v>EPA
United States
Environmental Protection
Agency
Region V
Water Division
230 South Dearborn Street
Chicago, Illinois 60604
September
905R81107
6189
-------
DRAFT
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
October 1981
U.S. Environmental Protection Agency
Region 5, Library (5PL-16)
230 S. Dearborn Street, Room 1670
Cnicago, IL 60604
Approved by:
n
Valdas V. Adamkus
Acting Regional Administrator
-------
DRAFT 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, USEPA
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 decentralized small-flow 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 wastewater 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. Reasonable use of the methods outlined here for construction
grant applications already in hand will result in an estimated savings
exceeding $420 million in Region V alone.
-------
TABLE OF CONTENTS
Section Page
Executive Summary i
Terminology xv
List of Tables/Figures xvii
Chapter I: WHAT THIS EIS DOES AND WHY (PURPOSE OF AND NEED FOR ACTION) 1
A. What it is About (Scope) 3
B. What does it Wish to Accomplish and How Does it Propose to do it (Proposed Actions) 4
C. Why Do These Things Need to be Done (The Need for Action) 9
Chapter II: SMALL WASTE FLOWS TECHNOLOGIES 19
A. On-Site Systems 21
B. Small-Scale Off-Site Treatment 31
C. Needs Documentation Policies 36
D. Needs Documentation Methods 38
E. Designing the Optimum Operation Alternatives 49
F. Cost Analysis 54
G. Shortcutting the Construction Grants Process 63
H. Use of Segments in Planning and Implementation 64
Chapter III: COMMUNITY MANAGEMENT 65
A. The Need for Management 67
B. Six Community Management Models 69
C. Design of Small Waste Flows Management Programs 71
D. Public Involvement in Agency Design and Operation 74
E. Use of Variances 75
F. Access Considerations 77
G. Implementing Water Conservation Programs 78
H. Monitoring Groundwater and Surface Water 79
I. Recovery of Local Costs 82
J. Broader Responsibilities of Public Agencies Related to Rural Wastewater Management 84
K. Personnel 84
L. Revising the Management Program 86
-------
TABLE OF CONTENTS--Continued
Section Page
Chapter IV: FACILITIES PLANNING TECHNIQUES 87
A. Planning Area Definition 89
B. Demography 92
C. Land Use and Environmental Constraints 98
D. Water Resources 101
E. Financial Impacts 106
F. Public Participation 109
Chapter V: FUNDING AND ADMINISTERING THE OPTIMUM OPERATION ALTERNATIVE—MITIGATING MEASURES 110
A. Federal Concerns 112
B. State Concerns 118
C. Training 122
D. Does Anyone Want the Small Waste Flows Approach? 123
Chapter VI: ENVIRONMENTAL AND SOCIAL CONSEQUENCES OF THE PROPOSED ACTION 125
A. Water Quality Impacts 127
B. Environmentally Sensitive Areas 129
C. Economic Impact 131
D. Land Use 133
E. Resident Privacy and Inconvenience 134
Chapter VII 136
List of Preparers
Index
Bibliography
Appendices
Region V Needs Document Guidance A-l
Sanitary Survey B-l
Green Lake Limited Action Cost Sheets C-l
Otter Tail Limited Action Cost Sheets D-l
-------
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:
o that wastewater management based on optimum operation of existing on-site sys-
tems differs substantially from either new centralized facilities or new small
waste flows facilities, and
o that wastewater management based on existing systems allows substantial savings
in capital costs and operation and maintenance expenses, compared with cen-
tralized 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 con-
ventional 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 esti-
mated 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 sys-
tems. 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 analy-
sis 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.
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 signi-
ficance of on-site malfunctions is amplified by the very factor that makes them
inexpensive--their 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 maintenance.
Many owners simply neglect the routine preventive measures required by their sys-
tems. 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, upgrading, or replacement measures they may take.
Off-site alternatives are either too expensive or not implementable by the indi-
vidual 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 acd 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 granteee evaluation and adoption of mitigations measures.
8. Encourage public participation.
9. Encourage grantees' innovation with small waste flows technologies and com-
munity 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:
o direct discharges,
o surface malfunctions,
o backups into the household, and
o 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 ground-
water failures.
Reported failure rates seldom specify type. Also, reports cannot usually be com-
pared 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 characteristics, and groundwater hydro-
logy can be controlled by upgrading or replacement of 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 per-
formance 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 sur-
veys, 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 economi-
cally feasible, and upgrading or replacement of the existing soil absorption system
alone may not solve failures or prevent future failures. In such cases, consi-
deration should be given to use of one or more of the following technologies:
o flow reduction,
o water metering,
o segregation of waste streams,
o reuse/recycle,
o holding tanks, or
o 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 water sheds 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 dis-
posal of septage and, where generated, holding tank wastes. General options in-
clude 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 deter-
minations for collector sewers is illustrated in a decision flow diagram in the
text. The decision flow diagram is based on national policy contained in Program
Requirements Memorandum 78-9.
Region V's policy 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 devel-
-------
opraent, 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 preparation of the
Seven Rural Lake EIS's, some for the first time in Construction Grants programs.
It explains limits to their utility arid discusses eligibility considerations. The
needs documentation methods include:
o review of local well and septic tank permit records,
o interviews with local officials and contractors,
o windshield surveys,
o review of soil maps,
o preparation of base maps,
o aerial photographic interpretation,
o septic leachate detection,
o mailed questionnaires,
o partial sanitary surveys, and
o 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 rough costs are estimated for comparison
with sewered alternatives. Preliminary delineation of sewered and unsewered ser-
vice areas may be possible.
The second stage is based on system selection. Partial sanitary surveys and repre-
sentative 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 treat-
ment 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 con-
struction needed.
This EIS contains special cost curves developed for preliminary comparison of
on-site, small scale off-site, and centralized alternatives. This level of analy-
sis 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 units
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. Also 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 verification 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.
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 responsi-
bility 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:
o certifying that a public body will be responsible for the proper installation,
operation, and maintenance of the funded systems;
o 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
o obtaining assurance of unlimited access to each individual system at all rea-
sonable times for inspection, monitoring, construction, maintenance operation,
rehabilitation, and replacement.
These and other relevant requirements for the management of funded on-site facili-
ties 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 sensitivity 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.
The six steps in management program design 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.
TABLE 1. FACTORS TO BE CONSIDERED IN THE DESIGN OF SMALL WASTE FLOWS MANAGEMENT PROGRAMS
Existing or Projected Community Characteristics
o types of wastewater facilities utilized and proposed,
o expertise available to the community,
o size of the community or management district and number of systems in use,
o available regulatory authority,
o community jurisdictional setting,
o community attitudes toward growth, and
o community attitudes toward public management of private wastewater facilities.
Potential Consequences of Program Design Decisions
o costs, including initial costs and economic impact of failures,
o environmental impacts, especially impacts on water resources, and
o level of risk assumed by various parties.
TABLE 2. POTENTIAL MANAGEMENT PROGRAM SERVICES
Administrative
o Staffing
o Financial
o Permits
o Bonding
o Certification programs
o Service contract supervision
o Accept for public management privately installed facilities
o Interagency coordination
o Training programs
o Public education
o Enforcement
o Property/access acquisition
Technical
o System design
o Plan review
o Soils investigations
o System installation
o Routine inspection and maintenance
o Septage collection and disposal
o Pilot studies
o Flow reduction program
o Water quality monitoring
Planning
Land use planning
Sewer and water planning
-------
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 govern-
ment.
Options affecting the way specific services might be provided include:
o public involvement in agency design and operation,
o use and construction variances,
o gaining access to on-site systems,
o implementing water conservation programs,
o monitoring groundwater and surface water,
o recovery of local costs,
o personnel, and
o 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 economics of scale in
management program costs.
The Cost Variability Study prepared for this EIS provides environmental and devel-
opmental criteria to identify at an early stage planning areas where optimum opera-
tion 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-OFFS 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
Collection Centralized Land Cluster
Scenarios only treatment application system
0% 50% 0% 50% 0% 50% 0% 50%
1 No constraints 54 <38 92 - - -
8' adc1
2 No constraints - 123 - - - - -
16' adc
3 Steep topography 73 53 - 111 - - - -
1 pump
4 Flat; 6' to -- -- -- --
groundwater; peat2
5 Flat; 6' to -- -- -- --
groundwater
6 Steep topography; - 85 - 128 - - -
1 pump; 6' to bedrock
7 Flat 87 72 108 - - -
8 Steep topography; 87 69 - 95 - 135 - 130
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.
vii
-------
to off-site technologies. In general sewering any area developed with on-site sys-
tems 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 construc-
tion 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 their ability to remedy water quality and public health problems, not on
present worth comparisons.
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 en-
countered. The conclusions 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.
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 upgrad-
ing 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 alternatives 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 significant
change in plant productivity within the main body of lakes. A new graphical analy-
sis 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 observations and analysis during
preparation of the Seven Rural Lake EIS's, preventing nearshore plant growth along
open shorelines of a lake is not a sufficient justification for abandoning on-site
systems. However, abandonment of systems adjacent to particularly sensitive embay-
ments and canals may be justified 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 demonstrate 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 homeowner'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,
operation and maintenance and reserve fund. 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 equip-
ment, material, and labor. Small waste flows technologies can usually be installed
with local inputs whereas much of the equipment and labor for centralized facili-
ties will be imported.
Planning for wastewater facilities in rural and developing communities provides
opportunities for public participation not available normally in urbanized set-
tings. In particular, the inspection, evaluation, and construction of on-site
facilities will result in numerous contacts between residents and planning per-
sonnel. 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 parti-
cipate 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 owner's 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 Alternative—Mitigative Measures
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:
o On-Site Systems for Seasonal Properties—Duration of residency is not a determi-
nant of eligibility where public ownership of on-site systems or its equivalent
are feasible. For on-site upgrading or replacement, adequate access, documented
need and demonstrated cost-effectiveness will allow efficient distribution of
construction grant funds.
-------
o 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.
o 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.
o Pilot Studies—Program Operations Memorandum 81-3, issued during preparation of
this EIS, authorizes pilot studies of innovative and alternative technologies
under Step 1 facilities planning.
o Conventional Water Use--Facilitating 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.
o Potential Failures—Upgrading 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.
o 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 CRF 35.918-1(h).
o Innovative and Alternaive Off-Site Facilities—Facilities 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 or 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 dwelling.
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. How-
ever, 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 experiences 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 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 construc-
tion. 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:
o Review state policies regarding continued use of existing on-site systems.
-------
o 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.
o Either test in court the implied authority of civil divisions to implement small
waste flows management programs or legislate explicit authority for this pur-
pose .
o Review the regulatory and institutional powers of civil divisions to gain neces-
sary access to private wastewater systems for public management.
o Review the need for modification of variance criteria and procedures parti-
cularly in regard to existing on-site systems.
o Review state policies toward the use of innovative technologies weighing poten-
tial 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:
o 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 communi-
ties in finding alternative funding sources or in a reassessment of goals.
o Planning assistance may be provided in identifying rural areas where wastewater
improvements are needed and in delineating facilities planning area boundaries.
o States could establish separate priority lists for small communities.
o 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 per-
sonnel have been unsuccessful because relevant data are not available on the man-
power currently working in this field and on the number of small waste flows pro-
jects 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 waste-
water facilities. These motives include:
o avoiding prosecution,
o malfunctioning septic tanks,
o residential and commercial growth, and
o industrial growth.
Environmental and Social Consequences of the Proposed Actions
The proposed actions will impact groundwater quality, lake water quality, environ-
mentally 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 hydro-
geologic 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 devel-
-------
opment, 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 establish
funding procedures for analysis of viruses and toxic substances in wells. As an
initital proposal, this EIS recommends:
o sampling of selected, properly protected wells previously found to exceed bac-
terial or nitrate standards and suspected of contamination by nearby on-site
systems,
o concurrent sampling of suspected wastewater sources, and
o 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 devel-
opment in nonfractured and nonchanneled geology, description of groundwater re-
sources 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 groundwater. 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 malfunctions. Groundwater trans-
port 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 stimu-
late 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 compared 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 on lake
trophic status will be small. Trophic status improvements will seldom be a sup-
portable 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 abandon-
ment 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 up-
grading 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 control-
ling nearshore plant growth will not be eligible.
Development of several types of environmentally sensitive areas, especially flood-
plains, 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 alter-
native, 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 constraints 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 alternatives. Local governments will be able to finance
schools, hospitals, and other community facilities rather than needlessly expensive
wastewater facilities.
Operation and maintenance costs will not be reduced in proportion to ca'pital reduc-
tions but will generally be lower than with properly maintained conventional faci-
lities. As with conventional centralized facilities, 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 alternative.
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 then 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 techno-
logies. 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 treat-
ment system separation distances will be retained. The net effect of such con-
straints on new development may be adverse or beneficial depending on local com-
munity development objectives.
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 devel-
opment, and into areas possibly unsuitable for residential development. Multi-
family systems could have a positive impact where planned higher density devel-
opment 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 devel-
opment 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 sancity
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 wastewater
facilities will have as an incidential benefit the removal of practical restric-
tions 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 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.
-------
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 the 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, incinerator 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.
Management Program - A plan for providing necessary services in a small waste flows
district. The plan should describe funding, organization of the management 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 analy-
sis, 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.
