater treatment technology that
partially or entirely overcomes unfavorable site conditions, or that takes
advantage of more favorable off-site conditions, may enable developers to
circumvent these controls. These treatment systems could thus result in
significant environmental impacts as a result of the encroachment of
housing development on sensitive environmental resources. Also, this could
permit a development pattern inconsistent with local goals and objectives.
The use of on-site technology such as elevated sand mounds may enable
development to occur in areas with a seasonal high water table or shallow
depth to bedrock. Off-site treatment such as cluster systems can circum-
vent on-site limitations altogether and could thus permit development in
any of these areas. Impacts from the use of these treatment systems
include markedly higher density residential development within existing
development areas, a development pattern inconsistent with local goals and
objectives, loss of open space buffers between existing developments, and
encroachment into environmentally sensitive areas.
EIS III-D To anticipate these impacts, localities should consider conducting land use
planning prior to or concurrent with wastewater treatment facilities plan-
ning. This would ensure that the suitability of the area for development
would be analyzed, that community development goals would be defined, and
that appropriate performance standards would be drafted to mitigate impacts
of both wastewater treatment facilities construction and associated
residential development.
The limited amount of literature available on the land use effects of
on-site systems demonstrates the use of sanitary codes to enforce large lot
sizes. For example, Twichell (1978) points out that local health officials
and sanitarians have often become the permitting officials for new housing
development and that stipulation has been made for housing densities of .5
to 2 dwelling units per acre in order to prevent groundwater pollution.
Generalized dwelling unit per acre zoning in the Seven Rural Lake EIS
project areas requires .5-acre or larger lots in unsewered areas. Often
these lot size requirements have been based on the best professional judge-
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merit of sanitarians. These professionals have experienced the need for
larger lots because of site limitations or odd lot lines and have recom-
mended larger lots based on the need to protect community health and
welfare, not on community development goals.
Alternative on-site technologies may impact lot size requirements.
Elevated sand mounds may require larger lots because of larger system areal
requirements. Grey water/black water separation systems reduce the areal
requirements of the soil absorption system.
However, for public health protection, it is unlikely that well separation
distances will be reduced. Thus, lot size requirements may not change.
Cluster systems featuring centralized collection and off-site treatment
will have the same effect on lot size as large-scale centralized collection
and treatment systems. When the public health risk from well contamination
is avoided, smaller lot sizes are permitted in local zoning codes. For
example, Littlefield Township in the Crooked/Pickerel Lakes, Michigan, area
allows 4.5 dwelling units to the acre with the provision of public water
and sewer. In the Otter Tail Lake, Minnesota, area, provisions for
clustered development in the local zoning ordinance allow for 8 to 9
dwelling units to the acre where central sewer service is provided.
The predominant settlement pattern and housing type with standard septic
tank/soil absorption systems is reported as single-family detached units in
small subdivisions and dispersed low density sprawl patterns (Twichell,
1978). This development pattern has been determined by access to and the
spatial distribution of suitable soil. If on-site technologies continue to
be used, this development pattern may lead to a situation where the future
option to sewer may be precluded because of the great expense of construct-
ing sewers between dispersed houses. Further dependence upon local
sanitary codes may thus severely restrict the amount and distribution of
developable land in lake areas. Such restrictions may run counter to local
growth plans or subdivision plans of large landholders.
EIS VI-B One of the most consistent impact findings in the Seven Rural Lake EIS's
was that, in the absence of local development controls, centralized collec-
tion and treatment systems would induce growth in environmentally sensitive
areas such as floodplains, wetlands, and steeply sloping areas. Alterna-
tive and innovative forms of wastewater treatment may have similar effects,
though to a lesser degree. Historically, sanitary codes have been used as
tools to limit or control growth, and as such have become a form of zoning
(Wisconsin Department of Health and Social Services, 1979, Twichell, 1978).
Some sanitary codes do not permit development of on-site wastewater treat-
ment systems in these marginal areas. However, local municipal officials
in many rural lake areas do not have the staff or the budget to conduct
land use planning and zoning and do not have formally adopted land use
plans. Nor do they have the tools to inventory and analyze their environ-
mental resource base and to formulate performance standards that permit
development but prevent significant impacts.
Planning for wastewater treatment facilities gives local municipalities the
opportunity to contract for the necessary expertise to conduct land use
planning in concurrence with facilities plans. Because the two topics are
so closely linked, anticipation of impacts prior to facilities design and
formulation of an impact mitigation strategy could save considerable time
and expense. An understanding of the environmental resource base, housing
types, lot sizes, and existing densities, in conjunction with a program
that involves land use planning concurrent with facilities planning, would
lead to an environmentally sound wastewater management program.
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E. WATER RESOURCES
TRD II-A Consideration of water resources was consistently one of the weakest ele-
XII-A-G ments in the facilities plans that the Seven Rural Lake EIS's evaluated.
XIII-A-C Documentation of the water quality reasons for proposing new facilities was
generally based on the conventional wisdom that on-site systems should not
be allowed near lake shores. Where nutrient models had been developed
previously by U.S. EPA, low estimates of phosphorus inputs from on-site
systems were played down in the facilities plans. Similarly, predictions
of water quality impacts of alternatives, especially nonsewered alterna-
tives, were not well founded on theory or fact.
EIS I-B-3 Early U.S. EPA facilities planning guidance (U.S. EPA, 1975) and adminis-
tration of Step 1 grants have emphasized the use of available data and have
not provided sufficient guidance for needs documentation. Administration
of the Construction Grants Program is thereby reflected in the weak con-
sideration of water resources in the original Seven Rural Lakes and count-
less other facilities plans. It is one of the stated objectives of this
EIS to encourage more thorough assessment of water quality in rural areas.
This section emphasizes U.S. EPA interests in water resources and provides
suggestions for analysis of water quality needs and impacts.
I. Bacterial Contamination
EIS II-A-2 Pathogen contamination of drinking waters and primary body contact waters
VI-A-1 by septic tank effluents is unacceptable and, where detected, must be
abated. In any case where state standards for untreated drinking water or
primary body contact are violated and the source is demonstrated to be an
on-site system, the system should be upgraded, replaced, or abandoned as
appropriate provided that:
the fecal coliform counts are above background counts,
the source is verified to be wastewater by other indicators such as high
nitrogen concentrations, surfactants or brighteners, and
there is a probable hydrologic connection between the suspected waste-
water source and the point of use.
EIS II-A-2-a The "point of use" may be an existing well, spring, lake shore, stream
bank, potential well sites that comply with state separation distances from
wastewater facilities, or other place where use of the water resource may
be impaired.
EIS II-D-2-b Care must be taken in applying this policy to drinking water wells that are
unprotected against entry of surface water or shallow (0 to 3 feet) perco-
lating water. Sampling of unprotected wells or wells that cannot be in-
spected should be avoided during surveys to avoid compounding the errors
created by false positive results (that is, tests that indicate the
presence of wastewater when the source of the indicator is something else).
If few of the wells in a community are properly protected, the survey
should include analysis of constituents normally found only in domestic
wastewaters, such as surfactants or brighteners.
EIS II-D-l-c It should not be necessary to sample for bacteria in every septic leachate
plume located during a shoreline scan. An average of five or fewer fecal
coliform samples per mile of shoreline taken in leachate plumes will pro-
C.27. vide sufficient data for initial surveys. One or two background samples
per mile, including some center lake samples, should be collected from
locations where there is no development or where no leachate plumes are
C.27. detected. More intensive sampling may be justified later depending on the
findings of the initial survey.
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EIS II-D-2-b If results are confused by high background counts or are otherwise
ambiguous, it may also be necessary to sample groundwater at the point of
plume emergence or on the shoreline between that point and the nearest
drainfield. Shallow groundwater sampling can be complicated by mucky or
silty sediments, steep banks, or man-made structures. However, small
diameter sand points can be fabricated for sampling in sandy or gravelly
soils and sediments where bacterial movement would be expected to be most
severe.
2. Eutrophication
TRD II-D Abandoning septic tank/soil absorption systems along shorelines will seldom
result in significant change in lake trophic status. Shoreline septic
leachate surveys on the 35 lakes in the Seven Rural Lake EIS study areas
and detailed nutrient analysis of 17 individual leachate plumes demon-
strated that the limiting nutrient, phosphorus, is normally released to
lakes in small quantities. The cumulative phosphorus input of shoreline
systems was estimated to be less than 10% of the total phosphorus load for
most of the 35 lakes. Elimination of shoreline systems would not have
noticeably improved the trophic status of any of these lakes.
This is not to say that improving lake trophic status is not a goal of the
Federal Construction Grants Program. However, the nominal improvements
expected have not yet been proven to be worth the expense required for
sewering rural lakes.
TRD XII-F Exceptions no doubt will be found. Lakes with small watersheds, high
densities of on-site systems, or numbers of surface malfunctions that run
off into the lake may be substantially improved by abandoning all on-site
systems. Figure IV-E-1 has been prepared to assist grantees in recognizing
these sensitive lakes. This nomograph relates morphological characteris-
tics of a lake and number of shoreline (within 300 feet) on-site systems to
the phosphorus concentration in the lake from on-site systems. This graph
can be used with a minimum amount of data to make a preliminary determina-
tion on the need for more detailed modeling and field data collection.
C.25. To use Figure IV-E-1 the following data are required:
number of soil absorption fields within 300 feet of the lakeshore,
3
water flow through the lake, Q, in cubic meters per second (m /s), and
2
surface area of the lake in square meters (m ).
These data are then used in the following sequence:
3
Areal w^ater load, q, is calculated by dividing flow, m /S, by surface
area, m , and then multiplying by 31,536 seconds/year.
The lake's phosphorus retention coefficient, R, is estimated from Figure
IV-E-2.
3
Convert Q from m /S to cubic feet per second (cfs) and calculate the
lake's hydromorphological constant, K = (1-R)/Q. Locate K on the scaled
diagonal, K-K', in Figure IV-E-1.
The K line is drawn perpendicular to K-K'through K for your lake.
The intersection of the K line with the vertical line passing through
the number of systems near the lake defines the phosphorus concentration
resulting from on-site systems as read on the vertical axis.
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100
10
a: to
H ui
z \-
LU
ฃ
O
CO
O
I
0.
i.o
0.1
1.0
K =
I-R
R = Retention coefficient
Q =lnflow/0utflow(cfs)
m3/s = 0.0283 cfs
10
100
1,000
NUMBER OF ON-SITE SYSTEMS WITHIN
300 FEET OF LAKE SHORELINE
FIGURE IV-E-1. LAKE PHOSPHORUS CONCENTRATION DUE TO ON-SITE SYSTEMS
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1.0
R = 0.426exp(-0.271 q) + 0.574exp(-0.00949q)
80 120 160
AREAL WATER LOAD, q(m/yr)
200
240
FIGURE IV-E-2.
RELATIONSHIP BETWEEN AREAL WATER LOAD, q,
AND PHOSPHORUS RETENTION, R. (KIRCHNER
AND DILLON, 1975)
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TRD XII-A-C If more detailed modeling is justified, the next level of analysis is based
on available data. It includes estimation of phosphorus inputs from major
sources such as non-point runoff, precipitation, known point sources and
on-site systems. Phosphorus load and lake morphological characteristics
are then related to trophic status using empirical models such as that
proposed by Dillon (1975).
The preliminary model presented here and the more detailed model are based
on a number of assumptions that may not be valid for specific lakes. If
choices between alternatives depend on eutrophication impacts or if assump-
tions are suspected of being inappropriate, field studies may be necessary.
For on-site systems, U.S. EPA's National Eutrophication Survey assumes that
0.25 pounds (0.1 kilograms) per year of total phosphorus enters lakes from
every person served by on-site systems within 300 feet of lakeshores. This
represents 5% to 10% of the phosphorus in raw domestic wastewater on a per
capita basis. Based on the modeling and field studies done for the Seven
Rural Lake EIS's, this number is judged to be a conservatively high but
reasonable average for systems that do not discharge directly or by surface
malfunction to glacially formed lakes. In fact, many systems will not dis-
charge to a lake at all. Other systems will have higher inputs. As a
check on the 0.25 pounds/capita/year assumption, leachate plume samples
EIS II-D-l-c collected from open water and during shallow groundwater sampling for
bacterial analysis may also be analyzed for filterable total phosphorus.
Generally, significant numbers of open water plume samples with phosphorus
concentrations above background or of shallow groundwater samples above 1
mg/1 of phosphorus indicate that above-average phosphorus loads are
entering the lake from on-site systems. Grantees must use their judgment
in deciding whether the total estimated input from on-site systems should
be changed to reflect field data.
TRD XII-B Where available streamflow and nutrient concentration data adequately
describe phosphorus inputs from non-point sources, they should be used in
TRD XII-D developing nutrient budgets. Lacking this information, reasonable esti-
mates can be developed using methods based on the universal soil loss
EIS II-D-l-a equation or National Eutrophication Survey statistical analysis of
tributary data. Long-term sampling and gauging of streams to determine
non-point source nutrient inputs will normally not be eligible for
Construction Grants funds. Exceptions may be made on a case-by-case basis
where reasonable estimates are not otherwise developable and understanding
of non-point sources is critical to facilities planning decisions.
3. Localized Plant Growth
While on-site system effects on the trophic status of an entire lake are
usually minor, localized impacts can be more apparent and of greater public
interest. Localized impacts include nearshore plant growth stimulated by
leachate plumes at their point of emergence and plant growth stimulated by
accumulation of nutrients in embayments or canals. Public interest is
generally based on the proximity of plant growth to houses and on
residents' fears that local growth will become more widespread.
TRD II-D Direct stimulation of aquatic plants, especially the filamentous green
EIS VI-A-2 alage Cladophora, was apparent at plume emergence points studied in detail
during preparation of the Seven Rural Lake EIS's. The areas covered by
these growths were small but growths were very dense. The most pronounced
growths were located on shores underlain by peat deposits. These deposits
appear to acidify and chemically reduce groundwater, thereby mobilizing
phosphorus which stimulates the plant growth. At their worst, the growths
will make swimming unpleasant. Where groundwater is naturally alkaline and
aerobic, none of the growths would interfere with recreational use of the
lakes or lakeshores. Except for unusually severe cases, preventing these
nearshore plant growths in the main body of a lake is not a sufficient
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justification for abandoning on-site systems. Some kinds of on-site up-
grading, such as filter field relocation, gray water/black water separa-
tion, and plume interception, may be useful in reducing these growths.
Embayments and canals surrounded by on-site systems often have much more
plant growth than adjacent lakes. Lack of mixing and concentrated non-
point source loading, as well as septic tank leachate, contribute to
locally accelerated eutrophication. Abandonment of ori-site systems adja-
cent to such sensitive parts of lakes may be justified if non-point source
control measures are implemented prior to or along with the construction of
off-site facilities. These sensitive lake areas are particularly vulner-
able to poor design or construction of on-site systems. Filter field
relocation or reorientation, gray water/black water separation, or plume
interception, as well as more common on-site upgrading, may be helpful.
F. FINANCIAL IMPACTS
1. ASSESSMENT OF MUNICIPAL FISCAL CAPABILITIES
EIS VI-C-2 Communities applying for U.S. EPA Construction Grants funds are required to
demonstrate in their facilities plans that they have the necessary finan-
cial resources to insure the adequate construction, operation, and main-
tenance of the proposed facilities.
Municipal fiscal capabilities are determined by investigating the ability
of a community to pay for and maintain wastewater facilities. The term
"communities" refers to a city, town, county, or special purpose district.
First, a community must acquire funds to meet the local share of the
capital costs attributed to the wastewater facilities. This generally is
accomplished through the use of either general obligation or revenue bonds.
Second, the community must be able to bear the total annual debt service
costs (principal and interest payments on bonds) and operation and main-
tenance costs. Indicators of municipal fiscal capability include property
values, median family income, community growth characteristics, and the
revenues, expenditures, assets, and total outstanding indebtedness of the
local government.
The availability of and terms for bonds depend on supply and demand in the
bond market and on the nature and size of the planned wastewater facilities
project in comparison to the community's fundamental fiscal capabilities.
Supply and demand are influenced by regional and national trends beyond the
control of a particular community. It will be more difficult for a com-
munity to arrange debt financing when funds are in short supply. The
community's fundamental fiscal capabilities will affect its ability to
obtain funds and will affect the interest rates to be paid on these funds.
If the community's fiscal capabilities are marginal, interest charges on
bonds will likely be higher. This will further reduce the overall fiscal
capabilities of the community.
Communities generally depend on two types of bonds to pay the capital costs
of wastewater facilities: general obligation bonds and revenue bonds.
General obligation bonds are backed by the "full faith and credit" of the
community. That is, they are ultimately supported by the property tax base
of the community. Revenues generated by user charges may be used to pay
the debt service on general obligation bonds. However, if the revenues are
not sufficient to meet debt service payments, the community is obligated to
draw upon property taxes to meet payments. In some states, there are
ceilings on general obligation debt, and many states require voter approval
prior to a community's issuing general obligation bonds. Revenue bonds
are usually paid solely through the collection of user charges. Revenue
bonds may carry a higher interest rate than general obligation bonds
because there is a greater risk of payments not being met.
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When evaluating a community's ability to meet bond payments, the financial
community (credit-rating firms, investment bankers, and large institutional
investors) evaluates the following factors (Moak and Hillhouse, 1975):
net direct and overlapping tax-supported debt per capita,
percentage of current property tax delinquency,
percentage of debt service on tax-supported debt to total revenues of
the community's operating budget,
average life of existing tax-supported debt in terms of general
obligation bonds,
the ratio of projected revenues to the total annual debt service, and
the ratio of the depreciated value of the community's revenue producing
facilities to the outstanding (remaining) bonded indebtedness of the
facilities.
Other factors can also indicate municipal fiscal capability. One such
factor is the diversity of income-generating sources in a community.
Another is the community's past experience with bonded indebtedness. It is
more difficult for a community that has never incurred such debts to secure
financing than those communities whose past performance can be judged.
Dependence on one major industry or company may be a liability because of
the possibility of the plant closing or a labor strike. Favorable growth
prospects in terms of system users and income is viewed as a positive
factor. Finally, the degree of public support after the public is informed
of the costs for the undertaking of a wastewater facilities project can
serve as an indicator of users' willingness to pay for the facilities once
they are constructed (Moak and Hillhouse, 1975).
Certain types of special purpose districts face more problems in securing
financing than do cities, towns, and counties. Newly established special
purpose districts that do not have property taxing authority will have dif-
ficulty raising funds to meet front-end costs. These types of districts
also will not be able to issue general obligation bonds and will have to
pay a higher rate of interest on debt. New districts, whether or not they
have taxing authority, will have no record to prove how reliably they
discharge their debts. New districts are, therefore, likely to face higher
interest rates.
Both capital costs and operation and maintenance costs must be considered
in evaluating the community's ability to pay for wastewater facilities.
Wastewater facilities with high capital costs may strain the debt-carrying
capacity of the community and may prevent the community from using bonds to
pay for other needs such as schools and hospitals. High operation and
maintenance costs associated with other alternatives will not strain the
community's debt capacity but may place an excessive burden on lower income
users and reduce their willingness to pay for the facilities.
Communities should retain the services of a bond attorney. Estimates of
the local share of capital costs, operation and maintenance costs, and
administrative costs should be submitted to the bond attorney as early as
possible in the facilities planning process. Bond attorneys can assist
communities in assessing their financial resources and can recommend the
types of financing available to the community.
2. ASSESSMENT OF ECONOMIC IMPACTS FOR RESIDENTS
EIS VI-C-3 Expensive wastewater facilities may have a significant financial impact on
II-F-4 users who will pay the capital and operation and maintenance costs asso-
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elated with the facilities. Average annual homeowner costs measure the
costs that residents will have to pay. These charges are calculated as
discussed in Section II.F.4.
The U.S. EPA has provided a guide for judging whether a project will have
an adverse effect on the finances of users (U.S. EPA, Facilities Planning,
1981, March, 1981 and Construction Grants - 1982, May, 1982).Under this
guidance U.S. EPA considers projects expensive when the average annual user
charges (including debt retirement) are:
1% of median household incomes less than $10,000.
1.5% of median household incomes between $10,000 and $17,000.
1.75% of median household incomes greater than $17,000.
A project having average annual homeowner costs exceeding these income
limits is likely to place a burden on system users and may prevent the
community from meeting debt service obligations. Communities proposing
facilities with higher user charges should satisfy themselves, the
potential users, and state or Federal review authorities that all less
expensive alternatives have been rejected for good cause.
EIS IV-B-4 In any community, some users will pay a higher percentage of their incomes
than the project price guidelines. Estimation of the percentage of users
thus affected by various wastewater alternatives provides another useful
basis of economic comparison. Percentage of users likely to experience
financial burdens is determined by comparing average annual homeowner costs
with the statistical distribution of household income in a community. The
financial burden may cause families to alter their spending patterns sub-
stantially by diverting money from their accustomed expenditures. In the
case of low incomes, the burden may be severe enough to cause households to
be displaced, that is, move out of the wastewater facilities service area.
A "rule of thumb" was used to estimate displacement pressure in the Seven
Rural Lake EIS's. Displacement pressure was considered to be placed on
residents if user charges were equal to or exceeded 5% of a household's
annual income. Financial burden and displacement pressure can be estimated
only on the basis of annual homeowner costs. Owing to data limitations,
valid estimates of impacts on specific user groups ordinarily cannot be
made.
Average annual homeowner costs may vary from the actual user charges
depending on the way in which private costs are to be paid. House sewers,
hook-up fees, front-footage assessment, and flow reduction devices are
private costs to be paid by users. A community may require these costs to
be paid during the first year of the system's operation instead of having
them averaged in with user charges over the life of the project. If
private costs are paid during the first year, then actual first-year user
charges will be higher and future user charges will be lower than the
average annual user charges. Under this scenario, the initial year
financial burden will be much more severe than it will be in following
years. The method by which private costs are paid is not a decision made
by U.S. EPA.
Front footage or benefit-based assessments should be carefully evaluated
for economic effect on households and the community. Seemingly small unit
assessments can result in extremely large total assessments for large
areas, such as farmland within district boundaries.
3. BENEFITS FROM LOCAL PROCUREMENT OF GOODS AND SERVICE
EIS VI-C-5 Wastewater alternatives utilizing small waste flows systems and flows
reduction devices can have a positive impact on a community's economy. The
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construction of centralized systems generally involves the use of contrac-
tors and equipment from outside the local area. Optimum operation
alternatives, however, involve local contractors, labor, and supplies to a
greater extent and keep the funds spent on the project within the com-
munity. For example, equipment for centralized wastewater facilities must
usually be obtained directly from manufacturers and wholesalers outside of
the local area. But flow reduction devices may be available from local
hardware and department stores and septic tank suppliers, installers, and
pumpers are found in most communities. Local laborers may be employed to
construct and operate both centralized and small waste flows alternatives,
but on-site alternatives rely on local laborers to a greater extent and
require their work over a longer period of time. On a community-wide
scale, the use of local goods and services associated with on-site waste-
water alternatives may partially offset any negative economic impacts
resulting from growth restrictions imposed by minimum lot size restrictions
and bans against room additions.
G. PUBLIC PARTICIPATION
TRD XIV-A Planning for wastewater facilities in rural and developing communities
provides opportunities for public participation not available normally in
urbanized settings. In particular, the inspection, evaluation, and
construction of on-site facilities will result in numerous contacts between
individuals in the community and planning personnel. These contacts can
provide a personalized forum for explaining the purpose and methods of the
project. The contacts can also be a way for citizens to provide input to
the planning process.
EIS II-D-l-b&c The primary opportunities for personal contact will be during sanitary
II-D-2-a surveys. The interview with which each on-site sanitary inspection starts
can be partially devoted to discussing the project as a whole. Other
opportunities for discussion will arise during field checking of aerial
photography, septic leachate detector surveys, and other field work.
During these contacts, it would be most helpful if field workers were
well-informed about the project as well as their own task. While the
contacts are an excellent means of gathering and spreading information,
they can also generate and perpetuate misinformation. If field workers are
not well briefed, therefore, they should have knowledgeable project
personnel available to respond to citizen's questions in a timely manner.
Property owners will also want to be involved in selection of the facili-
ties required on their property. Their first opportunity for this will
likely be public hearings on facilities plans. At this time, technologies
selected on a tentative basis should be reviewed with interested owners.
Maps indicating the tentative selections should be posted at the meetings
for this purpose. Facilities planners should be prepared to explain the
basis of selection and to discuss additional steps that will be taken to
confirm or modify the selection.
EIS II-A-4 If the on-site sanitary inspection or other information indicate a need for
on-site construction, the next step will be a detailed site analysis. The
site analysis may require minor excavation and other property disturbances.
Property owners should, therefore, be given reasonable notice prior to the
work so that they may attend. Reasonable care in preserving the property's
appearance at this point and during construction will also help preserve
the owner's cooperation.
EIS III-D Some property owners may object to the facilities specified on the basis of
site analysis. They may have a feasible alternative in mind which
minimizes their cost or disruption to their property. On the other hand
they may want the public to help pay for a larger or more elaborate system
than is necessary. One method for dealing with disputes between property
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owners and facility designers is a sanitary review board. Analogous to a
zoning board, a sanitary review board would include citizens of the
community whose job it would be to weigh owners' concerns against public
concerns about cost, water quality, and public health.
Depending on the role the community takes in operation and maintenance, the
need for effective public participation may not end with Construction
Grants activities. Communities will, no doubt, find cooperative and
individual means for dealing with their own citizens.
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Chapter V
Funding and Administering the Optimum Operation Alternative-
Mitigative Measures
Environmental Protection Agency vWOIols
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CHAPTER V
FUNDING AND ADMINISTERING THE OPTIMUM OPERATION ALTERNATIVE
MITIGATIVE MEASURES
One important short-term impact of the Optimum Operation Alternative,
whether implemented with Federal funding or not, is the way in which it
raises new administrative questions and requires new local or even state
administrative structures to work well. This chapter describes some of the
mitigative steps taken by the Agency, Region V, and other steps available
to the states to overcome this largely psychological hazard by answering
these questionsboth in general and as they affect the Construction Grants
Program.
Only a limited number of optimum operation projects have yet been build,
operating under only a limited range of conditions, thus leaving many
important questions unanswered. Similarly the legal authority and
administrative structure needed for proper project operation may vary
considerably among the several states of the Region or even within those
states. Typical questions of this kind have involved the legal authority
for establishing an on-site wastewater management district, available means
of training, eligibility of particular treatment methods for state or
Federal funding, and many others.
Some of these questions have required U.S. EPA clarification in Regional or
even Agency guidance. Several states and many municipalities have
requested advice as to how to respond to questions of this kind, even apart
from the Construction Grants Program. This chapter represents the first
time some of the most recent clarification and guidance of this type has
been brought together in one place. It also offers an update of some
questions still being discussed.
A. FEDERAL CONCERNS
The 1977 amendments to the Clean Water Act made many kinds of treatment
systems eligible for Federal funding that had previously been the sole
responsibility of their owners. This of course raised many questions,
especially about the eligibility of some on-site treatment systems under
various special circumstances. Many of these were resolved in the
subsequent Program Requirements Memoranda (PRM's) and more recently in
Facilities Planning - 1981 and Construction Grants - 1982.
Legend for Cross-References in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change in
the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
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On some questions, however, individual states differed as to the precise
meaning of the PRM's, requiring regional guidance, or even clarification by
Agency headquarters. The Regional Guidance on Needs Documentation was one
example of this, as was the July 16, 1980, memorandum of the Facilities
Requirements Division on use of local ordinances to establish access for
on-site maintenance.
1. ELIGIBILITY ISSUES
a. Seasonal Properties
Publicly owned collection and treatment facilities serving seasonally
occupied dwellings were eligible for Federal funding long before the 1977
amendments to the Clean Water Act. The text of the 1977 amendments and the
associated regulations (40 CFR 35.918(a)(2) and 35.2005(b)(18) specifically
excluded privately owned "individual systems" serving seasonal properties
from the definition of an individual system. Although there are good
arguments that can be made against any Federal subsidy to seasonally
operated treatment systems, this would have resulted in a confusing
situation with only the (usually) less cost-effective alternatives being
fundable.
Therefore, in order to be eligible for Construction Grants funding of
upgrading or replacement, systems serving seasonally used properties must
be publicly owned. For purposes of making grant determinations, seasonally
used systems will be considered to be publicly owned if (1) the applicant
can provide assurance of access to the systems at all reasonable times for
such purposes as inspection, monitoring, building, operation, rehabilita-
tion and replacement, and (2) these activities will beprovided by or under
the supervision of a public management agency. Local or municipal ordi-
nances granting access and control would satisfy these requirements for
EIS V-A-3-a publicownership (see Section V-A-3-a).
Thus for seasonally occupied residences, access and control, rather than
simple patterns of use, are the determinants of eligibility. Of course
along with access, actual need and cost-effectiveness of any alternative
must be demonstrated. Together they allow selection of the most cost-
effective and environmentally sound alternative.
2. INTERAGENCY COORDINATION
a. Incorporation of Property Value Changes in Cost-Effectiveness Analysis
Property values can be affected by the adequacy of the wastewater facili-
ties serving the property. The value-added concept is the amount of value
added to a property as a result of availability of utilities such as roads,
water, electricity, and wastewater disposal. The availability of these
utilities usually makes a property more valuable. Centralized facilities
and public on-site wastewater districts can add to the value of property by
minimizing failures and preventing potential public health hazards and
nuisances. The U.S. Department of Housing and Urban Development (HUD) uses
the value-added concept when reviewing a developer's or community's
application for HUD mortgage insurance. HUD generally requires that public
facilities be provided if the costs do not substantially exceed the value
added to the property by the facilities. HUD appraisers determine the
definition of the phrase "substantially exceed" based on whether or not the
cost of public facilities would cause the project to be noncompetitive with
surrounding housing costs. Public facilities generally are considered to
mean centralized facilities. However, a strong case can be made for
including publicly managed on-site systems in the definition of public
facilities.
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It is difficult to assess the value added to property by having public
management of on-site systems. Because the approach is so new and data are
incomplete, it is impossible to make valid statements on its effects on
property values. More data are available for assessing the value added to
property values by centralized facilities. However, in comparing
centralized and small waste flows facilities, a cost-benefit analysis
should not be used that includes the value added to property by centralized
facilities and neglects the value added by public management of on-site
systems.
Although the net impact would be positive, two factors may minimize the
amount of property value added by public management of on-site systems.
The first factor is the stigma attached to septic tanks by many persons who
may place more value on property served by centralized facilities, regard-
less of performance. The second factor relates to the degree to which flow
reduction measures that affect lifestyle are required. Water restrictions
such as a ban on room additions, shorter showers, etc., do limit the way
that property can be used. Property with these restrictions is less
valuable than property where such restrictions have been circumvented
through the provision of centralized facilities.
As a policy, current cost-effectiveness analysis guidelines do not allow
inclusion of property value changes. A theoretical case can be made for
including such values as monetized social impacts. However, since there
are no data or experience with which to estimate the property value changes
associated with the optimum operation alternative, incorporation of values
added is not practical.
b. Application of the Davis-Bacon Act to Small-scale Construction Projects
TRD XVI-E The Davis-Bacon Act is a Federal law that regulates the wages paid to
laborers and mechanics under Federally funded construction contracts. The
act requires contractors and subcontractors to pay at least the prevailing
wages paid corresponding classes of laborers and mechanics working on
projects of similar character in the area where the Federally funded con-
struction is to be performed. All U.S. EPA funded wastewater facilities
construction projects are subject to the Davis-Bacon Act.
The purpose of the act is to protect the stability of local area wage
rates. "Local area" is defined by the act as the city, town, village, or
other civil subdivision of the state in which the work is to be performed.
Surveys of prevailing wages in various trades and various types of projects
throughout the nation are conducted by the U.S. Department of Labor (DOL).
The Davis-Bacon Act can cause problems for communities trying to implement
an optimum operation alternative. When there is no project of a similar
character in a rural area, the DOL bases its wage determination on
"similar" projects in the nearest urban areas. "Similar" projects in terms
of the optimum operation alternative can include large-scale urban waste-
water treatment facilities that currently are classified by DOL as "heavy
construction projects."
Most of the companies that would be contracted to carry out the optimum
operation alternative are small firms that have had little or no experience
with Federal regulations promulgated under the Davis-Bacon Act. Firms with
few employees may have to pay the same worker at different rates for
different types of jobs performed. This situation can create worker
dissatisfaction and bookkeeping confusion. Contractors are required to
post specified wage rates at the construction site and to pay at least once
a week the full amount due their workers according to the wage rates set by
the Secretary of Labor. This requirement can add several hours of book-
keeping time each week for a small contractor. Small contracting firms
with little experience in dealing with U.S. EPA projects may be discouraged
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from bidding on U.S. EPA funded projects as a result of the Davis-Bacon Act
requirements. This would reduce competition and possibly increase the cost
of projects.
U.S. EPA can take steps to lessen the impacts of the Davis-Bacon Act on
on-site facilities contractors. The act enables Federal agencies funding
construction activities to request DDL to establish a project wage determi-
nation based on individual projects until enough data have been collected
by DOL to establish general wage guidelines for these types of projects.
DDL should be requested to change the classification of small waste flows
projects from heavy construction to commercial or residential. Finally,
U.S. EPA and state Construction Grants agencies can take the initiative to
educate smaller businesses on the requirements of the Davis-Bacon Act.
3. MISCELLANEOUS
a. Use of Local Ordinances for Access
40 CFR 35.2110 40 CFR 35.2110 requires access to individual systems in order for them to
be eligibile for Federal funding. Within a very large on-site wastewater
management district with many residents, or within a very small one with
particularly limited administrative capabilities, acquisition of individual
easements with a detailed legal description may be complex, costly and
imprecise, particularly in those states not surveyed according to the
Township and Range method, or where a "meets and bounds" legal description
must be used.
Because of these concerns, U.S. EPA's Facilities Requirements Division, on
July 16, 1980, in a memorandum to Mr. Charles Sutfin, U.S. EPA Region V
Water Division Director, stated that a local or municipal ordinance
granting access and control would also be considered equivalent to public
ownership. This, along with the "Fill in the blanks" easement form
described below, should make organization and management of on-site waste-
water district considerably easier. Access by ordinance is also particu-
larly useful when there is no Federal funding at all.
b. Pilot Studies
The reliability and long-term performance of many alternative wastewater
processes are unknown. To develop performance data and determine the local
feasibility of a particular wastewater technology, the use of pilot studies
CWA 212 (1) is desirable. The 1981 Amendments to the Clean Water Act make field test-
204 (d)(l) ing of alternative and innovative technologies eligible for Construction
Grant funding. The Act also requires that the engineer responsible for a
project direct its operation and train operating personnel. These provi-
sions cover both the construction and operational supervision needed for
40 CFR 35.2118 the pilot studies. In addition, the new Construction Grant regulations
40 CFR 35.2262 permit the Regional Administrators to approve field testing of alternative
and innovative technologies as preliminary Step 3 work. That is, field
testing may be started before actual award of a grant for other planned
facilities. The requirements are that the approval could avoid significant
cost increases due to delay and that the environmental review for the
project as a whole be completed.
c. Performance of Field Work (New Section)
CWA 201(1)(1) The Municipal Wastewater Treatment Construction Grants Amendments of 1981,
CWA 201(1)(2) Public Law 97-117, prohibits grant funding of facilities planning and
design (Step 1 and 2). Instead, allowances based on a percentage of total
project cost will be used to help defray the costs of planning and design.
"The allowance is not intended to reimburse the grantee for costs actually
incurred for facilities planning or design. Rather, the allowance is
intended to assist in defraying these costs. Under this procedure, ques-
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tions of equity (i.e., reimbursement on a dollar-for-dollar basis) will
not be appropriate." Proposals for allowance percentages to apply for
planning and design range from 5.6 percent for the largest projects up to
13 percent for building costs of $100,000. (Proposed rules for 40 CFR Part
35, Subpart I, Appendix B published in the May 12, 1982 Federal Register.)
The law and regulations have significant implications for analysis and
implementation of the optimum operation approach by small communities.
Protection of water quality and public health with this approach absolutely
depends on thorough field work to locate and analyze problems with
individual systems. Based on assumptions and cost estimates for the
EIS II-F-1 optimum operation alternative prepared in support of this EIS (see Section
II-F-1), the cost of detailed site analysis ranges from 23 to 183 percent
of building cost. And this does not include review of available data or
community-wide surveys that are considered to be needs documentation.
Nevertheless the total construction plus site analysis costs averaged only
$475 to $3,900 per house of which the detailed site analysis was $307 to
$720.
The incentive to do thorough field work lies in the cost avoidance
resulting from not building unnecessary facilities. However, Region V's
concern is that, if funds for field work come only from Step 1 and 2
allowances, communities may allocate insufficient money for other
necessary, but less rewarding, planning and design tasks. The result,
predictably, will be facilities plans and other parts of grant applications
that will need to be returned to applicants.
This EIS makes several recommendations which are intended to help
applicants keep costs of field work to a necessary minimum. Sequencing of
field work with decision making steps, a decision flow diagram for
selecting appropriate technologies, and opportunities for self-help are
discussed in Chapter II.
4. REGIONAL CONCERNS
a. Conventional Water Use
State 201 agencies, notably in Minnesota, have stressed the need for funded
upgraded and replacement facilities to be designed for conventional design
flows as used in designing new facilities. The supporting argument for
this position is that substandard facilities will fail in the future.
EIS II-A-5 Where standard on-site treatment facilities can be installed, this is obvi-
ously the preferred course of action. However, on many existing developed
lots, full-sized facilities may not be feasible. Staying on-site may
require flow reduction devices; limitations on building additions; pro-
hibitions on garbage grinders, dishwashers, or clothes washers; subcode
sized drainfields and/or advanced on-site treatment (mounds, sand filters,
dosing, etc.). Where these measures have a reasonable chance of remedying
failures, they should be implemented and be eligible for funding unless
off-site facilities can be shown to be cost-effective.
EIS VI-E-2 The use of flow reduction devices and prohibitions on water-using
appliances may sometimes affect homeowner convenience. However, this
policy places higher priorities on water quality improvements and cost-
effectiveness. It is based on prior findings that subcode systems can
often perform adequately and that avoiding off-site facilities is the key
to maximizing cost-effectiveness in unsewered areas. The policy relies on
careful site analysis to assess both the causes of malfunction and the
operability of the subcode systems.
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b. Potential Failures
EIS II-D-2-a Contrasting philosophies have been encountered in determining eligibility
for the upgrading and replacement of on-site systems. Several state and
local officials currently favor an approach that correlates eligibility
with compliance with current design codes. This philosophy holds that,
where existing systems do not substantially meet key design criteria, they
should be abandoned and replaced with funded on- or off-site facilities
that meet the codes. The assumption behind this approach is that noncon-
forming systems will fail.
On the other hand, some Federal and state officials interpret Construction
Grants regulations as prohibiting the funding of any construction that does
not remedy an on-going water quality or public health problem. In recogni-
tion of the potential for future failures, this approach would include or
recommend the establishment by the grantee of a reserve fund for any future
failures.