Technology selection is suitable for describing proposed action in facilities
plans.
Facility Specification - 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 facili-
ties, 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 represen-
tative sampling, may be scheduled concurrently 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 surveys 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 taken to
determine the causes of problems with existing, individual on-site systems and to
develop information for selecting appropriate repairs, replacements or upgrading.
-------
LIST OF TABLES
Page
1-1. Estimated Costs of Centralized and Optimum Operation Alternatives - 11
Seven Rural Lake EISs.
I-C-1. Estimated Total Small Community Project and Rural Lake Projects 16
U.S. EPA Region V - 1980-1985
II-A-1. On-site Wastewater Management Options for Specific Limitations or Constraints 27
II-B-1. Land Treatment Options and Characteristics 34
II-B-2. Types (and Locations of) Wetlands Systems Investigated 35
II-B-3. Surface Water Discharge Options for Small Communities 35
II-F-1. Factors Varied and Technology Considered in the Cost Variability Study 55
II-F-2. Trade-off Densities (in homes per mile at the end of the 20-year 60
planning period) Above Which Off-Site Facilities are Competitive
III-C-1. Potential Management Program Services 73
IV-A-1. Factors that Determine Limits of the Small Waste Flows Niche 91
IV-B-1. Seven Rural Lake EIS Population Projections (Increase to the Year 2000 and 93
Seasonal Population Expressed in Percentage)
IV-B-2. Recreation Demand in the North-Central Region of the United States 94
V-B-1. Estimates of Personnel Involved in Regulation of On-Site Systems 121
LIST OF FIGURES
1-1. Monthly cost of gravity sewers. 10
I-C-1. Involvement of small communities in the Construction Grants Program. 15
II-A-1. Decision flow diagram for existing on-site systems. 28
II-B-1. Septage treatment and disposal. 32
II-C-1. Collection sewer eligibility - decision flow diagram based on PRM 78-9. 37
II-C-2. Detailed site analysis. 39
II-F-1. Cost-effectiveness curves for on-site small scale and centralized treatment 57
alternatives for Scenario 1; 50% growth.
II-F-2. Cost-effectiveness curves for on-site small scale and centralized treatment 58
alternatives for Scenario 4; 0% growth.
IV-D-1. Number of septic systems relationship between total phosphorus concentration 103
and number of septic systems.
IV-D-2. Relationship between areal water load, Q, and phosphorus retention, R 104
(Kirchner and Dillon, 1975).
xvii
-------
Chapter I
What This EIS Does And Why
(Purpose Of And Need For Action)
Failing Absorption Field
I' iv _-.-•.. s,-"^,-^ ti - •
I ?* - •-—' ** -:f
' !*U,rt sHk*r — '--SZ? *-'-*\tt " ''•
? ** »!» *KS" "™m*^™ « 5?-S
-------
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:
o centralized approaches--installing new sewers and centralized treatment
facilities--or
o small waste flows technologies and management--optimizing the operation of
existing on-site systems and construction of new small scale treatment facili-
ties where appropriate.
EIS I-C-4 This EIS emphasizes unsewered lake communities because of their large number and
environmental significance within the Region. Issues, alternatives, and methods
TRD X-A. 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:
o Case Study Number 1: Crystal Lake Area Sewage Disposal Authority, Benzie
County, Michigan (Final EIS July, 1980);
o Case Study Number 2: Green Lake Sanitary Sewer and Water District, Kandiyohi
County, Minnesota (Final EIS December, 1980);
o Case Study Number 3: Springvale-Bear Creek Sewage Disposal Authority, Emmet
County, Michigan (Final EIS December, 1980);
o Case Study Number 4: Steuben Lakes Regional Waste District, Steuben County,
Indiana (Final EIS January, 1981);
o Case Study Number 5: Otter Tail County Board of Commissioners, Otter Tail
County, Minnesota (Final EIS November, 1980);
o Case Study Number 6: Salem Utility District No. 2, Kenosha County, Wisconsin
(Preliminary Draft EIS serf to applicant and the state, EIS preparation ter-
minated July 1979); and
o Case Study Number 7: Williams County Commissioners, Nettle Lake Area, Williams
County, Ohio (Draft EIS to be published July 1981).
These Seven Rural Lake EIS's were specifically intended to evaluate the feasi-
bility, cost-effectiveness, and environmental impacts of alternative wastewater
collection and treatment systems. The alternative systems were compared to cen-
tralized systems that had been proposed in Step 1 Facilities Plans. Varying modu-
lar combinations of the two were also considered. To date, Final EIS's have been
published for the first five case studies. Each 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, soon to be published in
Draft EIS form, is anticipated to recommend optimum operation, replacement or
upgrading, 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 signi-
ficant portions of EIS work, is being constructed.
One major finding of the Seven Rural Lake EIS's is that wastewater management 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.
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.
B. WHAT DOES IT WISH TO ACCOMPLISH AND HOW DOES IT PROPOSE TO DO
IT (PROPOSED ACTIONS)
This Draft EIS has 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.
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 faci-
lities.
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 exist-
ing on-site facilities will not always satisfy a common local objective of provid-
ing reserve capacity for future growth. The costs of reasonable reserve capacity
are presently eligible for Construction Grants funding of conventional sewers and
treatment plants. However, provision of reserve capacity is not an objective of
-------
Federal funding. The absence of reserve capacity in optimum operation alternatives
will not be grounds for finding conventional alternatives 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
EIS III-A-2
EIS III
TRD I
EIS II-A-2-D&C
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 condition 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. Typically, this
involves responding to complaints from owners or neighbors and encouraging owners
to make suitable repairs.
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 considered 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 controlling them among exist-
ing systems are:
Factors Determining On-site
System Performance
o system design
Example Control Measures
o system usage
o maintenance
o soil characteristics
expand drainfield size; upgrade system with
dosing, additional settling capacity, aerobic
treatment; convert to alternate design such as
shallow placement, mounds, evapotranspiration, or
alternating drainfields
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 con-
tracts between building occupant or owner and
private firm; public education
change system design and/or usage, move drain-
field; import soil fill
o site constraints
(size and shape of
lot; relationship
to other lots;
location of house,
well)
evaluate system performance as it is affected
by these constraints; evaluate design and usage
modifications as means of overcoming site charac-
teristics; acquire land off-site for wastewater
disposal where necessary
-------
o groundwater hydrology install curtain drains, French drains, or drain-
age ditches; septic leachate recovery for irri-
gation.
o surface drainage disconnect roof drain connections to waste-
water system; divert runoff away from septic
tank and drainfield, mound soil over drain-
field.
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 governments 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.
TRD V-A&B The lack of testing has produced a high degree of design conservatism among engi-
neering consultants, the principal source of professional advice available to local
governments. This conservatism is self-perpetuating; until the control measures
are tested, engineers 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 di-
rectly with on-site system problems and to test the reasons typically given for not
seizing those opportunities. In particular, the Region recommends increased com-
munity supervision of design, usage, and maintenance for existing on-site systems
EIS III-A-2 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 ofc failure, and
sensitivity of water resources to failures.
2. DEVELOP EVALUATION METHODS FOR OPTIMUM OPERATEON OF EXISTING ON-SITE SYSTEMS
This second Proposed Action has been partially accomplished in the preparation of
TRD II-D-G this EIS and the Seven Rural Lake EIS's. Two new evaluation methods, aerial photo-
graphic surveys and septic leachate detection, as well as a simple, effective form
EIS II-D of sanitary survey were given their first full-scale applications during these
studies. Evaluation of optimum operation of existing on-site systems is addressed
EIS II-E 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 University, Morgantown, West
Virginia 26506, and through the Small Waste Flows Coordinator in Region V's
Chicago offices.
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 un-
sewered 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 applications for
any unsewered areas. The need for performance data is even greater if the optimum
operation approach is proposed. If sewers are proposed, the need for them must be
documented. This requirement is 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 is provided by Program Require-
ments 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 operation
and maintenance cost savings of small systems over conventional collec-
tion 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
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 investi-
gation, including soil profile examination, percolation tests, etc., on
each and every occupied lot should rarely be necessary during facility
planning.
Applying these policies during preparation of the Seven Rural Lake EIS's, Region V
TRD II-C 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 needless 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 non-
conformance alone as a criterion would result in the abandonment of many older
systems, even though they may have many more years of use remaining.
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-
EIS II-D-9 site systems work and affect our water resources. So that performance data col-
lected with Construction Grants funds can thus improve the state of the art, Region
V will promote development of standardized 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 iacluded
explicit means or intent for evaluating and improving on-site system performance.
Published regulations clearly define the design of new conventional on-site sys-
tems. 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
political 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. However, a
number of possibilities are discussed, primarily from local government's point of
view. Many of the possibilities require enabling legislation or regulations for
EIS V-B which states retain authority. This EIS encourages the states within Region V to
evaluate comprehensively their roles in the management of existing as well as new
on-site systems and to provide localities with the necessary legal and information
resources to provide their delegated management services. The states within Region
TRD XV-A V do not have to look extensively beyond the Region to find excellent examples of
what can be done in this field.
6. ENCOURAGE BETTER WAYS TO PLAN FACILITIES AND ACCESS THEIR IMPACTS
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 for unsewered
EIS IV areas. It can help in making these decisions whether or not they are part of a
Construction Grants facilities plan. There are no mandatory rural facilities
TRD X-XIV 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 new sewers and
EIS IV-C treatment facilities will be economic. Economic impacts can be avoided by imple-
menting less costly alternatives, such as the optimum operation alternative, where
feasible. Optimum operation may itself have potential adverse impacts, parti-
cularly 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 operation
alternative and ways to limit them. These mitigating measures can often both
reduce impact and save money; either of these is sufficient to recommend their
consideration and use by the grantee.
8. ENCOURAGE PUBLIC PARTICIPATION
EIS III-D, IV-F Experience shows the public's interest in wastewater control projects is at least
as great in rural lake areas as in any other type of community. This high level of
TRD XIV-A 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 man-
agement that necessarily involves residents to a greater degree than do conven-
tional sewered approaches.
-------
In one sense this entire document is intended as an aid to public participation.
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 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 obso-
lete 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 NEEDS 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 nonexistent
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
TRD XV-A form the basis for many state regulations.
During the 1960s and early 1970s, state and local governments formulated and imple-
mented procedures for preconstruction approval of septic tank systems. These
procedures and the standard design requirements greatly reduce the occurrence of
surface malfunction and plumbing backups for new systems. However, old and new
systems that are overloaded or not maintained continue to fail. A third type of
failure, groundwater contamination, has also been recognized as a potential
problem.
Relying on such failures, municipalities and facilities planners continue to pro-
pose new sewers. This is done without exhausting means for improving the per-
formance of existing systems.
Training and education programs in on-site wastewater management have, until the
last several years, been rudimentary. Those programs available primarily reached
TRD V 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 organiza-
tion 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 conventional
sewerage facilities for small communities. Typically, 80% or more of the total
capital cost of wastewater facilities for newly sewered rural areas is spent for
•^40
m
3
O
30
-------
en
_
CjQ
1 — 1
fTT
•2
. T
HH
pj
u
^
g
m
i
C/3
1 — I
H
^
W
H
<3
tS
o
1 — 1
H
S
a
CM
o
S
JH
hH
H
t.
O
Q
5
S3
f-3
W
N]
1 — 1
l_^
^
H
CJ
CJ
o
frH
cn
o
o
p
W
H
jH
H
c/l
W
rH
I
r- 1
1
H
rH
CO
4-1
o
f— (
co Ln
so r- co rn
O co r— co
o o -j- o
QJ
rJ
o
rH ,<"]
4-1 O
4-J
QJ
^*
^
•H • d
rH O -H
•H Z M
•P d
P 4-1 O
U U
£ -H W
QJ JH TH
rH 4J ^
CO W
C/J -H
^
QJ
CO
hH1 CO
4-)
rH O
• H M
CO QJ
H d
3
SH -H
i_j
4J
o
cn
QJ
CO <0
hH d
CO
d -H
QJ T3
,0 d
3 rH
QJ
4->
C/J
^
cn
TJ QJ
d .vi
CO CO d
hH1 TO
TJ 00
QJ rH -rl
.X CU XI
O SH CJ
O CU -H
U CJ
• H
OH
*~CS]
CU CO
CO O
hH W
QJ
d d
QJ d
QJ -rH
O
n
QJ
co d
i-l co
rH -H
co .d
4-1 U
M -H
^ JTJ
SH
C_j
uO in O ~^J" uO ON sCJ
vo vjo>, K » n *v
CO rH ^O rH
CM CM oo r^ r~~ o
•^ o SO ^d" uO uO O CO so CO CO
CO O O ON O> ON O SO rH cj> CM
co in o -•3" r*^ r^- ON oo rH ^
r, ** r. ^ r> r.