The Seven Rural Lake EIS's, Region V's Guidance for needs documentation,
and this EIS take an intermediate approach to eligibility. Existing
systems identified as potential failures because of obvious underdesign and
other factors would be eligible for funding provided these systems are
similar to systems that have already failed. Similarity is measured by
system design, usage, soil characteristics, site limitations, site
drainage, and groundwater hydrology, as appropriate.
c. Simplified Easement Forms
Access to individual systems required by 40 CFR 35.2110 does not necessi-
tate a new property line survey of every individual dwelling, especially in
states that use the township and range survey method. In such states the
exact legal description of the property may commonly be obtained from
county tax rolls, allowing use of a simple "fill in the blanks" easement
form. Figure V-A-1 shows a sample easement form of this type developed by
residents of Benzie County, Michigan.
d. Innovative and Alternative Off-site Facilities
In many communities that adopt the optimum operation approach, some of the
developed lots will never successfully support on-site systems. Innovative
and alternative off-site facilities such as holding tanks, cluster systems,
or other small-scale treatment methods will be eligible for Federal funding
if:
1. a public health or water resource contamination problem is documented
that cannot be abated by any combination of on-site conventional,
innovative, sub-code, flow reduction or waste restriction methods, or
2. the life cycle costs of off-site treatment and disposal for an
individual building or group of buildings is less than the costs of
appropriate on-site technologies for the same buildings.
EIS II-F-3 Innovative and alternative off-site facilities may be included in optimum
operation alternatives for purposes of cost-effectiveness analysis and
environmental assessment as indicated by partial sanitary surveys and
representative sampling. Selection of an off-site facility as an alterna-
tive depends, as always, on its cost-effectiveness and environmental
soundness. However, unless needs documentation conclusively demonstrates
that on-site methods will not be operable, final eligibility determinations
for proposed off-site facilities will be contingent on completion of on-
site sanitary inspections, detailed site analysis (where indicated), and
microscale cost-effectiveness analysis.
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Figure V-A-1
SEWER EASEMENT AND RIGHT OF WAY
(I)(WE)
of
respectively, in consideration of the prospective benefits to be derived from
a new or upgraded sewer and/or improved water quality in Crystal Lake, do
hereby convey and release to the an ease-
ment and right of way for unlimited access to the present or future on-site
sewer system or other systems of sewage disposal, at all reasonable times for
such purposes as inspection, monitoring, construction, maintenance, operation,
rehabilitation, and replacement, over, upon and across lands owned by (me)(us)
and situated in the Township of , County of Benzie, State
of Michigan, and more particularly described as follows:
In witness, whereof, I have hereto set my hand this
day of , 19 .
WITNESSES:
STATE OF ) ss.
COUNTY OF )
Subscribed and sworn to before me this day of , 19
Notary Public
My commission expires:
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B. STATE CONCERNS
1. ADDRESSING REGULATORY AND INSTITUTIONAL REQUIREMENTS OF THE OPTIMUM
OPERATION ALTERNATIVE
The implementation of the optimum operation alternative may require changes
in existing state regulatory and institutional requirements. Specific
topics that will need to be addressed include regulatory requirements per-
taining to existing systems; the authority to manage private wastewater
systems; the authority of a community to acquire access to privately owned
wastewater systems; and policies relating to the granting of variances for
individual systems. These topics are discussed in this section.
TRD XV-A The right to continue to utilize on-site systems constructed prior to
adoption of current design standards is an issue that has not been directly
addressed in most states. Current regulations appear, by omission of
statements to the contrary, to allow the continued use of these systems
until such time that the systems fail. Once a system has failed, it is
normally required to be upgraded to code conformance if possible.
Minnesota statutes, however, require automatic upgrading for some types of
nonconforming systems, failing or not. If local communities are to have
the option of considering use of the optimum operation alternative, state
policies toward the continued use of existing systems may have to be recon-
sidered. Rights to the continued use of systems should be specified, as
well as when upgrading will be required. Requirements for the upgrading of
existing systems may also be made more flexible and site-specific to allow
local governments discretion in requiring upgrading based on local condi-
tions rather than a set of uniform standards.
Illinois is the only Region V state that has granted explicit authority to
local governments to manage on-site systems. Small waste flows management
agencies can be established in the other Region V states under implicit
authority granted to certain public bodies to manage centralized wastewater
facilities. The interpretation of implied authority will vary from state
to state and may be challenged in courts on the grounds that the authority
to run publicly owned facilities does not imply authority to manage
privately owned on-site facilities. Thus, while small waste flows manage-
ment programs can be operated on the basis of implied authority, there is a
need in each state to test these implied authorities judicially or to grant
explicit authority to certain public agencies.
EIS III-F Inherent in any community management program for privately owned individual
V-A-4-c systems is a means for the management agency to obtain access to these
TRD VIII-A systems. Methods of obtaining access have already been discussed in
Sections III-F and V-A-4-c. Regulatory and institutional powers within
each state should be reviewed and amended as appropriate to provide manage-
ment agencies with the necessary access capabilities.
EIS III-E State control over local variance decisions may be desirable in recognition
of potential problems arising from improper administration of variance
TRD VII-A requirements and the lack of uniformity in granting variances throughout
the state. However, flexibility in variance requirements would be
desirable to allow local governments to adapt variance requirements to
local conditions.
Innovative technologies used to solve existing problems are characterized
by a less certain level of risk for system failure than risks with
conventional technologies. However, assumption of somewhat higher risk may
be justifiable by economic savings associated with the use of these
technologies. State policies toward the use of innovative technologies
should reflect the trade-off between risks and economic savings and ensure
that the systems do not prove to be future economic liabilities.
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2. STATE PLANNING ACTIVITIES FOR SMALL COMMUNITIES
EIS III-K Small communities involved in the management of small waste flows systems
can be assisted by various state planning activities. Many of these acti-
TRD XV-C vities normally could not be carried out by the local community because of
lack of expertise or authority. U.S. EPA policies toward the improvement
of wastewater facilities are founded on the goals of improving water
quality and protecting public health. State and local communities may,
however, have additional goals associated with the improvement of waste-
water facilities, such as the promotion of growth, housing development, and
economic recovery. These goals may in fact be considered higher priority
in many rural areas. In this context, states could assist local communi-
ties in defining local goals and wastewater needs. Where these goals may
be inconsistent with U.S. EPA goals for Construction Grants funding, the
state may assist the local community in finding alternative funding sources
or in a reassessment of goals.
Illinois provides a prime example of the type of planning assistance for
wastewater facilities that a state may provide for rural communities. In
recognition of the lack of facilities planning for small communities, the
Illinois EPA and designated 208 agencies prepared Municipal Needs Analyses
(MNA) for communities with populations over 200. These MNA's were less
detailed than typical facilities plans, but they did define and project
communities' wastewater needs and provide recommendations to meet these
needs. In a number of communities, these recommendations consisted of the
continued use and upgrading of on-site systems.
EIS IV-A-1&2 State and regional planning assistance may also be utilized in defining
rural areas where wastewater improvements are needed. For rural lake
communities, use of Section 314 lake inventories will identify lakes with
major pollution problems and identify corrective measures to control pollu-
tion sources. Such corrective measures may include the upgrading of exist-
ing wastewater facilities, including on-site systems. In non-lake areas,
regional and county assistance may also be utilized in delineating rural
areas with wastewater needs. Chapter IV, Section A-l, has discussed
approaches for defining planning area boundaries.
TRD XV-D State Construction Grants Programs should consider the use of separate
priority lists for funding small community projects. None of the states in
Region V currently uses a separate priority list. Small communities with
substantial unsewered development have wastewater problems as severe as
problems in larger communities with centralized facilities. However, the
conventional measures of severity such as population and volume of pol-
lutants are not appropriate measures for problems in unsewered areas.
EIS III-A-2 Comparisons among predominantly unsewered areas would more equitably be
based on the factors that define a community's obligation to take action:
development density, failure rates, and sensitivity of water resources.
Establishment of a small community or unsewered areas priority list with
separate funding would avoid unrealistic comparisons of need between urban
and rural communities.
3. STATE GRANT AND TECHNICAL ASSISTANCE
Small communities encounter many problems in participating in the Con-
struction Grants program. Lack of an effective administrative and manage-
ment structure to deal with the Construction Grants process and the lack of
personnel with expertise in the Construction Grants process or wastewater
technology are major reasons for these problems. The U.S. EPA (1980d) has
identified the major problems small communities have with the Construction
Grants process as:
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difficulty in meeting the program's administrative requirements,
problems with managing consulting engineers,
problems in dealing with U.S. EPA, the state, and the Corps of
Engineers,
problems in employing the environmental assessment process,
difficulty in meeting the accounting requirements for post-grant audits,
and
difficulty in structuring local share of financing and determining
affordability.
To overcome some of these problems faced by local communities, a state or
regional 208 or similar regional agency could provide management assistance
to the local communities. Such management assistance could range from
providing technical assistance to assuming full management responsibility
for the community's Construction Grant. States that have been delegated
responsibility for administering the Construction Grants Program have been
authorized to use Federal funds to manage waste treatment construction
grants for small communities. This authority is given by Section 205(g) of
the Clean Water Act.
U.S. EPA has developed four models describing potential "third party"
assistance to local communities in managing Construction Grants and waste-
water facilities (EPA, 1980d). Two of these models are based on existing
state programs in New Hampshire and Maryland. The other two are the
circuit rider model and the contractor assistance model. These four models
are discussed below.
a. New Hampshire Model
In this model, the state agency would develop a staff to negotiate con-
tracts for all or some specified number of small communities within the
state. The state staff would develop a "prequalified" list of consultants
to be submitted to a community for selection. The community would pick
three preferred firms with which the state staff would negotiate. State
staff involvement would be the greatest during Step 1; the staff would
monitor the consultant's and community's progress during Steps 2 and 3, but
not as actively.
This type of assistance program would relieve local communities from the
responsibility of negotiating and managing contracts with consulting
engineers and would provide a centralized staff for all small community
wastewater grant assistance, thus greatly streamlining the grants process.
Local communities may resent the loss of their local authority, however,
and local consulting engineers may resent not being able to work directly
with the communities. This type of program would tend to work best in
smaller states where close contact between the communities and the state
staff can be maintained.
b. Maryland Model
This management model involves the establishment of a non-profit corpora-
tion to provide assistance to small communities. The corporation could
provide a wide variety of services to small communities dependent on the
contractual requirements with an individual community. Services may
include the review of facility plans; the planning, design, construction,
and operation of treatment facilities; and acting as the community's agent
in application for grants and negotiating contracts.
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The corporation may be more responsive to community needs and concerns than
a state staff since it relies on the communities for its existence. The
corporation could also be more flexible than state agencies in providing
and tailoring assistance to a local community's needs. The corporation
would have to have a close working relationship with the state regulatory
administration to be effective. State subsidy of the corporation may also
be necessary to keep down local costs.
c. Circuit Rider Model
The state regulatory agency could also establish through direct hiring or
contract a series of "circuit riders" who would provide technical
assistance consisting of planning, design and construction, financial
planning, or actual operation and maintenance of the treatment facilities.
The circuit rider could provide quick and efficient service and provide a
liaison between the local communities and the state. This approach is
well-suited to larger states where several circuit riders may be required
to maintain close community contact. Problems may arise from the lack of
uniformity of work performance among circuit riders and their personal
ability to deal with communities. This option would be costly in a state
with a large area and small population, but might be practical for smaller
areas such as those served by a 208 or regional planning agency.
d. Contractor Assistance Model
Under this option, the state would contract with a private firm to provide
special assistance to local communities. Contractors would then conduct
site visits to small communities, assess community needs, and provide
appropriate assistance.
This option would allow the state to provide contractor assistance to those
areas of greatest need. The state would only pay for assistance that is
actually utilized by the small communities. The cost for the assistance
could be shared by the local community. State management of contractor's
assistance would be required. The ability of the contractor to work
effectively with the local community, state personnel, and a community's
facilities planning consultant will be a key to the success of this
approach.
4. STATE STAFFING
Present manpower involved in the regulation of on-site systems in Region V
is difficult to quantify. Sanitarians are normally the personnel involved
with the regulation of these systems. Identification of the number of
sanitarians in each state could therefore provide a measurement of manpower
levels. However, there are problems with this method. First, not all
sanitarians will be involved in on-site regulation because of the broad
range of typical sanitarian duties. Illinois is the only state in Region V
requiring sanitarians to be registered, allowing for an accurate assessment
of total manpower. Other Region V states have voluntary registration
programs that make assessment of total manpower difficult. Furthermore,
Wisconsin does not have a sanitarian classification as such involved in the
regulation of on-site systems. Wisconsin requires on-site inspectors to be
certified as plumbing inspectors, system installers to be licensed as
master plumbers, and soil evaluators to be certified as soil testers.
Estimates of total existing manpower within the limitations discussed are
given in Table V-B-1.
TRD X-E There are approximately 3.3. million on-site systems in Region V. Existing
state management of on-site systems is primarily limited to permitting new
systems and repairs, installation inspections, and responding to com-
plaints. In some areas of Region V, even these minimum regulatory services
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TABLE V-B-1. ESTIMATES OF PERSONNEL INVOLVED IN REGULATION OF ON-SITE SYSTEMS
Illinois
Indiana
Michigan
Minnesota
Ohio
Wisconsin
1,189
680
550
329
775
3,111
Registered sanitarians
Voluntarily registered and unregistered sanitarians
Voluntarily registered and unregistered sanitarians
Voluntarily registered sanitarians
Voluntarily registered sanitarians
Certified plumbing inspectors and 3,000 certified
soil testers
are not provided. Based on assumptions developed and presented in the
Technical Reference Document, Chapter X-E., perhaps 1.1 million systems in
the region may eventually be publicly managed through their entire life-
cycle. To the extent that greater state and local roles in the regulation
and management of on-site systems are assumed, additional trained manpower
will be required.
TRD VI-D Optimum operation alternatives will require manpower for initial imple-
mentation, continuing operation and maintenance. During the implementation
EIS III-K phase, personnel will be required for planning (including needs documenta-
tion), design, and construction. These personnel may include facilities
planners specialized in small waste flows applications, system designers,
inspectors, soil scientists, laborers, equipment operators, environmental
and financial planners, small waste flows contractors, and water resource
scientists. Once the alternative is implemented, personnel such as
administrators, clerks, inspectors, wastewater system operators, and
laborers will be required to insure proper operation and maintenance.
Definitive estimates on the types and quantity of personnel required are
impractical because of the wide range of variables affecting both manpower
requirements and the number of potential small waste flows projects.
C. TRAINING
TRD VI-F&G
An effective small waste flows management program relies on competent per-
sonnel to perform a myriad of tasks related to small waste flows manage-
ment. This required competency is gained through experience and training.
Because of its widespread use and acceptance, a wealth of training and
experience has been gained in conventional centralized wastewater tech-
nology. There is a definite recognized need for improved training of
multidisciplinary personnel to work in small waste flows management.
Training programs of many types are offered throughout Region V by a
variety of sponsors. Training programs in most states have some excellent
aspects, but no one state appears to have developed a comprehensive
training program for all levels of personnel involved in small waste flows
management.
Better training programs in small waste flows technology are required at
many levels. At the university level, more classroom training should be
provided in the use of small waste flows wastewater technology. Tradi-
tionally, university training in wastewater treatment has focused on
conventional technology and on large-scale treatment works. Little
emphasis has been placed on on-site and other alternative wastewater
treatment technology. Even schools with degree programs in environmental
health science, which are often considered as sanitarian training programs,
do not normally extensively cover the topic of small waste flows techno-
logy. Few of these programs incorporate the "hands-on" training necessary
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to train an individual fully, and only one program, at Ferris State College
in Michigan, was identified as having an entire course devoted to the
subject. Classroom training is available at many colleges and universities
in subjects directly associated with small waste flows technology, such as
soil science, hydrology, geology, and related subjects.
Training programs for field personnel such as system designers, installers,
and soil testers are continually needed to keep personnel informed of new
developments. These programs may be offered by universities and state,
regional, and local levels of government, as well as by trade associations.
The Home Sewage Treatment Workshops sponsored by the University of
Minnesota Extension and the Minnesota Pollution Control Agency, as well as
various workshops offered by the University of Wisconsin-Extension, are
excellent examples of these programs. Another example of such a program is
the two day course on alternative system design offered by U.S. EPA through
its Small Wastewater Treatment Clearinghouse.
Universities can also develop research and demonstration projects in
aspects of small waste flows management. Through these projects, universi-
ties can develop and disseminate valuable information concerning new
technology and other matters related to the field. Two universities in
Region V, the University of Wisconsin and Purdue University, are performing
research and developing demonstration projects that further the current
knowledge of small waste flows technology. These programs should be
supported, encouraged, and fostered at other universities.
Improvement is also necessary at the on-the-job or preservice training
level for regulatory personnel involved in small waste flows management.
Most states provide no formal training for new employees. Training that is
provided depends upon the place of employment. In some instances, this
means that new employees will receive inadequate, incomplete, and/or
incompetent training. The State of Ohio has an excellent voluntary
preservice training program that includes 4 weeks of classroom and 12 weeks
of on-the-job training. The Ohio program is a model for this type of
training program. Indiana also provides a 1-week orientation session that
includes about 8 hours of training in small waste flows technology.
A final level of training that is often neglected involves homeowner educa-
tion. Homeowners need to be instructed in the proper maintenance pro-
cedures for their individual on-site systems. As the need for homeowner
maintenance increases with the use of more technologically complex systems,
the level of homeowner education should also be increased. Examples of
homeowner education programs include educational brochures describing
on-site systems that have been published by the University of Wisconsin and
the University of Minnesota extension services. The University of
Wisconsin also offers a dial-a-cassette recording for receiving information
over the telephone related to on-site systems. Homeowner education can
also be provided locally by public meetings, workshops, and dissemination
of information related to on-site systems.
D. DOES ANYONE WANT THE SMALL WASTE FLOWS APPROACH?
There are many reasons why small communities seek Construction Grants
TRD XVI-A funding for improvement of local wastewater facilities. U.S. EPA, however,
is limited to granting such funds to communities that demonstrate that they
will use the funds to limit the discharge of pollutants and to improve
local water quality. Silverman (1980) has identified four common community
concerns associated with improved wastewater facilities, each of which may
be an important impetus for a community to improve their wastewater
facilities and to seek Construction Grant funds:
avoiding prosecution,
malfunctioning septic tanks,
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residential and commercial growth, and
industrial growth.
How these community concerns are addressed by the use of the optimum
operation alternative will determine in part the desirability of this
approach. These issues are discussed below.
1. AVOIDING PROSECUTION
A basic reason for communities to improve their wastewater facilities is to
avoid being prosecuted for noncompliance with state and Federal regulations
governing effluent discharges and water quality. Since most communities
are not currently liable for individual systems, this concern would be
absent in communities not served by a centralized wastewater system.
Therefore, communities with small waste flows systems likely have other
reasons for improving wastewater facilities.
2. MALFUNCTIONING SEPTIC SYSTEMS
A major reason why communities seek wastewater improvements is to correct
problems, real and perceived, associated with the use of on-site systems.
As has been discussed in this EIS, properly operated and maintained on-site
systems, and even neglected systems, have been found to be effective means
of wastewater treatment. Traditionally, however, on-site systems have been
looked upon as inferior in comparison to conventional wastewater faci-
lities. This practice has led to the sewering of areas where on-site
systems could have continued to operate satisfactorily. The use of the
optimum operation alternative will address this concern by insuring that
on-site systems are properly operated and maintained and that problems
associated with their use, if they do occur, will be quickly recognized and
corrected. While this may remedy the actual causes for community concern
with on-site system use, public education may also be required to change
traditional attitudes toward these systems.
3. RESIDENTIAL AND COMMERCIAL DEVELOPMENT
Many communities wish to improve or expand wastewater facilities, parti-
cularly collector sewer systems, to promote residential and commercial
development in suburban and rural areas. When such sewers are paid for in
large part by Federal money, this development broadens the community's tax
base and improves the community's economic status through relatively small
local investments. While the Clean Water Act was clearly not enacted to
promote rural development, it must be recognized that sewers funded under
the act have been precursors of rural development.
Where communities wish to use sewers to promote such growth, the use of the
optimum operation alternative would not be desirable. However, the use of
the optimum operation alternative along with liberal state and local
policies for the use of alternative systems may allow the development of
land previously considered undevelopable. Where this level of development
still does not satisfy a community's goals for residential and commercial
development, alternative sources of funding for sewers may be sought.
4. INDUSTRIAL GROWTH
Associated with the use of sewers to promote residential and commercial
development is their use to attract new industry and to service existing
ones. Clearly, the use of the optimum operation alternative lends itself
only to small industrial wastewater flows. Where industries are existing
or desired within a community, they may have to provide their own treatment
capabilities, or other sources of funding to improve wastewater facilities
may be required.
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Chapter VI
Environmental and Social Consequences Of The Proposed Action
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CHAPTER VI
ENVIRONMENTAL AND SOCIAL CONSEQUENCES OF THE PROPOSED ACTION
Widespread use of the design and operation method described in Chapters II
and III would produce its own impact. Like all other alternatives, it
entails its own particular mix of trade-offs. Like on-site treatment in
general, it is heavily dependent on intelligent installation and manage-
ment. If this is available, however, it can provide water quality improve-
ments closely comparable to those of any other alternative at a cost far
below that of any alternative other than No Action. For literally hundreds
of rural lake projects, the optimum operation alternative may offer the
greatest degree of water quality improvement for an affordable level of
community expenditure.
The planning, design and management methods of Chapters II and III have an
even broader application. They can be used to isolate portions of largely
off-site projects where optimum operation may be feasible, and to arrive at
a just determination of the action needed, of whatever kind.
A. WATER QUALITY IMPACTS
1. GROUNDWATER
a. Problems and Solutions
Any alternative involving improved operation of on-site treatment systems
will result in continued discharges to groundwater. Septic tanks will
probably be the most common source of these. Implementation of the
proposed alternative will allow identification and inventory of local
sources and impacts of these discharges. Continued reliance on upgraded
surface and subsurface land disposal will reduce, but not eliminate,
impacts of existing discharges to groundwater.
EIS II-A-2-a Many existing facilities such as cesspools, bottomless septic tanks, and
poorly installed drainfields are not providing the degree of treatment
possible. On some sites, points of groundwater use may not be protectable
due to unfavorable geohydrologic conditions. An objective of the optimum
operation alternative is to detect and eliminate or upgrade sources of
Legend for Cross-References in Margins
EIS I-C-2 Section of this EIS
TRD II-A Section of the Technical Reference Document published separately
CWA 201(g)(l) Section of the Clean Water Act which necessitates change in the text
40 CFR 35.2110 Section of the Construction Grants regulations which necessitates change in
the text
CG 82-6.2. Section of the program guidance document, Construction Grants - 1982, upon
which change was based.
C.26. Comment on the Draft EIS relevant to topic discussed (see Chapter VII)
All significant changes from the Draft except new sections are identified by underlining.
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contamination. Totally unsatisfactory systems can be replaced. Drain-
fields can be redesigned, rebuilt, or relocated to minimize groundwater
impacts. Gray water/black water separation can largely eliminate nitrate
loadings to groundwater.
EIS III-H-1 The key to reducing impacts of existing discharges is adequate identifica-
tion and analysis of problems followed by selection of appropriate
remedies. In addition to changes in the wastewater system, remedies may
include reconstruction or relocation of the well. The long-term success of
either type of remedy must be monitored by periodic sampling.
EIS III-H-1 Nitrate and bacterial contamination are the chief concerns related to
IV-E-1 septic tank effluent discharges to groundwater. At the housing densities
and in the hydrogeologic settings studied in the Seven Rural Lake EIS's,
contamination of wells by septic tank effluent was not shown to be a pro-
TRD II-A blem. The low density, linear development, and lack of fractured or chan-
XII-A-C neled bedrock in the study areas appear to preclude well contamination even
in areas of high groundwater. Indeed, high groundwater may actually pro-
tect wells since well screens used in many glacial deposits draw water from
levels deeper than the effluent plumes.
b. Future Work Needed
Contamination of groundwater by viruses and toxic substances that may be
discharged with sewage are unresolved concerns. Insufficient data exists
to define either the prevalence or public health implications of such
contamination. Thus, while this EIS gives broad support for the continued
use of on-site systems, it also recognizes the need for better analysis of
this concern than is now possible. Therefore, Region V will work with the
states in the Region to establish funding procedures for analysis of
viruses and toxic substances in wells. As an initial proposal, this EIS
recommends:
sampling of selected, properly protected wells previously found to
exceed bacterial or nitrate standards and suspected of contamination by
nearby on-site systems,
concurrent sampling of suspected wastewater sources, and
because of cost, limitation of sampling to single facilities planning
areas representative of each physiographic province in the region.
In California and New York, use of toxic septic tank cleaners (especially
trichloroethane) in certain kinds of on-site treatment systems (especially
cesspools installed in very high density) have been implicated in areawide
toxic contamination of aquifers. Limitations on the use of toxic cleaners
on a nationwide basis (possibly by the Federal Trade Commission or the
Consumer Products Safety Commission) deserve serious considerations.
c. Information Needed for Assessment
In facilities planning areas characterized by linear, single- or double-
tier development in nonfractured and nonchanneled geology, description of
groundwater resources based on available well logs and sampling data
augmented by representative sampling of properly protected on-site wells
will normally suffice for assessing impacts of on-site systems on ground-
water. In other settings, the existence or possibility of adverse impacts
should be assessed by a professional geologist or hydrogeologist.
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2. LAKES
The optimum operation alternative is likely to impact bacterial and
nutrient input to lakes. The two chief concerns are (1) whether on-site
treatment systems contribute a significant share to lake loading, and (2)
whether the systems are properly designed or installed.
a. Bacterial
EIS II-D Bacterial contamination can be identified by available survey and sampling
III-H-2 methods. The most likely routes of bacterial contamination from existing
IV-E-1 on-site systems are direct discharges and overland runoff of surface mal-
functions, almost all of which are remediable under the optimum operation
TRD XII alternative. Groundwater transport of bacteria to lakes is possible but
appears to be rare. On-site systems in sandy or gravelly soils and very
close to lakeshores are suspect and should be examined as sources of
bacterial contamination. On- and off-site technologies are available to
remedy bacterial contamination of lakes.
b. Nutrients - General
Impacts of wastewater nutrient inputs can include increases in the aquatic
productivity of a lake as a whole and localized stimulation of plant
growth. Localized stimulation may be at the point of plume emergence or in
sensitive parts of lakes such as embayments and canals. The optimum
operation alternative can, however, reduce or eliminate lake nutrient input
resulting from direct discharges or surface runoff.
EIS IV-E-2 Nutrient inputs to most lakes from on-site systems are generally small when
compared to total nutrient loads. The nutrient of primary concern is phos-
phorus. Except in small lakes with high lake surface area to watershed
area ratios and with large numbers of nearby on-site systems in sandy
soils, the beneficial impact of abandoning the systems on lake trophic
status will be small. Trophic status improvements alone will seldom be a
supportable reason for abandoning on-site systems.
Facilities planners for rural lakeshore communities will be required to
prepare phosphorus budgets for alternatives considered. This EIS presents
a modeling tool to use for making preliminary estimates of phosphorus
inputs from on-site systems. More rigorous models are also available to
analyze lake trophic status.
c. Nutrients - Local
EIS IV-E-3 Accumulation of phosphorus from on-site systems in poorly mixed parts of a
lake can result in nuisance plant growth well in excess of growth in the
main body. Where it can be demonstrated that 1) on-site systems are sub-
stantially contributing to nuisance plant growth, 2) abandonment of on-site
systems is cost-effective, 3) all other nutrient control methods have been
evaluated including non-point source control methods, and 4) the community
will commit to implementing other methods that are practically and
economically feasible, then facilities that allow abandonment of on-site
systems adjacent to such sensitive parts of a lake will be eligible.
Plant growth at the point of effluent emergence into the open waters of a
lake seldom interferes with recreational or other uses of the water.
Availability of suitable substratum, wave action, and fluctuations in lake
level normally control such nearshore plant growth naturally before it
becomes a nuisance. On-site upgrading and replacements may incidentally
reduce this growth, and innovative techniques such as effluent plume
recovery may eliminate it. Abandonment of on-site systems adjacent to the
main body of lakes solely for the purpose of controlling nearshore plant
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C.20.,23.,24. growth will not be eligible unless the growth impedes beneficial uses of
the water and is shown to be stimulated by wastewater effluent.
B. ENVIRONMENTALLY SENSITIVE AREAS
EIS IV-D-2 In rural and developing communities, any form of wastewater treatment
technology will have some impact on environmentally sensitive areas. His-
TRD XI-A-C torically, some of these areas were protected by on-site sanitary code
prohibitions and by the fact that on-site systems will not operate in them.
Sewers can overcome the natural constraints to development in such areas
and result in permanent environmental damage. These impacts include con-
TRD IX-A struction in and development encroachment on floodplains, wetlands, prime
agricultural lands, aquifer recharge areas, steep slopes, habitat for rare
and endangered species, as well as historic and archaeologic sites. These
impacts will also occur with off-site treatment provided by cluster sys-
tems, but limitations on the size of collection and absorption systems will
also limit the degree of impact. Innovative on-site technologies can
circumvent some site limitations and may permit development in sensitive
areas. Again, the degree of impact will probably be less than with cen-
tralized systems.
1. FLOODPLAINS
2. WETLANDS
Executive Order 11988 on floodplain management requires that U.S. EPA deny
Federal funding to projects that induce growth in floodplain areas. In the
Seven Rural Lake EIS's, no long-term impacts were anticipated from
secondary development in floodplain areas because most areas had zoning
ordinances or other development regulations. Some short-term impacts are
anticipated from construction of cluster system collection sewers. How-
ever, proper erosion and sedimentation control measures would mitigate
these impacts.
Some rural lake areas such as the Crooked/Pickerel Lakes Study Area in
Michigan have no inventory, mapping, or zoning exclusion for floodplain
areas. Cluster systems, shallow placement, or elevated mound systems may
overcome site limitations in these areas and thus encourage development.
Wetlands are afforded protection by Executive Order 11990 which calls for
the denial of Federal funding for projects that might induce secondary
development there. In general, small waste flows systems are not antici-
pated to cause significant impacts in wetland areas. Wetland site condi-
tions usually will not permit any form of on-site waste treatment. Con-
struction of even small-scale cluster system collection lines in wetland
areas, however, may require dewatering that can result in the decomposition
of peaty or organic substrate and thus significantly alter wetland charac-
ter. Construction may also alter the hydrologic flow patterns in the
wetlands. These collection lines may also induce development in or con-
tiguous to wetland areas where no development codes exist. In a number of
the Seven Rural Lake project areas, there was no delineation of wetland
areas or development codes that would prevent development. As a result,
dredge and fill may occur, buffers may be destroyed, and housing construc-
tion may be induced in wetland areas.
3. PRIME AGRICULTURAL LANDS
The regulations established by the Environmental Protection Policy Act
require identification and evaluation of impacts on significant agricul-
tural lands. The regulations implementing U.S. EPA's Agricultural Lands
Protection under the Construction Grants Program state that no award should
be made for wastewater collectors in a new sewer system "unless the system
would not provide capacity for new habitations...to be located on environ-
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mentally sensitive land such as wetlands, floodplains, or prime agricul-
tural lands" (40 CFR 35.925-13(d)). Cost-effectiveness guidelines of these
regulations, Appendix A, state that interceptors should not be extended
into prime agricultural lands unless they are necessary to eliminate point
source discharges or to accommodate flows from existing habitation.
Small waste flows technology, as proposed in the Seven Rural Lake EIS's,
was estimated to have limited or no impact on prime agricultural lands in
rural lake areas. This was in part due to the spatial distribution of the
agricultural lands being removed from somewhat poorly drained lakeshore
soils. In some cases, steeply sloping land contiguous to lakeshore areas
also prevented encroachment on prime agricultural lands.
However, small waste flows systems may potentially impact prime agricul-
tural lands. Because these lands are often relatively flat, well-drained
upland areas, they are also highly suitable for septic tank/soil absorption
systems. If sufficient market demand exists, prime agricultural lands near
lakeshore areas could experience development pressure.
EIS IV-D-2 Because small waste flows result in more scattered low density residential
development patterns, this type of technology may result in more agricul-
tural land being devoted to residential uses. Often, zoning provisions
permit higher density development in areas provided with centralized waste-
water treatment; thus, clustered development may occur. As an example of
this, the Seven Rural Lake EIS's estimated that 40% more land would be re-
quired to serve the same population with small waste flows systems than
with centralized facilities.
4. AQUIFER RECHARGE AREAS
The impacts of small waste flows systems on drinking water aquifers may
stem from bacterial, organic, suspended solids, and nitrate-nitrogen
contamination. In areas with soil texture finer than sand, bacteria,
organics, and suspended solids in wastewater are readily removed by
downward movement through 3 to 4 feet of soil. High concentrations of
nitrates in groundwaters are of concern because methemoglobinemia may occur
in infants who consume such waters. At high densities, septic tank/soil
absorption systems are suspected of causing groundwater nitrate-nitrogen
levels to be in excess of the 10 mg/1 national drinking water standard. If
this correlation is established in a sole source drinking water aquifer
recharge area, the U.S. EPA administrator may deny financing to projects
proposing additional decentralized facilities (40 CFR I49.10(a)).
None of the Seven Rural Lake EIS's anticipated that small waste flows
technologies would have any significant harmful impact on drinking water
aquifers. This was in large part due to the linear development patterns
that minimize overlapping of leachate plumes and resultant accumulations of
nitrates. In addition, some forms of treatment (cesspools, etc.) most
likely to lead to aquifer contamination would normally be eliminated.
Where hazards to the aquifer are severe, certain forms of on-site treatment
such as gray water/black water separation or plume interception can greatly
reduce nitrate hazards.
5. STEEP SLOPES
A common impact in the Seven Rural Lake EIS's was encroachment of develop-
ment on steep slope areas. Induced development may occur on unstable hill-
side areas with resulting erosion, sedimentation, and thus a probable
increase in non-point source pollution. In those communities with
significant development pressure this would occur to a lesser extent with
small waste flows systems than with centralized facilities.
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6. HABITAT FOR RARE AND ENDANGERED SPECIES
Because the rate, amount, and distribution of development dependent on
small waste flows systems is moderate compared with centralized facilities,
none of the Seven Rural Lake EIS's anticipated any impact on rare or
endangered species. It is conceivable that lower density residential
development may be induced in or adjacent to habitat areas with resultant
human activity. This activity could have the effect of altering species
diversity or stability.
7. HISTORIC AND ARCHAEOLOGIC SITES
Impacts on these resources were difficult to assess in the Seven Rural Lake
EIS's because inventories were largely incomplete. Much more effort is
needed to incorporate this resource information into facility design.
Anticipated impacts include possible induced growth infringement on or
contiguous to sites on the National Register of Historic Places. Facility
construction could also result in the destruction of below-ground
resources. As a result, a Phase 1 archaeological survey may be required
for Federally funded small waste flows systems including proposed on-site
facilities on private property (36 CFR 800.3). State Historic Preservation
Officers determine where archaeological surveys must be conducted for
Federally funded projects.
The Phase 1 reconnaisance survey requires the specialized knowledge of a
trained archaeologist who would be able to inventory the cultural resources
of an area and identify their significance. The survey would involve small
scale field analysis of known and potential sites as well as an inventory
of sites identified by local, state, and Federal interests. Documentation
would map and describe the local resources in order to mitigate possible
impacts.
Please note, however, that the shoreline development requiring wastewater
treatment has itself commonly led to site disturbance that reduces or
eliminates potential for further damage from on-site treatment repair or
upgrading. Because not all systems may require upgrading or replacement,
the potential for direct impacts on undisturbed sites is substantially
lower for an on-site treatment approach than for a sewered approach.
C. ECONOMIC IMPACTS
1. PRESENT WORTH SAVINGS IN THE REGION
EIS I-C-2-a An estimated 13% of all on-site systems in Region V could be either sewered
or publicly managed under an optimum operation alternative. For these
TRD X-E 430,000 systems the estimated difference in present worths between the two
approaches is $1.9 billion, an average of $4,436 per dwelling.
Several assumptions on which these estimates were based cannot at present
be verified. However, it is felt that local and state initiatives to
improve rural sanitation will have more effect on the ultimate savings than
will improvements in the assumptions.
2. COUNTY AND MUNICIPAL GOVERNMENTS
EIS IV-F-1 The economic impacts of the optimum operation alternative will typically be
less severe than the impacts associated with conventional centralized
wastewater facilities. The capital costs of small waste flows technologies
are less than the capital costs of centralized facilities. As a result,
the local share that county and municipal governments must pay will be
reduced. The local share is reduced further by the fact that the U.S. EPA
will fund 85% of grant eligible costs of small waste flows systems in
comparison to the 75% funding of conventional centralized facilities.
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Depending on the state matching grant, the local share of capital costs
will range from 6% to 15% of the project's total capital costs.
Many states have statutory limitations on the amount of debt that can be
incurred by municipal and county governments. Implementation of the
optimum operation alternative will enable local governments to incur less
debt than they would under conventional centralized alternatives because of
lower capital costs and local share. The Seven Rural Lake EIS's indicated
that publicly financed local costs were reduced between 89% and 98% under
some on-site alternatives. Local governments will be able to use their
credit for schools, hospitals, and other community facilities rather than
for needlessly expensive wastewater facilities.
Operation and maintenance costs will not be reduced in proportion to
capital reductions but will generally be lower than with properly main-
tained conventional facilities. As with conventional centralized facili-
ties, operation and maintenance costs associated with the optimal operation
alternative can be passed directly to users. County and municipal govern-
ments that had previously required property owners to bear all the costs
and responsibilities of on-site systems will incur some administrative
costs, due to the increased role of local governments in systems management
under the optimum operation alternative. Because of the flexibility local
governments have in the actual design of small flows management agencies,
they can match their costs to the actual severity of local water quality
problems.
3. PRESENT PROPERTY OWNERS
EIS IV-F-2 In unsewered communities where the optimum operation alternative is
feasible, the economic burden on present property owners, as a group, will
be less than it would be if a conventional centralized alternative were
selected. Owners with funded on-site systems will receive a combined
Federal and state subsidy of 85% to 94% on upgrading, site investigation,
and design services in return for a 6% to 15% contribution toward planning.
Other residents not receiving the subsidy may contribute toward the local
costs of planning, depending on the local decision on voluntary or
compulsory participation in the small waste flows management program.
Financial burdens and pressure placed on lower income residents to move
from the service area to avoid expensive user charges (displacement
pressure) will be relatively low.
TRD VIII-B The actual economic burden placed on present property owners may vary from
residence to residence depending on the manner in which capital, operation
and maintenance, reserve fund, and administrative costs are allocated. How
these costs are distributed is a decision that will have to be made at the
local level. Communities may decide to spread all costs evenly among all
users. Under this scenario, the severity of the economic burden placed on
owners will be solely a function of each owner's income. If the community
decides to allocate the costs based on the actual costs of serving a
specific residence, then economic burden will vary depending on the site
limitations, type of technology chosen, and the specific costs for insuring
proper system function. For some owners such as those using holding tanks,
these costs may be higher than the costs associated with centralized
facilities. The economic burden may be severe, regardless of income, for
owners having to pay high costs of site limitations.
4. FUTURE PROPERTY OWNERS
Future property owners served by on-site systems will have to pay the full
capital cost of their new systems exactly as they would without any manage-
ment system. U.S. EPA policy is not to subsidize future growth through the
Construction Grants program. Future capital costs for on-site systems are
deferred over the 20-year project period and are unlikely to be funded by
local government.
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Certain lots may require a very expensive on-site technology. The
individual costs on these lots in the future may equal or exceed the
individual shares of subsidized centralized facilities, if these facilities
were available. In cases where sewered off-lot technologies are selected
over on-site alternatives, the magnitude of economic impacts on future
property owners will be locally determined.