rH m rH
4J 4J CO
SH rH -iH -H
-P O CO d 4J
•H 2t d 3* d 3-nd d
d od-p ogdo o
34-1 'H d W -H g rH -H -rH
C -P < O 4-1 O14J -P
OCtnQJ C13 U CO CJ^-vrHCO CO
d4J« ^ OJ JH OcoJn SH
rH CU JH (U ft cO — QJ ft QJ O -fH ft QJ ft
rH rH P^i NO SH SH / — ' NO ft^ftO NO
QJ (0 /-^ -H CU QJ JH -H I-H (0 *~^ 'H
&> SnO •— l E w > d >> i— 1 S W M-cy>C_j4HO rH g W
P-H coo co P OO^CS111-^. CO 3 00 00s— ' O O CO 3 00
dCUOinSd O-c/J-SnSdd r-IOJHSd
O CJ1 >n 4-1 -H -H O QJ ^^ -P -H -H1 -H SH cO >H - 4J -H >H
COOJ IrH d-P >COS d -P > >>>UfOrH CJ 4-1 >
O\ O-CO-QJ ftcOONO QJ ftcO (0 OQJ-cr>-QJ ftcO
rH CM s— • ' CJ O t/a r- 1 £rj CJOWV3 h-3t>H ^— ' C_3 O C/H
en QJ
CU 4H CJ
'U MO d
QJ d cn co
SH QJ -P QJ 4-1
cu ft w E cn
& X O O -H
QJ QJ CJ W M
w en
oO QJ d «
>> d 4-1 -H
rH -H CO 00
-P -P > en d
d CO -H 4-1 -H
QJ SH SH w "O
M QJ ft O d
QJ ft U -J
S-l O SH <4H
ft O M
O 4H - QJ
JH OO JH 4J
O ON 4-1 QJ CO
4H rH Cl d 4-1
QJ 3 W
>> cn E o
4-J d >» QJ XI
•H rH CO £ 4-1
U ft ft O -H
CO Xi S
ft 4J r-H
CO (0 CO d TJ
U O d -H QJ
u d -p
4-1 d 13 CJ
d 4-J CO QJ d
QJ d *TJ SH
E QJ 4-J d 4-1
4-) £ d r- 1 M
CO QJ QJ U • d
QJ JH rH d cn o
SH -H CO -H ryj U
4J 4-1 > hH
QJ -H 4-> ft] 00
T3 SH d 0 d
C a1 d cu -H
co 4-J QJ XI QJ
X QJ 4-1 X
d QJ d SH
O T3! CO QJ d >>
•H S 'rH i — I
4J O T3 4->
CO OO QJ M d d
4-1 ON -O 4-> CO OJ
•rH i-H TJ C/] JCi CO
rH CO O -U QJ
•H W U SH
j~j - w i-i ft
CO >, -H SH (U
XI 4-1 (U Xl en
OJ -H W 3 00 H
SH d -H QJ -H
d XI cn xl E
SH E -P QJ
QJ E CU QJ 4-1
3 O O M Xi cn
cu u E-H d >,
en o - cn
W X QJ
o d xi cu o QJ
4H O JH . m N
4n co en QJ -H
tn T3 O Xl SH SH r-f
4-1 QJ W CO QJ CO
M SH QJ QJ Xl SH
O O VH 4-1 >, 4-1 4-1
U 4-> CO d d
U Xl QJ O - CU
•"rj to cn E c*o ^ o
OJ 4H QJ co
-J d CO -H O
rH QJ d 4J 4H W
CJ QJ CT1 CU CU
d XI QJ SH 4-» > rH
•H d -H CO
QJ M 4-1 QJ 4-> U
>> CU> -XiCJtO-H
rH >CO QJQJSHd 4-1
d -HXl UTJQJSH CU
O -P d ft QJ Xl
CO W QJ M 4-1 4-1
ft) d^3 TJ-HOOi — f O
CU SH QJ -H ,d "*^-. cO ft
SH QJ JH cn r- t>>
co 4-1 CO QJ 4H I T3 Xl
i — 1 SH O sO QJ
QJ CO TJ N QJ
CJ QJ QJ 4-1 4-J -H SH
•H T3JH ddcOrH CO
> QJ CU O QJ CO
SH N 3 CJ T3 JH QJ
QJ -H QJ M JH -H 4-1 >
W rHM QJQJcOd 'H
TJ SH ^ d CJ CO
CU 4-1 rH rH O CU d
W d-P cjCMSHSH JH
o cu d d QJ o QJ
ft CJQJ -HMH3MH 4-1
O W O rH
SH >> , QJ CO
ft rH SH 4-1 d QJ SH
rH ft W O XI QJ d
MH -J O -H 4-1 X! O
O 4-1 O U 4-» -H
4-1 d 4H d 4-1
c- QJ cn ,a -H 3 co
O Xl QJ - -H O SH
.,_( HrH iHSHWXl QJ
4J Xi QJ 4-> CO W ft
JH co d d O
O • 4-J 3 O /-^ 03
^ rH Xl CU £ d 3
13 d-H e^cud S
QJ O SH O d 3 O *H
JH 4-1 X! d QJ E -P
QJ d 4-> 4H W CO ft
S O CO rH O
QJ -H CO QJ OJ QJ
d C04-J dSndH O
-J E w d QJ o 4H
•HO CO M XI
>. x: o QJ w
rH o cu SH cn cn QJ
4-> SH 00 CO U3 4-i
C ft ' CO (0 hH CO
CU ft W SH X) PL} S
W (0 CO QJ W U -H
QJ QJ >' d d QJ 4-J
JH d*H
-------
EIS V-E-2
b.
Performance
ties. 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 charg-
ing $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 changes 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)].
Table 1-1 presents cost data developed for the Seven Rural Lake EIS's comparing
centralized alternatives with optimum operation alternatives. The potential pre-
sent 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 realized. One community has withdrawn its
application for Construction Grants funding using only part of the EIS recommenda-
tions 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.
Estimated reductions due to adoption of optimum operation approaches in average
annual homeowner costs ranged from 58% to 90%, averaging 82% or about $405 per year
per house. The estimated homeowner costs include all local costs, whether pri-
vately 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 con-
tractors .
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 collector 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%.
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 treat-
ment 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 faci-
lities, if properly designed and maintained, will provide more reliable and con-
trollable 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 maintained" 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 operated--in a word, management. Throwing money
into centralized collection and treatment 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 con-
struction that might occur could outweigh the benefits of centralization.
12
-------
EIS VI-B-1 Primary environmental and social impacts in rural areas occur as results of sewer
VI-B-6 construction or of the development supported by sewers. Examples are disruption of
VI-B-7 archaeologic sites, development in floodplains, destruction of wildlife habitat,
and increased non-point source pollution.
EIS IV-C Some environmentally sensitive areas are protected from development only by the
fact that on-site systems will not operate in them. Sewers can overcome the
EIS VI-B-2 natural constraints to development in such areas and, in lieu of protective laws
VI-B-5 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 sub-
sequent 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 collector sewers
through sparsely developed or undeveloped tracts provides incentive to develop that
land. This effect is enhanced when municipalities must actively encourage devel-
opment 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 sum-
marized above for the seven rural lake communities previously studied by U.S. EPA
Region V. For the six projects that may be implemented as recommended, 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 3.3 million on-site
TRD X-E 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 sav-
ings resulting from optimum operation, the following five steps were taken:
1. The number of residential on-site systems in the Region was estimated for three
categories:
o urban = 536,300
o rural non-farm = 2,036,600
o 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.
13
-------
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:
o sewer,
o sewer or optimum operation,
o optimum operation,
o 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 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 incorporated. Unincorporated places
are defined as closely settled population centers that have no corporate boun-
daries, 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 sur-
rounding cities of 50,000 or more population. "Rural population" is everyone else.
Unsewered development certainly exists in some urban places of over 10,000 popula-
tion. 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-1 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-1 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.
14
-------
3,000
2,500
o
u.
o
OL
LJ
m
2,000
1,500
1,000
500
3,426
1,066
291
483
297
96
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)
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-1.
Involvement of small communities in the
Construction Grants Program.
15
-------
TABLE I-C-1. ESTIMATED TOTAL SMALL COMMUNITY PROJECT AND RURAL LAKE PROJECTS U.S. EPA REGION V -
1980 - 1985*
State Total projects Lake projects
Illinois 240 48
0-2,500 156
2,501-5,000 48
5,001-10,000 36
Indiana 177 40
0-2,500 117
2,501-5,000 29
5,001-10,000 31
Michigan 122 68
0-2,500 66
2,501-5,000 29
5,001-10,000 27
Minnesota 276 120
0-2,500 232
2,501-5,000 35
5,001-10,000 9
Ohio 143 8
0-2,500 76
2,501-5,000 36
5,000-10,000 31
Wisconsin 163 88
0-2,500 128
2,501-5,000 24
5,001-10,000 11
Region V 1,121 372
0-2,500 775
2,501-5,000 201
5,001-10,000 145
* The table is based on data from Region V project files. 25% of project files for communities under
10,000 population were randomly selected to provide data for these estimates.
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-1
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 pro-
jects 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 Con-
struction Grants process. The majority, 89%, are rural places of less than 2,500
population.
16
-------
The number of places on priority lists or designated as potential candidates 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 manage-
ment 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 is
strongly biased toward worst cases.
What results are obtained when surveys are conducted just to monitor performance
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 documented per-
formance. 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 homeowners, sanitarians, engineers and municipal
officials are professionally concerned with failures for various reasons and tend
to overemphasize their 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 need-
lessly spent if valid performance data is lacking or if site suitability is
erroneously evaluated. This situation demands the collection and objective analy-
sis of performance data and corollary information such as design, usage, main-
tenance, soils, site constraints, groundwater hydrology, and surface drainage.
Other types of information are also lacking. Many technology and management alter-
natives discussed in this EIS have not been extensively applied and evaluated.
17
-------
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 performance, 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 contributions
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 lakes or embayments with still waters
and many shoreline dwellings. However, on larger bodies of water, wave action
seems to control such local plant growth. Lacking demonstrated bacterial con-
tamination from these plumes , the impact of concern is phosphorus loading to the
TRD XII-G lake as a whole. Phosphorus control strategies that include agricultural, silvi-
cultural, 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 re-
mainder 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 supervision, state initiatives, facilities planning
methodologies, and mitigating measures.
18
-------
Chapter II
Small Waste Flows Technologies
SMALL-TIAMETEP tSEAvlT\
SEFTlCTANk LiaUlf TO •-R
LA^OJW LAMP APPLIC
(,S|LV [CULTURE*
.rfAJp VP seFTicrANk WITH sum*^ ,
if^*^[ I *ei-l\MRiAl.ri9TEiBUTiONi
SEPTIC TANh CLUSTER
JEE SEWEKSl.STer\ 6EPriC
laUIP TO LA^CC-N f LANH
APPLICATION I
00 V &^
L A K. E
WATERLESS TOILED 3|Mk5
I SE-FTfCTANk V\iT* SOIL
VACUUM 5EWEKS,
LAi5^OW LANP
APFLICATION ,
I SEPTIC TANk VMT-H
El APOTRA^SFI CATION
BEP
*«£i ^>igr
i
^
ON
^T^-
:£NTRAL' SV^TEM*" I
r-^f-1 :WJV
^ ' <^^sr-.^.^1
^^_^__^ \ ^? .^\>fn •;^-
SMALL-riAMETEC 6KAUTV ^EWEKS
SEPTIC Liauir TJJ ALTERNATING
COMMUNITY FtELr ]
'i!(A«*.< ,
0-^C««T| 1
HOLrtHG TANK
&*f~lW<£Zt-''
N^-.rl*l»! ,"b"": „ n u T ' _ -
r gc? W
,< • :/'
^^*-
fe^^
SFPTIC TAWk VMfW I
-H^
^^=— ->,« >"'
-AJJOV. i1 *>.- •• \
THE SMALL COMMUNITY AND TYPICAL USES OF ALTERNATIVE
WASTEWATER SYSTEMS
-------
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 waste-
water 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 absorp-
tion 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 juris-
dictions had standards for siting, designing, installing, and operating septic tank
systems. As knowledge of these systems increased and early systems fai«led, regula-
tory codes were developed. These codes have changed through the years as experi-
ence and research have dictated. As a result, older systems do not satisfy exist-
ing 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.
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:
o direct discharges,
o surface malfunctions,
o backups into the household plumbing, and
o 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 waste-
water, 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.
21
-------
Surface malfunctions of soil absorption systems typically are due to inadequate
hydraulic capacity. Wastewater flows in excess of design, soil clogging, imper-
meable 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 Step I 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 sur-
face malfunctions. In addition, clogging of the plumbing itself will also cause
backups. As contrasted to the other types of malfunctions, the only way to quanti-
fy backups is by interview with residents. Residents' descriptions of the fre-
quency of backups may be the basis for a preliminary diagnosis. Non-recurring
backups or backups that were remedied by plumbing maintenance should not be con-
sidered as system failures. However, on some sites, plumbing backups may be the
only evidence of inadequacy in the on-site system.
EIS V-D-1 Contamination of groundwater is at once the most difficult failure on which to ob-
VI-A-1 tain reliable data, and the one with the most severe potential public health im-
pacts. Virtually all standard soil absorption systems and many alternative on-site
technologies discharge to groundwater, thereby contaminating it to some degree.
Whether the contamination is significant, however, depends on the use of the
affected groundwater, the contaminants discharged, and their concentrations at
points of use.
"Points of use" include:
o for unconfined aquifers, all locations around an on-site system beyond the
state's minimum separation distance to wells,
o for confined aquifers, the same except that perched groundwater tables with no
aquifer potential are not points of use,
o any existing water supply well, and
o 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 dis-
tances 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 failures is 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.