5. UTILITY CONTRACTORS AND LOCAL EQUIPMENT SUPPLIERS
EIS IV-F-3 Use of small waste flows technologies in rural areas can have a positive
impact on local utility contractors and equipment suppliers. Most con-
struction services and equipment for on-site and small-scale technologies
can be locally supplied. In contrast to conventional centralized facili-
ties where outside firms are typically used, optimum operation alternatives
may lead to the retention of more local, state, and Federal funds in the
rural community. The conventional contractors' objections to and unfami-
liarity with small waste flows technologies may indicate their inability to
compete successfully with local firms. Competition for contracts to con-
struct and provide supplies for small waste flows systems is likely to come
from non-local firms that have established expertise with these technolo-
gies. The degree to which Construction Grants funds are retained locally
will depend on the ability of local contractors to perform work on govern-
ment contracts. In some cases, the project workload and the meeting of
Federal contracting regulations, such as the Davis-Bacon Act, may be more
than small rural area firms can handle.
6. MINERAL PRODUCTION
Construction of replacement soil absorption systems will require gravel or
crushed stone. Some systems will also require select fill of loam, sandy
loam or sand. When a number of systems are constructed in a community at
the same time, demand on local sand and gravel or stone quarries may
require increased production rates. Coordination with quarry operators
could avoid construction delays.
Sand and gravel deposits are present throughout the states in Region V. In
1978 all six states were in the top ten states for sand and gravel produc-
tion. Ohio, Illinois, and Michigan were in the top ten for crushed stone
production (U.S. Bureau of Mines, 1978, 1979a-e). On state or regional
levels, therefore, increased gravel, crushed stone, and sand demands for
construction of soil absorption systems will have little impact on mineral
production.
D. LAND USE
EIS IV-D-2 Optimum operation alternatives may affect the amount, rate, and density of
development in communities within a reasonable commuting distance of
TRD XI-A&B employment centers. Often, large lot size requirements are called for by
local sanitary codes to protect the quality of groundwater used as domestic
water supply. These lot size requirements for new dwellings will probably
not change as a result of adopting alternative on-site treatment technolo-
gies. The net effect of such constraints on new development may be adverse
or beneficial depending on local community development objectives.
Cluster systems using off-site soils circumvent development controls based
on sanitary codes and soils limitations. Cluster systems may thus permit
considerably higher density residential development. High density develop-
ment may be counter to local development objectives. Cluster systems may
permit infilling within existing development areas resulting in loss of
open space buffers between existing development, and possibly into areas
unsuitable for residential development. Multifamily systems could have a
positive impact where higher density planned development permits conserva-
tion of open space in contiguous areas.
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The predominant settlement pattern and housing type in the Seven Rural Lake
EIS communities were single-family detached residential units in single-
tier development around lakeshore areas. Other rural areas depending on
on-site technology are also single-family units in small subdivisions or in
dispersed low density patterns. This pattern has been determined by
transportation access to lots and by spatial distribution of suitable
soils. If on-site technologies continue to be used, this development
pattern may lead to a situation where the future options to sewer may be
precluded because of the great expense incurred in constructing sewers
between dispersed homes. Further dependence upon local sanitary codes may
thus severely restrict the amount and distribution of developable land in
lake areas. Such restrictions may be counter to local development goals as
well. Wastewater treatment planning offers local municipalities an import-
ant chance to save on land planning concurrently with preparation of a
facilities plan. Because the two topics are so closely linked, anticipa-
tion of impacts prior to facilities design and formulation of an impact
mitigation strategy could save considerable time and expense. An under-
standing of the environmental resource base, housing types, lot sizes, and
existing densities, in conjunction with a program that involves land use
planning concurrent with facilities planning, would lead to an environmen-
tally sound wastewater management program.
E. RESIDENT PRIVACY AND INCONVENIENCE
1. INTRUSIONS ON PRIVACY
EIS III-A-2 Local access and control over on-site systems, although required by both
the Clean Water Act and common sense, raise concerns about individual
privacy and the sanctity of private property. The establishment of on-site
permit requirements a generation ago raised similar concerns. A poorly
planned, designed or funded version of the optimum operation alternative
might not offer benefits worth the costs that it incurs, whether in money
or privacy. Any transfer of authority to government reduces individual
choices, and may make some residents feel helpless, or more nearly so. For
this reason community authority should be exerted tactfully and sparingly,
balancing public health and water quality needs against any infringement of
privacy.
If something more than individual initiative and present management
practices is necessary, what are the differences in privacy between
sewering and the optimum operation alternative? The amount of money that
must be paid for wastewater treatment could be considered one measure of
intrusion into people's lives. On this basis, the optimum operation alter-
native will be less of an intrusion in any case where it is cost-effective.
In another sense, the legal requirement to abandon one's on-site system and
connect to a sewer is as severe an intrusion on private property as any
physical intrusion by inspectors or meter readers.
For the resident whose on-site system is causing no problems and is meeting
current design standards, short-term intrusions will include a one- or
two-hour interview and site inspection during the sanitary survey and
possibly a return visit for well water sampling. Continuing intrusions
would include periodic (1 to 3 years) site inspections by a surveyor,
routine septic tank pumping every 2 to 5 years and, for lakeshore dwel-
lings, possible groundwater and surface water monitoring activities along
their beaches. Some of these residents may be asked to allow well sampling
at the same time. All these intrusions can be minimized by careful
advanced notice and mutual agreement on public entry.
For residents whose on-site systems require repair, replacement, or up-
grading, intrusions caused by detailed site analysis and construction will
be roughly comparable to laying out and installing house sewers. Either
could require modification of interior plumbing that can be disruptive as
well as annoying. Intrusions resulting from on-site system construction
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will affect only a fraction of the total residents in a service area,
whereas all residents connecting to sewers will be affected.
For certain on-site systems needing repair, replacement, or upgrading, con-
tinuing intrusions would also be greater than with properly designed and
operating systems or with gravity sewers. On-site pumping units need
inspection and maintenance perhaps once or twice per year. If water flows
must be metered for hydraulically limited systems, meter readers would
enter the premises perhaps once per quarter. In general, continuing
intrusions will be related to the complexity of the facilities necessary to
deal with site limitations; the more complex the facilities, the more
maintenance would be required.
Intrusions will be greatest for residences required to install holding
tanks. Visits by the pump truck can be embarrassing as well as disturbing.
This (as well as nuisances and costs) can be minimized by constructing
holding tanks with hopper bottoms and riser pipes with quick-lock fittings
and by installing flow reduction devices in the house.
2. REMOVING RESTRICTIONS TO WATER USE
TRD XVI-A For many properties, modification of on- and off-site small waste flows
facilities will remove practical restrictions to water use. New or
upgraded systems may handle dishwashers, clothes washers, garbage grinders,
and additional occupants, which previously were avoided or prohibited.
Some properties will not be so fortunate, such as those on small lots for
which existing, subcode, or innovative facilities will be adequate with
minimum water usage and for which off-site facilities are not affordable.
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Chapter VII
Comments on the Draft EIS and Responses
LEGEND
ON-SITE DISPOSAL OR CLUSTER SYSTFMS
EXISTING GRAVITY SFWER
PROPOSED
BIO-DISC
PLANT
Limited Action Alternative
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CHAPTER VII
COMMENTS ON THE DRAFT EIS AND RESPONSES
U.S. EPA received numerous letters on the Draft Generic EIS following its
distribution in October, 1981. Many of these letters just confirmed
receipt of the document. These letters are not reproduced here and are not
responded to in this chapter.
Those letters which commented substantively on the Draft EIS are reproduced
here. Specific comments are paraphrased and responded to in the initial
pages of this chapter. Portions of letters from which comments were para-
phrased are identifed by notations on the letters. Also, cross-references
to specific comments are included in the text of the Final EIS.
The EIS Process
C.I. Is the intent of this EIS to eliminate future EIS's for rural lake projects
or to act as a guideline for project-specific EIS's and to aid communities
in planning, construction, and management? (Smit)
R.I. The EIS is not a substitute for future EIS's on rural lake projects.
Current guidelines for deciding to prepare EIS's will continue to be
applied to individual projects.
The EIS is not intended to act as guidance for defining the scope of
individual project EIS's. Such EIS's are supposed to address issues
specific to the project. Information provided in the Generic EIS may,
however, help address these issues once they are identified.
The EIS is very definitely intended to aid communities in planning,
construction, and management. We hope that their use of this information
will avoid the time and cost required for EIS preparation in most small
communities.
C.2. Why did EPA do seven EIS's on similar projects instead of doing one case
study and then requiring that the other communities' consultants do the
necessary work? (Czuprenski)
R.2. The intent behind selecting a number of projects was to ensure a broad
perspective on rural lake wastewater management. Projects were selected
from locations throughout Region V for this purpose.
We had no idea when the seven individual EIS's were started that the
recommended actions would be anything different from what was proposed in
previous facilities planningcentralized collection and treatment. In
fact, it was not until a substantial amount of field work was completed
that the possibility of continuing to use on-site systems was even
considered. That six of the original seven projects ended up with the same
recommended alternative was the result of the economic and environmental
realities of this type of project. If we had foreseen this, we might have
skipped the individual projects altogether and proceeded immediately with
the Generic EIS.
Technologies
C.3. Low-flow shower heads are only effective if the residents take showers
rather than baths. Facilities planners should not be overly optimistic in
estimating potential flow reduciton (Pycha - internal EPA memo not
reproduced).
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R.3. For most residents, the greatest benefit of low flow compared to conven-
tional shower heads is in reducing hot water use. Baths require even more
water than a shower with a conventional shower head. But if the resident
does not care about the cost of heating water, he probably will not switch
from baths to showers. Or he may not convert to a low-flow shower head.
Education programs or regulations supporting low-flow shower heads in
sewered areas may not be effective because the water user may not care
about the cost benefit.
The resident with a marginal on-site system has a different perspective.
If he does not control water use, his system may back up or have a surface
malfunction. Switching to a low-flow shower head and minimizing baths may
have the immediate benefit of avoiding sewage problems in addition to
reducing water heating costs. In this case the planner might be more
optimistic about potential flow reductions.
Section II-A-5-a has been modified to recognize the effect of bath-taking
on the flow reduction potential of low-flow shower heads.
C.4. Small-diameter (2- to 6-inch diameter) sewers discussed in Section II.B.2.
can be constructed with no minimum grade requirement as long as they are
designed for hydraulic carrying capacity. That is, they can have flat
sections (no grade) or even uphill sections (negative grade) as long as no
house sewers, cleanouts, or manholes overflow at low points along the
sewer. (Dix)
R.4. Successful operation of small-diameter sewers designed this way has been
reported recently for one location. This design has not been widely tested
and, so, would be considered innovative.
C.5. Vacuum sewers have been ignored. (Dix)
R.5. Vacuum sewers are mentioned briefly in Section II-B-2. The EIS does not
dwell on off-site collection and treatment methods. Because of the
economic advantages inherent in on-site treatment at low housing densities,
the EIS concentrates on these technologies. In this context, off-site
technologies are addressed because they may be the only safe way to manage
wastewater in parts of communities that cannot otherwise benefit from the
economies of on-site treatment.
C.6. It is well known that sewage can be treated by aeration; that is, bubbling
air through the liquid wastewater. The use of aeration along with
evapotranspiration would save billions of dollars in unnecessary sewer
costs. (Moore)
R.6. Mechanical aeration oxidizes the organic material in sewage and converts
reduced species of chemical compounds to oxidized species. Oxidation also
takes place naturally in soilat a fast rate in unsaturated soil and at
slower rates in saturated soil (depending on depth from the soil surface
and other factors). On-site and small-scale systems using mechanical
aeration are expensive to install and maintain. As a result, mechanical
aeration can only be justified where less expensive equipment and natural
processes cannot adequately treat the expected sewage flow.
The success of evapotranspiration beds in disposing of wastewater is highly
dependent on climate. (We assume that the commentor did not intend to
include percolation in his use of the word "evapotranspiration".) Year-
round reliance on evapotranspiration beds as the only means of disposal is
only feasible in arid and semi-arid climates such as our American South-
west. Within Region V, evapotranspiration beds might be feasible as the
sole means of disposal for dwellings used only during summer and early
fall. In this case evapotranspiration beds might be chosen over conven-
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tional soil absorption systems if soils are impermeable or if effluent
discharges to groundwater are not environmentally acceptable.
The use of mechanical aeration before evapotranspiration beds would
probably not be justified. Septic tanks provide adequate treatment with
this method of disposal.
C.7. Table II-A-1, "On-site Wastewater Management Options for Specific
Limitations or Constraints" does not include aerobic treatment units.
(Wilson)
R.7. Aerobic treatment units are included in this table as one of several
options for sites where subsurface disposal to the soil is not feasible.
Situations might arise where aerobic units would be useful in reducing
organic overloads to soil absoprtion systems. However, for most residences
organic loads can be reduced more certainly and at much less cost by other
means.
C.8. What type of on-site system repairs will abate the effluent plumes detected
by septic leachate detectors? (Czuprenski)
R.8. Most of the effluent plumes that have been sampled during preparation of
this EIS and the "Seven Lakes EIS's" were adequately treated before
emerging into the lakes, and required no action except continuing surveil-
lance.
For those effluent plumes having elevated nutrients or bacteria counts that
are not acceptable, several remedies hold promise, such as:
use of non-phosphate detergents,
elmination of garbage grinders (reduces organic load to the soil and
thus improves phosphorus retention capability of the soil),
segregation of toilet wastes by use of composting toilets or low-flow
toilets used with holding tanks (substantial reduction in organic load,
phosphorus, nitrogen and pathogenic organisms),
effluent plume recovery, discussed in Section II-A-5,
reuse/recycle and other maximum flow reduction methods (may improve
efficiency of septic tanks; will lengthen contact time of effluent with
the soil to improve soil treatment),
replacement of subsurface soil absorption systems with mounds, and
installation of a pump to dose the existing soil absorption system
(ensures better wastewater contact with the soil).
Due partially to the fact that we have only recently had the tools to
accurately locate effluent plumes, the extent of effluent treatment
provided by existing systems, much less the success of measures listed
above, has not been widely assessed. Region V encourages the states, local
governments, and consultants to assess this and other modes of on-site
system failure, and to experiment with cost-effective ways to remedy them.
C.9. The Minnesota Pollution Control Authority will not allow construction of
sub-code systems. (Wegwart)
R.9. This has been a common response to the performance-based decision making
that this EIS is recommending. The most frequently expressed reasons for
this reponse have been:
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1) There are not enough regulatory personnel with the necessary expertise
to do the studies or to make the many decisions needed with the
performance-based approach.
2) All on-site systems must be designed to treat and dispose of whatever
wastewater may be generated in a dwelling.
This EIS's response to this is two-fold.
For decisions to permit systems for new dwellings or other proposed
buildings, this EIS supports Minnesota's position. U.S. EPA is funding no
facilities for buildings constructed after December 1977, and so has no
direct interest in their design. The states are justified in being as
conservative as they see fit. This EIS supports reasonable efforts to
minimize the risks and consequences (both economic and public health) of
future failures.
For design decisions involving existing on-site systems, this EIS also
supports reasonable efforts to minimize risks of future failures. This is
what the EIS is all about. Where conventional, code-conforming on-site
systems are feasible and will minimize these risks, these are preferable to
innovative or sub-code system designs. We expect that most on-site
upgrades funded by the Construction Grants program will conform to state
design codes. However, when states and communities seek to realize the
benefits of the Optimum Operation Alternative, they will find, as we have,
cases where strict conformance to modern codes will rule out economical and
effective design decisions. We believe that providing the necessary
personnel to make such decisions and to monitor the effectiveness of the
chosen systems will be well worth the cost compared to the holding tanks
and off-site systems that might otherwise be constructed. When these cost
savings are reflected in lower user charges, it is likely that the communi-
ties will agree, even those residents whose use of their system is re-
stricted (see Sections III-E and VI-E-2).
C.10. The Minnesota Pollution Control Authority would not allow construction to
commence without knowing if the alternative should be on-site upgrade,
group clusters, or conventional sewers. Selections of technologies for
individual properties should take place in Step 1, not in Steps 2 or 3.
(Wegwart)
R.10. The issue of the level of detail required in a facilities plan proposed
action was debated intensively within EPA and with the states in Region V
during preparation of the Draft EIS and after publication. Region V's
position, stated in the Draft EIS and in Appendix A of the Draft EIS, was
that some designation of the facilities to be constructed be made on a
site-by-site basis by the end of Step 1. These designations could be
tentative and each did not have to be based on on-site inspections.
This issue and the reasoning behind it are now mute. Changes in Federal
funding of Step 1 and Step 2 made by the 1981 amendments to the Clean Water
Act eliminated the economic benefits to localities of deferring intensive
field work until Step 2.
Section II-E-2 has been changed to admit more flexibility in the level of
detail for optimum operation alternatives described in final facilities
plans. Section II-E-2-a recommends a minimum level that does not require
technology designation for specific sites. This is a less specific level
of detail than was recommended in the Draft. Section II-E-2-c recognizes
the perogative of a state to require a higher level of detail.
C.ll. The assumptions behind the Cost Variability Study need to be stated.
Vacuum sewers need to be included, and the effect of new design recom-
mendations (based on hydraulic carrying capacity instead of minimum grade)
for small-diameter sewers should be explored. (Dix)
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R.ll. The procedures and assumptions used in the Cost Variability Study will be
available when it is published in the near future with the other Technical
Reference Documents.
Vacuum sewers were not included in the study because: 1) At the time the
scope of the study was defined, cost data were too limited for this
technology; and 2) The literature at the time suggested that vacuum sewers
would be most appropriate for new buildings and moderately high housing
densities, infrequent conditions in the communities that the EIS is
concerned with.
As to reanalysis of small-diameter sewer costs, we agree that it would be
useful, but we believe that variation in cost resulting from this design
revision would be small compared to the variations already analyzed
resulting from the several environmental and developmental variables.
C.12. The Cost Variability Study does not state what discount rates have been
used to derive the cost comparisons. A sensitivty analysis using different
discount rates in computing present worths ought to show that the cost
comparisons presented in Chapter II, Section F, can change dramatically
according to what discount rate is used. In that the EIS is intended to
recommend analyses and methods for the evaluation of alternative wastewater
mangement solutions, it is deficient since it lacks any discussion of the
effect of the choice of discount rate on the relative merits of projects.
(Falcke)
R.12. The discount rate used in the Cost Variability Study was 7-1/8%, the Water
Resource Council's recommended rate in early 1980 when the study was
prepared. The discount rate used in the study is now reported in the text.
To assess the impact of varying the discount rate, the curves in Figure
II-F-1 and II-F-2 representing 50% replacement of on-site systems (Line ฃ7)
and construction of new sewers and central treatment plant (Line B) have
been recalculated with 2% and 10% discount rates. Figure VII-1 and VII-2
show the effect of discount rates on the curves. The 2% rate favors
sewering by lowering the present worth of new sewers and treatment plants
while raising the present worth of on-site system replacement. The reverse
is true for the 10% discount rate. Overall, the effect of this economic
variable is small compared to the effects of the environmental and devel-
opmental variables that were the focus of the Cost Variability Study.
In the process of making these new calculations, some errors in the on-site
replacement costs were caught and corrected. The net effect of these
corrections was to increase the on-site replacement costs. The increase is
reflected in Figures II-F-2 and VII-2. The errors were also corrected in
Figures II-F-1 and VII-1, but the average cost per house decreases in
Figure II-F-1 relative to what was presented in the Draft EIS. This is due
to the fact that per house costs in the Draft EIS for on-site replacement
were erroneously calculated from initial year houses instead of design year
houses as the sewered alternatives were.
Impacts
C.13. The EIS should provide a more in-depth discussion of the public health
implications associated with sewage contamination of surface and subsurface
waters. (Lisella)
R.13. Potential contamination of recreational and drinking waters is mentioned in
numerous places in the EIS, but specific diseases and other public health
effects are not detailed. This subject has been discussed in depth in
Technical Reference Document, Chapter II-A which will be available in the
near future.
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COST-EFFECTIVENESS CURVES
Scenario 1
50% Growth
20,000
18,000
16,000
% 14,000
O
co
3 12,000
O
o
o
5
10,000
CO
uj 8,000
cc
a.
a:
u
o 6,000
CM
4,000
2,000
A - Collector Sewers
B Collection/Transmission/Treatment
C - Collection/Transmission/Land Application @ Rapid Infiltration
0 - Collection/Transmission/Cluster Systems
Collection Components of Systems:
AI-..DI - Conventional Gravity Sewers
A2...D2 - Small Diameter Gravity Sewers with Septic Tanks
A3...D3 - Pressure Sewers with Septic Tank Effluent Pumps
A^.-.D^ * Pressure Sewers with Grinder Pumps
E ป On-Site Systems
ฃ5 102 Replacement Level
ฃ6 201 Replacement Level
ฃ7 50Z Replacement Level
jซ Trade-Off Between Collection Component
10%
71/8%
2%N N
1
38
75
113
150
FUTURE
25 50 75
HOUSES/MILE OF COLLECTOR SEWER
100
PRESENT
FIGURE VII-1.
EFFECT OF VARYING DISCOUNT RATES ON COST-
EFFECTIVENESS CURVES FOR ON-SITE SMALL SCALE
AND CENTRALIZED TREATMENT ALTERNATIVES FOR
SCENARIO 1; 50% GROWTH
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COST-EFFECTIVENESS CURVES
Scenario 4
0% Growth
20,000
18,000
16,000
1
O
O
14,000
12,000
oc 10,000
O
UJ
OT
UJ 8,000
OC
o.
ir
UJ
6,000
4,000
2,000
A - Collector Sewers
B * Collection/Transmission/Treatment
C - Collection/Transmission/Land Application @ Rapid Infiltration
D - Collection/Transmission/Cluster Systems
Collection Components of Systems:
AJ....DI - Conventional Gravity Sewers
A2--.D2 * Snail Diameter Gravity Sewers with Septic Tanks
A^.-.D-j - Pressure Sewers with Septic Tank Effluent Pumps
A^-.-D^ Pressure Sewers with Grinder Pumps
E - On-Site Systeas
ฃ5 - 10X Replacement Level
Eg - 202 Replacement Level
ฃ7 - 50X Replacement Level
As- Trade-Off Between Collection Component
10%
25 50 75
HOUSES/MILE OF COLLECTOR SEWER
100
FIGURE VII-2.
EFFECT OF VARYING DISCOUNT RATES ON COST-
EFFECTIVENESS CURVES FOR ON-SITE SMALL SCALE
AND CENTRALIZED TREATMENT ALTERNATIVES FOR
SCENARIO 4; 0% GROWTH
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C.14. The EIS should address impacts on mineral resources and mineral production.
(Huff)
R.14. Section VI-C-6 has been added that address use of sand and gravel for
construction of on-site systems.
C.15. Implementation of the alternative treatment systems discussed in the EIS
may create other environmental problems if coordination and approval are
inadequate. (Druckenmiller)
R.15 Comment noted.
C.16. We would like to see greater program emphasis placed on encouraging local
governments to recognize the potential for disturbance to and need for
protection of "sensitive areas" identified in the EIS. (Druckenmiller)
R.16. Comment noted.
C.17. Consideration of alternative systems should include a thorough evaluation
of the demographic and economic environment. (Druckenmiller)
R.17. Comment noted.
Needs Documentation
C.18. Section II-D-l-c mentions several limitations of the septic leachate
detector technique, but not the effects of timing. (Czuprenski)
R.18. Timing is addressed as one of the causes of false negatives: "Seasonal use
of dwellings may result in only periodic emergence of leachate at a
shoreline."
Obviously, the many facets of the hundreds of subjects discussed in the EIS
cannot be explored fully in a document that is required by regulation to be
no more than 150 pages. However, since this point is of interest to
consultants who will be using the data from septic leachate surveys, we
reproduce below a relevant part of our response to a similar comment from
the Final EIS for Green Lake, Minnesota:
"We have learned some very interesting things from both the winter and
summer Septic Snooper surveys and related studies at Green and Nest
Lakes and in the six other communities where EIS's are being done. For
instance, at Otter Tail Lake, Minnesota, EPA performed a winter Snooper
survey right after the Green Lake Snooper survey. Because nearly all of
the permanent residences showed evidence of plumes under the ice, EPA
surveyed again in the summer to see if the summer residents also
generated plumes in the lake. There were far fewer plumes in the summer
than in the winter. The difference points out the dynamic nature of
effluent plumes. It also reflects the results of several interacting
factors:
During snow melt, groundwater inflow to lakes is at its highest rate
of the year. This carries effluent plumes into the lake that
otherwise may not flow directly to the lake.
The direction and rate of groundwater, and therefore plumes, can be
altered by the level of a lake. At a high lake level, the ground-
water flow will not be as fast and can even be reversed.
Seasonal or year-to-year variations in groundwater flow in the
nearshore areas can result in the disappearance, then reappearance,
of some effluent plumes.
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The strength of a plume that is entering a lake, and therefore its
detectability, is strongly determined by mixing with the lake water.
EPA has observed plumes during a morning calm that were not detect-
able when afternoon breezes make waves on the windward shore. During
the winter, ice cover reduces mixing, thereby magnifying plumes
relative to their summer strength.
"As to the 4- to 6-month duration of plumes, it is now believed that too
many variables affect the detectability of effluent plumes to justify
use of this estimate. The actual duration period for a given system, or
the average for all systems around a lake, may vary substantially from
this original estimate. It may well be that we detected only plumes
from permanent residences. The pattern of effluent plumes, and the
presence of effluent or effluent-like substances in surface runoff
remain highly significant and should be used to guide future site
analysis."
Additional information on use of Septic Leachate Detectors will be found in
Section II-D of the Technical Reference Documents.
C.19. Septic leachate detector studies would have provided more fruitful informa-
tion if conducted on urban and suburban, unsewered inland lakes, and may
have modified some of the documentation of need criteria. (Czuprenski)
R.19. Every new lake we study with this instrument has potential for showing us
something not known before. We are also interested in seeing long-term,
repeat surveys of individual lakes.
We recognize the possibility that improved understanding of effluent plumes
and how they are detected may justify changes in needs documentation
criteria.
C.20. The impact statement concludes that preventing nearshore plant growth along
open shorelines of a lake is not a sufficient justification for abandoning
on-site systems. We do not agree that the localized changes in plant
productivity within the main body of lakes will always be so limited.
Instead of this generalized statement against abandoning on-site systems,
we recommend a preliminary evaluation of each lake to assess the potential
for localized productivity impacts. (Wandell)
R.20. What we have called "nearshore plant surveys" were recommended for lake
communities as a Phase I needs documentation method in the Draft EIS.
Additional emphasis is provided in the Final EIS. Especially when
conducted along with a septic leachate survey, a plant survey can indicate
the frequency and severity of plant growth problems contributed to by
on-site systems. It is recommended that such surveys be supervised by
persons who have studied not only the type and spatial distribution of
aquatic plant growths but also their habitat and nutrient requirements.
Sections in the EIS that discuss abandoning on-site systems to control
nearshore plant growth have been amended to support abandonment of on-site
systems where the associated nearshore plant growth impairs beneficial uses
of a water body. Alternative means of control should also be investigated.
See also R.8.
C.21. The EIS points out the value of Cladophora surveys along shorelines in
problem-assessment work. Cladophora surveys techniques should be included
in Section II-H-2 discussions of effluent surveys and non-point source
monitoring. (Grant)
R.21. Identification of shoreline plant growth during effluent surveys is men-
tioned in Section II-D-l-f, "Nearshore Plant Surveys." Plant growth can
also be located during sanitary surveys, as noted in Section II-D-2-a,
"Sanitary Surveys."
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On lakes where nearshore plant growth is a local concern, incorporation of
plant surveys may he a useful element in ongoing surface water monitoring
programs, to which Section III-H-2 is addressed. This is noted in an
addition to the section.
C.22. While the phosphorus contributions from septic tank systems to lakes may be
small in contrast to other sources, in combination with lawn fertilization
and waterfowl feeding they represent the sources which are most control-
lable at the local level. These problems should be corrected as part of a
total lake management program, and should not be minimized in importance in
the EIS. (Grant)
R.22. One of the goals of the U.S. EPA and its Construction Grants Program is
improvement and preservation of lake water quality. We encourage comprehen-
sive lake management programs. We believe that there would be fewer
applications for Construction Grant funds around lakes if there were more
comprehensive lake management programs. We therefore have no intention of
minimizing in the EIS the importance of effective management programs.
However, the EIS addresses the Construction Grants program as it applies to
rural lake and other small communities. The Construction Grants program is
limited to funding wastewater facilities. Hence, the document's emphasis
is on wastewater management.
C.23. The policy stated in Sections IV-E-3 and VI-A-2-c of the Draft EIS holds
that 1) except for unusually severe cases, preventing nearshore plant
growths in the main body of a lake is not a sufficient justification for
abandoning on-site systems, and 2) abandoning on-site systems adjacent to
embayments and canals may be justified if non-point source control measures
are implemented prior to or along with the construction of off-site
facilities. What constitutes an "unusually severe case," how is the
significance of non-point sources going to be determined, and where is the
community going to get the funds to implement non-point source control
measures? (Czuprenski)
R.23. In our experience of studying the 35 glacial lakes within the "Seven Lakes"
EIS study areas, we found no instances where fishing or swimming uses would
be impaired on open lakeshores by nearshore plant growth supported in any
significant measure by subsurface effluent plumes. The "unusually severe
cases" clause accounts for the possibility that there may be exceptional
cases where subsurface transport of nutrients does support plant growths
that obstruct fishing or swimming.
In contrast, many of the heavily developed embayments and, especially,
dredged canals were choked with rooted aquatic plants or were highly turbid
from planktonic algae growth. We suspect that non-point sources, surface
malfunctions, and subsurface nutrient transport all contribute to those
problems. Because, as the commentor suggests, assessing the nutrient loads
from each source on such a small scale may be difficult and costly, the EIS
recommends eligibility for small-scale collection and treatment in such
settings.
As to funding non-point source control, most relevant control measures are
in the hands of the lakeshore property owners themselves. Control will be
primarily a matter of continuing education about sources of nutrients such
as lawn fertilizer, wildlife feeding, pet droppings, lawn clippings, and
leaves. Evidence of a community's dedication to continuing education and
provisions for periodic nearshore plant surveys may suffice as a non-point
source control program.
If inspection of watersheds tributary to embayments and canals reveals
other significant non-point sources, the community is expected to take the
lead in minimizing them. There are presently no Federal funding sources
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for non-point source abatement. If funds are required for abatement, they
will have to come from state, local, or private sources. If funds are not
available from these sources, then the presumed eligibility of off-site
facilities for over-productive canals and emabyments will be eliminated,
and facilities will be selected without presumption of need for off-site
systems.
C.24. The policy on eligibility of collector sewers that correct nearshore plant
growth problems seems to be inconsistent with the collector sewer
eligibility diagram in Figure II-C-1 and in "Region V Guidance - Site-
Specific Needs Determination and Alternative Planning for Unsewered Areas."
According to the diagram, nuisance aquatic plant growth should be cate-
gorized as either a problem or not; then the density criteria of 10
persons/acre should be used to justify abandonment of on-site systems.
(Czuprenski)
R.24. Figure II-C-1 and the Region V Guidance both operate under the assumption
that whatever facilities are selected will have a reasonable chance of
remedying recognized problems. Therefore, the mere coincidence of nuisance
aquatic plant growth and high density development does not justify
abandonment of on-site systemsthe source of plant nutrients could be a
major tributatry, not on-site systems, for instance.
As stated above, the EIS's discussion of on-site system effects on near-
shore plant growth is based on our studies of glacial lakes, where we found
no aquatic plant growth at nuisance levels on open shorelines that could be
attributed to subsurface transport of nutrients. Where we found high
levels of plant growth in open lakes, the major nutrient sources did not
include on-site systems, so that abandoning them would not improve the
plant problem.
C.25. The description of a preliminary lake phosphorus concentration model in
Section IV-D-2 is unclear and difficult to follow. Symbols are not
consistent and procedures change from the metric to the English system of
measurement. (Wandell)
R.25. The discussion has been changed in response to this comment. (The relevant
section has been changed to Section IV-E in the Final EIS.) However, the
two systems of measurement have been retained. The numerical input to
Figure IV-E-1 from Figure IV-E-2 is dimensionless so that the user need
only calculate flow through the lake in both metric (m /s) and English
(cfs) units.
C. 26. Can the on-site systems/eutrophication model presented in Section IV-D-1
of the Draft EIS be applied to shallow lakes dominated by littoral
macrophytes or to kettle lakes with no surface inflow or outflow?
(Czuprenski)
R.26. The model was developed to identify lakes that may be sensitive to
phosphorus inputs from on-site systems. Those that appear to be sensitive,
as indicated by phosphorus concentrations due to on-site systems of greater
than .001 mg/L.-P, should have nutrient budgets developed from available
data and empirical models and, if shown to be necessary, collection of
field data. Where applicability of the EIS model is questionable because
of unquantifiable inputs, such as inflow/outflow for kettle lakes, the
planner may begin with a nutrient budget instead of the EIS model.
The dominance of macrophytes, on the other hand, is an irrelevant factor in
this preliminary step. The EIS model only indicates the level of enrich-
ment due to on-site systems so that an early judgement can be made on the
need for more detailed analysis.
C.27. Section IV-D-1 implies that only one fecal coliform sample be taken for
any particular effluent plume found along a shoreline. Michigan Department
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of Natural Resources has pointed out that their water quality standards for
total body contact require five or more samples within a 30-day period.
Therefore, a long-term sampling program would be necessary to document a
public health hazard from bacterial contamination. (Czuprenski)
R.27. Chapter IV deals with facilities planning, and a particular passage in
Section IV-E-1 deals with sample collection for bacterial analysis during
initial shoreline surveys. The suggested sampling frequency would result
in 3 to 7 samples per mile of shoreline. But no mention is made of addi-
tional sampling as part of "representative sampling" during Phase II.
Follow-up sampling in Step I is indicated if initial surveys reveal
problems. This section has been revised to suggest follow-up sampling
where appropriate. See also discussions of representative sampling in
Section II-D-2-b and Appendix A.
As to whether five samples are needed to justify abandoning an on-site
system, U.S. EPA does not intend to set detailed decision-making standards
that properly are the responsibility of state and local officials. We do
want state and local officials to seriously consider the economic and
practical implications of applying existing standards to new applications
of the data.
C.28. Depending upon county records to identify failing on-site systems is inade-
quate. You cannot get good information from regulatory people who are not
doing their job. (Wilson)
R.28. The effectiveness of local regulatory programs varies widely. It is
clearly the intent of the Congress, as expressed in the 1977 Clean Water
Act Amendments, that local programs be upgraded if a community is to
receive Federal funds for upgrading on-site systems.
Planners have to start somewhere to get information on on-site system
performance. If there is any regulatory program at all, the personnel in
charge of it should be an early point of contact.
There are many excellent exceptions to this commentor's observation. It
has been our experience that the communities with the most effective regu-
latory programs are the ones with the lowest on-site problem rates.
C.29. What is a "flowing effluent pipe" mentioned in the new "Region V Guidance -
Site-Specific Needs Documentation and Alternative Planning for Unsewered
Areas?" How does the identification of one constitute a water quality or
public health problem? (Czuprenski)
R.29. This is another term for a direct discharge; that is, untreated wastewater
or septic tank effluent discharged to the ground surface, drainage ditches,
streams, or lakes.
The following comments on needs documentation policies were made by Mr. Gordon E. Wegwart
of the Minnesota Pollution Control Agency. His comments relate to "EPA Region V Guidance -
Site-Specific Needs Determination and Alternative Planning for Unsewered Areas." Although
he commented on the Guidance in regard to an on-going Region V EIS for Moose Lake,
Minnesota, we are repeating his comments here since they are highly appropriate to the
Generic EIS, as well.)
C.30. In order for surface failures that are detected by remote imagery (aerial
photography) to be used as direct evidence of need, the imagery must be
ground truthed to be valid. (Wegwart)
R.30. We agreed. This position is stated in Section II-D-l-b of the Draft EIS.
C.31. The indicators of groundwater contamination listed in Section III-A-4 of
the Guidance (whiteners, chlorides, nitrates, fecal coliform bacteria)
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cannot conclusively prove defective sewage systems nor indicate which
system is the contributor. More extensive groundwater monitoring or a dye
study would be needed to link a contaminated well to a failing septic
system. (Wegwart)
R.31. We agree that more extensive analysis would be justified prior to abandon-
ing an on-site system or replacing it so as to protect a well. The more
extensive work (beyond well inspection and sampling) would only be justi-
fied, however, after a decision is made not to install sewers and, thereby,
abandon the on-site system anyway. See EIS Sections II-D-2-b and IV-D-1,
C.32. We are accepting positive tracer dye studies and effluent plumes located
during a septic leachate detection survey as direct evidence, not just
indirect evidence, as long as the source of the plume can be pinpointed.
(Wegwart)
R.32. We have sampled many effluent plumes both in the lakes where they emerge
and in the groundwater near shorelines. Most of them were sufficiently
treated, showing nutrients and bacteria at or near background levels.
Sampling of some identified plumes on a lake is essential to deciding
whether they constitute direct evidence. Until sampled, we recommend that
plumes located by a septic leachate detector should be considered indirect
evidence only.
C.33. MPCA considers holding tanks as direct evidence for evaluation of alterna-
tives, not just indirect evidence. (Wegwart)
R.33. We recommend that strict distinctions be maintained between direct evidence
and indirect evidence. The types of direct evidence listed in Region V's
guidance are recognized public health or water quality problemsno addi-
tional work would be required to establish a need for some sort of remedy.
(However, additional on-site tests may be necessary to select the right
remedy.) In contrast, indirect evidence indicates potential problems but
requires additional sampling or inspection to assess actual performance of
on-site systems.
We have classified existing holding tanks as indirect evidence because they
are not, of themselves, public health or water quality problems. Holding
tanks are often installed, not because a soil absorption system failed
without remedy, but because regulations prevented other measures from being
tried. They are also installed because property owners insisted on
building on lots that should not have been built on. These are not public
health or water quality problems; they are management problems.
The reason for making this fine distinction is our concern that planners
will look for the causes of the holding tank's presence, assume that it was
poor soil, small lot, etc. and then assume that all other similar proper-
ties will end up with holding tanks.
We support cost-effective means to reduce reliance on holding tanks.
Repeated pumping of the tanks is costly and disruptive. For some proper-
ties, frequency of pumping can be reduced by serious flow-reduction
measures and/or by allowing separate treatment and disposal of non-toilet
wastewater on-site.
C.34. In regard to Section III-B-9 of the Guidance MPCA considers a septic tank
discharge to surface waters direct evidence (Wegwart)
R.34. We emphatically agree. Including "systems which feature direct discharge
of septic tank effluent to surface water" as indirect evidence was an
oversight. It has been corrected.
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C.35. Age should not be accepted as indirect evidence, unless systems of a
specific age can be correlated to a specific type of installation that is
unacceptable. (Wegwart)
R.35. The Guidance recommends correlation of age with performance or excessive
maintenance requirements (such as undersized septic tanks) not just with
type of installation.
C.36. MPCA sees no value in limiting mailed questionnaires to those cases where
very high or very low failure rates are expected. They should be used in
all cases. (Wegwart)
R.36. Opinion on this matter is mixed. On the positive side questionnaires can
be inexpensive, can be a public participation tool, can be done during the
winter when other surveys are not possible, and can highlight parts of a
community where later efforts should be focused. On the other hand they
tend to be more of an opinion poll than an objective survey, responses are
not consistent, and some details required to identify remedies to problems
are not obtainable.