22
-------
While there is not 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 northcentral United States served by on-site systems
reported breakdowns where the systems were unusable one or more times for six con-
secutive 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°/o, 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 malfunctions. Surface mal-
functions present the greatest nuisance to neighbors, and are usually more identi-
fiable than direct discharges, which tend to be well concealed. Surface malfunc-
tion 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.
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:
o Failure rates vary widely from one locale to another. While the state or
regional rates may be low, specific communities or parts of communities may have
substantially higher than average rates.
o 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.
o Depending on the length of time failures are allowed to persist, one-time sur-
veys probably count more failures than actually start in any given year. Use of
survey statistics to estimate an annual failure rate is not, therefore, justi-
fied 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.
23
-------
Failure rates for groundwater contamination by on-site systems are, and will con-
tinue 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 a^L (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 No -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-l 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:
o system usage,
o maintenance, and
o surface drainage.
System usage includes number of occupants, daily per capita flow, and use of gar-
bage disposals. These can be controlled by installing water meters and flow reduc-
tion devices, limiting occupancy, and prohibiting garbage disposals. Maintenance
problems can be controlled by 1) a renewable permit 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:
o system design,
o soil characteristics,
o site characteristics (size and sh.ape of lot, relationship to other lots, rela-
tive location of house and well),
o groundwater hydrology, and
o 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.
24
-------
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 in-
creased 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 construc-
tion 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 determine if any system
EIS III-E failures such as plumbing backups, surface ponding, or groundwater contamination
II-D-3 have occurred. If the investigation concludes that no significant past malfunc-
tions 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 characteris-
tics are most amenable to evaluation prior to issuance of construction 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 per-
formance of existing on-site sewage disposal systems and to predict the performance
of future systems. Explanations and predictions may be based on either hypothe-
tical or empirical relationships between soil characteristics and system perfor-
mance. An example of a hypothetical relationship 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 rela-
tionships. 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
25
-------
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 relation-
ships 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 empha-
size reliance on empirical information for decisions on the disposition of existing
on-site systems.
4. SITE ANALYSIS AND TECHNOLOGY SELECTION
TRD 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
EIS II-D-1 appropriate technology to correct failures is presented 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 Guidance--Site-Specific Needs Determination and Alternative Plannning for Un-
sewered 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 pre-
liminary 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
EIS IV-F 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 wastewater treatment system problem.
The intent of the decision flow diagram is to show that specific evaluation proce-
dures beyond the on-site sanitary inspection are not required on every lot. Proce-
dures, especially expensive ones in the detailed site analysis, should be performed
only when justified by previous findings.
The decision flow diagram reflects no judgments regarding eligibility 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 pro-
vided. The process diagram (Figure II-C-2) relates the procedures in the decision
26
-------
TABLE II-A-1. ON-SITE WASTEWATER MANAGEMENT OPTIONS FOR SPECIFIC LIMITATIONS OR CONSTRAINTS
Limitation/constraint
On-site option
None
High groundwater or shallow
depth to bedrock
Conventional septic tank/soil
absorption system
Elevated sand mounds
Shallow placement system
Evapotranspiration system
Artificial drainage
Buried sand filters
Slowly permeable soil
Hydraulic, organic, or solids
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)
Oversized soil absorption system
Seepage pits
Electro-osmosis
Pressure distribution
Evapotranspiration system
Flow reduction
Waste stream segregation:
Chemical, biological, or
incineration toilets
Multiple septic tanks or chambers
Septic solids retainer
Septic tank baffles
Large diameter tubing
Grease trap
Septic tank baffles
Alternating drainfields
HO 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
27
-------
-------
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.
29
-------
flow diagram to the requirements of the Construction Grants process, necessary
management structures, and needs documentation guidance. Timing is discussed in
Chapter IV-G.
5. OPTIONS FOR THE DIFFICULT SYSTEM
TRD I Some on-site wastewater problems are harder to solve than others. An isolated sec-
tion of a community with very low density might have severe site limitations re-
EIS VI-E-2 suiting in high failure rates. Sewering is not economically feasible and alterna-
V-A-l-b tive on-site options are limited. In such cases, consideration should be given to
one or more of these technologies:
o flow reduction,
o water metering,
o segregation of wastes,
o reuse/recycle,
o holding tanks, or
o effluent plume recovery.
a. Flow Reduction
EIS V-A-l-c Where the feasibility of retaining on-site systems depends on substantial reduc-
tions in wastewater flows, highly effective and perhaps expensive flow reduction
TRD II-L devices should be considered. Since toilet use, bathing and clothes washers are
the greatest water users in most residences, these should be emphasized in achiev-
IV-D ing 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 bathing can be reduced 90% or more
by conversion, where feasible, to air assisted showers. 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 reduc-
tion, 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 pres-
sure reducing values. The total flow reduction achievable with minimum flow reduc-
tion 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-l-c 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 investi-
gated such as foundation or roof drains, air conditioner condensate, or storm
water. Where municipalities assume liability for on-site systems or grant re-
stricted 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,
30
-------
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, 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-l-g 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 a contaminated
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
EIS V-A-l-f for satisfactory results. For example, water conservation 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 categories 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 irri-
31
-------
-t
z
o
5
o
•o
c
o
CL
Q.
<
0) C
o o
o '^
in —
£i O.
3 Q.
co o
cti
to
O
cx
en
•H
c
o
w 'o
3 D.
CO O
o
Z>
cr
o
I-
0-
LJ
CO
I-
z
LU
<
LlJ
tr
£T
Q.
C
o
CT
LJ
o c
li-
«"5 c
o a> o
5 -t CL
•O 3
<•«
PS
• "3
•o cr
co : o.
o
CO
o
Q.
E
o
CJ
u
AS
C
03
4-1
0)
4J
Cfl
0)
0)
bO
CO
PQ
0)
M
3
00
U
J= X
O 0
o
"o o
!!
O CX
32
-------
gation, 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.
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 treat-
ment facilities. The process types currently in operation include chemical preci-
pitation, 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 conven-
tional 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 conventional 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 waste-
water under pressure to a treatment facility or to an area where gravity sewers are
utilized. Infiltration and inflow common in conventional sewers are nonexistant in
pressure sewers. Other advantages of pressurized sewer systems include 1) smaller
sized pipes, 2) easier installation (a downhill grade is not necessary), 3) and
lower costs than conventional sewers, especially in areas of steep slopes or shal-
low 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 application (surface
and subsurface), 2) wetland discharge, and 3) surface water discharge.
33
-------
TRD II-K Off-site subsurface disposal systems for several buildings are known as cluster
systems. Pretreatment in the form of septic tanks is required for cluster systems
and 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 provide drainfield
resting and an 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):
o wastewater characteristics,
o climatic conditions (water balance),
o soil characteristics,
o land area required,
o existing and surrounding land use,
o preapplication treatment,
o surface and groundwater hydrology,
o vegetative cover,
o treatment efficiency, and
o ultimate disposal.
TABLE II-B-1. LAND TREATMENT OPTIONS AND CHARACTERISTICS
Irrigation
o Predominant land application method
o Indirect or no surface water discharge
o Uses wastewater for production of marketable crops
o Groundwater recharge
o Typical land requirement of 100 to 200 wet acres/mgd
o Moderately slow to moderately rapid soil permeability
Infiltration-Percolation
o Indirect or no surface water discharge
o After infiltration, renovated effluent can be
recovered (underdrains or pumped withdrawal) or
allowed to recharge groundwater
o High-rate systems require 3 to 6 wet acres/mgd
o Low-rate systems require 20 to 60 wet acres/mgd
o Rapid soil permeability (sands, loamy sands)
Overland Flow
o Ultimate disposal of runoff is required
o Land requirements typically range from 25 to 110
wet acres/mgd
o Generally does not provide the BOD and SS removals
that irrigation and infiltration-percolation do
o Slow soil permeability (clays, silts, and soils with
impermeable barriers)
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
34
-------
TABLE II-B-2. TYPES (AND LOCATION OF) WETLAND SYSTEMS INVESTIGATED
Natural Wetlands:
Artifical Wetlands
o Peatlands (Michigan, Wisconsin)
o Cattail marshes (Wisconsin)
o Freshwater tidal marsh (New Jersey)
o Lacustrine Marsh (Hamilton, Ontario, Canada)
o Swamplands (Hay River, Canada)
o Wetlands, general (Massachusetts, Florida)
o Cypress domes (Florida)
o Meadow-marsh-pond system (New York)
o Ponds with reeds or rushes (Germany, Holland)
o Peat filled trench systems (Finland)
o Peat filter (Minnesota)
o Marsh pond system (California)
alternative, an inventory of available wetland sites should be made. Site charac-
teristics (hydrogeological, biological, etc.) must be investigated in detail if
preliminary planning stages indicate 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 sys-
tems. 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 constraints as required
effluent quality. Examples of simple treatment systems for surface discharge
are listed in Table II-B-3.
TABLE II-B-3. SURFACE WATER DISCHARGE OPTIONS FOR SMALL COMMUNITIES
Lagoons
o Facultative
o Aerobic
o Anaerobic
o With or without sand filters
Fixed Film Reactors
o Rotating biological contactors
o Trickling filters (various media, various rates)
Activated Sludge
o Oxidation ditch
o Package type (complete mix, contact stabilization, extended aeration)
35
-------
C. NEEDS DOCUMENTATION POLICIES
1. NATIONAL
EIS I-B-3
EIS II-F-4
EIS I-B-3
2. REGION V
In the first years of the current Construction Grants program under P.L. 92-500,
detailed analysis of need for facility construction was seldom provided in Step 1
facilities plans. There were enough obviously severe water quality problems to
fill up state priority lists. The priority lists reflected 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
Construction 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 Require-
ments Memorandum, PRM 77-8, later superceded by PRM 78-9, which established cri-
teria for eligibility of collector sewers, the publicly owned laterals that typi-
cally are the point of connection for privately 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. 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 faci-
lities planning should be limited to what is reasonably required to prepare a
cost-effectiveness analysis.
Region V's policy 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 the current guidance is attached as Appendix A. A key
feature of this guidance is integration 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.
The accompanying decision flow chart (II-C-2) shows the combined needs documenta-
tion 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. Chapters III-V discuss
the other two important aspects of such an alternative: system 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.
However, when followed in the sequence shown on the flow chart, these methods
minimize wasted time, effort and expense in needs documentation and alternative
development regardless of project potential for Federal funding.
36
-------
f V)
1 v-
i a> t-
( tCc
\ If)
Q
2£
k-
c
* -a-2
£ 0
c c
|1
= 2
0 C
0 o
a o
a>
>
in
3
o
c
o
o
C;
1
q> in
in "a
o «
£ 2
m \
-2 \
r.? J
V
L
2 j
O
o
^x
>» «
in o
c in
a> >-
Qg.
.£ 0
O
Q. A
^c £
T5 2 >
o a
S.2
_2 >
.c « 2
-if 0 0
03 0 Z
>
'in
3
O
C
o
Q. Z
i
in
c
o
in
O
a>
L.
C
a>
E
3
U
Q
Q
(V
a>
^3 tn
•5 £
0 fc
in
k_
<0
>
^
^
i. in
|?
0) '<-
£"S
0 °2
SS°
co-g
S.§S
flj *- o*
k- in i:
Q. «.£
'$ a>
O -Q
~ o =
w o> o — r
0) 3 C CD
S ° ^* t.
>v -^ O ^3
"5 « ® ^
_Q O "tl O
a ^
« Q.S C
H 0-5 °
in O> S'i:
o a) o'x
-Q "O ^ H)
/
1
1 _c 1
C-t. ^_ ,
o S
— 3 a>-
•5 « c
c£°
o o c
111
•S'f.
« 0 >
~ *^- _
° = l_
o o fe-
•>-•- >>.
~
3 « aj
tft '^Z Q
°~ ™
jn o O>
~ "O O
^5^
~ 0 0
~ s °
Oi "• C
'^ O in.
LU o a
cvi
a>
o
r £
111 H-
s§
^co
J
o
z
luman
•ocont
— C
0
•-~ C
c.S
2 c
w .±
J3 j:
c^J
;
u.
a>
a.
o
i>
si
u
in
V
$
a>
CO
parison
E
o
u
tn
O
CJ
ii
* CT
(DOC
J 0 C
5 "E "
E §1
5 - c
— c <
/•^ rt i
J —
°- c
in >>C
O ~ «
a § «
o> °",i
> ^^ C
l-g-l
*> S -
in O (.
^§2
0 CJU
CT3f
|51
c 2a
o a. t
i: a. c
> o c
- >
.-o )
'f J
«y
^
: *
5 c
/ ^—
ii
E "5.
>^
> §
5 al
|
1
OJ
in 0>
i — •
ll
|1 /T>
<" ^/ »«r^
^l «S~
\ cn "S
1 E
•H 03
H M
•H 00
,n nj
•H -H
00 T3
•H
rH ^ •
Q) O ON
)-i M-i OO
0) r^
& C
0) 0 S
CO -H S
03 PL,
S-l -H
O O C
4J 0) O
O T3
a) -a
iH 1 0)
i — 1 CO
O >-, C3
u 4J ,a
,— i
I
I
M
\—\
OJ
1-1
M
•r-l
PM
37
-------
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 documentation of their
need. Needs documentation efforts in Region V's unsewered areas involve the col-
lection 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 the figure shows, these assignments may be reviewed or revised as data collec-
tion proceeds. The purposes of the Phase I and Phase II work are three-fold:
o To reliably estimate the need for any action,
o 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.
o To effectively organize date acquisition, avoiding duplication of on-site work
and excavations.
Recommended methods by which need may be documented include:
o gathering and analysis of available data,
o aerial photographic interpretation,
o septic leachate detection,
o mailed questionnaires,
o eutrophication modeling
o nearshore plant surveys
o partial sanitary surveys, and
o 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
As outlined in Figure II-C-2, 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 for detection of marginal con-
tamination 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 assump-
tions, and cost curve analysis as described in Section II.E).
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:
38
-------
3
00
s -g i
§ F o
SgE
Jsi
1
1 II
II li
-------
RIFICATION
ilT
il"»II
-*
r
^-T-
1^1
g
^•T-
5
^>«
ll
**+>.
rL
S^.
1
pL
S-
pL
s
1
V
r^i
1
>
fi
r
1 0
^
vernied dromfield
'
-
it
r1.
1
i
o
S
»
i -E
\ S.
pL
I
c
o
V
r1!
20Z treatment
SJ
rS
od drainfield lines
V
1
ll
ll
r1.
^
i
S-
^
•o
o
S-
r1!
a
1
E
SJ
r^i
o
&
l
s
S-
r1]
euse /recycle
S-1
1
eplace septic tankorse
li
ll
1 -
a c
ill
S si
j
1
ff-site treatment
TTTTTT
rTTTTTfTTTTTT
-------
o 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.
o Interviews with sanitarians, soil scientists, septic tank installers and haul-
ers, well drillers, and zoning officers. Information gathered during these
interviews can identify the location of on-site system problems (surface mal-
functions, 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 witn these officials and contractors.
o 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. As a result, the applicant's small
waste flows specialist can develop a strategy and cost estimate for Phase II
field investigations.
TRD III-A o Review of soil maps. General and detailed soil maps may be available to the
EIS II-A-3-c 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 de-
lineate 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 docu-
mentation of need. However, they are particularly useful in planning site-
specific field investigations of on-site system suitability.
TRD XI-B o Preparation of base maps. A recommended final step in the gathering and analy-
sis of available data involves the preparation of a base map. This map synthe-
EIS 1V-C-1 sizes information collected and facilitates its use in subsequent needs documen-
tation 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. All of these
available maps are useful because they illustrate the location of individual
buildings. Overlays can be prepared that delineate:
o developed areas obviously requiring centralized facilities.
o individual buildings with obvious problems, and
o developed areas with indirect evidence of problems.
o 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 rela-
tive role of on-site systems and non-point pollution sources, so that efforts
may be concentrated in those areas yielding the greatest water quality improve-
ment. It is very important, however, to know the assumptions made in devel-
opment of the model and how they may be modified by actual on-site system per-
formance .
41
-------
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 conjunction 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 interpre-
tation 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 malfunc-
tions include:
o conspicuously lush vegetation,
o dead vegetation (especially grass),
o standing wastewater or seepage, and
o dark soil indicating excessive accumulation of organic matter.
EIS IV-F 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 reclassi-
fied as:
o confirmed malfunctions - standing wastewater from an on-site system is visible
on the land surface,
o marginal malfunctions - accumulation of excess organic matter or the presence of
dead vegetation indicate that wastewater had surfaced in the past, or
o 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 during
XI-B facilities planning such as:
o house counts,
o land use, vegetation and wetlands analysis, and
o layout of wastewater collection and transmission facilities.
To accomplish the last purpose precision flights are necessary to overcome resolu-
tion problems that can result from the normal tilting of the airplane during photo
missions. No special preflight measures (establishment of reference points, etc.)
42
-------
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 groundwater
inflows or surface runoff conveying domestic wastewater into lakes. The opera-
EIS IV-F tional 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 wastewater. 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 EISs.
The septic leachate detector is subject to certain limitations that must be recog-
nized in its use and in interpretation of the data it generates. The most signi-
ficant limitation is that it cannot quantify the strength of wastewater in a sample
or body of water. The organic and inorganic parameters that it monitors can be
transported through soil and water quite independently of other wastewater con-
stituents. Even the fluorescence and conductivity are recorded in relative, not
EIS IV-D-1 quantitative, units. In order to quantify the concentrations of nutrients, bac-
terial, or other wastewater constituents, flow through the meter can be subsampled
or samples can be collected by conventional means for later analysis. The advan-
tage of the detector is that it permits collection of samples in demonstrated
effluent plumes.
Aside from the limit on quantification, septic leachate detector surveys are sub-
ject 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:
o Naturally fluorescent decay products from dead vegetation. Swamps, marshes and
peat deposits can leach tannins, lignins and other compounds that fluoresce in
the detection range of the fluorometer. The conductivity measurements provided
by the detector are intended to differentiate such signals, but in practice
dilution may eliminate detectable conductivity changes expected from waste-
waters, thus making a wastewater plume appear to be the same as natural decay
products.
o 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.
o Eddy currents carrying large wastewater or bog plumes can appear to be indi-
vidual plumes from on-site systems.
The more serious errors are false negatives since they may indicate no problem
where actual problems exist. Notable false negatives are:
o As mentioned above, high dilution of wastewater in lake or groundwater may
reduce conductivity differences to the level of normal background variations.
43
-------
The absence of conductivity differences will cause the detector to electronicly
mask fluorescence signals that are detected.
o Mixing of lake water by wind and waves can disperse leachate very rapidly so
that normally strong effluent plumes can be missed altogether. The time it
takes for leachate to accumulate along a shoreline to detectable concentrations
is dependent on several, so far unstudied, factors.
o Fluctuations in lake level can slow or even reverse normal groundwater flow,
temporarily eliminating leachate emergence at a shoreline.
o Groundwater recharge by rainfall , snowmelt or irrigation will also affect the
dynamics of leachate movement.
o Seasonal use of dwellings may result in only periodic emergence of leachate at a
shoreline.
Many of these "false negatives" can be minimized through careful use of the equip-
ment. 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.
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 experi-
ence, knowledge, and judgment of the surveyor. Until additional 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 detec-
tor model being used. At least two weeks of field experience is necessary for
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 com-
munities 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 com-
munity that will be affected by the results of the needs documentation effort. The
objectives of this method are to:
o 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;
44
-------
o 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 pro-
perty, maintenance records, proximity to private water supply and surface
water bodies,
- lot size,
- dwelling use (number of bedrooms, permanent or seasonal status),
- private wells including type, construction, location, depth, etc., and
- water use in the home;
o Determine willingness of residents to allow follow-up surveys and site investi-
gations .
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 data indicate a significant number of on-site
system problems and preliminary economic analysis indicates that sewering will be
cost-effective. Use of mailed questionnaires is discouraged where optimum opera-
tion alternatives may be cost-effective since on-site sanitary inspection would be
required.
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 question-
naire 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 pur-
pose 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 impact of
on-site systems on lake eutrophication potential. A preliminary estimate can be
made with a procedure described in Chapter IV-D-2. The procedure uses basic hydro-
logical and morphological data for lakes. Based on the outcome of this estimate,
development of more detailed nutrient budgets may be justified, possibly supple-
mented 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 con-
trol 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. Near-
shore 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 mini-
mized. Results can be correlated with known locations of effluent plumes and other
treatment problems.
2. PHASE II: Data Collection and Comparison
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 ground-
water sampling) . Its aim is not necessarily to do these things for all inconclu-
sive sites but to study enough of them that reasonable conclusions about systems
not studied may be drawn from those that have been.
45
-------
Phase II data collection, like that of Phase I, affects not only needs documenta-
tion but actual alternative design. It makes possible a preliminary system selec-
tion for each dwelling in the study area. As with needs documentation, not every
site receives an interview, survey and sampling, but only those providing suffi-
cient conclusions about the sites not studied. This is discussed at length in
Section II-E.
a. Partial Santiary 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 devel-
oped lots within the facilities planning area into one of three groups: those with
obvious problems, no problems, or inconclusive problems. Field work in Phase I
will have been limited to rapid, community-wide surveys requiring little or no
access to private property. In the absence of substantive information relevant to
the performance of existing on-site systems, only hypothetical statements regarding
the causes of system failures and predicted performance of future systems can be
made.
Partial sanitary surveys and concurrent representative samplings involve field
investigative efforts (Phase II) to acquire the empirical data necessary for per-
formance explanation or prediction relevant to existing and future systems, respec-
tively. The primary objectives of such efforts are to:
o reclassify developed lots from the "inconclusive" category to "obvious problem,"
"no problem," or "potential problem,"3 and
o develop requisite information to predict appropriate technologies and attendant
costs for responding to community wastewater management problems.
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 appro-
priate for individual segments depending on the quality of data available prior to
design of the survey.
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
should include at least 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 con-
nections 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
EIS II-F-1 known site limitations. 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.
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
a 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.
46
-------
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 meaningful community-wide, however. Causal relation-
ships may be used in conjunction with other local data to expand survey results to
unsurveyed systems.
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:
o 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;
o 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 facilities; 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
o 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, nonprofes-
sional personnel could be trained in a relatively short period to be competent in
EIS IV-F the conduct of sanitary surveys. It should be impressed upon these personnel that
straightforwardness 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 used by U.S. EPA during its preparation 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 support of partial
sanitary surveys can identify previously unrecognized but documentable water qua-
lity and public health problems, thereby verifying the number of "obvious problem"
lots. Representative sampling may involve one or more of the following parameters:
o 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 con-
ducted during dry weather, soil mottling may offer an indication of high ground-
water elevations. In this case, a soil scientist with knowledge of local soils
should be involved.
TRD II-H o 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 direc-
tion and velocity of groundwater flow. This information is not likely to be
available during Phase I. Phase II efforts will generally be limited to evalua-
tion of well logs and other available data and to rapid surveys in lakeshore
areas. More intensive work will be conducted as required.
47
-------
EIS II-A-2-a o Well water contamination. Where contamination by on-site systems of aquifers
IV-D-1 used for drinking water is suspected, sampling of existing wells is encouraged.
VI-A-1 Initial sampling efforts should be limited to a survey not to exceed 20% of
on-site wells. 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 and other sources un-
related to wastewater. Sampling must be accompanied by inspection of the well.
EIS IV-D-1 o 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.
o 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 samplir-gs data can be increased through extrapolation
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 hydrogeologists, these data can be
related to specific soil map units, thereby providing predictions for all areas
containing the same map units.
TRD XVI-D The scope of representative sampling funded in Phase II needs documentation will
depend on the conclusiveness of prior decisions to adopt the optimum operation
EIS IV-G approach. If it is clear prior to Phase II that this approach will be adopted,
sampling at a level equivalent to detailed site analysis (normally conducted in
Step 2) may be eligible. 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 pre-
dicting future system performance. As such, this data base enables local officials
to make informed decisions on technology selection and system permitting. Obvi-
ously, 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 collec-
tion. 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 deci-
sion-making, this EIS recommends a standardized information system be developed
that will facilitate statistical correlation of soil characteristics, other deter-
minants 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
48
-------
low cost of optimum operation alternatives. A standardized format and local stor-
age of the data (by fire numbers, segments, etc.) could facilitate extrapolation 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 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.
This EIS recommends that Region V, Headquarters, the Office of Research and Devel-
opment, 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
1. Phase I
The several Rural Lake EIS's recommended (wholly or in part) optimum operation of
existing on-site systems, upgrading or replacement of failing systems, and con-
struction 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 opera-
tion 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 needs documentation and system selection procedures in
Figure II-C-2 and the Region V Needs Documentation Guidance (Appendix A) will, if
diligently 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
Phase I Needs Documentation
Phase II Needs Documentation
Detailed Site Analysis
Alternative Development
Technology Assumption
System Selection
Facilities Verification
The purpose of sequencing these efforts is to build decision points into the plan-
ning 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.
Figure II-C-2 demonstrates this approach as it might be used in a three-step Con-
struction Grants project. Even without Federal funding, however, the approach will
save time and effort. In general, the development, costing and evaluation of
alternatives proceed at a pace only slightly behind that of needs documentation,
and at a comparable level of detail.
The following sections discuss the alternative development tasks as they relate to
the key data collection steps.
The areawide information obtained during Phase I of needs documentation is also
49
-------
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 assumption of the need, cost and
II-F-1 feasibility of centralized and small waste flows approaches. The costing tech-
niques need not be detailed since on-site technology selection for each residence
would not yet take place. Decisions to proceed with development of optimum opera-
tion 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 need for some response (see II-D), de-
TRD IX-C lineation of segments is the first task of alternative development. Unless exist-
ing data is extremely limited, this can be done from available data and community
surveys that do not require access to individual lots.
This task used information such as:
o housing density
o failure rates (and kinds of failures) for existing systems
o soil types
o groundwater conditions
o 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:
o exclude from further planning those segments with limited need, and
o 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-D-2), which require continuing attention as
decisions are made.
c. Technology Assumptions
Available data and Phase I data collection will rarely 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 re-
quire small waste flows management, and those that are suited for "no action." To
do this, the least detailed type of alternative description, technology assump-
tions, will suffice. For optimum operation alternatives, technology assumption is
an informed estimate of the overall number and types of replacement and upgraded
50
-------
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 indicated 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 indicated 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
2. 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 Variabi-
lity 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 planning 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 collection.