We respect MPCA's input on this matter, and have deleted qualified prohibi-
tions to mailed questionnaires in Section II-D-l-d.
C.37. MPCA considers a lot with two types of indirect evidence to be a need
situation. Should additional data be collected if a lot exhibits more than
one "inferred" evidence? (Wegwart)
R.37. Until a great deal more performance data is collected and correlated to
site, design, and usage data, we recommend that indirect evidence not be
used in the semi-quantitative manner suggested. Based on the data we have
collected, we are wary of creating any new rules of thumb about causal
relationships that influence performance.
We believe, however, that defining these causal relationships is feasible.
To do so would require compilation and management of the data collected for
needs documentation and detailed site analysis. Ultimately, this may
support more concrete use of indirect data and result in lower needs
documentation costs in the future. See Section II-D-3 of the Generic EIS.
C.38. In regard to terminating needs documentation activities when alternative
systems have been shown to be non-cost-effective, the guidance should
expand on this to say that this is more applicable in densely developed
parts of a municipality and where on-site systems are not viable.
(Wegwart)
R.38. The relationship between cost-effectiveness and housing desnity is a
central theme of the Generic EIS, and is discussed most directly in Section
II-F. We are hesitant to offer generalized criteria for terminating needs
documentation in the Region V Guidance for fear that, for instance,
planners would assume that the most densely developed part of a community
has to be sewered regardless of need, cost-effectiveness, or feasibility of
continued use of on-site systems.
C.39. The Region V Guidance states that the goal of needs documentation in Step 1
is to categorize lots into three groups: 1) obvious problems; 2) no
problems; and 3) potential problems. The Guidance also recommends
community-wide estimates of the type and number of needed on-site facili-
ties based on extrapolations from survey data. MPCA's policy is that all
lots will be evaluated, a designation of need or no need will be made for
each building, and technology will be selected for each need in Step 1.
(Wegwart)
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R.30. See reponse to comment 10, above.
C.40. MPCA feels needs should be established and approved before other facility
planning tasks are conducted. (Wegwart)
R.40. In theory, the need for a project should be established even before the
state puts it on the state priority list. Section II-C-1 briefly
discusses the evaluation of U.S. EPA's concern with defining needs.
Obviously, this EIS puts great emphasis on needs documentation.
Our analysis of the role of needs documentation in the Construction Grants
program has led to consideration of several levels of "need." First, there
is the need to start a project at all. A general description of local
water quality and public health problems backed up by some specific, if not
comprehensive, data should suffice. Facilities planning, including more
specific needs documentation work, might be authorized from this level of
description. Next, the problems must be quantified and evaluated to an
extent necessary to decide whether sewers are "needed" or not. Phase I
needs documentation will in most cases provide a sufficient data base for
this. Needs must be studied in greater detail (Phase II) in order to
estimate costs and management requirements for proposed actions using
optimum operation. The need studies get most specific in detailed site
analysis for final technology design.
Thus, we concur that sufficient evidence of water quality and public health
problems should be submitted before facilities planning is started. The
states, of course, have great discretion in saying how much evidence is
required. But once facilities planning is begun, needs documentation and
other facilities planning tasks should be closely coordinated and can often
be done concurrently.
Grants Administration
C.41. Despite the procedural guidance for needs documentation, alternatives
development, and shortcutting the Construction Grants process, the Generic
EIS does nothing to shorten or simplify the Grants process for small
communities. (Wolfson - informal comment not reproduced here)
R.41. Simplifying the Grants process, while a worthy goal, was not an issue of
the individual "Seven Lakes" EIS, the Generic EIS, or the Region V
Guidance. However, there has been an evolution of issues in Region V's
series of studies that produced these documents. Simplifying the planning
and design process is emerging as a key concern now that many of the other
issues have been addressed. We have addressed several possibilities for
speeding up and simplifying planning and in Technical Reference Document
XVI-D. "Alternative Construction Grants Procedures for Small Waste Flow
Areas" which has been incorporated in Appendix A along with the Guidance.
Until we have followed several communities through the steps outlined in
the Generic EIS, we are hesitant to get more specific about simplified
grant requirements.
C.42. The cost-effectiveness analysis charts presented in the Draft EIS (page 57
and 58) indicate that construction of sewers would be suitable only in
areas where significant growth is anticipated. Since sewer construction is
responsible, to some degree, for enhancing the growth of an area, the
conflict between growth and cost-effectiveness goals could be used by
reviewing agencies to withhold endorsement of sewers. (Smith)
R.42. There is no conflict between growth and cost-effectiveness. At issue is
whether the Construction Grants program will fund sewers where their only
advantage over the alternatives is to facilitate growth. The answer is no.
This does not preclude communities from seeking other means of subsidizing
sewer construction.
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C.43. On page 114, an internal EPA memo dealing with access to private wastewater
systems is paraphrased to say "that a local or municipal ordinance granting
access and control would also be considered equivalent to public owner-
ship." Has the EPA determined in which states such an ordinance is legal?
(Wolfson - informal comment not reproduced here)
R.43. No. This in an issue that EPA recognizes to be important. We have offered
several suggestions on gaining access in Section F of the EIS, and in more
detail in Technical Reference Document VIII-A.
We have studied and reported the benefits and costs of the Optimum
Operation Alternative. As expressed in Section I-B-5, it is now time for
the states to take the initiative, particularly on issues such as access,
to achieve this alternative's potential benefits.
C.44. Section V-A-4-d proposes that substandard on-site systems which 1) are not
failing but 2) are similar to systems that are failing, be eligible for
replacement. Data collection costs and time to establish similarity would
be excessive and possibly greater than the facility construction cost.
(Wolfson - informal comment not reproduced here)
R.44. The states and facilities planners will have to exercise judgement in
applying this guidance. Until they develop sufficient experience in
evaluating existing systems, some on-site testing and inspections may be
performed that, in retrospect, will be seen as unnecessary. Until the
learning curve is complete, some individual systems may have more time and
money spent on detailed site analysis than on construction.
The time and expense can be shortened and the benefits of experience made
available to more on-site designers by development of a performance
information system, as recommended in the Generic EIS, Section II-D-3.
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LETTERS OF COMMENT TO
TO THE DRAFT EIS
-------
J M HOLLAND D H NOLAND,JR RW FORCE
B H BACHTEAL R F BATZER
RETIRED PARTNERS
R L McNAMEt * S HERBERT j C SEELEY
McNamee, Porter and Seeleq
3131 SOUTH STATE STREET ANN ARBOR, MICHIGAN 48104 13131 665-6000
December 11, 1981
Gene Wojcik, Chief
EIS Section, Water Division
U.S. Environmental Protection Agency
Region V
230 South Dearborn St.
Chicago, Illinois 60604
Re : Draft Generic EIS
Rural Lake Areas
Dear Mr. Wojcik:
The following are comments on the Draft Generic Environmental Impact
Statement for Wastewater Management in rural lake areas.
ซ
1. The purpose of this document is unclear. Is the intent
to completely eliminate future EIS's for rural lake
projects, or to act as a guideline and a basis for
specific EIS's and aide communities in planning, construc-
tion and management?
2. If the intent of this document is to act as a guide, it
could be a valuable tool not only to those who prepare
EIS's, but to those who prepare any planning documents
(including 201 facilities plans) . If the intent of this
generic EIS is to replace future EIS's for rural lake
projects, it can only be detrimental to all rural lake
areas in question. Each lake and surrounding community
have specific characteristics applicable to their own area.
These factors may never be discovered and evaluated
by the sole use of this generic EIS. Portions of this
document could be used beneficially in the preparation of
an EIS for a specific area, and great costs could be saved,
however a Generic EIS could not effectively replace a specific
EIS.
3 . As a guidance tool , any alternative to optimization of an
existing on-site facility would be more difficult to get
approved by the reviewing agencies. Following this guide,
optimization of an existing on-site system would almost always
be the most cost effective alternative.
-------
MciNamee, Porter and Seeleq
Gene Wojcik
December 11, 1981
Page Two
4. Assuming the cost effectiveness analysis charts presented
in this document are accurate, the only time construction
of sewers (gravity or pressure) would be suitable, would
be in areas where significant growth is anticipated. Since
sewer construction is responsible, to some degree, for
enhancing the growth of an area, this conflict could be
used by reviewing agencies against an endorcement for sewers
5. The environmental inventory included in an EIS must be as
site specific as possible in order to get a true indication
of what impacts would be expected from the construction
of the proposed action. The Generic EIS would not be site
specific. The type of impacts that can be expected are
brought out by this document (such as, degradation of water
quality, erosion, etc.), however the results could not be
quantitative.
Thank you for providing the opportunity to comment.
Very truly yours,
MCNAMEE, PORTER AND SEELEY
BY' *...,,...,( \ 'V...A (
Raymfcnd J. Smit
RJS:dr
-------
Johnson & Anderson, Inc.
Consulting Engineers
2300 Dixie Highway
Pontiac. Michigan 48055
Telephone: 313-334-9901
December 3, 1981
'8i
\'t
%ซ
Sป
Mr. Gene Wojcik, Chief EIS Section
U.S. Environmental Protection Agency - Region V
230 South Dearborn Street
Chicago, Illinois 60604
Re: Draft Generic Environmental Impact Statement for
Wastewater Management in Rural Lake Areas
Dear Mr. Wojcik:
Thank you for sending me a copy of the Draft EIS for review. I am
currently developing facilities plans for two townships on the suburban
fringe of Detroit, specifically in northwestern Oakland County. As the
study areas encompass more than two dozen inland lakes, I have found
your case studies on "Alternative Wastewater Treatment Systems for
Rural Lake Projects" to be very valuable. We have used door-to-door
sanitary surveys, wellwater quality sampling, 'and the septic leachate
detection survey techniques in our attempts to document water pollution
and public health problems from septic systems per PRM 78-9. I believe"
that the EPA made their point in the first case study on Crystal Lake
that these techniques are required for adequately documenting the need
for the project. Therefore, though interesting, I have honestly failed
to see why EPA conducted six other (very similar) rural lake EIS's,
rather than requiring the communities' consultant to do the necessary
work.
Each of the three EIS's that I've seen (Crystal Lake, Otter Tail Lakes,
and Nettle Lake) are almost identical in approach, and are identical in
recommended actions. The recommendation for "site-specific environ-
mental and engineering analysis of existing on-site systems throughout
the proposed service area" has appeared in each EIS. This would seem a
better topic for a case study rather than preparing more EIS's
providing virtually a repeat of approaches taken in the earlier works.
I would especially be interested in knowing the correlation between
effluent plume detection by "septic snooping," and the type of repairs
able to abate this condition. Also, the application of the above-
menti^ned techniques to urban and suburban unsewered inland lake
communities would have provided more fruitful information, and may have
modified some of the documentation of need criteria.
Other questions I have concern the recurrent themes brought out in the
Draft that: (1) except for unusually severe cases, preventing nearshore
plant growths in the main body of a lake is not a sufficient
justification for abandoning on-site systems, and (2) abandoning
on-site systems adjacent to embayments and canals may be justified if
non-point source control measures are implemented prior to or along
with the construction of off-site facilities. What constitutes an
"unusually severe case," how is the significance of non-point sources
going to be determined (especially in the case of shallow lakes
dominated by macrophytes, which to my knowledge do not lend themselves
to current water quality modeling techniques), and where is the
8
19
23
-------
U.S. Environmental Protection Agency - Region V
Page Two
December 3, 1981
community going to get the necessary funds to implement the required
control measures (if for a private lake-not eligible for Section 314
grants)? Furthermore, the above two statements do not appear to be
consistent with the "collector sewer eligibility-decision flow diagram"
appearing in the Region V guidance. According to the flow diagram,
nuisance aquatic plant growth should either be categorized as a valid
problem, or not a problem, and the density criteria of 10 persons/acre
used to determine the justification for abandoning on-site systems.
Therefore, if nuisance aquatic vegetation are a problem, either the 10
persons/acre criteria should be eliminated (which would be violating
PRM 78-9), or the two themes mentioned above should be revised by
replacing "abandoning" with "upgrading, replacing or abandoning."
<
With regards to the eutrophication model developed in the Draft
(pp. 102 - 105), is the "water flow through the lake, Q" supposed to
represent inflow or outflow? Note that the areal water load should be
represented by the symbol "q" rather than "Q" when describing the __
sequence of calculations (just a typo). Is this model meant to be
applied to shallow lakes dominated by littoral macrophytes, or just to
deep lakes with algal populations? How can it be applied to kettle
lakes with no surface inflow or outflow? This section of the report
starts off by stating that abandoning shoreline systems will seldom
result in a change in lakewide trophic status. From my experience this
seems reasonable, however, as the report mentions, systems along
certain portions of a shoreline may produce localized water quality
degredation. For example, total phosphorus concentrations in surface
water samples taken from leachate plumes in two lakes we surveyed all
contained concentrations 2 to 3 times (0.05 - 0.12 tng/1) greater than
background levels. In addition, total-P in groundwater samples at
plume sites were generally elevated over background levels. It was
evident from these analyses that active discharge of phosphorus into
the lakes is occurring from certain shoreline septic systems, generally
from homes on low-lying lots, with dwellings tightly packed, and with
systems located on the lakeside rather than the roadside of homes.
Massive algae blooms and/or weed growths usually accompanied these
local problem areas and often prevented a septic snooper scan along the
entire shoreline. This example again brings out the point of: What
constitutes an "unusually severe case" of nuisance aquatic plant
growth? Can a model reflecting localized degredation be developed to
answer this question, since the model discussed above is really only
valuable for extreme cases?
*
In the section on bacterial contamination, it is implied that one fecal
coliform sample from leachate plumes during snooping would provide
sufficient data for alternative development and plan selection. Giving
credit to the Michigan DNR for pointing this out in our studies, it
should be noted that the State of Michigan Water Quality Standards
dictate that fecal coLiforra contamination (for total body contact)
shall be determined on the basis of the geometric average of any series
of 5 or more consecutive samples taken over not more than a 30 day
period. _
23
26
27
-------
U.S. Environmental Protection Agency - Region V
Page Three
December 3, 1981
Therefore, septic snooping may indeed be a rapid method for determining
locations of problem systems, but a long-terra sampling program would be
necessary to document a public health hazard from bacterial contamina-
tion.
The report mentions several limitations inherent with the septic
leachate detection technique. It fails to discuss one of the key
items, however, that of proper timing. Weed growths present an
obstacle that hinders adequate scanning, so a survey would have to be
scheduled for early spring (just after ice out) or late fall (hopefully
after weeds expire). However, since cottages aren't occupied in
spring, the only time to really obtain an adequate survey along a
summer-oriented recreational lake is during a month or two period in
late fall. The importance of Construction Grant funding in time for
such surveying is thus crucial, or a less than optimal survey would
have to be undertaken.
Finally, what is a "flowing effluent pipe" as mentioned in the new
(undated) Region V guidance as direct evidence demonstrating an obvious
problem; and how does the identification of one, in itself, constitute
a water quality or public health problem? The only reason I bring this
up is because the Region V guidance appearing in the Crystal Lake Final
EIS (July, 1980) considered the detection of sewage effluent through 29
"septic snooping" as a criteria for direct evidence, and now this
criteria appears as indirect evidence until the effluent is quantified
and shown to be a problem. The change seems to be warranted in order
to obtain prima facie evidence of water quality or public health
problems, but I fail to see how detecting a flowing effluent pipe
provides similar evidence.
I'm sure that answers to these comments will help me immensely in my
facilities planning, and wish to thank you again for allowing me to
comment on the report.
Sincerely,
JOHNSON & ANDERSON, INC.
Michael A. Czuprenski, P.E.
Project Manager
MAC:klp
-------
Energy Research Center Morgantown, West Virginia
EPA Small Wastewater Flows Clearinghouse 26506
(800) 624-8301 . (304) 293-4191
West Virginia
University October 13, 1931
Jack Kratzmeijer
US EPA EIS
5WEE
230 S. Dearborn
Chicago, IL 60604
Dear Jack:
A quick review of the executive summary for the "Draft Generic
Environmental Impact Statement for Wastewater Management in Rural
Areas" by WAPORA Inc. raised the following concerns with that report.
1. Vacuum sewers have been ignored. These systems have proven
cost effective in areas with high groundwater around water bodies,
or in areas with shallow soils over bedrock. Figures of the
cost per resident vs. density need to be developed. Brian E.
Foreman, Chief Engineer for AIRVAC, should be contacted for
information or review of figures from WAPORA. He may be
reached at 219-223-3980.
2. Recommendations for design of small diameter sewers with septic
tank effluent hayt recently changed. A copy of a paper by
Otis following his experience along with that of Simmons is
enclosed. These recommendations are based on inspection of
an existing system which remained full at all times, having
been designed on hydraulic grade lines instead of pipe grades.
These recommendations will have a very significant impact on
the cost of these systems and therefore needs to be evaluated
by WAPORA. Figures for these "effluent sewers" should be
included in the cost effective curves along with the small
diameter sewers. Acceptance of either design may vary from -.
site to site and the cost of rejecting the "effluent sewers" -'-'-
must be recognized.
3. In general the assumptions for all the cost effectiveness
curves need to be clearly stated. It may be appropriate to
add them in an appendix. Without this information the value
of a curve is significantly diminished. For example on
pressure sewers or vacuum severs, what is the density of
pumps or valves to residential units? If more than one
unit is served, cost savings are very significant. There are
many other assumptions which may have a significant impact on
cost and therefore must be defined.
Equal Opportunity / Affiimative Action Institution
-------
Page 2
October 13, 1981
I would appreciate receiving a copy of the final copy of this
report. Could you also please put me on your mailing list for
draft and final Environmental Impact Statements. Should you need
additional information, please give me a call.
Dix
Technical Director
SPD/kap
Encl:
-------
MOORE & PETERSON
CONSULTING ENGINEERS
CIVIL ENGINEERING DESIGN
WATER SUPPLY \Mป STRUCTURAL
SANITARY ^ SEWERAGE
COMMERCIAL AND INDUSTRIAL BUILDINGS
HERBERT MOORE REPORTS . APPRAISALS EXPERT TESTIMONY LAWRENCE E. PETERSON
REGISTERED PROFESSIONAL ENGINEERS AND UNO SURVEYORS 2351 NORTH HUMBOLOT AVENUE MILWAUKEE, WISCONSIN 53212 414-372-8680
December 12, 1981
Mr. Gene Wojik, Chief EIS Section,
Water Division
OS EPA Region 5
230 South Dearborn St.
Chicago, Illinois 60604
Dear Sirs
My comments on the Draft Generic Environmental Impact
Statement for Wastewater Management in Rural Lake Areas are as followsI
On-site waste disposal constitutes a sanitary engineering
problem. For 100 years it has been known that sewage can be treated
by aeration by bubbling air through the liquid waste water*
Organic matter is oxidized and becomes water and carbon dioxide*
Yet State Health Departments and County Agencies seem to be
preoccupied with code changes, and have not yet,to my knowledge,
encouraged the use of aeration which along with evapo-transpiration,
would save billions of dollars in unnecessary sewer costs.
Sincerely,
--I i-t-CH IL
Herbert Moore
-------
The E. J. Wilson Company
22O9 E. 1OTH ST.
INDIANAPOLIS, IND. 462D1
(317) 637 - 93D7
RECEIVED*
DEC 1 5 1981
P.O. BOX IBB
CDRDRY LAKE
NINEVEH, INDIANA 46164
(317) 933 - ZD45
December 12, 1981
7
Mr. Valdas V. Adamkus De^i/%
Acting Regional Administrator ฃPA REGION 5
U.S. EPA Region V
230 South Dearborn St.
Chicago, 111 6o60*t
Subject: Comments on the DRAFT GENERIC ENVIRONMENTAL IMPACT STATEMENT
for WASTEWATER MANAGEMENT IN RURAL LAKE AREA.
Page 27 Table II-A-1 Does not included better treatment than a septic,
i,e, aerobics that will provide great reduction in
BOD, SS and Fe Col plus provide life-supporting
oxygen that will help in the soils.
Consequently: A system does not require as much sub-surface finger system
as for a septic to have the same safety criteria.
Will transpirate through soils deemed too severe or proven
unfit for septic effluent.
Comments: Depending upon County records is very inadequate. For example, _J 28
in Boone County Indiana the Sanitarian testified a few weeks ago
in a lawsuit where the homeowners were demanding $90,000.00 for
damages, etc. because of a malfunctioning septic system. The
Sanitarian presented as evidence their file. Two adjoining homes
are similiarly affected, but nothing was reported of them. After
a bench trial, the folks were awarded only $4,000.00 which would
not recompense them for even a part of their alleged costs to
say nothing of their non-use and inconvenience.
In another sub-division in Boone County two systems have been
re-worked in less than two years. I know of another in the same
area that is fiiling. Boone County does not recognize these as
failures.
Cedar Bend sub-division has many failures. No reports, otherwise
their would be abatement efforts, woundn't there?
A Lawn & Garden shop in Boone County has been pumping effluent
out of an end of a finger onto the ground for ^ years. No record.
Oil, Inc. a new fueling station just off 1-65 ฐn 33^ has a new
septic/mound. Failed from the start. No abatement (naturally,
because the state regulatory people designed it by regulation)
In summary, you cannot get good information from regulatory people who are I 28
not doing their job (just why would write another page). I
I am very successful working four sub-divisions around Mores & Geist lakes,
which are the Indianapolis Water supply. With over 60 satisfied customers,
I must be doing something right. Why don't you see what is being done?
Enc: Several newspaper stories
Edward J. WiZfeon
-------
ZIONSVILLE - WHITESTOWN
HOMETOWN NEWSPAPER
Wednesday Morning, December 2,1981
Judge Awards $4000
In Sewage Suit
Boone County Circuit
Court Judge Ron Drury
has awarded $4000 to a
Ziorisville couple in their
suit against the R.L.
Turner Corporation over
damages from a septic
tank failure. Anthony
(Hank) and Paula Ander~
son had asked $90,000 fin
damages and inconve-
niences resulting from sep-
tic failure at their house}
on Zion Lane east of U.S. t
421.
According to Mrs.
Anderson, the problem
began shortly after their
house was built in March ;
of 1977,' with toilets.back-
ing up and a backyard
odor so bad that at times
the family was forced to
(Cont'd. on Page 14)
Judge Awards -
vacate the house and stay
either with friends or in a
motel because of un-
sanitary conditions.
Greta Hawvermale,
Boone County Sanitarian,
gave a deposition staling
that the septic tank in-
stallation was in accord
with county regulations
and that an appropriate
size tank was used. Ac-
cording to Ms. Hawver-
male, "The installation |
met code and re-'
quirements,"
Ms. Hawvermale says
that the county ordinance
has changed and that there
is now a state regulation
governing the installation
of on-site sewage disposal
systems. She adds that
soil criteria has also
changed for such systems,
and no on-site systems will
be allowed where soils are
rated "severe."
Asked if the new legisla-
tion should keep such a
failure as the Andersons
from happening, Ms.
Hawvermale said, "I can't
give an absolute answer to
that, but, generally speak-
ing, the state regulation is
a lot stronger than a lor of
from Page 1
local ordinances; so
theoretically, you
shouldn't have this type of
problem occuring unless
you have abuse by the
homeowners."
Mrs. Anderson says
that her concern is that
such a problem can exist
and the system still have
met standards. "We feel
like we won but we won a
losing battle," she says.
"Until something is done
to make the county realize
you just can't say that
those are the standards
and not follow up to see
that they are'waking pro1:
perly, then thert'i* a pro-
blem."
Judge Drory said that
the Andersons were
awarded money when the
court determined their
allegations were true.
"The court found that the
allegations of the com-
plaint were true and
awarded money," said
Drury on Tuesday. "They
(the Andersons) alleged a
faulty septic^ 'system and
water damage to the
home, and that's what
they recovered on."
"Thought" provoking comments........
How long is a builder responsible?
Regulations do not assure performance, do they?
Do the regulatory people assume any legal or financial responsibility?
Now ..... what do the owners do?
Can they continue to live in the home under described conditions?
Will the County regulations regarding "correction" or "cease & desist" be applied?
What about neighbors and others who have similiar problems? Will they sue?
"Severe" is a relative definition it is not "all things to all people"!
How much of your county has "severe" rated soils?
Are they going to stop people from building on their land, if possible?
Why not be more receptive to private industry developed "higher technology"?
Concerned,
PS Maybe they should have spent more money and had a Cromaglass Aerobic System....
-------
The E. J. Wilson Company
22C39 E. 1OTH ST.
INDIANAPOLIS, INO. 462O1
(317) 637 - 93O7
Since 1950
P.O. BOX 188
CDRDRYLAKE
NINEVEH, INDIANA 46164
(317) 933 - 2045
THE INDIANAPOLIS STAR
WEDNESDAY, NOVEMBER 19,1980-
Funds for septic tank check'
The U S Environmental Protection Agency has
awarded the Indianapolis Department of Public Works
$435,000 to develop a system of locating septic tank
failures and studying their solution
City officials are notified of failures either by the
Marion County Health and Hospital Corp. or petifions
from citizens wishing to be annexed into the sewer
system
The grant, under the Clean Water Act, will finance
the use of aerial infra-red photography to spot potential
problems, analyze soil and groundwater data and find
environmentally sound and cost-effective''methods for
disposal of the waste, public works director Richard A.
Rippel said.
-------
The E. J. Wilson Company
2209 E. 1QTH ST.
INDIANAPOLIS, INO. 462D1
(317) 637-93D7
Since 1950
P.O. BOX 18B
CQRDRYLAKE
NINEVEH, INDIANA -46164
(317) 933 - 2045
THE INDIANAPOLIS STAR
FRIDAY, NOVEMBER 14,1980
City given federal grant
to study sewer overflows
The Indianapolis Department of Pub-
lic Works has received a $1.7 million
grant from the U.S. Environmental Pro-
tection Agency to study sewer flooding
problems.
The 18-month survey, required by fed-
eral law, will examine the causes of the
overflows, their extent, the environmen-
tal effects and costs of correcting the
problems, said Richard A. Rippel, works
department director.
"In the past, the prevailing thinking
was that sewer overflows during rainfalls
were looked upon as having negligible
environmental impact, due to stream
dilution," Rippel said.
"However, recent experience indi-
cates that the overflow pollutants may
settle in streams, causing pollution prob-
lems and health hazards long after the
rainfalls have ended," he said.
The extent to which overflow reaches
the treatment plants and causes damage
there also will be reviewed.
The study will concentrate on the
older sections of sewers that handle both
floodwaters and wastewaters, but also
will include 123 points where overflow is
discharged into White River, Fall Creek.
Pogue's Run, Eagle Creek and Pleasant
Run.
Two firms, Mid-States Engineering
and Howard Needles Tammen and
Bergendoff, will conduct the study, which
will produce a report which may be used
as the basis for a federal grant applica-
tion to correct flooding problems, Rippel
said.
-------
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-------
BROWN COUNTY DEMOCRAT
WEDNESDAY. JL'NE 3,1981
Helmsburg Elementary School
Brown County, Indiana
Specified (based on 7000 GPD)
Use existing 7260 gal septic
Eliminate dosing syphon
1157 gal dosing chamber
2 3 Hp 230-V Weil sewage pumps
60' x 40' above ground sand
filter (concrete)
1077 Gal chlorine contact tank
Stick chlorinator
Flow recording meter
Piping to stream to Lake Lemon
Bid; $73,000.00
Extras needed:
+ NPDES permit
+ Certified operator
+ Reports, etc.
Conversations at Board Meeting
Engineer Rep: "The Indiana
State Board of Health wrote
the specifications!"
Board Member: "Then why are we
paying you
911
Conversation at ISBH office.
Staff member: "If you use
the alternate and have the
slightest failure, we will
close the school in a day!"
Note: Mr. Ralph Pickard
corrected that statement!
As another taxpayer, knowing
school financial problems
What do you think?
Septic-improvement costs
awger school board;
blame is laid on state
Complaining bitterly all the way, the
Brown County school board last week
approved spending what the mem-
bers believe is about twice as much as
necessary to upgrade waste-treat-
ment at Helmsburg Elementary
School.
Board members laid the blame for
the alleged excess on the state Board
of Health.
The state's insistence on a relative-
ly-expensive solution to a pollution
problem was termed:
"Extortion" by school superinten-
dent John O'Dell,
"Blackmail" by board member
Rupert Miller, and
"Pretty much twisting our arm"
by board member Steve Miller.
* Septic improvements are sched-
uled for both Helmsburg and Sprun-
ica as part of expansions at both ele-
mentary schools. The school board
is under the gun to award a contract if
the work is to be completed on time.
Board members said they wished
they could choose between a bid cov-
ering both projects and totaling
$143,765 and a proposed alternative
that might cost half that much.
But, the state board of health won't
allow the alternative.
The complaints focused on the work
at Helmsburg, where no additional
plumbing is planned.
Rupert Miller was less eager to
argue about the Sprunica work be-
cause additional plumbing was
planned there.
But why, Miller asked, should the
school system pay $73,000 for work at
Helmsburg that could be done for
$24,000 when the upshot would mean no
extra demands on the school's waste-
treatment system.
"They (the state) are saying,"
board member Canden Nelson
reasoned, "that we've had a defective
system for years" and that it should be
fixed-
School business manager Jack Lutes
acknowledged the Helmsburg septic
system had been using an illegal drain
for as long as 12 years.
Nelson granted the weakness of
most septic systems in the county.
"In (rainy) weather like we're
having now," no systems in the county
are working, he said.
Still, O'Dell appeared mystified.
"All you need is a hole in the ground
with enough sand filters . . . There
truly are simpler systems (than what
the state requires)," he said.
Because of the need to make a quick
decision, the board voted to bow to the
state requirements and approve the
more-expensive work. Rupert Miller
voted against that position as a
protest, although he admitted, "We've
done about all we can."
In other business at its meeting last
Wednesday night, the school board:
Delegated to O'Dell the re-
sponsibility for determining when the
regular school day hours will be al-
tered S'r1- - "ซ- ปvn-
P
-Qreg Temple
Alternate Considered
Edward J. Wilson, P.E. (practical exp-
erience) found tank type urinals running
24 hr/day 7days/week 52 weeks/year
Actual water use now: Under 3000 GPD
Bona-fide offer to install;
Use 7260 gal septic tank as comminutor;
trash collector; pre-treatment; lift
station; equalization tank to spread
the 8 hour loading over 2k hours.
Two (2) Cromaglass Aerobic "Batch-Treat"
CA-25's (2500 gpd each, or
One (1) Cromaglass CA-50 (5,000 GPD)
6000 sq ft "Proven Performance" aerated
sub-surface finger system.
Full two (2) year warranty.
Offer to bond entire system!
Price: $35,000.00
Savings:
Call "Mr. Experience" Ed Wilson ac 317 637-9307 2209 E. 10th St., Indpls
-------
ZIONSVILLE - WHITESTOWN
HOMETOWN NEWSPAPER
The SENTINEL DISPATCH (USPS 560-850) \*
publi ibinlake,
Incoi vn, IN
4607
4607 Wednesday, June 10, 1981 *"' IN
ft anges to
SEN testown,
IN 4hU75.
OW>ED AND PUBLISHED BY
CABINLAKE, INCORPORATED
Darvl and Susan Dean
EDITOR: Donna Monday
ASSISTANT EDITOR: Joan Lyons
LETTER TO THE EDITOR
Boone Health Department
Warns Of Sewage Problems
At Cedar Bend
Editor's Note: The
following letter was sent to
Beaty Realtors, which will
handle Satnrday's Cedar
Bend auction by Greta
Harermale of the Boone
County Health Depart-
ment.
It has come to the
attention of the Boone
County Health Depart-
ment that you will conduct
a sale of lots in the Cedar
Bend Sub-Division located
in Boone County. This
sale is advertised to be on
June 13, 1981.
if Our department is
K9|re of serious sewage
pftposal problems in Ce-
ffarBend. We believe that
we should advise you of
this problem so that you,
as the seller, can accurate-
ly inform potential buyers
of what they might expect.
There is approximately
a forty percent failure rate
of on-site sewage disposal
systems. Basically, the
problem is caused by the
absence of topso.il on most
lots and hard clay just
beneath the surface which
prevents adequate sewage
absorption.-
Because of the problems
experienced with tradi-
tional methods of sewage
disposal, we required the
owner, Jack Clark, to
submit additional data
with his permit applica-
tions for approval of sew-
age systems. The details
are contained in a letter to
Jack Clark dated October
3, 1980, a copy is enclosed.
Copies of correspon-
dence concerning this
problem are attached for
your edification.
In my opinion, any
sub-surface absorption
system has limited chance
of success at Cedar Bend.
Mr. Jerry March, Boone
County Planning Director,
met with me to discuss our
responsibility and duty
relative to this problem.
He will submit his position
to you in a separate letter
which is to be sent with my
correspondence.
If you have any ques-
tions, please call me at one
of the numbers given
above.
Very truly yours,
Boone County Health
Department
Greta J. Hawvermale,
RPS., Chief Sanitarian
-------
WEDNESDAY. OCTOBER 28,1981
BROWN COUNTY DEMOCRAT
Residents are doubtful
sewage woes will end
with new lift station
Alberta Schrock sat and lis-
tened for about an hour as the
experts did their best to assure
her the sewage probably
wouldn't continue to back up in
her shower and flood the cabin
she hasn't been able to rent for
three years.
When they were finished,
and town board member Bob
Piers asked Mrs. Schrock
what she thought, she replied:
"I guess I'm from
Missouri."
"You mean," replied Piers,
"we're going to have to show
you?"
Mrs. Schrock nodded.
The Schrocks and other resi-
dents of southwestern Nash-
ville have for years lived with
the stench and extreme
nuisance created by a mal-
functioning sewage lift station
at the end of Washington
Street near Salt Creek.
They believed with the new
expansion and improvement of
the town sewage system that
lift stationand their
troublewould be moved
across the creek.
It won't be.
A final revision in the plans
calls for the station to be re-
placedbut not moved.
Steve Williams, represent-
ing A&E Engineering, the con-
sultant to the town on the im-
provement project, outlined
for Mrs. Schrock and the town
board last Thursday evening
how the new lift station would
work.
First of all, he said, the new
equipment in the station would
be much improved over the
present equipment and would
work much better and more
quietly.
Second, since the sewage
from the east side of town-
including the heavy sources
from the motels and thk
nursing homewould be
diverted to a new station be-
hind the Brown County Inn, the
Washington Street station
would have far less work to do
and would run less often.
Third, but not least, moving
the station across the creek
would cost about $200,000 as
compared to the $65,000 cost of
replacing the station at its
present site.
As Williams proceeded, Mrs.
Schrock, speaking for her
neighbors, too, questioned his
explanations.
Basically, she said she'd
heard all he had to say
beforeyears before. And she
wasn't about to believe what
she heard until she saw it
work.
Out of the discussion Thurs-
day grew the suggestion that
Williams investigate the cost
of installing in the sheriff's
office an alarm that would
sound if and when the Wash-
ington Street station malfunc-
tioned.
Presently, there is only a red
light that, when it burns,
raises questions about the
neighborhood, but is more
often than not burned out, Mrs.
Schrock said.
Also present for the dis-
cussion was Nashville resi-
dent Oral Hert. recently
retired executive secretary of
the state Stream Pollution
Control Board.
Hert advanced suggestions
and questions, but declined to
give an over-all professional
opinion of the plans for the
town project.
"I've been in administra-
tion for 10 years and out of it
(technical work) too long," he
said.
In an informal discussion
with town board president
Marge Tissot before the meet-
ing started last Thursday,
Hert explained that the state,
rhad not cracked down on the
^malfunctioning of septic*
' systems in the Coff ey Hill area"
I east of town because the situa-,'
'(tion involved only residential
systems.,
'__ If the state investigated all
'residential complaints. "T
^could spend aH their time in_
'Indianapolis^' he salcL"
As a practical1matter.t.ho!me...
problems are left to the county^
^sanitarian to solve, he said,
' Hert did observe that 30 to 40,
per cent of all septic systems"'
"have problems.
Even "newT homes bein
Duilt (with septic systems) wi
ivsu
thre
I-
have probTemsln three to four,
years." he said "~"
Some municipalities have
attempted to solve home
septic-system problems by
taking homeowners to court
and having a judge declare
their homes unfit for human
habitation and order correc-
tions made.
One purpose of last Thurs-
day night's board meeting was
to review matters that may
arise at the town board's
regular monthly meeting on
November 2.
,Itwas noted that Carl Brum-
metf "ha"cf; complained* - about *
drainage problems caused by
damage done to a culvert near
the Bean Blossom cemetery
when town water lines were
being installed.
Greg Temple
-------
1981-16-81
Mr. Gene Wojcik
Chief, EIS Section, Water Division
U.S. EPA, Region V
2320 South Dearborn St.
Chicago, CA 60604
Attn: 5WEE
Dear Mr. Wojcik,
In response to Mr. Adamkus' solicitation for comments of 1981-09-24, on the
Draft Environmental Impact Statement (EIS) for Wastewater Management in
Rural Lake Areas, we are submitting the following observations.
(1) The report is intended to serve in a generic way to recommend analyses
and methods for the evaluation of alternative wastewater management
solutions.
*
(2) That being so, the report is deficient since it is totally lacking any
discussion of the effect of the choice of discount rate on the relative
merits of projects.
(3) The report does not even state what discount rates have been used to 12
derive the cost comparisons in Chapter II, Section F. A sensitivity
analysis using different discount rates in computing the present worths
ought to show that the figures in the Section can change dramatically
according to what discount rate is used, thus indicating that the choice
of discount rate is an important matter.
(4) Nor does the report offer any suggestions as to what discount rate to
choose. Appendices C and D use as an example a certain rate but no
justification is given for that particular choice.
(5) At a minimum, the report should offer guidelines in the choice of
discount rates taking into account that most wastewater management
project are financed largely through public funds. Therefore, the
discount rate ought to reflect the opportunity cost to the society for
undertaking such projects. The weight of credible evidence seems to
suggest a real (that is without inflation) discount rate of the order 4 to
5%.
(6) I am attaching a copy of a memorandum from David M. Dornbusch on
the matter of discount rates, for your information.
Sincerely, /
v^l " .,
Caj OJFalcke
Sr. Economist
cc: Larry Silverman
David M. Dornbusch & Company, Inc. 1736 Stockton Street San Francisco, California 94133 (45) 981-3545
-------
i \ UNITED STATES ENVIRONMENTAL PROTECTION
WASHINGTON, D.C. 20460
DEC 2 1 1981
OFFICE Of
WATER
nOfORANOUM
SUBJECT: Qircount Rate for Cost-Effectiveness Analysis
/ ^ ' \
t Rate for Cost-
^ !]>'1 V s i ^ -< ..'
FROM: Henry L. L'onge'srn, Director^
Office of Water Program Operations (VJH-546)
TO: Water Division Directors
Regions I-X
The Water Resources Council published the new discount rate of 7 5/8
percent to cover the period of October 1, 1981 through September 30,
1982. in previous years grantees have been required to use the discount
rate published by the Water Resources Council in cost-effectiveness
analyses during facilities planning. As proposed, the revised program
regulations no longer include this requirement. This will allow grantees
to use other discount rates when appropriate.
You should recommend the use of this new discount rate for
cost-effectiveness analyses for facility plans starting 30 days after the
date of this memorandum. Discount rates applied to facility planning
starts .luring prior fiscal years are:
1978 - 6 5/8 percent (PRM 78-2)
1979 - 6 7/8 percent (PRM 79-4)
1980 - 7 1/8 percent (PRM 80-1)
1981 - 7 3/8 percent, (PRM 81-2)
1982 - 7 5/P percent
A copy of the Federal R_ฃ(jij>ter notice published by the Water
Resounds Council TiTrtTacfiecn TJopies of this memorandum should be
furnisned to the States and to new Step 1 grantees.