Phase II takes the project through completion of all remaining facilities planning,
including development of an appropriate alternative. 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 acquistion proceeds, it becomes increasingly possible to estimate
both needs and possible remedies, until by the completion of Step 1 we also have a
preliminary treatment recommmendation for each individual site. Because of this,
Phase II data collection effort should seek information to assess the reasons for
existing system failure as well as to recommend appropriate solutions.
a. Systems Selection
After Phase II needs documentation work and the reclassification of developed lots,
the measures needed to remedy failures become increasingly clear. 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 unsarapled systems with similar characteristics.
EIS V-A-l-d 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 facili-
ties for a similar site not surveyed.
The aim of system selection is to allow a tentative recommendation for each dwel-
ling 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.
b. Alternative Description
System selection is the core of a final optimum operation alternative. Other
elements need to be added:
51
-------
EIS II-B-1 o Septage Disposal. Estimated quantities of septage, feasible treatment methods,
TRD I final disposal sites, and collection equipment must be described.
EIS III-C-3 o Administration, Operation and Maintenance. The management services necessary
TRD VI-A for the successful long-term performance of selected systems need to be identi-
fied on a preliminary basis.
EIS II-F-3 o 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 o Average Annual Homeowner Cost. See Section II-F-4.
EIS III-B-4 o 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 alter-
native stage:
EIS III o Management Program Outline. Construction Grants regulations require a compre-
hensive 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-l(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.
o Availability of Cluster System Sites. If small scale off-site treatment appears
to be necessary, the availability of potential treatment sites should be in-
vestigated. Where the need for sites is contingent on detailed site analysis of
existing on-site systems, availability does not have to be conclusively demon-
strated at this point.
EIS III-I o Proposed User Charges. The "average annual homeowner costs" estimated for
final alternatives include private costs and do not recognize different user
TRD VIII-B classes. Based on decisions made for the management program, 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.
3. Facilities Verifications and Design
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 "facili-
ties verification." It includes the selection of type, location and significant
design parameters for all on- and off-site facilities required for an optimum
operation alternative.
52
-------
EIS II-D-5 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
EIS II-A-4 unacceptable design or similarity with failed systems), detailed site anslysis 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.
EIS II-F-3 Given the complete data base generated to this point, the final level of cost
III-E analysis needed to select particular facilities for buildings or groups of build-
ings is possible. Where on-site facilities will be adequate, little cost analysis
TRD VII 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 analy-
sis step provides a retrospective on the individual decisions made in the field and
permits consideration from the entire community's perspective of potential econo-
mies 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 analy-
sis, the neighborhood cost-effectiveness analysis and, possibly, management program
design decisions.
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. Particularly
where a large proportion 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 construction.
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. Com-
bined Step 2 and 3 grants are intended to simplify and speed up the grants process
for small communities.
Typically, design, bid document preparation, contract award and construction are
separate steps completed in this sequence. When on-site facilities are to be
constructed, however, disruption of property and intrusion on privacy might be
minimized by following facilities verification (design) immediately with construc-
tion. 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
contractors 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.
53
-------
5. BID DOCUMENTS FOR SEPARATE STEP 2 AND STEP 3 GRANTS
Communities over 25,000 population or projects with construction costing more than
$2 million ($3 in some states) will not qualify for combined grants. The parts of
their projects using the optimum operation alternative will have to follow tradi-
tional grant and procurement procedures. Applicants may be able to speed up abate-
ment 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 "seg-
menting" here is different from its use in regard to identifying parts of a com-
munity for environmental contraints evaluation, needs documentation and alternative
development.)
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 alterna-
tive 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 com-
petition 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 inde-
pendent variable on all cost curves. Environmental factors were associated in
reasonable combinations in either 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 20-year design period.
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 tech-
nologies was selected for on-site systems appropriate to the constraints incor-
porated 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:
o technology curves - each sewered technology and on-site technology mixes are
portrayed on a graph with eight curves, one for each scenario;
o scenario curves - for each scenario, curves are included representing the on-
site technology mixes and competitive sewer/treatment combinations;
o 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.
54
-------
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 C
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
The technology curves show the cost consequences of environmental constraints 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.
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.
55
-------
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 technologies. 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:
o Small diameter and conventional gravity sewers are highly competitive throughout
the density range with conventional gravity sewers becoming cost-effective above
65 homes/mile.
o Because of economies of scale, centralized treatment is highly preferable 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.]
o Rapid infiltration, the least expensive of the three land application methods
evaluated, is still more expensive than cluster systems or centralized treat-
ment. Convergance of the rapid infiltration curve with cluster and centralized
curves at low density is due to the finding that very small scale land applica-
tion 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 gite, thereby
providing economies of scale at lower densities not achievable with other
sewered technologies.
o Only centralized treatment/collection and collection only are competitive with
replacement/upgrading of on-site systems at or below 50% replacement levels.
o Collection only is cost-effective compared to 50% replacement throughout the
range of densities and becomes competitive with 20% replacement of 100 homes/
mile. This comparison is biased somewhat in favor of collection because opera-
tion and maintenance costs for treatment and transport 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 lakeshores. Comparisons with Figure
II-F-1 include:
o The cost-effective sewering method throughout the density range is pressure
sewers.
o 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.)
o 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 condi-
tions in the collection area.
Decisions to sewer or not, will be determined utlimately by two analyses: the
feasibility of abating failures of on-site systems by replacement or upgrading, and
56
-------
COST-EFFECTIVENESS CURVES
Scenario 1
50% Growth
20,000
18,000
16,000
14,000
en
(T
O
Q
12,000
c: 10,000
O
I-
LJ
(/)
Ui 8,000
o:
CL
u
O 6,000
4,000
2,000
A - Collector Severs
fl • Collection/Transmission/Treatment
C - Collectlon/Tranawission/Land Application @ Rapid Infiltration
0 " Collection/Transmission/Cluster Systems
Collection Components of Systems:
A^...Dx " Conventional Gravity Sewers
A2--.D2 • Saail Diameter Gravity Severs with Septic Tanks
AJ...D3 « Pressure Sewers with Septic Tank Effluent Pumps
A^.-.D^ • Pressure Sewers with Grinder Pumps
E " On-Site Systems
£5 - 10Z Replacement Level
E£ • 20Z Replacement Level
£7 • 502 Replacement Level
AJ- Trade-Off Between Collection Components
38
I
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.
57
-------
COST-EFFECTIVENESS CURVES
Scenario 4
0% Growth
20,000
CO
ct
O
o
18,000 -
16,000
14,000
12,000
cc 10,000
O
UJ
CO
ui 8,000
c
a.
tr
LJ
CM
6,000
4,000
2,000
A » Collector Severs
8 « Col lection /Transmission/Treatment
C - Collection/Transmission/Land Application
D * Collection/Transalssion/Cluater Systems
Rapid Infiltration
Collection Components of Systems:
AI-..DI • Conventional Gravity Severs
A2...D2 • Saall Diameter Gravity Severs with Septic Tanks
AJ...03 * Pressure Sewers with Septic Tank Effluent Pumps
A^...D^ • Pressure Severs with Grinder Pumps
£ - On- Site System
£5 • 102 Replacenent Level
Eft • 20Z Replacement Level
£7 - 50X Replacement Level
Aj- TradB-Off Between Collection Components
A3
E7
E6
I
I
•E6
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.
58
-------
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, how-
ever, 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:
o 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.
o Where extension of existing sewer systems is being compared to on-site solu-
tions, costs to overcome constraints to sewering become relatively more
important. Field inventories of these constraints and determination of local
excavation, blasting and dewatering costs may be necessary to preparation of
valid cost-effective analysis.
o 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 con-
straints to sewering exist or when expensive replacement systems do not appear
to be necessary, cost-effectiveness analysis will not depend on an exact predic-
tion of the on-site facilities required.
o Where existing sewer systems are not available nearby, decisions to sewer or not
EIS V-A-l-f 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 faci-
lities planning than accurate determinations of the mix of replacement tech-
nologies .
2. COST CURVE ANALYSIS
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.
EIS IV-H The cost curves might also be used to make preliminary decisions on what alterna-
tives to consider (in the Plans of Study accompanying applications for Step I
TRD IX-C grants) and on preliminary service area delineations (with input from available
needs documentation data and community surveys). To do this, the development parts
of the facilities planning area are segmented. Segments do not have to be one mile
in length or have one mile of potential collector sewer. The environmental and
59
-------
TABLE II-F-2. 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
Scenarios
Collection
only
0% 50%
Centralized
treatment
0% 50%
Land
application
0% 50%
Cluster
system
0% 50%
1 No constraints
8' adc1
54 <38
92
2 No constraints
16' adc
123
3 Steep topography 73 53
1 pump
4 Flat; 6' to - -
groundwater; peat2
5 Flat; 6' to -
groundwater
6 Steep topography; - 85
1 pump; 6' to bedrock
7 Flat 87 72
8 Steep topography; 87 69
2' to bedrock;
50% of houses need
grinder pumps
111
128
108
95
- 135
- 130
adc = average depth of cut.
Imported fill needed to replace 1,000' of peat soil.
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 moat improve subsequent detailed
cost-effectiveness analysis.
Use of the cost curves beyond very preliminary analysis is not warranted for the
following reasons:
o 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.
o The curves have not been tested yet by applying them to actual situations, then
comparing the costs to detailed cost-effectiveness estimates or bid data.
o 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.
60
-------
3. COST-EFFECTIVENESS ANALYSIS
The main consideration in performing a cost-effectiveness analysis for combinations
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 alternative to another, costs of items such
as collection sewers, transmission lines, and house sewers do not affect the out-
come 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:
o 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
o Installation
- flow reduction devices
- house sewers and connections
- house plumbing modifications
- monitoring wells
- future on-site systems
o Abandonment
- on-site systems
- obsolete treatment plants (include any salvage benefits)
o Operation
- monitoring program
- on-site system inspection
- energy savings from flow reduction program
- income from crop production in land application alternatives
EIS II-D Several levels of cost-effectiveness analysis may be useful during planning and
design of optimum operation alternatives. The first level is represented 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 delineation of centralized and small
waste flows service areas early in Step 1.
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, parti-
cularly for estimating work and costs for the detailed site analysis, mix of faci-
lities, 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.
61
-------
EIS III-A-1-g 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 projections
derived for planning areas. Centralized and optimum operation alternatives should
use these projections in establishing cost estimates even though an optimum opera-
tion 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 con-
structed in a particular area, local septic system contractors might provide esti-
mates if presented with plans and a schedule of materials.
4. AVERAGE ANNUAL HOMEOWNER COST
Conventional centralized alternatives have very different cash flow characteristics
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 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-E-2 Given the diverse cash flow characteristics between optimum operation and centra-
lized alternatives and the need to compare their local costs, a parameter 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 opera-
tion 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:
o local shares of Step 2 design and Step 3 construction costs amortized at current
municipal bond interest rates;
o total private costs for flow reduction devices, house sewers, plumbing changes,
etc. amortized at current mortgage interest rates;
o the first year's operation, maintenance, and administration costs, and
o 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 in part
V-A-1 the magnitude of annual average local cost. The facilities planner should make
preliminary judgments on the eligibility for Federal assistance of capital costs
for facilities in each alternative. This judgment is based on a review of current
U.S. EPA eligibility guidelines and results of needs documentation studies.
62
-------
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-E-2 The average annual homeowner cost can be compared to median family income, indi-
vidual 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 judgments can
EIS III-I be made by local decision-makers on the distribution of the local costs.
G. SHORTCUTTING THE CONSTRUCTION GRANTS PROCESS
TRD XVI-D 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 Guidance — Site Specific Needs Determina-
tion 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 assumptions implicit in the Region V
Guidance that make it widely applicable are:
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 sub-
stantial use of off-site, innovative, and/or subcode designs thereby neces-
sitating delays in facilities verification until all individual developed
sites are thorougly surveyed and analyzed.
EIS II-B When communities are not affected by some of the above assumptions, the needs docu-
mentation 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 result-
ing 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, alterna-
tive development, costing, and selection to suit their specific situations.
Examples of such modifications and suggestions for abbreviating the process are
listed below:
o 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 avail-
able).
o Collect data early or on an on-going basis for existing systems, failures, etc.
o Avoid duplication of effort by limiting the number of return visits to indi-
vidual sites.
63
-------
o Separate areas requiring centralized treatment from the remaining areas to
expedite the facilities planning process.
o Use standard on-site system designs when appropriate.
o Acquaint local officials with the Construction Grants process.
o Use milestones (preapplication conference, plan of study, mid-course meeting,
and facilities final plan) for decision-making and adjusting the scope of faci-
lities planning as necessary.
o Enact county ordinances and/or state enabling legislation to provide access to
private systems.
o Perform detailed site analysis in Step 1 during Phase II needs documentation
work.
o Verify facilitities, design non-standard on-site systems, and construct on-site
systems with a Step 2 and 3 Grant.