Attach-- :-nt
-------
52066
Feck-nil Kt^Ninr / Vol. -JO. No. ;;o5 / .Friday, October 2.'!. mi] / Notice*
Flows of t^e Advise: y Committee on
Inlcrn.itional Invcsfinrnl. Technology.
and Development. The Woikmy Group
will men! from 10 00 a.m. 'o 12 0') iuon.
The mt-eiing will be held in the I.oy
Henderson Conferev p Room of the
Slato Dcniiiimenl. ;.J1 C Slrci-l. N W.,
Washing.".:;). D.C. ;'<.'it Hit- mci-lmg
will be open io the [\:b;ic.
The purpose of !!;' nu'C'ing will lie Io
review the results r. the Sr-:jti:m!n:r M-
17 meeting of the 1C JP Working P lily.
the October 5-6 m.'.v.r^ on Pmacy
Guidelines Follow-up ll.e 0. Ujrr lii-21
Special Session on .'cforrr-atian
Technologies, Pic-ri -.^tivily and
Employment and lh< October 2'J-30
metling of the IB! U ukir.j; Party on the
International Context of Tr.u'sl.order
Data Flows. There v.iil elso be a
discussion of the pr; ,;osed U.S.
comments on the B'mq Report on Legal
Issues related to Trar.sborJnr Da!a
Flows, which comments are scheduled
for submission to ttv QF,CD in early
December.
Requests for further infoim.iliim on
the meeting should be directed io Philip
T. Lincoln, jr.. Deparimenl a Slato.
Office of Investment Affairs. Bureau of
Economic and Business Affairs,
Washington. D.C. 20520 He mny be
reached by telephone on (area C'ide 202)
632-2728.
Members of ths public u ishmg Io
at'end the meeting rrjst conuicl Mr.
Lincoln's office in order to arrange
entrance to 'He State IXparuni-nt
b-jtIJing
The Ch.iirman (,f !!:> Wuiknii; Croup
will, rti tirut permits enU-rinin oral
comments from men hers of the public
at!ซn',..(
DEPARTMENT OF T'r't TREASURY
Fiscal Service
(Depl. Circ, S70, 1961 ftjv,
Kj. 91
Surety Companies AccepUhlc on
Federal Bonds
A ci'rtific,jlfc of aulhoniy us un
acceptable sun-ty on T> dciai i)o>-.ilป is
hen by issi.cd to iha fallen in,; tumpnuy
under Socticru 5 to 1? c-f Ti:1'- 0 nf ilif
Uniied Stales Code. A.i
limitation of $202 000 has been
established for the company.
t\'ut:tc
VOYAGCR CASUA1TY INSURANCE
COMPANY
P 0 Dox JtUfl
I icls.somille. Florn1.;!
5,'a.'.:1 ci/ //u (i.'ojruf.1-.);
Co; ti fit. dies of jiiili.uity expire on
jun'j 30 ench ^ear, unless renewed prior
to that Jute or sooner revoked. The
c; rtificalcb me subject to subsequent
annual renewal so long as the
companies remain qualified (31 CFR,
Part 223). A list of qualified companies
h. published annually as of July 1 in
Dup-ir'incist Circulai 570, with details as
to underwriting limitations, areas in
which licensed Io transact surety
business and oiher infori^iation. Federal
bond-approving ofliters should annotate
Ihcir reference copies of the Treasury
C.rmlar 5"0. ll'Si Revision, at page
33975 to reflect tnis addition. Copies of
the circular, when issued, 'may be
obtained from the Audit Siaff, Bureau of
Government Financial Operations,
Department uf the Treasury,
Washington, D.C. 2022G.
n.ik'd Ociobi.T !fl. IJtil.
W. E. Douylas,
Cinniiii^si.'iiicr. V'irfOu of (.'di i-nnien/
CODE
WATER RESOURCES COUNCIL
and Standaras 'or V/ater
and Rfatcd L.anJ Resources Pint, rung:
Chan'j^ in Discount Hale
N'oiuji- is hereby jjivijn in uccordonce
>-. ;th 18 CFK 711 1~9 lh; t (ho interest rale
to be iJs-rd by Fedci'U aycniica in the
foinuilatinn and evaluation of plans for
w.iiei xind related Uinil ru&uurces is 74/B
pi.-rcunt for ihr; peiiod Ottobcr 1, 1081,
through a"d mcludiny September 30,
15H2.
'iliij rule has bet;.i cumpulud in
.u.cunl.mcH with 1ซ CFR 7IH.39
"D'bCt'unl Rale" of Ihe Wuler Resources
Cuuiu.'l. an! 19 to be tisfd by all Federal
a^i'iu u i in tha formul.ition and
i \ .I'tK-tion i,f w.itt-r and n-l.ilcj l.md
lir,c;ii>'i;S p'uns for ihu purpube of
disi ojntmg future bentfits and
g c-'^ts, or otb'Jiv\ isซ
viT'.mg brnefi's and co-,t<, to a
t uuu;ซ,!i siiTie basis.
Tin; I )opai Intent of the Treasury on
Oc.lobiM in, 1'Jtil, informed (lit- Wuler
Rrsourci-.i Council puisuant to laCTO
7(M 3')(b) that Ihe interest rate wduld be
12 !!< ju'K.rnl b.ised upon the formula sel
fiuth in 70'1 3D(ii): ..... the average
yield dm my iht; piecedmy fiscal year on
mliTi-il lic.niny mjiket.ibie securiiii'* uf
the IJiiih'd Sluti/s which, at the time ihu
C"i:iput.ilio:i i:. made, have terms of U
yc.ns i:r more lemaming to maturity
' ' '." llowi-vi-r. ง 704. 2!){a) further
pruvideM "" '" ' Thut in no event sh.ili
ill/- r.iic lie rmsi-d or lo\vorซ d moro than
om--i|Uiii IIT of one percent for any
year." Since the r.iie in Fiscal Yt-.ir I'JUl
\\,.is7jV,.j'rrcfiU H5_FR 70167), the raia
_
l_Dp2J_3_7jrperu(_'nl: '<
:l Ch.lolicr 15. 1iปBl
U. Si'in\viU,
JH< IVx.
COOE ซซIป-01-M
-------
MEMORANDUM
THE CHOICE OF A DISCOUNT RATE FOR
EVALUATING WATER RESOURCE PROJECTS
DAVID M. DORNBUSCH & CO., INC.
SAN FRANCISCO, CALIFORNIA
APRIL 81
-------
THE CHOICE OF A DISCOUNT RATE FOR
EVALUATING WATER RESOURCE PROJECTS
The evaluation of a long-term water resource project requires the
comparison of capital, operating and maintenance costs with a stream
of benefits that will likely occur over a long period of time. Because
the costs and benefits accrue at different times throughout the project
life, it is necessary to "discount" the streams of costs and benefits
to present values that can be compared with one another in a benefit-
cost ratio.
The "discounting" is performed using a discount rate that recognizes
the time value of money (future dollars having a lower present value
than current dollars). The choice of the appropriate discount rate is
complicated by inflation. If benefits and costs are projected in terms
of prices that rise with inflation, then the discount rate should in-
clude an inflation component. However, if the future stream of bene-
fits and costs are expressed in dollars that assume no inflation (con-
stant dollars), then the discount rate should also be one that omits an
inflation component. Either method is correct, as long as prices and
discount rate are consistent in their inclusion or exclusion of infla-
tion.
As economist Charles W. Howe states:
...it is permissible to follow either of the two paths:
1. Project future benefits and costs in terms of the
prices that will exist at the appropriate points in
time and take into account the expected rate of infla-
tion. This discounting process should then use a dis-
count factor that includes a component to compensate
-------
(2)
fully for inflation.
2. Project future benefits and costs in construction
period prices and make no upward adjustments for in-
flation. The discount factor must then not include
a component for inflation. General practice is to
project benefits and costs in construction period prices
and to make a downward::adjustment, if required, to the
discount factor.1
Thus we conclude that, in the case of general infla-
tion, it makes no difference whether we use (1) bene-
fits and costs all stated in construction period prices
and a discount rate containing no inflationary premium,
or (2) benefits and costs inr the prices of the period
in which each is incurred and a discount factor that
fully compensates for the rate of inflation.
The approach recommended by the U.S. Water Resources Council is
to express all costs and benefits in construction period prices and
make no upward adjustment for inflation. As stated by Hovje, this
requires the use of a "real" discount rate that does not include a
component for inflation.
In a 1975 discussion paper, the U.S. Water Resources Council concurs
in this approach:
Characteristics of the Discount Rate
The first characteristic of the discount rate is that
it is a "real" rate. The Principles and Standards
require an economic evaluation not a financial evalu-
ation of projects. An economic evaluation is the
comparison of the "real" benefits and costs of a project.
1. Howe, Charles W. ; "Benefit-Cost Analysis for Water System Panning";
Water Resources Monograph 2;American Geophysical Union, Washington,
D.C., 1971, p. 55.
2. Ibid.;p. 81.
-------
That is, the economic benefits in terms of goods and
services received are compared to the economic costs
in terms of goods and services required to produce the
benefits. This is done by measuring the benefits and
costs of projects in constant dollars, e.g., 1975
dollars. Because the effects of inflation (a rise in
the general price level) are excluded from the esti-
mates of project benefits and costs, each dollar of
costs or benefits represents the same purchasing power
regardless of when it occurs. Similarly, the discount
rate used to express future benefits or costs as present
values should be a real discount (interest) rate, that is
a discount rate in terms of goods and services as .opposed
to money. For this reason, observed market rates of inter-
est that is, nominal rates of interest are, not
directly applicable to water resource projects.'3
A problem arises in the selection of the proper discount rate to
use in analyzing the feasibility of a water resource development
project. The WRC recommends using a rate that seeks to reflect the
cost of long-term Federal borrowing. However, the WRC discussion
paper recognizes that this rate is inappropriate in that,
"the current WRC rate is related to the nominal
cost as opposed to the real cost of long-term
Federal borrowing."
In the early sixties when the nation's inflation was nearly zero,
the recommended discount rate was virtually identical to the real rate
and ranged in the neighborhood of 3 percent. However, when
inflation increased, the recommended discount rate was allowed to
rise, and it is then that it became related"to the nominal rate
(as opposed to the real rate and real long-term cost of Federal
3. "Options for the Discount (Interest.) Rate"; Part 4, Planning and
Cost Sharing Policy Options for Water and Related Land Programs;
U.S. Water Resources Council; Washington, D.C.; November 1975; pp. 4-5,
4. Ibid, p. 18.
-------
borrowing.) Presently, the WRC rate is somewhere between the real
rate and the nominal (fully inflated) rate, since its annual in-
crease has been arbitrarily limited to J percent. Therefore, the
WRC rate is now inappropriate for...either method of analysis described
by Howe.
Having established that the appropriate discount rate to use when
projecting future costs and benefits in terms of constant dollars
is a "real" rate, the next step is to determine what the long-term
real rate of interest is. The weight of credible evidence suggests
that the long-term real rate of interest is in the range of 2 to 4
nercent per annum.
Mr. Paul W. McCracken, Edmund Ezra Day University Professor, of Busi-
ness Administration at the University of Michigan and former Chairman
of the Council of Economic Advisors under President" Nixon; .stated in
an editorial in the Wall Street Journal, November 13, 1980:
"...the true interest rate [is] 2% to 3%..."
Messrs. Dale Jorgenson and Alan Auerbach, Harvard University economists,
were cited in Fortune Magazine, March 9, 1981, as follows:
"Why 4%? Because Jorgenson and Auerbacti believe that
is the best estimate of the average real return on
business equipment." (p. 96)
Messrs. William P. Yohe, Professor of Economics and Director of
Graduate Studies in Economics at Duke University, and Dennis S.
Karnosky, ^n economist with the Federal Reserve Bank of St. Louis,
-------
presented the results of a study of "Interest Rates and Price Level
Changes, 1952 - 1969" in the Federal Reserve Bank of St. Louis Review
December, 1969.
"Most significant is.-.the finding that price level
changes, rather than 'real' rates, account for nearly
all the variation in nominal interest rates since
1961." (p. 36)
(In other words, price inflation has accounted for the increase in
nominal interest rates).
Yohe and Karnosky used three different statistical methods to calcu-
late the long-term real interest rate between 1961 and 1969, and found
that while the nominal rate rose to nearly 8%. the rea.l rate was
consistentlv in the 2-4% ranere for each of the years during the*
period. (pp. 34-5)
Messrs. Roger G. Ibbotson and Rex A. Sinquefield reported the results
of a study of 50 years of real and nominal interest rates in a book
called: Stocks, Bonds, Bills, and Inflation: The Past (1926 - 1976)
and the Future (1977 - 2000), Financial Analysts Research Foundation,
1977. They show that thป average long-term real rate of interest,
averaged over the past 50 years, has been:
Long term corporate bonds: 1.8 percent
Long term government bond: 1.1 percent (p. 10)
Mr. Ranson, partner in H.C. Wainwright & Co. Economics, Boston,
writing in the Wall Street Journal, March 16, 1981, states:
-------
(6)
"The real rate of interest does indeed appear to be
roughly constant, averaging about 1.75% through 1965
and 2.5% thereafter."
Hence, we conclude that the real.interst rate, and therefore, the-
appropriate discount rate to use in determining the present values of
costs and benefits expressed in constant dollars is in the range, of
2 to 4% and is certainly not over 4%.
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333
(404) 262-6649
December 9, 1981
Mr. Gene Wojcik
Chief, EIS Section
Water Division
U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
We have reviewed your Draft Generic Environmental Impact Statement (EIS) for
Wastewater Management in Rural Lake Areas within Region V. We are responding
on behalf of the U.S. Public Health Service and are offering the following
comments for your consideration in preparing the Final EIS.
In general, we have no major objections to the development and management of
decentralized wastewater treatment in Region V provided such planning practices
satisfactorily protect public health and safety. The recommendations in the
EIS that define and document project need and water quality impact in unsewered
areas will hopefully encourage and enable State and local governments to (1)
assess the significance of their water quality and public health problems,
(2) optimally operate existing facilities and other low cost alternatives to
correct those problems, and (3) recognize those situations in which the optimum
operation approach is preferable.
The impact of a wastewater treatment plan and system upon existing and potential
vector populations capable of causing vector-borne disease problems or nuisance
problems should be considered in determining the acceptability of a given waste-
water treatment plan, particularly wetland treatment and pond treatment measures.
We believe the EIS should provide a more indepth discussion of the public health I
implications associated with sewage contamination of surface and subsurface I
waters. -I
We appreciate the opportunity to review this Draft Generic EIS. Please send us
one copy of the final document when it becomes available.
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
NORTH CENTRAL REGION
176 WEST JACKSON BOULEVARD
CHICAGO, ILLINOIS 60604
December 16, 1981
ER 81/2264
Mr. Valdas V. Adamkus
Acting Regional Administrator, Region V
U.S. Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
DEC 17 1981
EPA REGIOM 5.
OFOCfi PE BBSI.O.NA4!
ADMINISTRATOR/
The Department of Interior has reviewed the draft-generic environmental
statement for Wastewater Management in Rural J-,ake Areas and has found it
to be generally adequate with respect to consideration of resources within
our areas of jurisdiction and expertise.
"MMI
One item which should be addressed is the impact to mineral resources and
mineral production. Bureau of Mines data indicate that the principal minerals
or mineral products produced in the six-state area include cement, clays,
iron ore, lime, magnesium compounds, salt, sand and gravel, and stone. The
final report should acknowledge the existence of mines and potential mineral
resources within the project area and should define any adverse impacts that
the proposed action may have on mineral production. If no ongoing mineral
activity or mineral resources will be affected, a statement to that regard
should be incorporated into the project.
Thank you for the opportunity to comment.
Sincerely yours
Sheila Minor Huff
Regional Environmental Officer
-------
State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Carroll D. Besadny
Secretary
BOX 7921
MADISON, WISCONSIN 53707
December 22, 1981 File Ref: 1650-2
Mr. Valdas V. Adamkus, Regional Administrator
Environmental Protection Agency
Region V
230 S. Dearborn Street
Chicago, IL 60604
Re: Draft Generic Environmental Impact Statement,
Alternative Waste Treatment Systems for Rural
Lake Projects
Dear Mr. Adamkus:
The Department of Natural Resources has completed its review of the
above document.
As identified in this Draft Generic EIS, the use of alternative
treatment systems may represent significant cost savings over
convential treatment systems for many proposed projects. However,
implementation of these alternatives may also create other environ-
mental problems if coordination and approval are inadequate.
The purpose of on-site convential or alternative waste treatment systems
is to provide levels of waste treatment suitable to protect the environ-
ment. To encourage the use of alternative systems is commendable and
necessary, but should also include a thorough evaluation of the
demographic and economic environment as well.
As an additional recommendation, we would like to see greater
program emphasis placed on encouraging local governments to
recognize the potential for disturbance to and need for protecting
"sensitive areas" identified in this document.
As in the past, the Department will assist EPA in implementation of
this program pursuant to our statutory responsibilities. We hope
our comments will prove useful to your agency's development of this
Draft Generic EIS.
15
17
16
-------
Valdas V. Adamkus December 22, 1981 Page 2
The Department's Southeast District Office has requested an
additional copy of this document. Could you please forward one
additional copy for their use. Their address is: Box 13248,
Milwaukee, WI 53213.
Sincerely,
Bureau of Environmental Impact
Howard S. Druckenmiller
Director
cc: District Directors
Bob Steindorf - WW/2
John Cain - WQM/2
Oliver Williams - ILR/4
-------
STATE OF MICHIGAN
NATURAL RESOURCES COMMISSION
JACOB A HOEFER WILLIAM G MILLIKEN, Governor
E M LAITALA
PAUALRYHFWENDLLER DEPARTMENT OF NATURAL RESOURCES
HARRY H WHITELEY STEVENS T MASON BUILDING
JOAM L WOLFE BOX 30028
CHARLES G YOUNGLOVE LANSING, Ml 48909
HOWARD A TANNER, Director
April 19, 1982 ,,;; ^
11; ?, "H
.-"* t
!-rป ro
Mr. Jack Kratzmeyer, Project Monitor -' '->*
Water Division .7,'= r~ ป~1
U. S. Environmental Protection Agency -'-'- ',..-ซ
230 South Dearborn Street C-~ ^ '" -'
Chicago, Illinois 60604 'ฃ>
Dear Mr. Kratzmeyer:
Staff of the Department's Land Resource Programs Division, Inland
Lake Management Unit, has reviewed the Draft-Generic Impact State-
ment, "Alternative Waste Treatment Systems for Rural Lake Projects,"
by the U. S. Environmental Protection Agency, Region V. The remarks
of this Unit of the Department are limited to those elements of the
impact statement dealing with needs assessment of and environmental
impacts upon lake ecosystems.
Comments are brief due to the fact that the Division is in basic
agreement with the impact statement's assessment of the environmental
components, its evaluation of system alternatives, and generally sup-
ports the document's conclusions regarding lake ecosystems. Conse-
quently, remarks are limited to the following points:
v
1. The impact statement on pages viiiand ix and at other places
presents the conclusion that "preventing nearshore plant growth along
open shorelines of a lake is not a sufficient justification for aban-
doning on-site systems." The impact statement does, however, indi-
cate that this conclusion may not apply for particular, sensitive
areas, such as embayments, canals, and small lakes. It is suggested
that the open water areas of many large lakes can be similar to the 20
sensitive areas regarding recreational and water quality degradation.
Environmental factors, such as shoreline development shape factor,
orientation of the long axis of the lake in relation to the prevail-
ing winds, bottom sediment characteristics, etc., can also influence
the localized impact of nutrient loading. Consequently, we do not
agree that limited changes in plant productivity within the main body
R1026 1/80
-------
Mr. Jack Kratzmeyer -2- April 19,, 1982
of lakes is so universal to justify a generalized statement against
abandoning on-site systems. Instead, we would recommend a simple,
preliminary evaluation of each lake to assess the potential for
localized productivity impacts. This assessment would be very
simple and would require very little time. For a minimal cost, it
would permit resource managers to be relatively certain they were
not overlooking a problem that should be corrected. _
2. The section on modeling eutrophication (pages 102-105) is
unclear and difficult to follow. Symbols employed are not consis-
tent with usual notation used in limnological modeling. For
example, "Q" in the impact statement is defined as "water flow
through the lake" in m^/sec; it is normally defined as "annual
volume rate of water inflow" in m^/yr. Additionally, terms seem
to have several definitions. "Q" is defined as water flow through
the lake and, also, as inflow/outflow. The procedures also flip-
flop back and forth from the metric system to the English system of
measurement, i.e., Figure IV-D-1. It is recommended that this sec-
tion of the report be redrafted with a better definition of terms.
It may also help if an example were provided.
We thank you for the opportunity of providing comments for the Rural
Lakes Projects, Draft-Generic Environmental Impact Statement. If
there are any questions regarding these remarks, our staff is avail-
able for comment. ~~
Sincerely,
LAND RESOURCE PROGRAMS DIVISION
20
25
Howard Wandell, Aquatic Biologist
Inland Lake Management Unit
Land, Lake and Stream Protection Section
Telephone: (517) 373-8000
HW/cs
-------
1
fc^
TDCC
r^
Northwest Michigan
REGIONAL PLANNING AND
DEVELOPMENT COMMISSION 1^
ClWIE
BO East State Street Traverse City, Michigan 49684 (616)946-5922 Robert C. Morris, Exec. Dir. /
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10 December 1981
21
Mr. Jack Kratzmeyer, Project Monitor
Water Division, USEPA
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Kratzmeyer:
We have reviewed the Draft Generic Environmental Impact Statement
for Wastewater Management in Rural Lake Area's and have the
following comments.
Over the past several years our Commission has conducted several
lake studies using Cladophora as an indicator of phosphorus
sources to lakes. Our EPA project officer, Bernie Orenstein, is
familiar with our work and has copies of our reports. We have
been able to specifically link Cladophora growths with septic
system, lawn fertilization, and concentrated waterfowl-feeding
problems. We feel the Cladophora survey techniques should be
included on page 81 under "Effluent Surveys" or "Nonpoint
Source Monitoring" as a problem-identification technique. Your
EIS work particularly on Crystal Lake points out its value espe-
cially for Step I problem-assessment work.
You do discuss Cladophora on pages 105 and 106, but in terms of
the algae showing localized phosphorus contributions that you
feel will not affect overall lake trophic status, and in terms
of the algae itself negatively impacting swimming areas. We
can generally agree with the probable, minimal effect on trophic
status of these phosphorus contributions, but stressing the
impact on swimming makes it sound as though the physical pres-
ence of Cladophora is really the main problem. The main problem
is, of course, not the Cladophora itself, but the phosphorus
contribution which causes it. Unfortunately no one knows how
much of the phosphorus is used by the Cladophora and how much
remains available for use by other forms of plants such as free
floating algae. We assume t'oe Cl?c]ophora uses only a small amount
of the phosphorus entering the lake at that spot. We realize
that most nutrient budgets indicate that the total phosphorus
from septic systems is relatively small in contrast to other
sources, but what happens when you add to the septic problems
lava fertilization and/or concentrated waterfowl-feeding problems
which the Cladophora also pinpoint? Although individually a]] .
these phosphorus contributions uiay be small, they clo add up, and ' ^
1
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Jack Kratmeyer
Page two
10 December 1981
most important they are often controllable at the local level
in contrast to precipitation, dry fallout, and certain nonpoint
sources. These problems should be corrected as part of a total 22
lake management program and should not be minimized in importance
in the statement although we agree with practical cost considered
solutions.
We recommend that the discussion on pages 105 and 106 incorporate
the point we raise here and also make reference to the discussion
on using Cladophora as a survey technique which we recommend you
add on page 81.
If you have any questions about these comments please get in
touch with me.
Sincerely,
Chuck Grant
Water Quality Specialist
/cmt
cc. Bernie Orenstein
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*-1&r~J ^ "->
Jrntj j_ Minnesota Pollution Control ^Agency
r'i/V^XX^
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NOV 0 4 1981
Mr. Jim Novak " c.
U. S. Environmental Protection Agency
Region V
Attention 5 WEE/EIS
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Novak:
Re: Wastewater Treatment Facility/Environmental Impact
Statement, Moose Lake - Windemere Sanitary District
EPA Project No. C271301-01
We have reviewed the Initial Plan of Study (dated August, 1981)
and the Plan of Study (dated September, 1981) for the Moose
Lake - Windemere District and would like to offer the following
comments regarding the proposed tasks.
1. WAPORA proposes a soil mapping program for the shorelands
of the affected lakes in Pine County and to consider the
existing data regarding soils in Carlton County as adequate.
In order to verify the soils data in Carlton County it would
be beneficial to spot check areas with soil testing around
the lakes, such as soil borings and perculation tests.
2. The usefulness of a biological evaluation of the littoral
areas of Island, Sturgeon, Passenger and Rush Lakes is
questionable when considering the large number of variables
involved in sucli a st idy (i.e. time of season, bottom orienta-
tion to sunlight, bottom types, fish communities, etc.).
Collection methods for this type of data are likely to be
imprecise, and data interpretation may be highly subjective
and, therefore, subject to a good deal of error.
Phono 612/296-72101
1935 Woflt County Road 02. RosuซvilU\ Minnesota 551 13-2785
l Ollicor, Ouitith Ui.unoict D.'tioit L.iKi's M.itslull'Hoclu'stor
f Ulliil Op|><'((unity t mployt'r
-------
Mr. Jim Novak
Page 2
NOV 0 4 1981
3. The evaluation of swimmer's itch and blue-green algae
toxicity does not appear to provide any pertinent data for
this study. Swimmer's itch is a common summertime problem
in Minnesota and there is no reason to hypothesize the
existence of a special relationship between swimmer's itch
and the septic tank systems of these lakes. We are not
aware of any reported toxic algae blooms occuring in these
lakes. In conversations we have had with Philip Economon
from the Minnesota Department of Natural Resources, he
stated his January 16, 1980 letter, that had raised this
issue, was written in a more general context and not specific
to problems experienced in the Moose Lake area. We do
recommend you contact Philip Economon to expand upon this.
4. The plan of study states the data development for needs
documentation will be performed in accordance with the U. S.
EPA Region V Guidance on Site Specific Needs Determination
and Alternative Planning for Unsewered Area. In previous
discussions we have indicated some aspects of the EPA's
draft guidance (the one to be used for this EIS) that is in
conflict with the MPCA's criteria in this matter. Included
is a rather lengthy critique of the EPA's guidance that we
hope will be considered in development of Needs Documentation
and Alternative Evalution for Moose Lake. If these comments
are adequately addressed in the final EIS, the level of
documentation required for MPCA approval of a final alter-
native for Moose Lake should also be adequately provided.
Page 1 I. Objective - EPA - Statement that this procedure
"allows for a degree of risk inherent to limited
data gathering".
Comment - This seems to be a prelude to EPA usage
of limited survey samples.
Page 1 II. Goal - 2PA - Statement that the goal of this
process is that at the end of process, lots will
fall into 3 categories (1) obvious, (2) no problem,
(3) potential problems.
Comment - This seems to conflict with MPCA goals
of placing lots in either need or no need by the
end of this process. We would consider this 3
group concept as goal of phase I of the Needs
Survey.
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Mr. Jim Novak
Page 3
NOV 0 4 1981
Page 2 III.A.I. - EPA - Surface Failure by remote imagery
is direct evidence.
Comment - Remote imagery must be ground truthed as I -&\
part of the process to be valid. (
Page 2 III.A.4. - EPA - Contamination of water supply by
sewage is direct evidence.
Comment - Presence of these indicators cannot
conclusively prove defective sewage systems nor
indicate which system is the contributer. Other
more extensive ground water monitoring should be
included or perhaps an easier and conclusive dye
study may be used to link a contaminated well to a
failing septic system.
31
Page 2 III.A.5. - EPA - Samples of surface waters,
late
32
Comment - This appears to be a septic leachate
detection survey, which we also are accepting as
direct needs as long as the source of the plume
can be pinpointed.
Page 2 III.B.2. - EPA - States the water well isolation
criteria may be used as area wide evidence.
Comment - Caution should be used if this criteria
is used for the whole area. Each lot should be
substantiated to have this problem of water well
isolation. Also, proximity to wells does not
necessarily indicate a problem system.
Page 2 III.B.3. - EPA - Documented g.w. flow from drain-
field to well can override adequate separation
distance.
Comment - This is not included in MPCA criteria,
however, with consideration of distance and soil
types this should be acceptable to us.
Page 3 III.B.4. - EPA - Tracer dye show up in surface
water considered an inferred evidence.
Comment - MPCA criteria considers positive tracer
dye study as direct evidence, provided the source
is pinpointed.
32
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Mr. Jim Novak
Page 4
NOV 0 4 198!
Page 3 III.B.8. - EPA - Holding tanks considered indirect
evidence .
Comment - MPCA considers holding tanks a direct
evidence for evaluation of alternatives (holding
tanks can be a final solution, however) .
Page 3 III.B.9. - EPA - Direct discharge of septic tank
effluent to surface water is an indirect evidence.
Comment - MPCA would consider a septic tank dis-
charge to surface water a direct evidence.
Page 3 III. B. 10. - EPA - Age can infer failure if it
characterizes excessive failure rates.
33
_ j
Comment - Age in itself should not be accepted.
It could be acceptable if the specific age used
can be correlated to a specific type of installa-
tion and that the installation is unacceptable. _^
Page 3 III. last paragraph - EPA - Predict the type
and number of onsite system needed in community.
Comment - This paragraph may be interpreted to
make extrapolated estimates from a smaller number
of known needs. These estimates into areas of
unknown information is not acceptable to MPCA.
Page 4 IV.A.2. - EPA - Should interview local health
department tank installers, etc.
Comment - This is not in MPCA criteria but is a
very good (and consistent with MPCA attitude)
addition.
Page 4 IV.A.7. - EPA - Leachate detection survey for
phase 1.
Comment - MPCA states other data gathering is
acceptable, which we interpret to include septic
snooper. This looks like a good inclusion.
Page 4 IV.A.8. - EPA - Mailed questionairc should be used
only in very high problem rates.
Comment - We see no value to this limitation of
questionaire use. Questionaires should be used in
all cases. They also help as a public relations
tool.
35
36
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Mr. Jim Novak
Page 5
NOV 0 4 1981
Page 5 1st paragraph - EPA - Inconclusive group consists
of lots with indirect evidence of problem.
Comment - MPCA considers 2 indirect evidence a
need situation. Should further data gathering be 37
pursued if a lot already exhibits more than one
inferred evidence?
Page 5 IV. last paragraph - EPA - Other facilities
planning should proceed concurrently with phase 1.
Comment - MPCA feels needs should be established
and approved before other facility planning tasks
are conducted.
Page 5 IV.B.I. - EPA - Phase II may not be needed if
preliminary estimates show conventional sewer more
cost effective.
Comment - The EPA guidance does not expand on this
as MPCA does to say this is more applicable in -TO
highly concentrated areas of a municipality and
where on sites are not viable. I think this extra
explanation MPCA uses is important.
Page 6 IV.C. 2nd paragraph from bottom - EPA - Field
work should be done with idea of site information
needed for a onsite alternative to avoid duplica-
tion of site visits.
Comment - This is not in MPCA guide but is a very
good addition.
Page 7 IV.C.I. Rep. Sampling - EPA - This is an example
for representative sampling.
Comment - 1 iis is not included in MPCA criteria
but is a good addition to clarify representative
sampling.
Page 8 IV.C.2. Partial Survey - EPA - It is not the
intent to identify all problems in community. It
is not cost effective to select appropriate tech.
for each lot in Step 1. Take a small sample and
predict.
Comment - This is totally apposite of MPCA guide
lot by lot evaluation and alternative selection. 10,39
This is the major part of difference between MPCA
and EPA policy.
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Mr. Jim Novak
Page 6
NOV 0 4 1981
Page 8 IV.C.2. Sanitary Survey - EPA - Details of survey.
Comment - These details not in MPCA, but are a
good addition.
Page 9 V. 4th paragraph - EPA - Allow sub code installa-
tion of new systems lot limitations exists.
^H
Comment - MPCA would not allow sub code (WPC 40)
systems to be recommended for installation. _
Page 9 V. 5th paragraph - EPA - Use a projection for
numbers of selected alternative.
Comment - MPCA is against this. We require site
by site recommendation.
Page 9 V. 6th paragraph - EPA - Infeasibility of fixing
onsite system not justification of central collec-
tion.
Comment - This is not explicit in MPCA but good.
Page 9 V. last paragraph - EPA - Community wide cost
estimates is adequate for proposed action in
Step 1.
Comment - Again, MPCA requires site by site recom-
mendation not area wide estimates.
Page 11 1st paragraph - EPA - Selection of technology is
Step 2 or 3 work. Construction can be tandem to
analysis.
Comment - This is again, in direct opposition to
MPCA criter .a of lot by lot alternative s
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Mr. Jim Novak
Page 7
NOV 0 4 1981
Comment - In itself this is acceptable, but it is
one more allowance to not finalizing alternative
selection until Step 3.
If you have any questions or concerns regarding the above
comments please do not hesitate to contact Lawrence S. Zdon
at (612) 296-7733 or Michael K. Vennewitz at (612) 296-7375,
Sincerely,
Gordon E. Wegwart, P.E.
Chief, Technical Review Section
Division of Water Quality
GEW/LSZ:jdm
Enclosure - MPCA Needs Criteria
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State of Wisconsin \ DEPARTMENT OF NATURAL RESOURCES
Carroll D. Besadny
Secretary
BOX 7921
MADISON, WISCONSIN 53707
CTD
February 26, 1982 File Ref:rsO
Mr. Valdas K. Adamkus, Regional Administrator
Environmental Protection Agency - Region 5
230 S. Dearborn Street
Chicago, IL 60604
Attention: Gene Wojcik
Re: Draft Generic Environmental Impact Statement,
Alternative Waste Treatment Systems for
Rural Lake Projects, Supplemental Comments
Dear Mr. Adamkus:
Enclosed are some additional comments on the above documents. These
comments were basically developed by the Department's Northwest District
office.
Specific Comments
Page 21, 2.a. Last Sentence - What constitutes a minor impact or an
unreasonable cost of abatement?
The Department recognizes the difficulty of developing comprehensive
solutions to all situations, however, when a noncomplying system is
found, certain measures should be implemented or sought that would at a
minimum alleviate these adverse conditions.
Page 22, 2.a. Types of Failures, Third and Fourth Paragraphs - These
paragraphs appear to be endorsing a "write-off" of certain groundwaters.
The Department recognizes the complexity of this problem; however, as of
this letter, there is still a certain amount of emphasis on a non-
degradation policy in our agency.
Page 23, Paragraph 5, Fourth Sentence - Aerial surveys may prove useful
for general surface malfunction identification but cannot be substituted
for accuracy obtained through carefully performed on-site surveys.
Aerial surveys should be coordinated with some type of on-site verification
program to ensure accuracy.
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Mr. Valdas Adamkus February 26, 1982 Page 2
Page 24, C. Causes of Surface Failures and Plumbing Backups, Second
Paragraph - An intensive public education program identifying advantages
of maintenance and proper system usage may prove to be the most effective
measure in alleviating or preventing surface failures and back-up problems
in existing on-site systems.
Page 25, 3. Available Alternative On-Site Options, b. For Existing
Systems Not In Compliance With Codes - Perhaps a record keeping system
can be developed on a local basis that red flags "sub-standard" systems
identified by surveys and investigations. Then, prior to a transfer of
ownership (sale of property), a rehabilitation program on these "sub-
standard" on-site systems may be implemented to put them into compliance
with appropriate codes.
Page 26, c. Use of Soils Data, Third Paragraph, Last Sentence - The
Department endorses this concept that "the policies and procedures
recommended in this EIS emphasize reliance on empiracal information for
decisions on the disposition of existing on-site systems."
Page 35, Table II-B-3. Surface Water Discharge Options for Small Communities
Although the "simple" treatment systems indicated here are effective
effluent treatment options, they are also dependent on proper operation
and maintenance programs. Since many of these options are energy
intensive, their effectiveness is dependent on qualified personnel.
Page 44, d. Mailed Questionnaires - The results obtained by mailed
questionnaires are probably only as good as can be verified. A well
developed and implemented educational program prior to sending out these
questionnaires may pave the way for a cooperative dialog between planners
and potentially impacted property owners.
Page 46, 2. Phase II; Data Collection and Comparison, First Paragraph -
Are the numbers of sites requiring examination so great that individual
surveys of all or most properties are impractical?
Page 47, b. Representative Samplings - The Department agrees that soil
mottling is a good indicator of high groundwater elevations.
Page 48, Well Water Contamination, Top of Page - Does the 20% figure
assume federal grant assistance eligibility? Will this number provide a
representative sample?
Page 48, 3. Retention and Future Analysis of Needs Documentation Data,
Second Paragraph - The agency approval system needs enough flexibility
so that reviewers can endorse the obvious without having empirical data
collected to the "n degree".
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Mr. Valdas Aflamkus February 26, 1982 Page 3
Page 49, Top of Page - The Department agrees with the statement that "as
discussed in Section V.C., transferability of needs data would enable
state officials to manage information gaps that may include small waste
flows, state of the art, costs and management techniques."
Page 49 E. Designing an Optimum Operation Alternative, Fourth Paragraph -
The Department agrees with the points presented here that "The purpose
of sequencing these efforts is to build decision points into the planning
process. If at various points, 'no action1 or centralized alternatives
are demonstrated to be better than optimum operation, subsequent planning
efforts can be redirected as appropriate."
Page 52, C. Proposed Action Description - Regardless of Grant eligibility
or participation, a comprehensive program for regulation and inspection
of small waste flow systems is needed.
Page 63, G. Shortcutting the Construction Grants Process - Perhaps this
section should be moved to an earlier portion of this text to increase
its visibility.
Page 68, 2. Community Obligations for Management of Private Wastewater
Systems - Local management of these facilities will be instrumental in
preventing future environmental degradations. Obligations will need
continual emphasis.
Page 75, Top of Page - The Department agrees with the point that "where
community management is desirable, the public must be educated about its
benefits if the program is to be successful."
Page 75, E. Use of Variances, First Paragraph - The second sentence
reads "All states in Region V currently allow construction variances for
the new construction of on-site systems where conditions prevent conformity
to code." This is a broad statement which should be clarified in order
that the reader can interpret what "conditions" are relevant as construction
variances.
Page 75, E. Use of Variances, Last Paragraph - While your studies indicate
the natural assimilative capacity of soil/groundwater/surface water
systems is greater than previously expected, the fact still remains
areas are being degraded by improperly operated or installed systems.
The overall objective should be to alleviate or eliminate existing
problem areas coupled with a process which prevents "new" sources from
occurring.
Page 78, Implementing Water Conservation Programs - Water conservation
programs will need greater governmental emphasis. It is one of the more
obvious beneficial measures in protecting future uses of ground and
surface water resources.
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Mr. Valdas Adamkus February 26, 1982 Page 4
Page 89, Facilities Planning Techniques, Top of Page - The Department
concurs with the second paragraph that reads "Definition of planning
area, assessment of water quality impacts, and calculation of current
and future population and land use impacts, are sometimes technically
difficult and even controversial subjects. If properly explored,
however, they allow realistic assessment of project values and whether
it will do more harm than good. Such information is of great value to
the project whatever the Federal or State role may be. Indeed it may be
of greatest value for the community that must plan and implement a
wastewater system using only its own resources."
These are good points that need reemphasis.
Page 90, 2. Identification of Planning Area Where Optimum Operation
Alternatives Should be Considered, Third Paragraph - While low popula-
tion or housing densities may not result in significant public concerns,
some type of involvement is needed in order to organize and promote
solutions to these scattered problems. Their existence should not be
totally ignored.
Page 119, First Paragraph, Last Sentence - The Department agrees that
"State policies toward the use of innovative techniques should reflect
the trade-offs between risks and economic savings and ensure that the
systems do not prove to be future economic liabilitites." Many states,
including Wisconsin will need to be dutifully aware of this potential
problem.
Page 119, 2. State Planning Activities for Small Communities - Perhaps
there should also be a review priority system for projects ready to
proceed with their own funding. Unfortunately, review workloads are
tied into existing grant priority systems which are in most instances
already overloaded. Thus, certain organizations are not being rewarded
for their own initiatives.
Page 120, 3. State Grant and Technical Assistance, First Paragraph
First Sentence - This sentence states "To overcome some of these problems
faced by local communities, a state or regional 208 or similar regional
agency could provide management assistance to the local communities."
This concept should be considered for all grant assisted projects not
just the smaller scale projects.
Page 122, 4, State Staffing - As with any type of waste treatment system
whether on-site or centralized collection facility, their effectiveness
is limited to proper operation and maintenance. Future compliance or
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Mr. Valdas Adamkus February 26, 1982 Page 5
degradation prevention will be dependent on integrated efforts of all
concerned parties (system designers, operators, owners, inspectors,
regulators, etc.).
Page 127, b. Future Work Needed - This section on future work needed
will require continual emphasis to highlight its importance.
If you have any questions, please contact us.
Sincerely,
Burea/u of Environmental Impact
Howard S. Druckenmiller
Director
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Chapter VIII
Coordination
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LIST CE RECIP1EMS
List of those sent copy of Final EiS.
U.S. SENA1CES AND REPRESEMA1IVES
Senator Allan J. Dixon
Senator Charles K. Percy
Senator Richard C. Lugar
Senator Dan Quayle
Senator Carl Levin
Senator Donald Vv. Riegle, Jr.
Senator Rudolph E. Boschwitz
Senator David Durenberger
Senator John Glen
Senator Howard Metzenbaum
Senator Robert Vv. Kasten, Jr.
Senator William Proxmire
Illinois
Representative Harold Washington
Representative Gus Savage
Representative Martin A. Russo
Representative Edward J. Derwinski
Representative Gohn G. Fary
Representative Henry J. hyde
Representative Cardiss Collins
Representative Dan Rostenkowski
Representative Sidney R. Ic'ates
Representative John Edward Porter
Representative Frank Annunzio
Representative Philip M. Crane
Representative Robert McClory
Representative John Erlenborn
Representative Tom Corcoran
Representative Lynn Martin
Representative George C'Brien
Representative Robert H. Michel
Representative Ihomas F. Railsback
Representative Paul Findley
Representative Edward R. Madigan
Representative Daniel B. Crane
Representative Welvin Price
Representative Paul Simon
Indiana
Representative Adam Benjamin, Jr.
Representative Floyd J. Fithian
Representative John Biler
Representative Dan Coats
Representative Elwood Hillis
Representative David Vv. Evans
Representative John T. foyers
Representative H. Joel Deckard
Representative Lee E. Hamilton
Representative Philip P. Sharp
Representative Andrew Jacobs, Jr.
-------
Michigan
Representative John Conyers, Jr.
Representative Carl D. Pursell
Representative Howard E. Wolpe
Representative Mark Siljander
Representative Harold S. Sawyer
Representative Jim Dunn
Representative Dale E. Kildee
Representative Bob Traxler
Representative Guy Vander Jagt
Representative Donald J. Albost
Representative Robert V*. Davis
Representative David E. Bonior
Representative George Crockett
Representative Dennis Hertel
Representative William D. Ford
Representative John D. Dingell
Representative William M. Brodhead
Representative James J. Blanchard
Representative William S. Broomfield
Minnesota
Representative Arlen Erdahl
Representative Thomas K. Hagedorn
Representative Bill Frenzel
Representative Bruce F. Vento
Representative Martin Olar Sabo
Representative Vin Weber
Representative Arlan Stangeland
Representative James L. Oberstar
Ohio
Representative Willis Gradison
Representative Thomas Luken
Representative Tony Hall
Representative Michael Cxley
Representative Delbert Latta
Representative Bob McEwen
Representative Clarence J. Brown
Representative Thomas Kindness
Representative Ed Weber
Representative Clarence Miller
Representative William Stanton
Representative Bob Ehamansky
Representative Donald Pease
Representative John Seiberling
Representative Chalmers Wylie
Representative Ralph Fegula
Representative John M. Ashbrook
Representative Douglas Applegate
Representative Lyle Williams
Representative Kary Rose Oaker
Representative Louis Stokes
Representative Dennis Eckart
Representative Eon Mottl
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Wisconsin
Representative Les Aspin
Representative Robert W. Kastenmeier
Representative Steve Gunderson
Representative Clement J. Zablocki
Representative Henry S. Reuss
Representative Thomas Petri
Representative David R. Obey
Representative Toby Roth
Representative F. James Sensenbrenner, Jr.
FEDERAL AGENCIES
Council on
Department
Department
Department
Department
Environmental Quality
of Agricultural
of Commerce
of Health, Education, and Welfare
of Housing and Urban Development
of the Interior
Service
Department
U.S. Fish & Wildlife
Geological Survey
National Park Service
Department of Labor
Department of Transportation
U.S. Army Corps of Engineers
U.S. Soil Conservation Service
U.S. EPA Regional Offices
STATE AGENCIES
Illinois
Office of the Governor
Office of the Lieutenant Governor
Illinois Environmental Protection Agency
Illinois Institute of Natural Resource
Illinois Pollution Control Board
Illinois Department of Public Health
Illinois Department of Agricultural, Division of Natural Resources
Illinois Department of Conservation
Illinois State Geological Survey
Illinois State Water Survey
Indiana
Office of the Governor
Office of the Lieutenant Governor
Indiana State Board of Health
Indiana Stream Pollution Control Board
Indiana Department of Natural Resources
Indiana Geological Survey
Indiana State Soil & Water Conservation Commission
Indiana Department of Agriculture
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Michigan
Office of the Governor
Office of the Lieutenant Governor
Michigan Department of Natural Resources
Michigan Environmental Review Board
Michigan Department of Public HEalth
Michigan Department of Agriculture
Minnesota
Office of the Governor
Office of the Lieutenant Governor
Minnesota Pollution Control Agency
Minnesota Water Resources Board
Minnesota Department of Natural Resources
Minnesota Department of Health
Minnesota State Planning Agency
Minnesota Environmental Quality Board
Minnesota Department of Transportation
Minnesota Energy Agency
Minnesota Department of Agriculture
Ohio
Office of the Governor
Office of the Lieutenant Governor
Ohio Environmental Protection Agency
Ohio Environmental Board of Review
Ohio Department of Natural Resources
Ohio Department of Health
Ohio Biological Survey
Ohio Department of Fnergy
Ohio Department of Agriculture
Ohio Department of Transportation
Wisconsin
Office of the Governor
Office of the Lieutenant Governor
Wisconsin Department of Natural Resources
Wisconsin Department of Agriculture, Trade
and Consumer Protection
Wisconsin Department of Health and Social Services
Wisconsin Department of Transportation
Wisconsin Division of Energy
Wisconsin Geological and Natural History Survey
CITIZENS AND GROUPS
This list is available upon request from U.S. EPA.
-------
LIST OF PREPARERS
This Final Environmental Impact Statement was prepared under the
supervision of Mr. Jack Kratzmeyer, Project Officer, U.S. Environmental
Protection Agency, Region V, Environmental Impact Section and Mr. Alfred
Krause, Region V's Small Waste Flows Coordinator. Revisions to the Draft
EIS and new material incorporated into the Final EIS were prepared by Mr.
Gerald 0. Peters, Project Manager for WAPORA, Inc.
The Draft Environmenal Impact Statement was prepared under the supervision
of Mr. Theodore Rockwell, Project Officer, U.S. Environmental Protection
Agency, Region V, EIS Preparation Section and Mr. Alfred Krause, Technology
Section.
The Technical Reference Documents on which this EIS is based and materials
for the Draft EIS were prepared by the staff of WAPORA, Inc., Chevy Chase,
Maryland. Mr. Gerald Peters, Jr. was WAPORA's Project Manager. Mr. Eric
Hediger was WAPORA's Assistant Project Manager. WAPORA's project staff,
their areas of expertise and sections of the Draft EIS and Technical
Reference Documents for which they were principally responsible are listed
below. Four of the Technical Reference Documents were prepared by the
Clean Water Fund under the direction of Mr. Larry Silverman.
Name
Gerald 0. Peters, Jr.
Project Manager
Eric M. Hediger
Ass't Project Manager
Edward P. Hagarty
Environmental Engineer
Wu-Seng Lung
Water Resources
Engineer
Stuart D. Wilson
Environmental Health
Scientist
Richard M. Loughery
Public Administration
Specialist
Estelle K. Schumann
Environmental Health
Scientist
J. Ross Pilling
Environmental Planner
Roger Moose
Hydrogeologist
Highest Degree
M.S. Environmental Science
Registered Sanitarian
Draft EIS
I-A-C; II-C,E;
III-A,C,H,L
II-D.F; IV-A-2
II-A,B; III-F
M.E.M. Environmental
Management
M.S., Civil Engineering
E.I.T, Engineer in Training
PhD., Environmental
Engineering
Professional Engineer
M.S., Environmental Health
J,K; V-B,C
M.P.A., Environmental Policy III-I; IV-E
M.S., Environmental Science
Technical Reference
Documents
II-B, D,E,F,G;
VII-C; IX-A,B; X-E;
XV-D; XVI-D
III-A; IV-A
I; II-I,J,L; IV-A,
B,C,D; VIII-D
XII-C,D,E,F,G
VI-A,B,C,D,E,F,G,H,
I; VII-A.B; XV-C
M.R.P., Regional Planning
M.S., Geology
IV-A,B,C,F,H;
VI-B,D
VIII-B; XV-A,B;
XVI-A
II-A; XII-A; XIII-A
VII-A,F; IX-C;
X-C,D; XI-A,B,C;
XIV-A; XVI-B,C
II-C,H; XIII-B,C
-------
Name
Gerald D. Lenssen
Agricultural Engineer
Jerald D. Hitzemann
Demographer
Mirza H. Meghji
Sanitary Engineer
Rhoda Granat
Librarian
Melissa Wieland
Graphics Artist
Stephanie Davis
Editor
Catherine Skintik
Editor
CLEAN WATER FUND
Larry J. Silverman
Task Manager
Susan B. Grandis
Legal Researcher
Highest Degree Draft EIS
M.S., Agricultural Engineering
M.C.P., City Planning
PhD., Environmental Engineering
Professional Engineer
M.A., Psychology
B.A., Biology
B.A., English
M.A., English
L.L.D
B.A. Legal Studies
Technical Reference
Documents
II-K, III-B
X-A.B
IV-A; XII-B
V-A,B; VII-E; XVI-E
Edward Hopkins
M.A. History and Political Science
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INDEX
access considerations, 86-87, 128, 130-131
by acquisition of deeded rights, 86
by owner's permission, 86
by statutory grants of authority, 86-87
aerial photographic interpretation, 7, 25, 44, 46-47, 48, 106, 164
agency, 208 plans, 103, 105, 133
201 plans, 129
agricultural lands, impacts of
proposed action, 144-145
aquifers, 24-25
recharge areas, impacts of
proposed action, 145
sampling, 89
archaeologic and historic sites, 110
impacts of proposed action, 146
bacterial contamination, 24-27, 88-89, 113-114, 141-143, 145
aquifers 24, 89, 145
contact waters, 113
drinking water, 113
groundwater, 27, 88-90, 141-142
lake water, 143-144
bids, competitive for on-site systems, 59
black water, black water/gray water, 6, 30, 33, 112, 118, 142, 145
centralized approaches, defined, 3
certification programs, as function
of management agency, 82
Clean Water Act, 4, 38, 76, 86, 94, 102, 125, 128, 134, 138, 149, 156
cluster systems, 37, 54, 58, 61-62, 78, 89, 90, 111, 112, 130, 148
collection systems (see off-site treatment; sewers)
for small scale off-site treatment, 36
for sewers, 36
community management, of small waste flows systems, 75-96
cost, 91-93
public involvement, 83-84
need for, 75-77
program design, 79-83
variances, 84-85
community management models, 77-79
combined management approaches, 79
comprehensive water quality management, 79
owner volunteer, 78
status quo alternative, 77-78
universal community management, 78
Construction Grants:
administration, 125-138
and Davis-Bacon Act, 127-128
eligibility, 125-129
Federal concerns, 125-129
State concerns, 132-136
cost analysis, for small waste flows technologies, 60-69
cost curve analysis, 60, 66-67
cost-effectiveness analysis for small waste flows technologies, 67-68
cost variability study, 60-65, 157
costs:
of conventional collection & treatment systems, 10-12
of on-site systems, 19
for homeowners, 68-69
local, defined, 91
local, recovery, 91-93
-------
Davis-Bacon Act, 148, 127-128
and Construction Grants Program 127-128
application of, 127-128
demography, and facilities planning, 103-109
easements (See access considerations), 86, 130-131
economic characteristics, of residents, 107-109
economic impacts of facilities planning, 118-121
for residents, 119-120
economic impacts, of proposed action, 146-148
on county and municipal governments, 146-147
on future owners, 147-148
on mineral production, 148
on present owners, 147
on region, 146
on utility contractors and suppliers, 148
effluent plume, recovery, 34, 50, 84, 89-90, 155, 160-161, 165
eligibility, of small waste flows systems, 125-129
for Contruction Grants, 125-129
conventional water use, 129
field work, 128-129
flow reduction devices, 129
off-site facilities, 130
pilot studies, 128
potential failures, 130
seasonal properties, 126
embayments, 20, 117-118, 143, 162
empirical relationships, data, models, 29, 51, 53-54, 114, 163
enforcement, as management agency function, 82
environmental factors, 60, 62, 144
environmental constraints, and facilities planning, 60, 62, 65-66, 109-112
environmental impacts:
on collection and treatment facilities, 14
on on-site systems, 19-20, 23-24
on proposed action, 141-150
on sewers, 14
eutrophication of lakes, 19-20, 46, 114-117
evaluation methods, existing on-site systems, 7
facilities planning, 99-122
area boundaries, 99-101
demography, 103-109
development approach, 100-101
economic impacts, 119-120
environmental approach, 100
environmental constraints, 109-112
financial impacts, 118-121
identification, 101-102
jurisdictional approach, 100
and land use, 107, 109-112
mathematical projections, 106-107
and population estimates, 104-107
public participation, 121-122
ratio/share, 107
recreational facilities, 103-104
and second-home development, 103-104
water resources, 113-118
financial impacts, of facilities planning, 118-121
local procurement of goods
and services, 120-121
for residents, 119-120
financial responsibiilities, of management agency, 91-93
fixed film reactors, 28, 39
floodplains, impact of proposed action, 144
flow reduction devices, 6, 30, 33, 87-88, 129, 153, 154
-------
groundwater, 52-53, 88-90, 141-142, 145
contamination 10, 24-27, 141-142, 145, 164
effluents, 34, 50, 84, 88
future work, 142
hydrology 6, 26-27
monitoring, 88-90
problems & solutions, 141-142
proposed action, consequences, 141-142
sampling, 52-53, 88-90
surveys, 89-90
historic and archaeologic sites, impacts of proposed action, 146
holding tanks, 34, 93, 130, 147, 150, 165
homeowner cost, average annual, for small waste flows techniques, 68-69
hypothetical relationships, 29
impacts, environmental:
on-site systems 19-20, 23-24
proposed action, 141-150
sewers, 14
impacts, financial, of facilities planning, 118-121
industrial growth, sewers, 138
infiltration, percolation, 37
irrigation, 37
lakes:
bacterial contamination, 113, 143
eutrophication, 50, 113-117
nutrients, 143-144
plant growth, localized, 117-118
water quality, impacts of proposed action, 141-144
land application, 37
land use:
and environmental constraints, 109-112
and facilities planning, 109-112
impacts of proposed action, 148-149
planning, 111-112
treatment, 36-39
leachate, septic:
detection, 7, 44, 47-49, 90, 113-114, 160-161
plumes, 113-114, 145
management agency, 75
management agency personnel, 94-95
management programs:
design, 79-83
implementation, 83
feasibility for wastewater facilities, 80-81
ownership, of wastewater facilities, 80-81
public involvement, 83-84
responsibility for performance, 81-82
responsibility for services, 81-82
revision, 95
user charge structures, 91-93
maps, 45, 47, 52
monitoring, water quality, 88-90
municipal fiscal capabilities, assessment, 118-119
National Eutrophication Survey, 45, 117
National Pollution Discharge Elimination System, 12
nearshore plant surveys, 50, 90
needs documentation:
analysis, 53-54
-------
and Construction Grants, 129
data collection, 44-53
needs documentation methods, 44-53
aerial photographic interpretation, 46-47
data collection, 44-53
eutrophication modeling, 46-50
maps, 45
nearshore plant survey, 50
questionnaires, 49-50, 166
representative sampling, 52-53
sanitary surveys, 51-52
septic leachate detection, 47-49, 160-161
use of available data, 45-46
windshield surveys, 45
needs documentation policies, 38-40
national, 38-40
Region V, 40
nitrates,
contamination, 25, 26, 27, 33, 142, 143, 145
sampling, 89
non-point source, monitoring, 79, 90, 117, 118, 143
nonsewer development constraints, 109-110
off-site treatment, small scale, 34-38
collection systems, 36
for Construction Grants Administration, 130
land treatment options, 37
septage disposal, 34-36
surface water discharge options, 38-39
treatment methods, 36-38
wetland systems, 38-39
on-site systems, 23-24
community involvement, 76-77
costs, 14-15
evaluation methods, 7
failures (see on-site system failures)
history, 10
impacts, 19-20
noncomplying, 27-29
options available, 27-29
options for difficult systems, 30-34
performance data 7-8, 16-19
in Region V, 23
site analysis, 30
soils data, 29
technology selection, 30
types, 23
on-site systems failures, 24-27
contamination, 27
causes, 26-27
effects, 27
frequency, 25-26
survey, sampling, 56-57
types, 24-25
optimum operation alternatives, 54-59
alternative description, 57
bid documents, 59
cost analysis, 56
facilities verification and design, 58-59
and proposed action, 57-58
segment delineation, 55
systems selection, 56-57
technology assumption, 56
-------
small waste flows:
approach, 137-138
facilities, 5-6
history, 10
planning & land use, 93-94, 111-112
technologies, 3, 23-71
soils data, 29
soils maps, 45
state grant & technical assistance, Construction Grants Administration, 133-135
circuit rider model, 135
contractor assistance model, 135
Maryland model, 134-135
New Hampshire model, 134
state planning activities:
for Construction Grants Administration, 133
for small communities, 133
state staffing, 135-136
steep slopes, impacts of proposed action, 145
surface drainage, 6
surface failures, 24-27
surface waters discharges, 38-39
surveys, 51-52, 56
systems design, 5
as management agency function, 79-82
system maintenance, 6
system ownership & liability, 80-81
systems selection, 56-57
system usage, 6
training programs, as function of Construction Grants Agency, 136-137
treatment methods, small-scale
off-site systems, 34-39
land application, 37
surface water discharge, 38-39
wetland discharge, 38-39
unincorporated places, defined, 15
urban population, defined, 15
user charge systems, 16, 58, 91-93
variances, 84-85
waste stream, segregation of, 33
wastewater management, role of state, 8-9
public agencies, 93-94
wastewater treatment technologies, off-site, 36-39
water conservation programs, 87-88
water contamination, 10, 24-27, 113-116
water quality impacts of proposed action, 141-144
water resources, 113-118
bacterial contamination,113-114
eutrophication, 114-117
localized plant growth, 117-118
water use, 126-127, 150
wetlands, impacts of proposed actions, 144
windshield surveys, 45, 106
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BIBLIOGRAPHY
American City and County. 1980. On-site treatment for low density areas, 95(4): 45-48.
American Society of Planning Officials. 1976. Subdividing rural America: Impacts of
recreational lot and second home development. Government Printing Office, Washington
D.C., 139p.
Baker, Larry K. 1980. The Impact of Water Conservation on On-site Wastewater Management.
Weatherby Associates, Inc., Jackson CA, 38p.
Cohen, Sheldon and Harold Wallman. 1974. Demonstration of waste flow reduction from
households. NTIS PB-236 904. U.S. Environmental Protection Agency, National Environ-
mental Research Center, Cincinnati OH, 102p.
Cooper, Ivan A. and J. W. Rezek. 1977. Septage Treatment and Disposal. Prepared for the
EPA Technology Transfer Seminar Program on Small Wastewater Treatment Systems. Rezek,
Henry, Meisenheimer and Gende, Inc., 43p.
Craun, G. F. 1979. Waterborne disease: A status report emphasizing outbreaks in ground-
water systems. Groundwater 17:183.
Dearth, Keith H. 1977. Current costs of conventional approaches. Prepared for U.S. EPA
National Conference on Less Costly Wastewater Treatment Systems for Small Communities,
April 12-14, 1977.
Dillon, P. J. 1975. The phosphorous budget of Cameron Lake, Ontario: The importance of
flushing rate to the degree of eutrophy in lakes. Liminology Oceanography, 19.
Energy and Environmental Analysis, Inc. 1978. Evaluation of municipal wastewater treat-
ment plant operations. Referenced in "Improving compliance of existing municipal
wastewater treatment facilities," a preliminary concept paper prepared for EPA's 1980
Strategy by Mr. Pete Eagen, September 29, 1980.
Evans, Barry. 1981. Personnel communication, February 1981.
Kesswick, Bruce H. and Charles P. Gerba. 1980. Viruses in groundwater. Environmental
Science and Technology 14(11): 1290-1297.
Kirchner, W. B. and P. J. Dillon. 1975. An empirical method of estimating the retention
of phosphorus in lakes. Water Resource Research 11(1) 182-183.
Marans, Robert W. and John D. Wellman. 1977. The quality of nonmetropolitan living:
Evaluation, behaviors, and expectations of northern Michigan residents. University of
Michigan, Institute for Social Research, Ann Arbor MI, 428p.
Moak, Lennox L. and Albert M. Hillhouse. 1978. Concepts and practices in local government
finance. Municipal Finance Officers Association of the U.S. and Canada. Chicago IL,
1975, reprinted 1978, 454p.
Peters, Gerald 0., Jr. and Alfred E. Krause. 1980. Decentralized approaches to rural lake
wastewater planning - seven case studies. In N.I. McClelland (Editor), Individual
On-site Wastewater Systems, proceedings of the Sixth National Conference, 1979. Ann
Arbor Science Publishers, Inc., Ann Arbor MI, 522p.
Ragatz, Richard L. 1980. Trends in the market for privately owned seasonal recreational
housing. Paper presented at the National Outdoor Recreation Trends Symposium, Durham
NC, April 20-23, 1980.
-------
Silverman, Larry. 1980. A practical guide to the Federal law of septage treatment. In
Gravity, Zwick and Aoki (Editors), Shopping for sewage treatment: How to get the best
bargain for your community or home. Clean Water Fund, Washington B.C., 323p.
Tchobanoglous, George and Gordon L. Gulp. 1979. Wetlands systems for wastewater treat-
ment: An engineering assessment. Draft, University of California, Davis CA, and
Culp, Wesner and Gulp, EL Dorado Hills CA, for U.S. EPA, Washington DC, 43p.
Twichell, Joseph H. 1978. The effects of the use and regulation of septic tank systems
upon land use in Massachusetts. Publication No. 96. University of Massachusetts,
Water Resources Research Center. Amherst MA, 90p.
U.S. Bureau of the Census. 1978. County and City Data Book, 1977. U.S. Government
Printing Office, Washington, D.C.
U.S. Bureau of Mines. 1978. Minerals in the economy of Indiana. Pittsburgh PA, 17p.
U.S. Bureau of Mines. 1979a. Minerals in the economy of Michigan. Pittsburgh PA, 19p.
U.S. Bureau of Mines. 1979b. Minerals in the economy of Minnesota. Pittsburgh PA, 21p.
U.S. Bureau of Mines. 1979c. Minerals in the economy of Illinois. Pittsburgh PA, I4p.
U.S. Bureau of Mines. 1979d. Minerals in the economy of Wisconsin. Pittsburgh PA, 16p.
U.S. Bureau of Mines. 1979e. Minerals in the economy of Ohio. Pittsburgh PA, 17p.
U.S. Department of Commerce. 1979. Urban and Rural Housing Characteristics for
the U.S. and Regions, Annual Housing Survey: 1977. Series H-150-77, U.S. Government
Printing Office, Washington D.C., 177p.
U.S. Environmental Protection Agency. 1974. Advisory Council on Historic Preservation.
Procedures for the protection of historic and cultural properties, 36 CFR 800.3.
U.S. Environmental Protection Agency. 1975. Guidance for preparing a facility plan.
EPA-430/9-76-015. Office of Water Program Operations, Washington D.C.
U.S. Environmental Protection Agency. 1976a. Land treatment of municipal wastewater
effluents: Case histories. Technology Transfer, 79p.
U.S. Environmental Protection Agency. 1976b. Program Requirements Memorandum #76-3,
Government costs.
U.S. Environmental Protection Agency. 1977. Regulations on Review of Projects Affecting
Sole Source Aquifers. 40 CFR 149.10(a), Project Review Authority.
U.S. Environmental Protection Agency. 1977a. Alternatives for small wastewater treatment
systems. Vol. 1: On-site disposal/septage treatment and disposal. Vol. 2: Pressure
sewers/vacuum sewers. Vol. 3: Cost-effectiveness analysis. Technology Transfer,
Cincinnati OH, 90, 97, and 30p.
U.S. Environmental Protection Agency. 1977b. Process design manual for land treatment of
municipal wastewater. EPA-625/1-77-008. Technology Transfer, Cincinnati OH,
variously paged.
U.S. Environmental Protection Agency. 1977c, Program Requirements Memorandum #77-8,
Funding of sewage collection system projects, superceded by PRM #78-9.
U.S. Environmental Protection Agency. 1978a. Grant Regulations. 40 CFR 35.9, Grants for
Construction of Treatment Works - Clean Water Act.
-------
U.S. Environmental Protection Agency. 1978b. Program Requirements Memorandum #78-9,
Funding of sewage collection system projects.
U.S. Environmental Protection Agency. 1979a. Design seminar handout on small wastewater
treatment facilities. Technology Transfer, Cincinnati OH, variously paged.
U.S. Environmental Protection Agency. 1979b. Program Requirements Memorandum #79-8, Small
wastewater systems.
U.S. Environmental Protection Agency, Region V. 1980a. File of approved municipal revenue
systems (FOAMRS). Automated data printout of September 22, 1980.
U.S. Environmental Protection Agency. 1980b. Design manual on-site wastewater treatment
and disposal systems. Office of Water Programs, Washington D.C., and Municipal Env.
Res. Lab., Cincinnati OH, 391p.
U.S. Environmental Protection Agency. 1980c. Innovative and alternative technology
assessment manual. EPA-430/7-78-009. Office of Water Program Operations. U.S.
Government Printing Office, Washington D.C., variously paged.
U.S. Environmental Protection Agency. 1980d. Options for third-party management of Con-
struction Grants for small communities. Unpublished concept paper, 20p.
U.S. General Accounting Office. 1980. EPA should help small communities cope with Federal
pollution control requirements. CED-80-92, Washington D.C., 20p.
U.S. Public Health Service. 1957. Manual of Septic-Tank Practice. Publication No. 526.
U.S. Department of Health, Education and Welfare. Developed in cooperation with the
Joint Commission on Rural Sanitation, 85p.
Wisconsin Department of Health and Social Services. 1979. Final Environmental Impact
Statement on mount systems for private waste disposal. Madison WI, 25lp.
Woodward, F. L. , F. J. Kilpatrick, and P. B. Johnson. 1961. Experience with groundwater
contamination in unsewered areas in Minnesota. American Journal of Public Health
51(8):1130-1136.
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APPENDICES
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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 clarify fulfillment of the require-
ments regarding the demonstration of need for sewage treatment associated with
the application of Program Requirements Memorandum (PRM) 78-9, "Funding of
Sewage Collection System Projects," and PRM 79-8, "Small Wastewater Systems."
This guidance is written particularly with respect to the needs of small,
rural communities and the consideration of individual on-site and small scale
technologies. It suggests procedures which may be utilized to minimize the
time, effort, and expense necessary to demonstrate facilities needs. It is
also intended to provide guidance pertaining to the selection of decentraliza-
tion alternatives for a cost-effectiveness comparison. It is intended to
prevent indiscriminate definition of need based upon "broad brush" use of a
single criterion or on decisions unsupported by fact.
The procedure recommended herein may not be the optimum procedure for all
projects. However, compliance with this approach will be prima facie evidence
for the acceptability of the "needs" portion of a proposed plan of study. If
another method is proposed for documenting needs for wastewater facilities, 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 alter-
natives for a specific planning area. The guidance further recognizes 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 specific areas within
the community, and allows for a degree of risk inherent to limited data
gathering.
II. Goal
The goal of this process is to enable communities to categorize existing
on-site treatment systems into three groups. The groups are those experi-
encing: (a) obvious sewage treatment problems, (b) no problem, and (c)
potential problems representing a planning risk that requires resolution by
the acquisition of original data.
The acquisition of original data as described will support not only
documentation of need but also development of appropriate alternatives and
their associated costs.
A-l
-------
III. Criteria for site-specific needs determination
A. Direct evidence that demonstrates obvious problems includes:
1. Failure by surface (breakout) ponding of filter field discharges
can be identified through direct observations, mailed question-
naires, and remote imagery.
2. Sewage backup in residences can be identified through respones
to mailed questionnaires, knowledge of local septage haulers, or
knowledge of local health or zoning officials.
3. Flowing effluent pipes detected by aerial photography, site
visits, knowledge of local officials, or results of mailed ques-
tionnnaires.
4. Contamination of water supply wells (groundwater) by sewage can
be demonstrated by well inspection and sampling and analyses for
whiteners, chlorides, nitrates, fecal coliform bacteria, or
other indicators, and a finding of their presence in concen-
trations which significantly exceed background levels in ground-
waters of the area or primary drinking water quality standards.
Improperly constructed wells or wells inadequately protected
from surface runoff cannot be used to demonstrate an obvious
need. Wells for which construction and protection are unknown
cannot be used to demonstrate an obvious need.
5. Samples taken from effluents entering surface water through soil
that analysis shows to have unacceptable quantities of nutrients
or bacteria.
B. Indirect evidence that indicates potential problems due to site
limitations or inadequate design of treatment systems includes:
1. Seasonal or year-round high water table. 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.
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 commu-
nity 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 corre-
lation with results of limited representative sampling which
substantiate water well contamination must be made.
3. Documented groundwater flow from a filter field toward a water
supply well may override seemingly adequate separation
distances.
A-2
-------
4. Sewage effluent or tracer dye in surface water detected by site
visit or various effluent detection systems. Additional tests
that indicate unacceptable quantities of nutrients or bacteria
in the effluent reaching surface water will establish direct
evidence of need.
5. Bedrock proximity (within three feet of filter field pipe) can
be assessed by utilizing existing SCS soils maps.
6. Slowly permeable soils with greater than 60 minutes/inch perc-
olation rate.
7. Rapidly permeable soil with less than 0.1 minutes/inch percola-
tion rate. Soil permeability may be assessed by evaluating
existing SCS maps.
8. While holding tanks, in certain cases, can be a cost-effective
alternative, for purposes of site-specific needs determination,
a residence equipped with a holding tank for domestic sewage
should be considered as indirect evidence of need for sewage
treatment facilities. Location of holding tanks will be identi-
fied through records of local permitting officials, septage
haulers, or results of mailed questionnaires.
9. 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.
10. 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.
Indirect evidence may not be used alone to document the need for
either centralized or decentralized facilities. Prior to field
investigation, indirect evidence should be used to define the scope
and level of effort of the investigations. When the investigations
are finalized, indirect evidence and results of the field work can
be used together to predict the type and number of on-site and small
scale facilities needed in the community. Facilities predictions
form the basis for alternatives development in Step 1 facilities
planning.
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 two 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 include on-site investigations and representative sam-
A-3
-------
pling necessary to adequately define water quality and public health problems,
identify causes of the problems and predict measures that remedy the problems.
Phase II will also include development of alternatives and completion of the
facilities plans. Both phases should be addressed in the Plan of Study and
grant application. The phases are discussed in greater detail below.
A. Phase I
The review of existing or easily obtainable data may include the
following as appropriate:
1. Review of local well and septic tank permit records. Repair
permits for septic tank systems can provide valuable data on
rates and causes of system failures as well as information on the
repairability of local systems.
2. Interviews with health department or other officials responsible
for existing systems, with septic tank installers and haulers,
and with well drillers.
3. Review of soils maps
4. Calculation of lot sizes
5. Estimate depth to water table by reference to lake levels or from
information in soil maps.
6. Aerial photography interpreted to identify suspected surface
malfunctions
7. Leachate detection surveys of ground or surface water
8. A mailed questionnaire regarding each owner's or resident's
knowledge of the on-site system and its performance. Mailed
questionnaires will generate useful data only if well prepared.
Generally, mailed questionnaires should be used only where avail-
able information indicate very low problem rates (to support No
Action alternatives) or where the data indicate very high problem
rates (to support central collection and treatment alternatives).
This preliminary data will be used to categorize developed lots
within the planning area into one of three groups:
1. Obvious-problem
2. No-problem
3. Inconclusive
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.
The "no-problem" group consists of theose lots where there is no
direct or indirect evidence to indicate that the present system is
inadequate or malfunctioning.
A-4
-------
The "inconclusive" group consist of developed lots with indirect
evidence of problems. The size of this group and the types of in-
direct evidence associated with it will dictate the scope and level
of effort of field investigations conducted during Phase II.
Typically field work in Phase I will be limited to rapid, community-
wide surveys which require little or no entry onto private property.
Examples are acquisition and interpretation of aerial photography,
field checking of aerial photography interpretations, and shoreline
effluent scans. Additionally, a windshield survey of the community
in the company of health department officials, soil scientists or
other locally knowledgeable persons will help the applicants' repre-
sentative or consultant develop a strategy and cost estimate for
Phase II field investigations.
To facilitate communication of Phase I information, preparation of a
planning area base map at a scale sufficient to locate individual
buildings will normally be helpful. U.S. Geological survey 7.5
minute maps (1:24,000) Soil Conservation Service soil maps (1:15,840)
or local tax maps can be used to inexpensively prepare base maps. At
the end of Phase I, base maps can be used to show developed areas
obviously requiring centralized facilities, individual buildings with
obvious problems and developed areas with indirect evidence of
problems.
Phase I as used here applies principally to needs documentation
activi ties. Obviously, other facilities planning tasks can proceed
concurrently with Phase I.
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.
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 be cost-effective for segments of the
community that have obvious needs. In this case, a preliminary
cost estimate for conventional collection and treatment should be
compared to that for the innovative/alternative treatment solu-
tion. If cost estimates and technical analysis indicate that the
use of alternative technology is clearly not cost-effective,
needs documentation may be terminated for these segments without
proceeding to the on-site investigations of Phase II.
2. The number of lots to be investiaged 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
A-5
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submitted and a grant amendment expeditiously processed provided
there is concurrence at the Mid-Course Meeting.
C. Phase II Work
Field investigations in Phase II have two primary purposes:
reclassification of buildings from the "inconclusive" category to
"obvious problem", "no problem" or "potential problem" categories
(defined below)
development of information needed to predict the technologies and
their costs for responding to the community's waste water
problems.
Field investigations can also be designed to accomplish other objec-
tives such as public participation, socio-economic data collection,
etc.
During Phase II previously unrecognised but documentable water quali-
ty and public health problems may be identified, increasing the
number of "obvious problem" buildings. The remainder of buildings
investigated will be classified in the two remaining categories. In
order to do this, representative sampling of site conditions and
water quality in conjunction with partial santiary surveys may be
conducted. Both "obvious" and "inconclusive" problem buildings
should be included in the partial sanitary survey so that reasonable
correlations between site conditions, system usage and system
failures in the community can be made.
"Potential problems" are systems which do not yet exhibit direct
evidence of failure but which can reasonably be expected to fail in
the future. Justifying this expectation must rely on analysis of the
causes for failure of substantially similar systems in the community.
Similarity will be judged on informaton for system usage (number of
occupants and types of sanitary appliances), system design and age,
and verified site limitations (permeability, depth to groundwater or
bedrock, slope, surface drainage, etc.). Buildings in the "inclu-
sive" category whose systems are not similar to any documented fail-
ing system will be included in the "No Problem" category.
This work should be proposed and conducted with the knowledge that
adoption of decentralized alternatives will necessitate complete site
analysis for each building later in the Construction Grants process.
Work should, therefore, be thorough enough that augmentation of the
Phase II work by later studies can be accomplished without duplicat-
ing the Phase II work. The work should also seek the causes of
problem, not just their existence, so that typical on-site and small
scale technologies can be tentatively identified and incorporated
into community alternatives.
Representative sampling of site conditions and water quality should
be carefully coordinated with partial sanitary surveys. While the
design of this work will obviously have to be tailored to each com-
munity's unique situation, general guidance is provided here.
A-6
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1. Representative Sampling
a. Seasonal or permanent high water table. Soil surveys and
comparison with known lake levels reviewed in Phase I may not
be accurate enough to explain specific on-site system problems
or to carefully delineate groups of lots where high water
table is a serious site limitation. Soil to a depth of 5 or 6
feet on or adjacent to suspect lots can resolve such uncer-
tainties. Where seasonal high water table is suspected and
work has to be conducted during dry weather, a soil scientist
with knowledge of local soils should be involved.
b. Groundwater Flow. The safety of on-site well water supplies
and springs on small lots may depend on the rate and direction
of groundwater flow. Estimating the effects of effluents on
surface waters may also require such information. Methods
which indicate groundwater flow characteristics should be
selected and supervised by qualified professionals. Generally
this work in Phase II will be limited to evaluation of well
logs and other available data and of rapid surveys in special
areas such as lakeshores. Exceptions for more intensive work
will be considered where uncertainties about sources of well
contamination need to be resolved for specific lots or groups
of lots.
c. Well water contamination. Where lot sizes are small or soils
are especially permeable, collection and analysis of well
water samples at residences included in sanitary surveys
should be considered. Parameters that can be evaluated as
pollution indicators include, but are not limited to: chlo-
rides, nitrates, phosphates, fecal coliforms, surfactants,
whiteners and other readily detectable constituents inherent
to domestic waste water. No well samples should be collected
from wells that are improperly protected from surface runoff
or other non-wastewater sources. An inspection report should
accompany each well analysis.
d. Shallow groundwater contamination. In areas with drainfield
to groundwater separation distances less than state standards,
shallow groundwater at or near affected water bodies (lake,
stream, unconfined aquifers) should be sampled before aban-
doning on-site wastewater systems on the basis of high water
tables. Discrete samples may be collected during checks of
high water tables for analysis of conventional parameters as
listed above. Alternatively, as rapid survey techniques are
perfected, they may be more appropriate.
e. Soil permeability. If very slow or very rapid soil per-
meability is suspected of contributing to surface malfunc-
tions, backups or groundwater contamination, soil characteris-
tics can be evaluated by augering to 5 or 6 foot depth on or
adjacent to selected lots. Usually, descriptions of soil
horizons by depth, color, texture and presence of mottling,
A-7
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water or bedrock will suffice. Percolation tests for existing
systems will be necessary only in extraordinary circumstances.