H. USE OF SEGMENTS IN PLANNING AND IMPLEMENTATION
TRD IX-C Segmenting a planning area involves systematically dividing the area into subsec-
tions according to specific criteria. Planning areas can be divided into segments
EIS II-F-2 on the basis of soils classifications or suitability for on-site treatment; housing
and land use patterns or neighborhoods; on-site system failure rates; for housing
occupancy status (permanent or seasonal). The purpose of segmenting an area is:
o to organize data and calculations (for use in developing alternatives),
o to make the project more understandable,
o to facilitate and schedule subsequent work such as sanitary surveys and detailed
site analyses, and
o 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 pre-
liminary 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 faci-
lities verification. The only short-cutting advantage is that individual segments
would have to wait for other areas that are not yet prepared to proceed to the next
step.
-------
Chapter III
Community Management
-------
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 contractors.
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 sharing systems management responsibility through agreements with
other agencies. The term "management program" in this chapter 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.I., governmental concern with the use of on-site sys-
tems has increased in response to perceived and actual inadequacies of early sys-
tems. Most governmental authorities now regulate the installation of new systems
and can require upgrading and replacement of failing on-site systems. Few authori-
ties, however, have accepted supervisory responsibility for operation and main-
tenance of on-site systems.
The value of small waste flows systems as a long-term rather than short-term alter-
native 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).
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:
o certifying that a public body will be responsible for the proper installation,
operation, and maintenance of the funded systems;
o 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
o obtaining assurance of unlimited access to each individual system at all rea-
sonable times for inspection, monitoring, construction, maintenance operation,
rehabilitation, and replacement.
PRM 79-8 extends these requirements to grants for publicly owned systems.
67
-------
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 possession 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 poten-
tially 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 public health by actual conditions.
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 deter-
mining community obligations while minimizing or eliminating intrusion. Overesti-
mation of systems' adverse impacts may lead to overregulatiori, increased community
costs and reduced community support for management programs. Underestimation of
the problems or necessary management may perpetuate problems to the detriment of
the entire community.
EIS I-B-1 The previous chapter discussed ways to measure the impacts of existing on-site
systems. On-site system density, failure rate, and the vulnerability of the
affected water resources can all affect the level of management needed. When
houses are far apart, the probability of a system malfunction harming other resi-
dents 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 com-
munity.
The significance of failures relates directly to density. Among denser popula-
tions, 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 re-
ceiving a small amount of nutrient input from on-site systems, the community obli-
gation to abate the input may be absent. However, when a lake is oligotrophic or
is used as a water supply, the community may have to recognize a greater obliga-
tion.
Community involvement with existing on-site systems should be limited to assessment
of water quality and public health impacts, requiring remedial action where un-
68
-------
acceptable impacts exist and implementing management programs to deal with future
impacts. Community obligations associated with future wastewater systems should be
to regulate their design, installation, and operation and maintenance, in order to
limit their potential to affect public health and the environment.
B. SIX COMMUNITY MANAGEMENT MODELS
The following six models reflect increasing levels of community obligation for the
management of private wastewater systems. When community obligation is low, com-
munity management may be limited to initial installation. Increasing community
obligations may require management of all phases of system life, including instal-
lation, operation and maintenance, failure, renovation and, ultimately, abandon-
ment. 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 because 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. Management programs such as this are currently in general use
throughout Region V.
Under this approach, the homeowner is completely liable for system operation 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.
This approach is normally adequate for rural land areas where scattered devel-
opment, 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, periodi-
cally 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.
69
-------
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 in-
cluded 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 responsi-
bilities 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 responsibility for per-
forming 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 ser-
vices actually provided.
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 treat-
ment 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 com-
munity 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 facili-
ties. The management program in these communities would consist of universal
70
-------
community management of the wastewater facilities and be expanded to identify and
control other sources of water pollution. Additional management agency responsibi-
lities may include pollution control assessment and control activities such as:
o non-point source monitoring,
o non-point source control,
o education of residents and visitors about individual pollution control prac-
tices, costs, and benefits,
o inventory of the biological resources of the lake and its tributaries,
o research into the chemical, hydrological and biological dynamics of the lake,
and
o 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 maintenance 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:
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 characteristics. First-order factors include:
o types of wastewater facilities utilized and proposed,
o expertise available to the community,
o size of the community or management district and number of systems in use,
o available regulatory authority,
o community jurisdictional setting,
o community attitudes toward growth, and
71
-------
o community attitudes toward public management of private wastewater facilities.
"Second-order factors" are potential consequences of program design decisions.
These factors include:
o costs, including initial costs and economic impact of failures,
o environmental impacts, especially impacts on water resources, and
o 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 remain-
ing 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.
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 block-
ages. The liability for individual system failures has traditionally remained with
the system owner. With improved management of decentralized 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 wastewater sys-
tems. 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 for accepting this liability, the agency
EIS III-I 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 malfunc-
tions 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 repairs quickly. A resolu-
EIS III-E tion 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 discre-
tion. 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 management program is left to community discretion.
Table III-C-1 lists administrative, technical and planning services that a com-
munity might select.
72
-------
TABLE III-C-1. POTENTIAL MANAGEMENT PROGRAM SERVICES
Administrative
o Staffing
o Financial
o Permits
o Bonding
o Certification programs
o Service contract supervision
o Accept for public management privately installed facilities
o Interagency coordination
o Training programs
o Public education
o Enforcement
o Property/access acquisition
Technical
Planning
o System design
o Plan review
o Soils investigations
o System installation
o Routine inspection and maintenance
o Septage collection and disposal
o Pilot studies
o Flow reduction program
o Water quality monitoring
o Land use planning
o Sewer and water planning
4. DETERMINING HOW SELECTED SERVICES WILL BE PERFORMED
It is an artificial distinction to separate selection of services from the defini-
tion 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 monitoring. Then the ground-
water monitoring plan, and other monitoring as decided, must be designed. This
EIS III-I 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 innova-
tive systems may be established or existing standards and procedures may be con-
firmed.
5. DETERMINING WHO WILL BE RESPONSIBLE FOR PROVIDING SERVICES
Generally there are three groups who could provide the services selected and de-
tailed in the two prior steps:
73
-------
o the public management agency (includes assistance from regional and state organi-
zations) ,
o property owners or occupants, and
o 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
TKD VI-C 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 different parties to provide them and the risks attendant on
poor performance.
EIS IV-A-3 The public management agency need not be a new or single-purpose organization.
Personnel with appropriate expertise may already be available in agencies with
necessary authority to provide public management services. A combination of inter-
agency 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 estab-
lish a new operating agency.
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:
o drafting and adopting county or municipal ordinances establishing the agency or
providing it with needed authorities,
EIS III-I o hiring new personnel,
o notifying potential contractors and consultants of performance criteria and
contract requirements for operating within the management district,
o drafting and adopting interagency agreements,
EIS III-D o creating a sanitary review board, and
IV-F o 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 waste-
water facilities must be considered in agency design decisions.
EIS IV-C-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 con-
trolled by effective land use planning if the problem is recognized.
74
-------
Community understanding of public management of private wastewater facilities 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 opposition unless an effective public education program
is initiated to inform homeowners about their role in the community management pro-
grams. Homeowners should be notified and kept informed of their responsibilities
and obligations to the management agency.
EIS IV-F 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 manage-
ment 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 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 are granted where practical or physical constraints prohibit literal
compliance with the regulations. All states in Region V currently allow construc-
tion 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 conditions, 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, up-
grading 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, in-
cluding those which may not be in conformance with existing code requirements.
Data developed during the study of alternative waste treatment systems for the
Seven Rural Lake Projects indicated that many nonconforming systems operate satis-
factorily 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
TRD II-D effort. 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/groundwater/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.
75
-------
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 con-
sidered as a construction variance since it allows construction which is noncon-
forming 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. Difficulties arise, however, when non-
conforming 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 sys-
tems to be upgraded, since the government was cognizant of the systems' noncon-
formity. 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 re-
quired. 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 situations 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 per-
formance 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
76
-------
for high risk sites would also be desirable. Where financial resources and experi-
enced staff will be limited, more conservative variance guidelines may be con-
sidered. 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 management 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.
F. ACCESS CONSIDERATIONS
TRD VIII-E U.S. EPA Construction Grants regulations (U.S. EPA, 1978a) implementing the 1977
Clean Water Act require in Section 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, con-
struction, maintenance, operation, rehabilitation, and replacement." PRM 79-8 also
applies this to publicly owned on-site treatment systems, or their equivalent.
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 le-
gally gain access to 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 legislation.
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
circumstances. 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
77
-------
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 muni-
cipal 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.
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, communi-
ties can regulate and take actions necessary to assure compliance with their re-
quirements 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 management
districts have also granted communities access rights once the management district
is formed. To minimize problems arising with utilization of such blanket
authority, the degree of intrusiveness of any inspection program should be mini-
mized consistent with maintaining the effectiveness of the district. Public educa-
tion 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 is considered equivalent to public ownership or easement
in satisfying requirements of 40 CFR 35.918-l(h). Some state statues 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 com-
munity distribution system. Homeowners supplied by public systems often use more
water than those with individual systems. The chances for hydraulically over-
loading on-site wastewater systems is subsequently greater for those served by a
public water system. Methods for implementing water conservation programs in these
areas include:
o rate structure changes (increases in price),
o use restrictions,
o changes in plumbing codes,
o public education, and
o community subsidized distribution of flow reduction devices.
For rural areas served by individual wells, pricing schemes, use restrictions, 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
78
-------
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 centralized 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:
o reduced well water pumping,
o reduced water treatment (where treatment is necessary),
o reduced energy costs for heating water, and
o prolonged life of on-site wastewater treatment system.
Public education should be used in conjunction with other methods of implementing
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 distribution. 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 AND 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 pro-
bability 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 comple-
ment 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 ground-
water. 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 operational success depend on sample collection
and laboratory analysis.
EIS II-D-6 Groundwater sampling programs for facilities planning are discussed in Chapters
II.D.6 and IV.D.I. Information developed for planning will help define the need
IV-D-1 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.
79
-------
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. Requirements for monitoring potable
water wells are stated in 40 CFR 35.918-l(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.
The following suggestions may be useful in developing local monitoring programs.
o On-site wells within 50 feet of drain fields, within 100 feet and down gradient
from drain fields in unconfined aquifers, or penetrating unconfined fractured or
channeled aquifers could be sampled annually.
o 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.
o 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.
o Private wells serving more than one dwelling could be sampled as suggested for
on-site wells except where water withdrawal may be sufficient to alter natural
groundwater flow patterns. These could be sampled annually unlees a hydro-
geologist demonstrates why more or less frequent sampling is appropriate.
o 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 concen-
trations, 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 waste-
water 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 groundwater 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.
80
-------
Monitoring programs for cluster systems, rapid infiltration, or slow rate land
TRD II-K application should be developed in concert with detailed design of the system
III-B 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 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 ground-
water failures of on-site systems and improve understanding of factors influencing
effluent plume movement. As with septic leachate surveys conducted in Step 1, 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. Pur-
chase 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 moni-
toring 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.
81
-------
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 co'sts, public capital costs (local share
of capital), interest on public debt, operations and maintenance, and the reserve
fund. With the exception of private costs, communities have a great deal of flexi-
bility in determining 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 modifications, 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 charge system. U.S. EPA PRM 76-3
requires that the facilities plan include the estimated monthly charge for opera-
tion 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.
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. However,
most communities do include capital costs in their user charge systems. For cen-
tralized facilities and cluster systems, capital costs 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 govern-
ment 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. 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. In the case of some on-site technologies, some operation
and maintenance costs may be paid by users directly to private contractors such as
septic tank pumpers and haulers.
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 facili-
ties. 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 each type of system used. 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. USER CHARGE STRUCTURES
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, estab-
lishing user groups, (that is, charging on the basis of criteria such as flow,
82
-------
technology used, or location), and charging each user the specific costs of faci-
lities and services provided by the community. The method of allocating costs
chosen by the community may be based on considerations such as the costs of imple-
menting 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 consi-
deration 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 inter-
mediate 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
improvment, replacement or operation of their on-site systems, beneficiaries may
include:
o residents and non-residents who use the water resources being protected,
o where off-site facilities are constructed, land owners who could not previously
build but are thus enabled to,
o businessmen whose revenues depend on the attractions of the water resources
being protected, and
o property owners do not require assistance at present but for whom the avail-
ability of assistance is a benefit,
o 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 possi-
bility of use restrictions can be expected to present a more complex benefit dis-
tribution. 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.
83
-------
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 economically 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.
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 communities, the small waste flows
systems alone may not justify full-time positions, 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
TRD VI-A
VIII-A
EIS IV-C-2
EIS III-H-1
TRD X-D
EIS IV-A-3
TRD VIII-B
TRD II-C
XII-G
EIS III-H-2-b
K. PERSONNEL
TRD VI-D
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 wastewater
disposal. These restrictions may be altered through approval of innovative on-site
systems or adoption of performance-based design standards by a management agency.
If this occurs, the community may desire to develop appropriate land use
designations. The management agency could be designed to provide this service.
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. The periodic inspection and
monitoring of individual wells by a management agency is already mandated by
Construction Grants Regulations Section 35.918-1(1) for grants involving individual
systems.
Section 201(f) of the Clean Water Act of 1977 states that the administrator shall
encourage waste treatment management that combines open space and recreational
considerations with such management. A community management agency could coor-
dinate the use of wastewater management district properties 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.
In communities with particularly sensitive water resources, the management 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 of broader responsibilities in
this area could be of great community benefit.