2. Partial Sanitary Surveys
It is not the intent of needs documentation to finally identify
each and every wastewater problem in a community. It is not
cost-effective to select appropriate technologies for each
property in Step 1.
Therefore, Phase II sanitary surveys will include only a suf-
ficient number of existing buildings to confirm the level and type
of need present, and to predict the type and approximate number of
measures to correct the problems. Correlation of partial sanitary
survey data, representative sampling, and indirect evidence of
system problems should be sufficient to meet these objectives.
Sanitary surveys should include for each building:
an interview with the resident to determine age of the build-
ing and sewage disposal system, design and location of the
sewage disposal system, system maintenance, occupancy of the
building, water using appliances, use of water conservation
devices, and problems with the wastewater system.
an inspection of the property, preferably in the company of the
resident, noting location of well, septic tank, soil absorption
system, pit privies and other sanitary facilities; lot dimen-
sions; slope; roof and surface drainage; evidence of past and
present malfunctions; and other relevant information such as a
algae growth in shoreline areas.
any representative sampling that is appropriate to the site and
that can be scheduled concurrently.
preliminary conclusions on maintenance, repairs, applicable
water conservation methods, and types and location of replace-
ment or upgrading for existing wastewater systems.
As a rule of thumb, the number of buildings surveyed should not
exceed 30 percent. Where Phase I data is very incomplete, the
buildings may be selected on a random basis and should include a
minimum of 20 percent of existing buildings. Where buildings with
obvious problems and areas with indirect evidence of problems are
well delineated in Phase I, the surveys can be better focused,
perhaps requiring fewer buildings to be surveyed. From 10 to 50
percent of buildings having obvious problems should be surveyed.
In areas with indirect evidence of problems, 20 to 30 percent
would be sufficient. Areas with neither direct nor indirect
evidence may be surveyed where system age, unusual occupancy
patterns or especially severe consequences of system failure so
indicate.
A-8
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V. Planning of Alternatives
In unsewered, low housing density areas, PRM 78-9, "Funding of Sewage
Collection System Projects", puts the burden of proof for need and cost-
effectiveness of sewers on the applicant. The four criteria outlined in PRM
78-9 for eligibility of collector sewers are:
need
cost-effectiveness
substantial human habitation in 1972
2/3 rule
Figure 1 portrays the relationship of these criteria in a decision flow
diagram.
Definition of need by the approach outlined above will address the first
criterion. Estimating cost-effectiveness will typically require two steps:
determining the feasibility of non-sewered technologies for remedying obvious
and potential problems, and comparing the present worth of feasible non-
sewered technologies with the present worth of sewers.
The determination of feasibility for non-sewered technologies should not
be limited to standard septic tank/soil absorption systems. Where lot sites,
site limitations or excessive flows can be overcome by alternative techno-
logies, these must be considered. To the extent that the needs documentation
results show that existing soil absorption systems smaller than current code
requirements can operate satisfactorily sub-code replacements for obvious
problems should also be considered if lot site or other restrictions preclude
full sized systems.
The use of needs documentation results in developing alternatives should
be guided by methods selected to design the Phase II field investigations. If
sanitary surveys and representative sampling were conducted on a random basis,
then the types and numbers of technical remedies should be projected for the
entire area surveyed without bias. However, if efforts were focused on
identified problem or inconclusive segments of a community, then predictions
from the data should be made for surveyed segments only. Real but unre-
cognized problems in "no problem" areas can be accounted for by assuming
upgrading or replacement of existing systems in these areas at frequencies
reasonably lower than surveyed segments.
Infeasibility of remedying individual, obvious problems on-site will not
be sufficient justification for proposing central sewering of a community or
segment of a community. Off-site treatment can be achieved by pumping and
hauling and by small scale, neighborhood collection and treatment systems.
The choice between these approaches should be based upon a cost comparison
which includes serious flow reduction measures in conjunction with any holding
tanks.
Segment by segment cost-effectiveness comparisons will be required only
for those segments where new facilities for off-site treatment are proposed.
Community-wide cost estimates for upgrading or replacement of on-site systems
in decentralized areas will generally be adequate for description of Proposed
Actions pending detailed site analysis and cost estimates for each building in
Step 2.
A-9
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A-10
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Field work necessary to thoroughly evaluate the condition of individual
on-site systems and to select technology for necessary upgrading or replace-
ment is generally to be viewed as Step 2 or Step 2 + 3 work. Typical field
work for this level of analysis includes completion of the sanitary survey
and, as appropriate to each building, installation and monitoring of water
meters, inspection of septic tanks, redding house sewers and effluent lines,
probing or limited excavation of soil absorption systems for inspection, and
other measures listed above for representative sampling. Construction of
on-site replacements and upgrading may proceed in tandem with this site
specific analysis provided:
state and local officials concur (their prior concurrence might
be limited to standard systems),
contract language allows for flexibility in the facilities to
be constructed,
property owner concurrence with the selected alterations is obtained,
and
additional cost-effectiveness analysis to support technology selection
is not necessary.
Necessary state and local agency approval of off-site, non-standard, or
owner-protested facilities or those requiring additional cost analysis would
optimally proceed on a segment-by-segment basis to minimize the time between
technology selection and construction.
The establishment of a management district's authority to accept re-
sponsibility for the proper installation, operation and maintenance of indi-
vidual systems per 40 CFR 35.918-1(e) and (i) should be completed before award
of Step 2 or Step 2 + 3 grants. Development of a management district's pro-
gram for regulation and inspection of systems must be completed before a Step
3 grant award or before authorization 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. Although mailed questionnaries have limited utility for needs docu-
mentation, they can serve as useful public participation tools. A
useful "mailing list" may include all owners of residences within
unsewered areas in the planning area and other interested anJ
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."
A-ll
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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 determination of
their need status. A map with each lot designated as no-need,
obvious-problem, or inconclusive would be helpful for public under-
standing. This meeting could be conveniently scheduled at the end of
Phase I.
C. Partial sanitary surveys conducted during Phase 2 of needs documen-
tation offer an excellent opportunity to gain public input provided
surveyors are adequately informed about the project or can refer
difficult questions to a knowledgeable person for immediate re-
sponse.
D. The final public hearing required by 40 CFR 35.917-5 should be sche-
duled at the end of facilities planning. At this public hearing a
map showing service areas for grantee supervised decentralized
technologies will be displayed. Within service areas, tentatively
proposed methods of treatment and disposal for individual developed
lots will be available to the lot owners. It should made clear to
the public that site investigations conducted in Steps 2 or 3 may
result in adjustments to the proposed treatment and disposal methods
for individual lots.
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VII. ALTERNATIVE CONSTRUCTION GRANTS PROCEDURES FOR SMALL WASTE
FLOW AREAS
1. INTRODUCTION
The three-step Construction Grants process requires consideration and
documentation of literally hundreds of topics or activities. For any one
community, many of these topics or activities can be addressed cursorily,
thereby simplifying and shortening the process. However, local decisions to
pass over items can be expensive and time-consuming if state or U.S. EPA
officials disagree with the omissions. To a great extent, coordination between
applicants and reviewing officials will minimize such omissions and their
consequences. However, in any planning situation, there is an irreducible
level of manpower and expertise required to ensure informed coordination and
to allow for local decision-making. Many rural communities and some developing
communities do not have the requisite manpower and expertise. Attempts to
simplify the Construction Grants process without such appropriate decision-
making capabilities can be frustrating and counter-productive.
At a minimum, completion of the Construction Grants process requires
several years. New program guidance, problems in state and Federal review,
contract difficulties, and other factors can prolong the process even more.
The time required for the process can frustrate the individuals in a community
who have taken the initiative to achieve clean water goals.
The evaluation of alternative technologies, as addressed in this docu-
ment, adds to the potential number of topics and activities to be considered
in rural communities. This section first addresses the differences in Con-
struction Grants procedures between unsewered and previously sewered areas.
Then, specific opportunities for facilitating the Construction Grants process
are reviewed. The goal of this presentation is to explore ways of simplifying
and shortening the Construction Grants process for rural and developing com-
munities that will be evaluating alternative, particularly decentralized,
technologies.
2. UNSEWERED VS. SEWERED AREAS: DIFFERENCES IN PLANNING,
DESIGN, AND CONSTRUCTION
There are several potentially expensive and time-consuming activities
that will rarely be necessary in unsewered areas. These include:
Infiltration/Inflow analysis,
Sewer System Evaluation Survey,
Sewer rehabilitation,
Location, design, flows, and performance of existing treatment plants
(although small privately owned plants may be present),
Industrial pretreatment program (although individual plants may be
treating and disposing of process wastes), and
Value engineering.
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On the other hand, long-standing requirements to inventory existing
treatment systems and to evaluate optimal operation of existing facilities
have been reinforced in unsewered areas by provisions of the Clean Water Act
and related regulations that make existing on-site systems eligible for
upgrading and replacement.
Activities that may be necessary for the inventory and evaluation
include, but are not limited to:
Compilation and review of septic tank and well records,
Interviews with responsible officials, septic tank contractors and
well drillers,
Review of soils data,
Calculation of lot sizes,
Estimation of depths to water tables,
Aerial photography interpretation for identification of surface mal-
functions ,
Leachate detection surveys of ground and surface waters,
Mailed questionnaires to residences,
Base map and overlay preparation showing soil, groundwater, and
geologic conditions along with identified failures,
Representative sampling of depths to water tables, groundwater flow,
well water contamination, shallow groundwater contamination, and soil
permeability,
Sanitary surveys involving resident interviews and property inspec-
tions ,
Supplemental site analysis, such as inspection of septic tanks, house
sewers, and effluent lines, and probing or limited excavation of soil
absorption systems, to determine causes of failure,
Delineation of centralized and decentralized service areas,
Development of monitoring programs for ground and surface waters, and
Pilot programs to evaluate innovative or subcode wastewater techno-
logies and flow reduction devices.
Eligibility requirements for individual systems (and, by analogy, other
on-site and decentralized facilities) include applicant certification that...
"such treatment works will be properly installed, operated, and maintained and
that the public body will be responsible for such actions." Management and
implementation measures that need to be addressed in response to this require-
ment include:
A-14
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Methods of securing access to facilities on private property,
Review and possible modification of current regulations and legal
authorities, and
Delineation of private/public/contractor functions and responsibi-
lities .
A major difference between centralized and decentralized approaches is
the degree to which feasible technologies can be selected with the level of
field data collection normally allowed for facilities planning (Step 1). For
centralized technologies, field data needed to address feasibility and
approximate cost seldom go beyond soil borings to determine subsurface
conditions for pipe installation and foundation support. Given the assumptions
of proper engineering and operation, it is presumed that conventional,
centralized collection and treatment facilities will operate reliably.
However, performance data on many decentralized technologies are insufficient
to support such generalities. Because of this and because of dependence on
conditions at many sites instead of one or a few, field data collection for
decentralized facilities must be more extensive. Yet, if all available means
of site analysis were applied to each existing building in a facilities
planning area, the costs of data collection would substantially reduce, and
perhaps exceed, the savings due to the lower costs of decentralized
facilities. The need for effective management of field data collection efforts
is obvious.
In terms of time and cost, increased requirements for field data collec-
tion are offset by decreased requirements for design work. The keys to most
design problems for decentralized technologies are selection of the appro-
priate technologies and knowledge of the individual site. Structural,
mechanical, and electrical design elements will normally be trivial compared
to those for centralized technologies. Designs and specifications for many
on-site technologies can be standardized for any given community. Designs and
specifications for systems requiring construction variances and for off-lot
technologies will be more demanding, but will seldom require the effort needed
for the more complex processes and structures of most mechanical, centralized
technologies.
3. FACTORS AFFECTING PROJECT COMPLEXITY
The opportunities discussed below to reduce project duration and com-
plexity apply to a number of facilities planning elements. Three elements,
however, are likely to be of greatest consequence. These are:
1. Need for both centralized and decentralized facilities,
2. Lack of performance, design, and usage information for existing waste-
water facilities, and
3. Community development goals.
Many rural and developing communities have existing sewer and centralized
treatment systems or have housing and commercial densities sufficiently high
to make centralized systems cost-effective for part of the facilities planning
A-15
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area. The need for or, particularly, the presence of, sewer systems
essentially creates two planning, design, and construction projects within a
community. In the past, the decentralized project has either been ignored or
sewers have been extended into areas where decentralized technologies would
have been cost-effective. The Clean Water Act, regulations supporting the Act,
and conclusions of the Seven Rural Lake EIS's demand that decentralized
projects be seriously considered unless no need exists for improvements in
unsewered areas of a community. Two projects with dissimiliar information
requirements, planning and impact considerations, and design procedures are
obviously going to be more complex technically. Local administration of grants
and local decision-making may require more effort and sophistication than
either centralized or decentralized projects alone.
As discussed above, selection of decentralized technologies is highly
dependent on field data collection. It is indicative of traditional management
practices for decentralized systems that performance and usage data are almost
always lacking and that design information is reliable for only the past ten,
or at the most twenty, years of installation. Costs and time required for data
collection can become exorbitant if not well managed. To address the necessary
balance between need for data and the cost and time for obtaining it, U.S. EPA
Region V in conjunction with states in the region has prepared "Region V
Guidance - Site Specific Needs Determination and Alternative Planning for
Unsewered Areas." The current version is attached as Appendix A to this sec-
tion. Basically, the guidance describes a sequential process with decisions
after each step on technology selection and the scope of subsequent, more
detailed field studies.
Other matters besides field data affect the outcome and timing of deci-
sions to sewer or not. The sooner in Step 1 that this decision is made or that
service areas for sewered and non-sewered approaches are delineated, the
quicker and cheaper will the Construction Grants process be. Besides field
data, three matters are of primary importance:
1. Cost-effectiveness,
2. Risk of selecting the wrong approach, and
3. Compatibility between local growth objectives and development capacity
of the selected technology.
To enable preliminary comparisons of cost-effectiveness for various
centralized and decentralized technologies, the Cost-Variability Study
reported in Chapter IV.A. has been prepared. The methods developed there are
based upon readily available housing density, topographic, and soils data.
Applicants can use the cost curves either during preparation of their Plan of
Study or early in Step 1 to generate rough present-worth costs. Early deci-
sions can then be made regarding areas that definitely would or would not be
cost-effective to sewer and areas where more work is necessary to reach this
conclusion. For parts of a community where sewers are clearly not cost-
effective, sequential approaches to data collection may be short-circuited and
full-scale site analysis might be initiated thereby saving time and redundancy
in field trips.
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Any decisions made to use decentralized technologies before all relevant
data are collected contain the risk of reversal when final and complete data
become available. Obviously, the more data on hand, the less risk is involved
in making such a decision. The most likely consequences of the decision's
being reversed are the time and cost of redundant planning and design activi-
ties. In the event that decentralized facilities are upgraded or installed,
and then fail, the consequences of being wrong are more substantial. Addi-
tional expenditures for cluster systems, holding tanks or sewers may be re-
quired.
Finally, it is often the case that community objectives in applying for
Construction Grants assistance are more related to growth and development than
to resolution of water quality and public health problems. For areas where
sewering is needed and is cost-effective, this emphasis creates few conflicts
with Construction Grants funding goals. Indeed, cost-effectiveness criteria
allow for sewer and for treatment capacity to accommodate 20 years of growth
at "reasonable rates." Additional capacity can be bought by the applicant at
the margin--that is, for its incremental cost.
In contrast, decentralized technologies, especially on-site systems,
provide little or no reserve capacity for new development. Reserve capacity is
dependent on the stock of land suitable for development with these techno-
logies. (See futher discussion in Chapter VIII.A.)
Therefore, if decentralized facilities are likely to be cost-effective
solutions to local water quality problems, some applicants may want to
initiate early public debate on growth and alternate funding of centralized
technologies. Other applicants may want to incorporate planning tools in their
Step 1 application that assess the stock of suitable land. (See Chapter IX.B.
for an example).
4. OPPORTUNITIES FOR FACILITATING THE CONSTRUCTION GRANTS
PROCESS
a. Managing Field Data Collection
Identifying the Need for Field Data Collection. Three sources in exist-
ing regulations and guidance relate to how much and what type of data are
required in Facilities Plans (Step 1). 40CFR 35.917-4 titled "Planning Scope
and Detail" states:
(b) Facilities planning shall be conducted only to the extent that
the Regional Administrator finds necessary in order to insure that
facilities for which grants are awarded will be cost-effective and
environmentally sound and to permit reasonable evaluation of grant
applications and subsequent preparation of designs, construction
drawings and specifications.
Program Guidance Memorandum 79-8 states in part:
Though house-to-house visits are necessary in some areas, sufficient
augmenting information may be available from the local sanitarian,
geologist, Soil Conservation Service representative or other source
to permit preparation of the cost-effective analysis. Other sources
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include aerial photography and boat-carried leachate-sensing equip-
ment which can be helpful in locating failing systems. Detailed
engineering investigation, including soil profile examination,
percolation tests, etc., on each and every occupied lot should
rarely be necessary during facilities planning.
These statements agree in intent. Only the second source provides
guidance on field data collection, and this guidance is general in nature. The
intent, however, is to prohibit overly conservative data collection programs.
Appendix A, "Region V Guidance-Site Specific Needs Determination and
Alternative Planning for Unsewered Areas" addresses the need for data in more
detail.
The third source of guidance does not discuss data collection directly,
but could be interpreted as calling for comprehensive data in Step 1. 40 CFR
35.917-1, "Content of Facilities Plans" states in part:
(b)...For individual systems, planning area maps must include those
individual systems which are proposed for funding under ง 35.918.
If this is taken to mean that every system with problems has to be located or
that the specific on-site technology proposed for funding has to be selected,
then all of the field work otherwise reserved for Step 2 would have to be done
during Step 1. While this may be appropriate for communities with low levels
of problems amenable to conventional on-site measures (as discussed later in
this section), it would not be appropriate for many communities where collec-
tion of the data would hold up other activities and decisions.
Timing. Several types of field data are best collected during certain
parts of the year. Examples are:
Method
Sanitary Survey - permanent residents
Sanitary Survey - seasonal residents
Aerial Photography
Groundwater Depth Determination
Septic Leachate Detections
Time Limitation
Wet weather; spring
Summer; in some cases winter
After snow melt-before tree
foliation; after leaf fall
Wet weather
Variable. Depends on seasonal
occupancy patterns and weather
For any of these methods, usable data can be collected at other times.
However, there is a risk of having to repeat them should the data be insuffi-
cient or inconclusive. Decisions about balancing this risk with the costs of
delay should be made with the assistance of persons familiar with the methods
and how they relate to alternatives development and subsequent technology
selection.
A-18
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Early Collection of Available Data. Decisions on delineation of cen-
tralized and decentralized service areas are key to expeditious completion of
Step 1 facilities planning. Plans of study can be much more specific and
service area delineations could be made earlier, if available data is col-
lected as described in "Region V Guidance-Site Specific Needs Determination
and Alternative Planning for Unsewered Areas" (Appendix A) were started or
substantially completed before Step 1. This could be accomplished in two ways:
by the applicant or by regional planning agencies.
First, the applicant should have access to available data on existing
on-site systems. This information should include well and septic tank permits,
lot sizes, and soils maps. Some of this should be reviewed in preparing a Plan
of Study for unsewered areas anyway. A more extensive review, perhaps includ-
ing graphic presentation of the data, and interviews with septic tank instal-
lers and haulers would be even more informative. This often could be
accomplished by existing public works, health department or planning agency
staff during winter months or other periods when ordinary demands for their
services are low
Regional or state agencies could also compile available data. Several
208 agencies in Region V have already collected data relevant to performance
of on-site systems (See Chapter XV-C). Significant economies of scale could
be achieved by having knowledgable regional planning agency staff compile
available data and organize community survey data collection in advance of
rural 201 planning within an agency's planning area. Possible sources of
funding for such efforts include:
Section 106 grants (grants to states and interstate agencies to assist
them in administering pollution control programs), and
Section 205(g) (grants to states to administer Sections 201, 203, 204
and 212).
Avoiding Duplication of Effort. The data collection and decision-making
steps described in "Region V Guidance..." (Appendix A) could result in several
return visits to individual residences or businesses. Besides the cost of
mobilizing personnel, numerous visits could unnecessarily interfere with
privacy and thereby decrease public support for the project. Suggestions for
minimizing return visits include:
Mailed questionnaires can provide a certain level of problem documen-
tation but seldom yield complete returns and cannot be expected to
develop information for alternative development or subsequent tech-
nology selection. They require the recipient to respond and to return
the questionnaireto some people a greater intrusion than answering
questions from an interviewer. For these reasons, it is recommended
that mailed questionnaires be used only where previously available
data indicate very low problem rates (to support No Action alterna-
tives) or very high problem rates (to support central collection and
treatment alternatives).
Field verification of aerial photographic interpretations could be
accomplished along with sanitary surveys.
A-19
-------
Each visit to a dwelling or business should result in as much unequi-
vocal data as possible. Sanitary survey formats developed during
preparation of the Seven Rural Lake EIS's require a substantial amount
of data to be requested from the occupant and recorded. Gaining the
needed information before the patience of either the surveyor or
occupant runs out requires that the surveyor understand on-site
systems and local jargon (see Staffing below). Additional information
sheets can be added to the survey format. However, as increased data
requirements are added, the skill of the interviewer should also
increase.
Sanitary surveys are intended to collect data useful for subsequent
technology selection if decentralized approaches are selected.
Reducing the scope of information in the survey format or using
surveyors whose skills are below the minimum will only thwart that
intention and ultimately necessitate return visits.
Soil or well water sampling conducted to support sanitary surveys
should either be concurrent with the interview and site inspection or
scheduled to take place as soon thereafter as possible. Occupants will
readily forgive a few days' lag between interview and sampling if
warned of the "second part of the survey" in advance. Longer delays
may be seen as new intrusions. Waiting for the second visit may create
subtle anxieties that increase occupant resistance.
Where access agreements must be sought from each property owner, the
sanitary surveyor should have the necessary forms available and should
be able to respond to related questions or have ready access to
someone who can.
Detailed site analysis (which could include water meter installation,
excavations of septic tanks and portions of soil absorptions, and
augering holes for groundwater or soil sampling) is likely to be the
most intrusive procedure short of actual upgrading or system replace-
ment. Optimally, all detailed site analysis on a lot would be done in
one or two days. Contractors or public employees doing this work
should be required to restore the site before leaving it.
Staffing. The success of some data collection efforts is dependent on the
personnel selected. Some methods, such as aerial photography interpretation
for surface malfunctions, and septic leachate detection, must be carried out
by professionals. Other methods require only professional supervision or
input; these would include sanitary surveys and site analysis. Much of the
effort could be provided after some training by local residents whose main
qualifications are familiarity with the community and a willingness to achieve
good sanitation and water quality.
As with the design of field studies, designation of the types of person-
nel to be used should be made by persons who understand Construction Grants
procedures for rural areas and who can weigh the cost and skills of potential
personnel against data requirements for decision-making.
An effective way to minimize time required for Construction Grants
activities is to assign or hire key staff for the management agency as early
A-20
-------
as possible. Continuity of decision-makers from Step 1 through implementation
of the agency and facilities construction will make for better decisions.
Also, key staff involvement in planning, design and construction of a project
will be excellent preparation for subsequent decisions during long term
operations.
b. Planning Considerations
Voluntary Participation in the Construction Grants Process. Much of the
discussion here assumes that counties or municipalities will be designating
parts or all of their jurisdictions as wastewater service areas and that
either centralized or decentralized wastewater management will be provided to
all buildings in the designated service areas. Construction Grants regulations
(especially 40 CFR 35.918) and the nature of decentralized facilities provide
an alternate approachthat is, participation only by owners who volunteer.
The advantages of this approach include:
Rapid identification of sites to be evaluated. Instead of community-
wide surveys, sanitary surveys, etc., the applicant would publicize
data on soil conditions and past failure rates, then designate a place
for owners to sign up for assistance.
Access considerations would be reduced to requiring contractual
permission to enter property as needed for inspection and repairs as a
condition of grant assistance.
Field data collection could be limited to detailed site analysis in
Step 1. Individual sites could be demonstrated in the Facilities Plan
as called for in 40 CFR 35.917-1. Technologies could be selected for
each site in Step 1.
Step 2 work for this approach would be relatively trivial.
This approach would be appropriate for areas with relatively low housing
densities, with no unusually sensitive surface or groundwater resources and
with problems amenable to on-site solutions. Where these conditions are not
met, the following disadvantages may be encountered:
Serious public health and water quality problems may be missed.
Individuals who know they have difficult problems with solutions that
require high operational costs may not find grant assistance for
construction very attractive.
Unless most occupants in segments with high density or high failure
rates volunteer, feasible off-site solutions may not be affordable by
those who do seek relief.
The applicant's decision to adopt this voluntary approach can be made any
time during Steps 1 and 2. However, within limits, the decision should be made
as soon as possible to gain the advantages cited.
Initiate Analysis of Growth Objectives and Impacts Early. This subject
has been discussed in detail in Section 3 above.
A-21
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Initiate Management Planning Early. Planning of management approaches
that complement decentralized technologies can be a complex process. Although
most of the decisions are based on common sense, many types of information are
needed to make good decisions. Communities that forsee the need for management
approaches discussed in Part Two of this document could save time in Steps 1
and 2 by examining the following topics at the onset of Step 1:
Inventory skills of existing personnel that might be available from
local, state, and Federal agencies and from consultants and contrac-
tors. (See Chapter VI.C.)
Assess the impacts of existing regulatory authorities on the local
management agency's design.
Familiarize local decision makers and the interested public with the
functions that may be required and options for providing those func-
tions (See Chapter VI. A and B. and Chapter VII).
Begin Pilot Renovation and Flow Reduction Studies in Step 1 or 2. Tech-
nology selection, whether at the end of Step 1 or in Step 2, will take into
account the probability that various modification or replacement technologies
will perform as expected. A number of potentially useful technologies are not
well demonstrated, however. Most alternatives may never have been tried in a
specific community or physiographic province. Technology selection will be
improved if some of the most promising techniques have been installed and
monitored locally for a period of time.
At present, such initiatives could only receive Federal funds if applied
for separately from the Facilities Plan grant. Coordination and timing of
separate grants in order to get timely performance data would certainly add
complexitiescomplexities that may not be worth the trouble.
In order to achieve the benefits of technology demonstration at the local
level, the Regional Administrator could allow Step 1 or 2 funding of construc-
tion and monitoring provided that the applicant can justify its applicability
and utility to wastewater management decisions for the rest of community or
physiographic province.
Establish Standard Design Packages. Specifications and layouts for
various decentralized technologies will be similar for many individual sites.
Time and effort may be saved in Step 2 by the development and description of
standard specifications and layouts. Designers should be allowed flexibility
within the standard design packages to accommodate individual site charac-
teristics .
c. Sequences For Field Data Collection, Alternatives Develop-
ment, and Design of Decentralized Approaches
"Region V Guidance - Site Specific Needs Determination and Alternative
Planning for Unsewered Areas" (Appendix A) defines an approach to rural waste-
water planning that is generally applicable to a wide variety of rural plan-
ning situations. This section discusses modifications to the planning sequence
reflected in the guidance. The section also reviews factors to be considered
in selecting these modifications. In very general terms, persons considering
modifications should constantly weigh the following objectives:
A-22
-------
Minimize Minimize
Planning time and cost Repetitious field work
Design time and cost vs. Repetitious cost analysis
Intrusion on occupants Premature failure of selected
technologies
The subjects discussed in this section will have to be considered along
with other planning and design exercises such as environmental analysis,
management agency design, and public participation. However, to make the
concepts discussed manageable, this section primarily considers the impact of
field data collection on the development of alternatives and the transfor-
mation of the selected alternative into a design that can be bid for and
built.
Figure XVI-D-1 portrays sequences for data collection, alternatives
development, and supporting cost analysis consistent with "Region V Guidance."
There are four implicit assumptions incorporated into the Guidance and Figure
XVI-D-1:
1) There exists very meager data prior to Step 1 that reliably define the
design, usage, and performance of existing on-site systems.
2) Service areas cannot readily be delineated for centralized collection
and treatment, community supervision of decentralized facilities, or
no action.
3) The severity of existing and potential problems with on-site systems
justifies active community management of all or a significant fraction
of the systems.
4) Technologies to replace and upgrade existing on-site systems will
include substantial use of off-site, innovative and/or subcode
designs, thereby necessitating delays in technology selection until
all individual developed sites are thoroughly surveyed and analyzed.
Note that all four assumptions are pessimistic. Lacking information to
the contrary, such assumptions should be made by applicants and grant adminis-
trators. This is appropriate because the pessimistic assumptions necessitate
more data collection. The high level of data collection also has to be staged
by the introduction of several decision points for the sake of flexibility and
ultimate economy.
Depending on verification or rejection of these four assumptions, six
modifications to Figure XVI-D-1 consistent with overall time, cost, and com-
plexity objectives, can be considered:
1) Collect and review all available data prior to Step 1 (See Section
G.4.a. of this Chapter). This could facilitate modifications 5 and 6
below.
A-23
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A-25
-------
2) Conduct community surveys prior to Step 1 (see Section G.4.a. of this
chapter). This could facilitate the same modifications as above.
3) Include supplemental site analysis and cost-effectiveness comparisons
(see Chapter II-H) for buildings in Phase II sanitary survey (up to
30% of buildings). This could enable modifications 5 and 6, depending
on conclusiveness of the data.
4) Include sanitary surveys and supplemental site analysis for all
decentralized service area buildings in Phase II. This would substan-
tially abbreviate Step 2 and more conclusively allow modifications 5
and 6.
5) Complete technology selection and preparation of standard designs and
specifications in Step 1. This could facilitate Modification 6.
6) Complete technology selection, design of non-standard on-site systems
and construction with a Step 2 and 3 grant. This modification is
subject to 40 CFR 35.909, .920-3(d) and .935-4.
Decisions to adopt these modifications may reasonably be considered as
milestones before and during Step 1, including the preapplication conference,
Plan of Study, mid-course meeting, public hearings, and final Facilities Plan.
Specific modifications taken from the list of six in preceding paragraphs
are noted for each alternate sequence.
Several possible modified Construction Grants sequences are portrayed in
Figures XVI-D-2 through 6. All of the sequences assume that decentralized
technologies are selected in the end. This obviously will not be the case for
all unsewered areas, but the several milestones allow for modifying future
work to incorporate selection, design, and construction of centralized alter-
natives as appropriate.
The sequences vary in the degree to which the Proposed Sections identify
the technologies specified for each building. Sequences 1, 3, and 5 end Step
1 with "preliminary technology assumptions," which would include:
Detailed service area delineations (sewered, grantee managed decen-
tralized facilities, or no action),
Within decentralized service areas, identification of neighborhoods
probably requiring off-site treatment,
For off-site decentralized facilities (including septage disposal),
identification of apparently suitable soils and expected availability
of sites, and
For the remainder of decentralized service areas, predictions based on
available data and field data collection of the mix of technologies,
including no action, for upgrading and replacing existing on-site
systems. Tentatively proposed methods of treatment and disposal for
individual developed lots should be available to lot owners at the
final public hearing on the Facilities Plan (see Appendix A, Part
VI.D.).
A-26
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A-30
-------
A number of officials have expressed concern with this level of techno-
logy specification. The primary purpose for allowing less than absolute
descriptions of funded facilities is to expedite Step 2 work on conventional
centralized treatment works. For facilities planning areas where Phase I
information indicates that centralized technologies will not be necessary, all
or most field data collection could be scheduled and completed in Step 1, as
portrayed in sequences 2, 4, and 6. Alternatively, if centralized technologies
are necessary, the project could be segmented and sequences 2, 4, or 6 could
be used for decentralized service areas.
d. Administrative Measures
Administrative measures to facilitate the construction grants process in
rural and developing communities include:
Overcome local unfamiliarity with the Construction Grants process. The
optimium means for doing this is to train a local elected or salaried
official by intensive review of regulations or by short courses
developed for this purpose. Regional or state officials may often be
very helpful in training local officials or actually providing
assistance in grant application and administration. Delegation of
local grant responsibilities to facilities planning and design
consultants is typically practiced, but is not always the best
solution (see Chapter V).
Use of milestones for decision-making. Several times during the
Construction Grants process, applicants are required to consult with
state or Federal reviewing agencies. Examples of interest are the
preapplication conference and the mid-course meeting in Step 1. These
meetings can be used to identify reasonable short cuts in field data
collection, alternatives development, environmental analysis, etc.
Informal contacts between applicants and reviewing agencies frequently
occur and can also be useful in tailoring the process to local
situations.
Segment projects for centralized and decentralized service areas.
Because of substantial differences in the Construction Grants process
for centralized and decentralized facilities, letting different
service areas proceed at their own pace may achieve project goals for
each part more rapidly. A typical objection to such segmenting is
based on fears that the state priority rating given decentralized
projects may be too low to set funding. This topic is addressed in
Chapter XV-D.
Enact county ordinances and/or state legislation enabling provision of
access to private systems. In many communities, housing density,
frequency of failures, or sensitivity of water resources are high
enough to require comprehensive management approaches (as opposed to
voluntary approaches). Gaining legal access to survey, test, upgrade,
replace, and maintain on-site systems can complicate and delay needed
action on some properties. This can be overcome by legislation
reasonably designed to protect the public's interest in water quality
and public health.
A-31
-------
Amend facilities planning guidance to reflect the need for site data
in developing, designing and constructing decentralized facilities.
Existing (February, 1981) regulations, Program Requirements memoranda,
and facilities planning guidance provide insufficient information on
the types of information necessary to develop and support viable
decentralized alternatives. Emphasis is generally placed on
documenting needs for improved wastewater facilities. However, it is
one thing to document a need. It is quite another to collect
sufficient information to select an alternative other than abandonment
of existing systems. Applicants and facilities planners would be well
served by a greater emphasis in the regulatory literature on data
requirements for alternatives to sewering.
A-32
-------
APPENDIX B
ON-SITE SANITARY INSPECTION FORM
-------
SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
Resident:
Owner:
Address of
Property:
Study Area:
Surveyor/Date:
Weather:
Lot Location:
Tax Map Designation:
Preliminary Resident Interview
Age of Dwelling: years Age of sewage disposal system:
Type of Sewage Disposal System:
Approximate Lot Dimensions:
feet by feet
fears
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,
adults,
Permanent Residents:
Seasonal Residents: , length of stay
Typical Number of Guests:
otential,
children
Planned
, 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
_Bathtubs
Bathroom Lavoratories
JToilets
Plans for Changes:
Problems Recognized by Resident:
JCitchen Lavoratories
_Garbage Grinder
_Dishwasher
Other Kitchen
_Clothes Washing Machine
_Water Softener
JJtility Sink
Other Utilities
Resident Will Allow Follow-Up Engineering Studies:
_Soil Borings
_Well Water Sample
Groundwater
B-l
-------
SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
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
B-2
-------
SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
Surveyor's Visual Observations of Effluent Disposal Site:
Drainage Facilities and Discharge Location:
Basement Sump
Footing Drains
Roof Drains
Driveway Runoff
Other
Property and Facility Sketch
B-3
-------
APPENDIX C
Example of a Cost Analysis for
an Optimum Operation Alternative
Appropriate to the First Level of Alternative
Development, i.e., Technology Assumption
Source: Appendix E, Final Environmental Impact Statement -
Alternative Waste Treatment Systems for Rural Lake
Projects.
Case Study Number 4, Steuben Lakes Regional Waste
District, Steuben County, Indiana, January, 1981.
-------
LIMITED ACTION ALTERNATIVE
PRESENT WORTH, USER CHARGES
ASSUMPTIONS
On-Site
Systems
Capital
Costs
0 & M
Year 1980 - 4171 EDU's (50% seasonal, 50% permanent)
Year 2000 - 6196 EDU's (50% seasonal, 50% permanent)
50% (4171) septic tanks to be replaced
10% (4171) ST-SAS's to be replaced
$1,877/ST-SAS
$ 265/septic tank
$60/ST pumping (50% once/3 years, 50% once/5 years)
$400/H202 treatment (2% of drainfields/year)
$6/well sample (1/well/5 years)
$40/groundwater sample (20 tests, 3 samples/test)
Sanitarian @ $25,000/yr. - 260 days/yr.
Surveyors @ $12,000/yr. - 130 days/yr. (1980), 200/yr. (2000)
Secretary @ $12,000/yr. - 260 days/yr.
(20% fringe benefits for sanitarian, surveyors, secretary,
soil scientist @ $325/day - 51 days/yr. (% day rentals -
see cost calculations
Salvage
Values
50 year useful life for ST's; 20 years for all else
Present
Worth
User
Charges
6 5/8%, 20 years
Eligibility - 100% of site analysis and replacement system charge
Federal funding - 85% of site analysis; replacements
State funding - 6% of these items
Debt retirement - 6 7/8%, 30 years, 1980 capital
Debt reserve - 20% of debt retirement
Alternative Costs
Existing Systems:
Replace 2086 ST's
Replace 417 ST-SAS's
Pump 1043 ST's/yr.
H20 83 DF's/yr.
Future systems:
Add 2025 ST-SAS's
Capital
Costs
552.8
782.7
-0-
-0-
1,335.5
190.05/yr.
190.05/yr.
($ x 1000)
O&M
Costs
-0-
-0-
62.58/yr.
33.20/yr.
95.78/yr.
1.52/yr./yr.
1.52/yr./yr.
Salvage
Value
429.3
429.3
C-l
-------
Alternative Costs (Continued)
Salaries:
Sanit. - $25,000/yr. - 260 days/yr. -0- 25.0/yr. -0-
Surveyors - $12,000/yr. - 130 days/yr. -0- 6.0/yr. -0-
$12,000/yr. - 3% days/yr/yr.-O- 0.16/yr./yr. -0-
Secretary - $12,000/yr. - 260 days/yr. -0- 12.0/yr. -0-
43.0/yr.
0.16/yr./yr.
20% fringe benefits -0- 8.6/yr. -0-
0.03/yr.
-0- 51.6/yr. -0-
0.19/yr./yr.
Retainer:
Soil Scientist - $325/day - 51 days/yr. -0- 16.58/yr. -0-
-0- 16.58/yr. -0-
Water samples analyses:
Wells - $6/sample - 834/yr. -0- 5.0/yr. -0-
Wells - $6/sample - 20/yr./yr. -0- 0.12/yr./yr. -0-
Shallow groundwater - $40 x 20 x 3 -0^ 2.40/yr. -0-
-0- 7.40/yr. -0-
0.12/yr./yr.
Engineering, Legal, Contingencies:
Site Analysis 120.2 -0- -0-
Legal, etc. (9% construction cost) 1,176.6 -0- -0-
1,296.8 -0- -0-
Alternative Costs
Total Alternative Costs
Total 1980 costs 2,632.3 171.35/yr. 398.0
Total 1980-2000 costs 190.05/yr. 1.83/yr./yr. 429.8
Present Worths
($ x 1000)
Total Alternative P.W. = 2,632.3 + 10.9909 (171.36 + 190.05) + 81.155 U.155
(1.83) - 0.2772 (398.0 & 429.8) = 6523.7
Local Share (1980)
($ x 1000)
1980 Local Share = 9% ($2,632.3) = 236.91
User Charge (1980)
($)
Debt Retirement - O.U/y58 (9%) ($2,632,300) 18,853
Debt Reserve - 20% (above) 3,770
Annual 0 & M 171,360
Total 1980 annual local cost $193,983
User Charge = $193,983/4171 % $50/residence/year
C-2
-------
APPENDIX D
Example of a Cost Analysis for an
Optimum Operation Alternative
Appropriate for Cost-effectiveness Comparisons of
Final Alternatives
Source: Appendices D and B, Final Environmental Impact
Statement, Alternative Waste Treatment Systems
for Rural Lake Projects - Case Study Number 5,
Ottertail County Board of Commissioners, Otter-
tail County, Minnesota. November, 1980.
-------
APPENDIX D
Modified Limited Action Present Worth and User Charges -
Otter Tail Lakes Project Area
Assumptions
Existing Systems** 938 ST/SAS's
176 Cesspools
Future Systems^
Labor
Operation &
Maintenance
(O&M) Costs
73 HT's
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
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-l
-------
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 \
$325/day Soil Scientist1^
Capital
Item Costs
+20% fringe benefits
Existing Systems:
389 ST/SAS's - Add Hatches
524 ST/SAS's - Replace ST's
25 ST/SAS's - Add Flow Redl, SM's
71 Cesspools - ST/SAS's
35 Cesspools - ST/shallow DF's
35 Cesspools - ST/dosed sh. DF's
35 Cesspools - ST/dosed SM's
13 HT's - Add Flow Reduction
8 HT's - Add Flow Reduction +
ST/Shallow DF
26 HT's - Add Flow Reduction +
ST/dosed shallow DF
26 HT's - Add Flow Reduction +
ST/dosed SM
81 EDU ST/Cluster Systems
Subtotal
Future Systems:
361 ST/SAS's
115 ST/dosed shallow DF's
114 ST/dosed SM's
46 EDU ST/Cluster Systems
Subtotal
38.9
235.8
235.3
90.2
44.4
114.5
309.8
13.1
18.2
111.3
256.4
426.2
1,894.1
22.92/yr
18.80/yr
50.44/yr
12.30/yr
104.5/yr
($ 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
4.10/yr
4.10/yr
5.62/yr
39.93/yr
2.2
7.0
7.0
167.8
396.3
0.26/yr/yr
0.40/yr/yr
0.40/yr/yr
0.16/yr/yr
1.22/yr/yr
Operation and Maintenance.
D-2
-------
Salaries:
Sanitarian @ $25,000/yr x 260 day
Surveyors @ $12,000/yr x 120 day
Secretary @ $12,000/yr x 130 day
Subtotal
20% Fringe Benefits
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 @ $300/mo x 12
Office supplies, telephone, etc.
Van lease, gas & oil
Small motorboat - 4 wks/yr
Subtotal
E&A Costs:
Contingencies - 9% of 1980 costs
Site Analysis
Cluster System Design*
-0-
-0-
-0-
-0-
-0-
-0-
25.00/yr
5.54/yr
6.00/yr
36.54/yr
7.31/yr
43.85/yr
-0
-0-
-0-
-0
-0.
-0
-0-
-0-
-0-
-o-
-0-
-0-
-0-
-0-
-0-
-0-
170.5
431.3
70.0
671.8
4.88/yr -0-
2.50/yr -0-
0.05/yr/yr -0-
2.25/yr ^
4.75.yr -0-
0.05/yr/yr
3.60/yr
2.00/yr
6.00/yr
0.40/yr
12.00/yr
0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
Total - As of 1980
- Increment 1980 - 2000
Present Worth
2565.9
104.5/yr
105.4/yr 396.3
1.27/yr/yr 310.1
($ 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-3
-------
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 T 1,181 = $102
D-4
-------
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
D-5
-------
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 T 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 person-days (900 systems T 6/person/day)
150 person-days (Jr. Engineer 150)
Additional costs - 3-man crew @ $450/day x 150
- waste disposal @ $20/tank x 900
Step 3
Soil
sampling
364
364
Step 4-- 40
Disposal unit 243
inspection 283
Step 5-- 44
Well water
Meters 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 -f \ persons/day)
person-days (Sanitarian 40, laborers 243)
person-days (15% x 1,181 wells x 6 inspections
inspections/person/day)
person-days (Surveyor 44)
T 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.
D-6
-------
Additional costs - Meter installation @ $175/meter x 177
Step 6--
Shallow
Groundwater
Sampling
20
80
100
person-days (10 days x 2 persons for scan)
person-days (80 plumes 4- 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
Shore ground-
water hydro-
logy survey
40
40
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 x
Laborers @ $12,000/yr x
Secretary @ $12,000/yr x
20% fringe benefits
456
40 25
50
44 24
243
283 44 100
x 260 days
464 days
243 days
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.
D-7
-------
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
Jr. Engineer @ $20,000/yr x 173 days
Soil Scientist @ 25,000/yr x 202 days
W.Q. Scientist @ 25,000/yr x 76 days
Report & Reproduction
Communication
Graphics, report preparation
House rental for office, sleeping x 12 mo's
Other per diem @ $20/day x 536*
65 RT x 250 miles x $0.20/mile
Direct labor x 3.0
Other direct costs x
Travel x 1.2
1.2
Total consultant
$11,440
13,310
19,420
7,310
$51,480
Total
6,000
10,720
3,250
$19,970
154,440
3,180
23,964
$181,584
$249,674
181,584
$431,258
Assuming that the consultants work 5 days/week.
D-8
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APPENDIX E
TABLE OF CONTENTS FOR TECHNICAL
REFERENCE DOCUMENT
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PART ONE
TECHNOLOGY ALTERNATIVES
Chapter I
FACT SHEETS
Individual Fact Sheets in order, as follows:
1.1 - 1.6 Water Conservation (6.2)
2.1 - 2.9 On-Site Technologies (6.3)
3.1 - 3.9 Septage Handling, Treatment, and Disposal (6.5)
4.1 - 4.2 Small Scale Technologies (6.4)
Chapter II
EVALUATION AND DESIGN METHODOLOGIES
A. Water Quality Impacts of On-Site Systems (4.4)
B. The Role of Needs Documentation in Alternatives Development (no #)
C. Review of Direct and Remote Sensing Techniques (4.5)
D. Septic Leachate Detector Research (9.1-9.4)
E. Septic Leachate Detector Policy (11.7)
F. Aerial Photography Methods and Policy (11.6)
G. Sanitary Survey Methods and Policy (11.5)
H. Evaluation of the Dowser Groundwater Flow Meter (no //)
I. Evaluation and Design Methods for Small Waste Flow Technologies (6.9-6.12)
J. Site Analysis and Technology Selection for On-Site Systems (6.8)
K. Geotechnical Investigations for Cluster Drainfields (6.9)
L. Impacts of Water Conservation on Alternative Technologies (6.6)
Chapter III
USE OF SOILS DATA
A. Soils Relationships Study (5)
B. Pickerel Lake, Michigan, Cluster System Site Analysis (6.17)
Chapter IV
COST ANALYSIS
A. Cost Variability Study (6.1)
B. Planning and Design Costs for Small Waste Flows Areas (6.13/6.14)
C. Cost Effectiveness Analysis in Small Waste Flows Areas (6.15)
D. Economic Analyses of Flow Reduction Devices and Programs (6.7)
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Chapter V
THE ROLE OF ENGINEERS
A. Problems of Professional Liability in Relation to Innovative and
Alternative Wastewater Treatment Technologies for Small Communities
in U.S. EPA Region V (7.7)
APPENDIXThe Law of Designer's Liability (7.7)
PART TWO
COMMUNITY MANAGEMENT ALTERNATIVES
Chapter VI
DESIGN OF SMALL WASTE FLOWS MANAGEMENT AGENCIES
A. Functions of Small Waste Flows Management Agencies (10.1)
B. Local Options in Design (10.2)
C. Guidance for Analysis of Existing Functional Capabilities: Manpower and
Authority (10.5)
D. Manpower Projections for Small Waste Flows Agencies (10.6)
E. Estimating Administration and Operations Costs (10.7)
F. Existing Training Programs for Small Waste Flows Management and Operations
(10.10)
G. Training Programs Needed (10.11)
H. Design Process for Small Waste Flows Agencies (10.8)
I. Hypothetical Small Waste Flow Management Programs (10.9)
Chapter VII
VARIANCES
A. Environmental and Economic Justifications for Variances (10.3)
B. Effects of Variance Procedures on Agency Design, Manpower and Cost (10.4)
Chapter VIII
IMPLEMENTATION
A. Rights of Entry to Private Property in Connection with Publicly Managed
Decentralized Wastewater Systems (7.8)
B. User Charge Study (3.7)
C. Water Quality Monitoring Plans (4.13)
D. Implementation Methods for Water Conservation (7.6)
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PART THREE
FACILITIES PLANNING METHODOLOGIES
Chapter IX
PLANNING AREA DEFINITION
A. Criteria for Identification of Small Waste Flows Areas (11.1)
B. Approaches for Defining Planning Area Boundaries (11.2)
C. Use of Segmentation in SWF Planning and Implementation (11.3)
Chapter X
DEMOGRAPHY AND RECREATION
A. Number and Range of Rural and Rural Lake Projects (3.1)
B. Population Projection and Impact Techniques (3.3)
C. Recreation Home Demand (3.2)
D. Recreation Planning (3.2)
E. On-Site Systems in Region V and Potential Cost Avoidance from Adoption
of Optimum Operation Alternatives (no #)
Chapter XI
LAND USE AND ENVIRONMENTAL CONSTRAINTS
A. The Interrelationship Between Small Waste Flows Facility Planning and
Land Use (3.5)
B. Environmental Constraints Evaluation Methodology (3.4)
C. Multiple Use of Cluster System Sites (3.10)
Chapter XII
SURFACE WATER RESOURCES
A. Extent of Surface Water Quality Data Available in U.S. EPA Region V States
(4.1)
B. Availability of Non-Point Source Data (4.3)
C. Review of Lake Water Quality Modeling Techniques (4.6)
D. Review of Rural Non-Point Modeling Techniques (4.8)
E. Guidelines for Surface Water Quality Data Collection in Step 1 Facilities
Planning (4.11)
F. Evaluation of the Significance of On-Site Systems in Water Quality
Management of Lakes (4.9)
G. Water Quality Benefits of Non-Point Source Control (4.10)
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Chapter XIII
GROUNDWATER RESOURCES
A. Extent of Groundwater Quality Data Available in U.S. EPA Region V States
(4.2)
B. Review of Groundwater Modeling Techniques (4.7)
C. Groundwater Resources Data Needed for Facilities Planning in Rural Lake
Areas (4.12)
Chapter XIV
PUBLIC PARTICIPATION
A. Public Participation Plans for Rural Planning Areas (11.4)
PART FOUR
STATE AND EPA ADMINISTRATIVE ALTERNATIVES
Chapter XV
STATE AND 208 PROGRAMS
A. Review of State Codes and Implementation Authority for SWF Management (7.1)
B. Organization and Manpower for On-Site Regulation (7.2)
C. Potential 208 Program Roles in Small Waste Flows Areas (10.12)
D. Benefits of Separate State Priority Lists for Small Waste Flow Areas (11.9)
Chapter XVI
FEDERAL PROGRAMS
A. EPA Policy Regarding Conventional Water Use and Population Growth (3.6)
B. Federal Water Quality Improvement Programs in Rural Lake Areas (7.4)
C. Federal Programs Affecting Construction Grants Activities in Rural
Lake Areas (7.5)
D. Alternative Construction Grants Procedures for Small Waste Flow Areas
(11.8)
E. The Davis-Bacon Act and Small Community Alternative Wastewater Management
Projects Funded by EPA (7.9)
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APPENDIX F
DELETIONS FROM THE DRAFT EIS
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APPENDIX F
DELETIONS FROM THE DRAFT EIS
Preparation of this Final EIS entailed deletion of material from the Draft and, in
most instances, replacement with new wording. Some of the deletions were necessitated to
reflect the 1981 amendments to the Clean Water Act and new regulations implementing the
Act. However, such deleted sections still apply to grants made before May 12, 1982, the
effective date of the new regulations. This appendix makes deleted material available for
ready cross-referencing.
Some material was deleted or replaced due to refinement in Region V's policies on a
few subjects. These deletions are also included here.
After each deletion, a short note explains the reason for the change.
Deletions are presented here in the order in which they appeared in the Draft EIS.
Section and page numbers preceding each deletion identify their location in the Draft EIS.
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EXECUTIVE SUMMARY DELETIONS
From "Small Waste Flows Technologies," p. iv:
Preliminary delineation of sewered and unsewered service areas may be possible.
The second stage is based on system selection. Partial sanitary surveys and representative
sampling of soil and groundwater provide the basis for more conclusive identification and
quantification of on-site system failures. The results are extrapolated to unsurveyed
on-site systems and appropriate systems (including no action), are tentatively selected for
each developed property in unsewered service areas. This will normally be adequate for
cost-effectiveness comparisons with centralized alternatives and for description of
facilities plans' proposed action.
The final stage of development for optimum operation alternatives will normally be
completed with a Step 2 or Step 2 and 3 grant because of the time and expense required for
detailed site analysis. Also, because eligibility of off-site treatment facilities may be
dependent on the detailed site analysis and subsequent micro-scale cost-effectiveness
analysis, final site suitability studies and site selection may be delayed beyond Step 1.
The final stage, facilities verification, is based on a detailed site analysis. The
analysis includes completion of the sanitary survey and, where needed, on-site work to
determine causes of failure and appropriate remedies. To avoid repeated inspection of
systems and owner annoyance this step may commonly be followed (in Step 2 and 3 projects)
by the actual construction needed.
Note: The replacement for these paragraphs allows greater flexibility in the amount
of field work required to describe optimum operation alternatives.
From "Community Management," p. v:
certifying that a public body will be responsible for the proper installation,
operation, and maintenance of the funded systems;
establishing a comprehensive program for regulation and inspection of on-site systems
that will include periodic testing of existing potable water wells and, where a
substantial number of on-site systems exists, more extensive monitoring of aquifers;
and
obtaining assurance of unlimited access to each individual system at all reasonable
times for inspection, monitoring, construction, maintenance, operation, rehabilita-
tion, and replacement.
Note: The wording of these items was changed to follow the May 1982 regulations more
closely.
From "Facilities Planning Techniques", p. viii:
Facilities planning can be a frustrating and time-consuming process for grantees. Changes
in grants program emphasis, as reflected in this EIS, procedural changes and funding
modifications contribute to the delays and revisions sometimes encountered. The conclu-
sions and recommendations this EIS presents will, hopefully, lead to well designed,
efficient facilities planning exercises. Other specific suggestions are made for
abbreviating the processes of needs documentation and development, costing, selection, and
design of alternatives.
Note: This paragraph was deleted based on the editorial opinion that it added little
useful information to the Executive Summary
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From "Funding and Administering the Optimum Operation Alternative," p ix:
Recent analysis of the opportunities and problems associated with small waste flow
management has led to numerous clarifications of the requirements of the Clean Water Act
and its regulation. Most of these are summarized in Facilities Planning 1981, the Program
Requirements Memoranda that contributed to it, and other U.S. EPA and Regional Guidance.
Among the most important items reviewed are:
Note: The replacement for this material recognizes the presence of new legislative
and regulatory documents.
From "Funding and Administering the Optimum Operation Alternative," p x:
* Needs Documentation for Alternative Sewers--While alternative sewers are excepted from
the various requirements specified in PRM 78-9, they are not exempt from the general
requirements for demonstrated need that rest upon every fundable action. Future
guidance will emphasize this.
Note: The PRM that was the source of this issue has been replaced with suitable
guidance. The item is deleted without replacement.
From "Funding and Administering the Optimum Operation Alternative," p. x:
Pilot StudiesProgram Operations Memorandum 81-3, issued during preparation of this
EIS, authorizes pilot studies of innovative and alternative technologies under Step 1
facilities planning.
Note: The wording and content of this item have been changed to recognize amendments
to the Clean Water Act that make field testing of alternative and innovative technolo-
gies eligible for Step 3 funding.
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CHAPTER I DELETIONS
From Section A, p. 4:
Throughout this document, cross-reference notes are printed in margins. These notes refer
either to related sections within the document or to sections of the separate Technical
Reference Document. The Technical Reference Document comprises over 70 new individual
technical and analytical reports. The recommendations of this EIS come from the experience
and data gained on the seven case studies and the Technical Reference Document.
Note: This paragraph has been omitted in favor of a more specific legend repeated on
the first page of each chapter.
From Section B, p. 4:
These objectives are consistent with present regulations implementing the Clean Water Act,
especially 40 CFR 35.917-1, which states in part:
Facilities planning must address each of the following to the extent considered
appropriate by the Regional Administrator: . . . (d) A cost-effectiveness analysis
for the treatment works . . . This analysis shall include: . . . (3) An evaluation of
improved effluent quality attainable by upgrading the operation and maintenance and
efficiency of existing facilities as an alternative or supplement to construction of
new facilities.
Note: This paragraph was replaced with language from new regulations.
From Section C.2., pp. 10 and 12:
New centralized facilities are capital intensive. Even with substantial Federal and state
grant assistance, municipalities can have difficulty financing the local share of construc-
tion costs. All local costs are ultimately passed on to users of the system and possibily
to taxpayers who are not even users. Annual user charges exceeding $200 are not uncommon
for new conventional facilities in small communities. Within Region V, annual residential
user charges rarely exceed $200--only 10 out of 687 user charge systems approved as of
September 1980 were greater (U.S. EPA, 1980a). However, all 10 of these communities and 14
of 17 communities charging $150-$200 per year have populations of 10,000 or less. [Only
communities that are building collection sewers and interceptors in the Region are included
in this analysis. The user charges do not include private costs for plumbing charges or
house sewer construction (often $1,000 or more) and most user charges have already been
minimized to varying degrees by initial hook-up fees (often $2,000 or more)].
Note: This paragraph was revised to reflect the fact that capital costs can be and
often are, recovered separately from 0 & M costs and that user charge systems are
required only to recover 0 & M costs.
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CHAPTER II DELETIONS
From Section A.4, pp. 26 and 30:
The decision flow diagram reflects no judgments regarding eligiblity of specific items or
their appropriate timing in the 3-step Construction Grants process. Generally, "actions to
take" will be eligible if adequate justification is provided. A subsequent process diagram
(Figure II-C-2) relates the procedures in the decision flow diagram to the requirements of
the Construction Grants process, necessary management structures, and needs documentation
guidance. Timing is disucssed in Sections II.D.E. and G.
Note: Due to changes in funding of Steps 1 and 2, emphasis on timing and eligibility
of items in the decision flow diagram is not critical to projects beginning after May
12, 1982. Figure II-C-2 and this paragraph referring to it have, therefore, been
modified in the Final EIS.
From Section C.2., p. 36:
The accompanying decision flow chart (II-C-2) shows the combined needs documentation and
alternatives development procedures associated with construction of an optimum operation
alternative under the Clean Water Act. The remainder of this chapter is a step-by-step
discussion of the procedures outlined in this chart, from collection of existing data
through actual construction....However, when followed in the sequence shown on the process
diagram, these methods minimize wasted time, effort and effort and expense in needs
documentation and alternative development regardless of project potential for Federal
funding.
Note: See note above.
From Section D, p. 38:
To produce a tentative system selection for every site at the conclusion of Step 1.
Even without Construction Grants funding, this early estimate can greatly reduce
public uncertainty about an optimum operation alternative.
Note: This Draft EIS recommendation has been changed to allow more flexibility in
describing optimum operation alternatives in facilities plans.
From Section D.l.c., p. 44:
Many of these "false negatives" can be minimized through careful use of the equipment.
The device should not be used during high winds. Monitoring of groundwater flow patterns
through use of a meter or other methods can clarify groundwater factors. Information on
changes in lake level and recent rainfall or snow melt is also important.
Note: An expanded discussion of supporting data collection for septic leachate
surveys replaces this paragraph.
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From Section D.l.d., p. 45:
Since the facilities planner wants to minimize intrusion on private property and reduce the
number of visits to any particular site, the mailed questionnaire should be sent only to
areas where available date indicate a significant number of on-site system problems and
where preliminary economic analysis indicates that sewering will be cost-effective. Use of
mailed questionnaires is discouraged where optimum operation alternatives may be cost-
effective since on-site sanitary inspection would be required.
Note: This cautionary recommendations has been deleted. Facilities planners should
use this judgement on the utility of any measure that intrudes on privacy.
From Section D.2.a., p. 46:
Sanitary surveys need to include only enough on-site sanitary inspections to meet these two
objectives. In general, not more than 30% of all developed properties in a community
should be inspected in Step 1. Higher or lower coverage may be appropriate for individual
segments depending on the quality of data available prior to design of the survey.
Note: This quantitative restriction has been removed to allow facilities planners
more flexibility.
From Section D.2.a., p. 46:
Because statistical accuracy is not critical, targeted surveys may cover as few as 10% of
developed properties in a segment or community. Up to 50% of those residences having
obvious problems may be inspected in Step 1.
Note: See note above.
From Section D.2.a., p. 46:
Causal relationships may be used in conjunction with other local data to expand survey
results to unsurveyed systems.
Note: Based on surveys conducted by Region V since publication of the Draft EIS, we
feel that selection of specific technologies, no matter how tentative, for individual
properties without at least an on-site sanitary inspection would be unnecessarily
misleading and could cause property owners to plan on actions that may change or not
be taken at all.
From Section E.2.a., p. 51
After the partial sanitary survey and representative sampling it should be possible to (1)
understand the nature and cause of specific on-site system problems, and (2) generalize
from sampled system to unsampled systems with similar characteristics.
In this task even indirect evidence can play a part. A specific system parameter (lot
size, separation distance from well, etc.) requires no action by itself; if, however, the
Phase II data collection shows that parameter to be closely correlated with one or another
kind of failure, it may be used to tentatively select facilities for a similar site not
surveyed.
The aim of system selection is to allow a tentative recommendation for each dwelling based
on at least some on-site data (even if indirect evidence).
Selections are contingent on detailed site analysis in Construction Grants, Steps 2 or 3.
Note: See note above.
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From Section E.2.C., p. 52:
Management Program Outline. Construction Grants regulations require a comprehensive
program for regulation and inspection of small waste flows systems. A plan for this
program must be submitted as part of a facilities plan (40 CFR 35.918-1 (i)). While
some specifics may change after detailed site analysis and facilities verification,
most of the decisions can be made once an optimum operation alternative is selected.
The plan should describe how the applicant will guarantee access to on-site systems.
Chapter III discusses management programs in detail.
Note: This material has been changed to incorporate language from new regulations.
From Section E.3., p. 52:
Phases I and II are intended to identify cost-effective solutions at the community and
segment levels. The next accomplishment is verification for individual systems of the
technology choices made during facilities planning. This is called "facilities verifica-
tion." It includes the selection of type, location and significant design parameters for
all on- and off-site facilities required for an optimum operation alternative.
To accomplish this, the sanitary survey of developed properties must be completed. For
properties having direct discharges, documented failures (surface malfunction, recurrent
backups, or groundwater contamination) or potential problems (because of unacceptable
design or similarity with failed systems), detailed site analysis is also required. As
suggested in Figure II-A-1, the work performed in the detailed site analysis depends on the
type of problem indicated.
Given the complete data base generated to this point, the final level of cost analysis
needed to select particular facilities for buildings or groups of buildings is possible.
Where on-site facilities will be adequate, little cost analysis will be required. For
marginal on-site systems where the risk of poor performance is expected to be high, more
intensive cost analysis may be indicated which weighs administrative, monitoring and
replacement costs against cost savings resulting from staying with high risk facilities.
In situations where the choice is between a low percentage of high cost on-site facilities
for a group of buildings and an off-site system for all the buildings, appropriate cost
analysis would also be indicated.
In practice, most on-site facilities can be verified in the field at the conclusion of the
detailed site analysis. The site or neighborhood cost-effectiveness analysis step provides
a retrospective on the individual decisions made in the field and permits consideration
from the entire community's perspective of potential economies in management services and
facilities costs.
Design of off-site facilities likely will require additional site work. The need for this
effort will optimally have been forseen and the work will have been initiated early in Step
2 and, in particularly obvious cases, in Step 1. However, decisions to go off-site may
well depend on completion of the detailed site analysis, the neighborhood cost-
effectiveness analysis and, possibly, management program design decisions.
Note: This material was rewritten to be more readable.
From Section G, pp. 63-64:
G. SHORTCUTTING THE CONSTRUCTION GRANTS PROCESS
In order to be eligible for U.S. EPA Construction Grant funds, rural communities must
demonstrate a need for wastewater treatment improvements in compliance with Federal
guidance such as PRM 78-9 and PRM 79-8. To clarify these requirements, U.S. EPA Region V
has prepared "Region V GuidanceSite Specific Needs Determination and Alternative Planning
for Unsewered Areas" (Region V Guidance) (Appendix A). To be useful in as many planning
areas as possible, the Region V Guidance assumes a "worst case" situation. Four assump-
tions implicit in the Region V Guidance that make it widely applicable are:
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1. Very little data exist prior to Step 1 that reliably define the design, usage, and
performance of existing on-site systems.
2. Service areas cannot readily be delineated for centralized collection and treatment,
community supervision of small waste flows facilities, or no action.
3. The severity of existing and potential problems with on-site systems justifies active
community management of all or a significant fraction of the systems.
4. Technologies to replace and upgrade existing on-site systems will include substantial
use of off-site, innovative, and/or subcode designs thereby necessitating delays in
facilities verification until all individual developed sites are thorougly surveyed
and analyzed.
When communities are not affected by some of the above assumptions, the needs documentation
and subsequent Construction Grants procedures may be shortened. For example, if sufficient
data on design, usage, and performance of existing on-site systems exist, preliminary data
gathering (Phase I) can be shortened accordingly. Subsequent data gathering (Phase II) can
then be targeted to specific areas resulting in less work than would be required if no
preliminary data were available.
Based on available data, complexity of service area delineations, and severity of on-site
problems, individual communities can tailor needs documentation, alternative development,
costing, and selection to suit their specific situations. Examples of such modifications
and suggestions for abbreviating the process are listed below:
Perform data collection at the proper time of the year to avoid having to return to
the field (for example, sanitary surveys when seasonal residents are available).
Collect data early or on an on-going basis for existing systems, failures, etc.
Avoid duplication of effort by limiting the number of return visits to individual
sites.
Separate areas requiring centralized treatment from the remaining areas to expedite
the facilities planning process.
Use standard on-site system designs when appropriate.
Acquaint local officials with the Construction Grants process.
Use milestones (preapplication conference, plan of study, mid-course meeting, and
final facilities plan) for decision-making and adjusting the scope of facilities
planning as necessary.
Enact county ordinances and/or state enabling legislation to provide access to private
systems.
Perform detailed site analysis during facilities planning during Phase II needs
documentation work.
Verify facilitities, design non-standard on-site systems, and construct on-site
systems with a Step 2 and 3 Grant.
Note: Means of flexibly applying the "Region V Guidance" are thoroughly covered in
Technical Reference Document XVI-D which is now appended with the Guidance in Appendix
A. Other recommendations in this section were covered elsewhere in the EIS. There-
fore, this section was replaced with a discussion of the community role in needs
documentations, facilities planning and detailed site analysis.
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CHAPTER III DELETIONS
From Section F., p. 77:
...35.918-l(h) that communities seeking funds for individual systems must "obtain assurance
(such as an easement or covenant running with the land), before Step 2 grant award, of
unlimited access to each individual system at all reasonable times for such purposes as
inspection, monitoring, construction, maintenance, operation, rehabilitation, and replace-
ment." PRM 79-8 also applies this to publicly owned on-site treatment systems, or their
equivalent.
Note: The text has been revised to contain wording from new regulations. This
wording is still in effect for grants approved before May 12, 1982.
From Section H.I.a., p. 80:
Requirements for monitoring potable water wells are stated in 40 CFR 35.918-1 (i) and PRM
79-8. PRM 79-8 states that a comprehensive program for regulation and inspection of
Federally funded publicly and privately owned small waste flows systems shall also include,
at a minimum, testing of selected existing potable water wells on an annual basis.
This policy allows the selection of wells tested each year on a case-by-case basis.
Note: Requirements for monitoring potable water wells do not appear in the new
regulations. This requirement is still in effect, however, for grants issued before
May 12, 1982.
From Section I.I. , p. 82:
U.S. EPA PRM 76-3 requires that the facilities plan include the estimated monthly charge
for operation and maintenance, the estimated monthly debt service charge, the estimated
connection charge, and the total monthly charge to a typical residential customer. The
stated purpose for this is to encourage the consideration of least costly alternatives and
the possible use of public and private facilities. A user charge system must be developed
by the community and approved by U.S. EPA during Step 3, at the latest, of the Construction
Grants Program.
Note: The text has been revised to contain wording from new regulations. This
wording is still in effect for grants approved before May 12, 1982.
From Section I.I., p. 82:
For optimum operation alternatives, proportionate use can be measured by type of user (for
example, residential), duration of use (seasonal, permanent), flow, or type of technology.
Users may also be billed directly for specific services provided by the management agency.
Note: The validity of this statement has been questioned. The section has been
revised to discuss the possibility of assessing costs according to type of technology
or specific services provided. However, it is made clear that current regulations do
not explicitly allow such basis for cost recovery.
From Section I, pp. 82-84:
2. USER CHARGE STRUCTURES
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The local public costs can be allocated by user charges in a variety of ways at the
discretion of the local government. Three major ways of allocating local public costs are
averaging the costs among all users in the project's service area, establishing user
groups, (that is, charging on the basis of criteria such as flow, technology used, or
location), and charging each user the specific costs of facilities and services provided by
the community individual user/specific cost method. The method of allocating costs chosen
by the community may be based on considerations such as the costs of implementing the user
charge system, the number and locations of residents benefitting from the project, the
extent to which a mix of technologies is used, and the consideration of equity and
efficiency.
The cost of implementing the user charge system may be high yet still politically feasible
if all users are charged by the community for the specific costs they impose on the
community. A sophisticated bookkeeping system would be required to allocate specific
capital, operation and maintenance, and reserve funds for each user; such a system may
exceed the administrative capacity of the local government. Averaging all costs among all
users would be the least expensive and time-consuming method of allocating costs. A system
based on user groups would probably be intermediate in cost.
3. BASIS FOR SELECTION
The beneficiaries of the project are the initial consideration in the design of a user
charge system. In addition to owners receiving direct assistance in the improvement,
replacement or operation of their on-site systems, beneficiaries may include:
residents and non-residents who use the water resources being protected,
where off-site facilities are constructed, land owners who could not previously build
but are thus enabled to,
businessmen whose revenues depend on the attractiveness of the water resources being
protected, and
property owners who do not require assistance at present but for whom the availability
of assistance is a benefit,
property owners who would otherwise be required to pay the price of sewers but who can
retain properly operating on-site systems under an optimum operation alternative.
If such benefits are well distributed among users, the case for averaging all local costs
is good. However, the range of technologies that may be used, the often localized or
spotty problems for which improvements are necessary, and the possibility of use restric-
tions can be expected to present a more complex benefit distribution. A useful exercise
for grantees, once the water quality problems are defined and appropriate technologies
selected, would be to identify classes of beneficiaries.
Allocating costs to classes of users is most reasonable when a mix of technologies is used.
Costs may vary significantly according to the type of technology used. Users with low-cost
systems might be reluctant to subsidize users with high-cost technologies. Charging by
user class requires the community to spend more time and effort for bookkeeping than it
would to average costs among all users. However, the user group method would be less
difficult and expensive than the individual user/specific cost method.
The final consideration in choosing a way to allocate costs involves the issues of equity
and efficency. Equity in this case refers to charging users in proportion to the costs
they impose on the management system. For the optimum operation alternative, the most
equitable user charge system is the individual user/specific cost method. For instance,
residents with conventional septic tank/soil absorption systems on large, well-drained lots
would have very low costs. They may be charged only for septic tank pumping and drainfield
inspection once every three years. Residents with dosed systems or residents served by
cluster systems may have to pay larger charges and more frequently. Residents using
holding tanks could have routine and quite substantial costs.
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4. CONSEQUENCES AND TRADE-OFFS
User charge systems can affect the efficiency of the wastewater management system. Charges
that encourage users to abuse their wastewater facilities are inefficient. Charges that
promote efficiency, however, may not be equitable. Consider owners of holding tanks: if
they have to pay the full cost of pumping their wastes, they may occasionally dispose of
the wastes themselves in a manner hazardous to themselves or their neighbors. However, it
is not equitable for the management agency to provide free pumping service for them and to
average the cost to all other users. Clearly in this case, equity and efficiency in a user
charge must be balanced. Charging substantial fees for water use that will not economi-
cally threaten the holding tank owners may encourage vigorous conservation and may prevent
owners from endangering others with unsanitary practices. A partial subsidy may otherwise
benefit the community by making holding tanks a feasible option so that everyone does not
have to contribute to buying a sewer.
Note: These subsections have been deleted in their entirely due to their reliance on
the unfounded assumption that regulations allow 0 & M costs to be allocated to users
on the basis of type of technology or on actual services provided. A new subsection 2
titled "Cost Recovery Options" discusses this basis for 0 & M cost allocation but
explicity states that current regulations do not consider its use in Federally funded
projects.
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CHAPTER IV DELETIONS
From Section A.I., p. 89:
Current Construction Grants Program guidelines (40 CFR 35.917-2 and 35.917-4) indicate the
responsibility for delineating facilities planning area boundaries. The guidelines require
that each state shall work with local governments in defining and mapping facilities
planning area boundaries. Planning areas will be large enough to take advantage of
economies of scale where individual systems are likely to be cost-effective. If the state
does not delineate the boundaries, the U.S. EPA Regional Administrator may make the
delineation or revise the boundaries in cooperation with state or local officials.
Note: Wording from the new guidance document, Construction Grants - 1982, has been
substituted for this paragraph.
From Section B.4., p. 97:
According to the cost-effectiveness guidelines (40 CFR 35.9, Appendix A), applicants may
perform their own population projections as long as their figures correspond to recent
trends in the local area. These projections could contain, for example, information on
recent building permit activity and/or an analysis of the land holding capacity based on
local codes and ordinances. If these projections are performed based on locally derived
data, considerable unneeded expense may be avoided and environmental impact may be
mitigated by facilities planning.
Note: The regulations cited continue to apply to projects receiving grants before
May 12, 1982, but they have no parallel provisions in new regulations and guidance.
From Section D.I., p. 102:
Inspection and sampling of all drinking water wells may be eligible in unsewered areas only
after the decision has been made to pursue the optimum operation approach. Exceptions can
be made so that all or most wells may be sampled before this decision if the data are shown
to be necessary to make the decision. In sampling all wells, provision should be made for
repeat sampling of those that were positive.
Note: Eligibility of specific facilities planning steps is no longer an issue under
the allowances now available for facilities planning.
From Section D.2., p. 102:
Submittal of this graph showing the position of local lakes will assist in application for
Construction Grants funds to collect and analyze water samples in support of detailed
nutrient modeling. As a rule of thumb, lakes that fall below 1.0 (symbol) of phosphorus
will probably not be eligible for sample collection and analysis. Between 1.0 and 10.0
(symbol), applicants may first propose to construct nutrient budgets based on empirical
models and available data, then collect confirmatory data appropriate to the major
uncertainties in the nutrient budget. Above 10 (symbol), applicants may propose to
construct nutrient budgets based on empirical models and available data. The need for
confirmatory sampling will be evaluated on a case-by-case basis.
Note: See note above.
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CHAPTER V DELETIONS
From Section A.I.a., pp. 112-113:
Fortunately, the existing text of the Clean Water Act and regulations offered a reasonable
solution to this problem: public ownership of single-family on-site systems. 40 CFR
35.918-1 requires that applicants for individual system funding "(d) certify that public
ownership is not feasible, and (h) obtain assurance (such as an easement or covenant
running with the land)...of unlimited access to each individual system at all reasonable
times for such purposes as inspection, monitoring, construction, maintenance, operation,
rehabilitation and replacement." PRM 79-8 specifically relates these two requirements,
stating that access and control by an agreement running with the land are "tantamount" to
public ownership. The July 16, 1980 memorandum from William A. Whittington, Acting
Facilities Requirements Division Director, extended this equivalence to public ownership to
access by local or county ordinance (see below).
Note: This material has been revised to be applicable to current policy decisions.
From Section A.3.a., p. 114:
As described above, 40 CFR 35.918(h) requires access and control at reasonable times (by
means of an easement or covenant running with the land) for Federal funding of all
individual systems. PRM 79-8 extends this to "publicly owned" single-family systems
occupied by seasonal residents.
Note: This has been revised to use language from new regulations.
From A.S.b., p. 115:
b. Needs Documentation for Alternative Sewers
The advantages of pressure, vacuum, and small diameter sewers over gravity sewers are
largely associated with cost-effectiveness. These include the virtual elimination of
infiltration and inflow, and much lower costs for unusual site conditions. Since they can
be built in environmentally sensitive areas that are difficult or impossible to sewer
conventionally, some alternative sewers can induce growth on sites otherwise undevelopable.
Except for cost-effectiveness and feasability of treatment for problem areas, there is no
special national interest in preferentially subsidizing alternative sewers.
Program Requirements Memorandum 78-9 established definite standards for eligibility of
collector sewers. Among these were the "two-thirds" rule, the requirement for substantial
human habitation of the areas served by a prescribed date, and a definition of needs
documentation that extended only to actual violation of water quality standards or an
identified immediate public health hazard. A later PRM (79-8) specifically exempted
alternative sewers from the entire policy set forth in PRM 78-9.
This exemption has sometimes been misunderstood as to exempt alternative sewers from any
kind of needs documentation at all. This is clearly a misunderstanding, since not only the
regulation but the text of the Clean Water Act itself specifically requires documentation
of need for every action. Future U.S. EPA and regional guidance will make it clear that
alternative sewers are exempt only from the two-thirds and substantial human habitation
rules applicable to collector sewers.
Please note, however, that there are needs that may satisfy the general needs requirement
of the text of the Clean Water Act and its regulations and still not satisfy PRM 78-9.
Certain algal blooms associated with discharge of septic tank effluent through groundwater
to a lake may seriously affect swimmability and fishability without violation of a specific
water quality standard or an immediate public health hazard. Grossly inadequate treatment
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systems (55-gallon drums, buried automobiles, etc.) may not be causing a public health
hazard, but have such an overwhelming probability of causing one as to constitute an
identifiable need.
Note: This section has been deleted and not replaced. New regulations covering the
eligibility of collector sewer do not contain the ambiguity that created this issue.
From Section A.3.C., p. 115:
Program Operations Memorandum (POM) 81-3 has indicated that pilot plant work for innovative
or alternative projects may be eligible for Step 1 facilities planning funds. The POM does
state that funding of such studies during the Step 1 phase does not imply U.S. EPA policy
or commitment to fund these studies during the Step 2 or Step 3 processes. Where long-term
studies are desirable, additional sources of funding may be required.
Note: The new discussion of pilot studies and field testing that replaces this
material is based on new legislation and regulations.
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CHAPTER VI DELETIONS
From Section A.2.b., p. 129:
Eligibility of surface water sampling programs to develop nutrient budgets will be
considered on a case-by-case basis but not until modeling excercises that can be completed
without field data are prepared and submitted for review.
Note: Eligibility of specific facilities planning tasks is not a consideration for
projects started after May 12, 1982. This limitations still applies, however, to
earlier grant-funded projects.
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