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 wastewater management
include:
84
-------
o system designer, o small waste flows contractor,
o clerk, o laboratory technician,
o administrator, o water resource scientist,
o inspector, o soil scientist,
o attorney, o laborer,
o equipment operator, o environmental planner, and
o plumber, o wastewater system operator.
Although the list of job classifications is long, one person could provide a number
of the 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 requires five
steps:
1. assess skills and skill levels required by the management agency,
2. estimate the level of effort required by skill,
3. inventory available personnel and define their skill levels,
4. select personnel to meet management agency needs and acquire their services
through interagency agreements, hiring, or contracts, and
TRD 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 limited
TRD XV-C to the local area. All sources of potential assistance should be evaluated, in-
cluding state, regional and other municipal personnel, U.S. Soil Conservation
EIS V-B-2 Service personnel, utility company workers, private contractors, and consultants.
State and regional agencies can provide many types of assistance, including:
o direct technical assistance,
o assistance to local communities in grant application and administration,
o preparation of community wastewater needs analysis,
o identifying the local feasibility of small waste flows technology and manage-
ment ,
o review and upgrading of local and state regulations,
o dissemination of information on small waste flows technology and management, and
85
-------
o 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 consul-
tants hired to perform management agency services are experienced in the utiliza-
tion 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 initial implementation of a management program in a community cannot be ex-
pected 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 imple-
mented, unforeseen problems with the system are likely to develop. Certain seem-
ingly prudent management practices may appear otherwise in actual operation.
The agency should encourage feedback on its management program by soliciting 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 to 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.
86
-------
Chapter IV
Facilities Planning Techniques
mi*. MJKM ««CH
WALKER
.f.v-*'*^.®/' \X^\y^ CAMP NOAROS
BEAUTY B£ACM
LO CAO> RESORT
--J
Legend
• NO INFORMATION AVAILABLE
D ® UPGRADING REQUIRtED
A SYSTEM REQUIRES NO UPGRADING
• BUSINESS OR RESORT
-------
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 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 de-
fining 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.
When applicants decide on facilities planning area boundaries, several factors must
be evaluated:
o local growth and development objectives,
o geographic, geologic and hydrogelogic conditions
o wastewater treatment needs,
o housing density and identified public health problems,
o sensitivity of local water resources to on-site system failure,
o availability of data (both socioeconomic and natural environment), and
o 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
89
-------
civil division). This approach maximizes the applicability of published population
and economic data, including census data, population (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 implementation of the facilities plan proposed action and can facilitate
the formation of a small waste flows management district to maintain facilities.
Additionally, finance mechanisms may be easier to implement at this level.
This approach has drawbacks, however. It could lead to conflicts between juris-
dictions 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 cross-
over. In addition, the approach may not adequately consider local growth objec-
tives. 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 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
difficulty 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 AREA 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 information
EIS II-F-2 regarding these factors may not be available. However, preliminary information can
be gathered from an inspection of topographic maps or aerial photographs (devel-
opment density), interviews with local health officials or natural resource per-
sonnel (number of on-site system failures, sensitivity of water resources, and
feasibility of abating failures on-site), and use of cost curves (cost-
effectiveness) .
If delineation of facilities planning area boundaries or decisions to consider
optimum operation alternatives in Step 1 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
90
-------
(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.
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
Cost-
Effectiveness
Do nothing
vs.
small waste
flows
These three factors together determine a community's
obligation to improve wastewater management in
unsewered areas.
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.
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.
3. ADVANCE PLANNING TO SAVE TIME AND EFFORT
TRD XIV-A
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 Step 1, considerable time would likely be saved in the facilities
planning process. While not grant-eligible at this stage, 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.
Almost every one of the Seven Rural Lake EIS's was prepared in the midst of signi-
ficant 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 coali-
tions 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.
91
-------
TRD X-D
EIS IV-C
VI-D
TRD VIII-A
XI-B
EIS III-C-5
EIS III-C-h
B. DEMOGRAPHY
The facilities planning process offers opportunities to analyze the need for re-
creation resources in an area and to maximize recreation potential. Under the
Clean Water Act, funding is available for recreation and open space planning as
part of overall planning for wastewater treatment facilities in Step 1. Because
only Step 1 monies are available for this purpose, local efforts should be made to
contact park and recreation experts on the local, regional, and state levels for an
inventory of existing plans, acquisition programs, and facilities. 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. Because -grant funds are not available for recreation
planning in the design and construction phases in Steps 2 or 3, an adequate pro-
posal must be made in the plan of study to allot sufficient planning funds in Step
1. In the case of the optimum operation alternative, certain forms of treatment,
especially cluster systems, may offer some recreational potential.
New forms of wastewater treatment that overcome unfavorable site conditions may
induce residential development in patterns and densities unanticipated at the local
level. To mitigate these impacts, land use planning and the adoption of growth
management controls should be considered before beginning 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 industrial 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 likely amount and spatial distri-
bution of growth for which wastewater treatment must be provided. A comprehensive
plan would also have undergone 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 significant controversy.
Accurate demoiigraphic information and projections play an important role in deter-
mining project need, designing workable alternatives, and assessing project impact.
Appendix A.8.a. of the current Construction Grant Regulations, for example, con-
tains a variety of population projection methods, which should be used if the
community is seeking Federal funding. 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 disposable 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
arid oil shortage between 1973 arid 1975 resulted in a significant downturn in
second-home development (American Society of Planning Officials, 1976). If this
92
-------
experience is extrapolated to current conditions, 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 in-
crease 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 present
increase in total population projected for each of the Seven Rural Lake EIS com-
munities to the year 2000 and the percentage of the total 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.
TABLE IV-B-1. SEVEN RURAL LAKE EIS POPULATION PROJECTIONS (INCREASE TO THE YEAR 2000 AND SEASONAL
POPULATION EXPRESSED IN PERCENTAGE)
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 total)
47.7
46.0
76.0
88.0
68.0
43.0
27.6
The overwhelming attraction for second-home development is accessibility to lakes
and rivers and the recreation opportunities that they afford (Marans anc( 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).
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 facili-
ties. 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 condominiums. The number of households owning
recreational properties is expected to increase by 21%, the number of households
93
-------
owning single-family vacation homes will increase by 14.2%, and the number of
households owing resort condorainums will increase by 32%.
Based upon data from the 1973 to 1975 housing recession, the rate of development 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.
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
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 evalua-
tion of impacts induced by a proposed system. Relevant data are frequently avail-
able 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 includes some type of natural recreational
resource (that is, lakes, mountains, rivers) is the determination of permanent
versus seasonal population. In many of the rural service areas where such re-
sources exist, seasonal residents (normally summer) comprise a major portion of the
total population. Even though the annual volume of wastewater that seasonal resi-
dents 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.
94
-------
Regional planning or 208 water quality agencies are required to have data per-
taining to facilities planning areas. These agencies are responsible for dis-
aggregating adopted national and state population projections to the 208 level and
the resulting data are required to be used in facilities planning and needs surveys
(40 CFR 35.9, Appendix A). 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, population 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.
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 characteristics 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 demographic
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 per-
sonnel are usually required to determine if such studies have been performed and
are available.
EIS 11-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 cur-
rent 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 utili-
ties 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.
95
-------
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.
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 facili-
ties planning areas.
Mathematical projection models assume that the components that characterized past
population change will continue for some period into the future. This extrapo-
lation 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 pro-
jection 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-C-1 Land use models project population on the basis of available land and expected
population density. This type of projection reverses the process of projecting
TRD XI-B population growth first and then determining what land area will be required.
Instead, it begins with the amount of developable land available and then deter-
mines 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 wastewater treatment
service.
The population projection methods discussed previously are applicable to small
rural planning areas in varying degrees. Data requirements, assumptions, and the
projection outputs may limit the usefulness of many of these projection techniques
for small rural planning areas. During the preparation 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.
96
-------
According to the cost-effectiveness guidelines (40 CFR 35.9, Appendix A), appli-
cants may perform their own population projections as long as their figures cor-
respond 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.
4. ESTIMATING ECONOMIC CHARACTERISTICS OF RESIDENTS
EIS VI-C-3 The decennial census is the most comprehensive available source of information 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 size, population levels, and vacancy rates are parti-
cularly 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 characteristics 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, agricul-
ture, 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 base-
line 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).
Ttis 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 infor-
mation is usually available on housing construction, 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 obtain-
able for seasonal residents. If economic impacts of wastewater alternatives on
seasonal residents will be decisive for alternative selection, a special economic
97
-------
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 documen-
tation 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, on the other hand, may be able to provide information
regarding housing vacancy rates and shifts from seasonal to permanent occupancy.
C. 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 significant dif-
ferences in population growth, land use conversion, and environmental 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 environmental and economic resources. They rely heavily on
general soil limitations 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, environmen-
tal resources, and economic factors in the design and evaluation 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 compi-
lation 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 charac-
teristics 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 informa-
tion 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 interpretation 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 development to occur,
where restrictive constraints permit limited development, where qualified con-
98
-------
straints 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 dwelling units permitted per acre.
TRD IX-B 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 ser-
vice 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 environmental constraints of an area will facilitate a deeper
understanding of the types of impacts that a wastewater management system may
generate.
2. THE INTERRELATIONSHIP BETWEEN SMALL WASTE FLOWS FACILITIES PLANNING AND LAND USE
TRD VIII-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 con-
trol (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 floodplain areas, on steeply sloping areas,
and in locations with shallow depth to bedrock because these areas are considered
unsuitable for on-site wastewater 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 con-
sidered "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 enahle 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 re-
sources. 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 shal-
low depth to bedrock. Off-site treatment such as cluster systems can circumvent
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
99
-------
pattern inconsistent with local goals and objectives, loss of open space buffers
between existing developments, and encroachment into environmentally sensitive
areas.
EIS III-C-5 To anticipate these impacts, localities should consider conducting land use plan-
ning prior to or concurrent with wastewater treatment facilities planning. 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 facili-
ties 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 require-
ments have been based on the best professional judgment of sanitarians. These
professionals have experienced the need for larger lots because of site limitations
or odd lot lines and have recommended 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 dis-
tances will be reduced, and 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 subdivi-
sions 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 constructing sewers between dispersed houses. Further depen-
dence upon local sanitary codes may thus severely restrict the amount and distribu-
tion 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 collection and treatment
systems would induce growth in environmentally sensitive areas such as floodplains,
wetlands, and steeply sloping areas. Alternative and innovative forms of waste-
water 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 waste-
water treatment 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
100
-------
do they have the tools to inventory and analyze their environmental resource base
and to formulate performance standards that permit development but prevent signi-
ficant impacts.
Planning for wastewater treatment facilities gives local municipalities the oppor-
tunity 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.
D. WATER RESOURCES
TRD II-A Consideration of water resources was consistently one of the weakest elements in
XII the facilities plans that the Seven Rural Lake EIS's evaluated. Documentation of
XIII 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 non-
sewered alternatives, were net well founded on theory or fact.
EIS I-B-3 Early U.S. EPA facilities planning guidance (U.S. EPA, 1975) and administration 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 consideration of water resources in
the original Seven Rural Lakes and countless 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, provides suggestions
for analysis of water quality needs and impacts, and discusses grant eligibility of
water resource investigations.
1. Bacterial Contamination
EIS II-A-2 Pathogen contamination of drinking waters and primary body contact waters by septic
VI-A-1 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:
o the fecal coliform counts are above background counts,
o the source is verified to be wastewater by other indicators such as high
nitrogen concentrations, surfactants or brighteners, and
o there is a probable hydrologic connection between the suspected wastewater
source and the point of use.
EIS II-A-2-a The "point of use" may be an existing well, a planned well site that complies with
state separation distances from wastewater facilities, spring, lake shore, stream
bank 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 unpro-
tected against entry of surface water or shallow (0 to 3 feet) percolating water.
Sampling of unprotected wells or wells that cannot be inspected should be avoided
during surveys funded in Step 1 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
101
-------
properly protected, the survey should include analysis of constituents normally
found only in domestic wastewaters, such as surfactants or brighteners.
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.
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 provide sufficient data
for alternative development and plan selection. 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 detected.
EIS II-D-2-b If results are confused by high background counts or are otherwise ambiguous, it
may 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 demonstrated that the limiting nutrient, phos-
phorus, is normally released to lakes in small quantities. The cumulative phos-
phorus 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-D-1 has
been prepared to assist grantees in recognizing these sensitive lakes. This nomo-
graph relates morphological characteristics 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 determination on the need for more detailed modeling and field data
collection. 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 pg/1 of phosphorus will probably not be eligible for sample collec-
tion and analysis. Between 1.0 and 10.0 (Jg/1, applicants may first propose to con-
struct nutrient budgets based on empirical models and available data, then collect
confirmatory data appropriate to the major uncertainties in the nutrient budget.
Above 10 |Jg/l> 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.
To use Figure IV-D-1 the following data are required:
o number of soil absorption fields within 300 feet of the lakeshore,
o water flow through the lake, Q, in cubic meters per second (ra /s), and
102
-------
100
5co
to
>-
co
ui
8°
O
x
0.
CO
O
I
a.
10
1.0
0.1
1.0
K =
I-R
R = Retention coefficient
Q =lnflow/0utflow(cfs)
m3/s"' = 0.0283 cfs"1
10
100
1,000
NUMBER OF ON-SITE SYSTEMS WITHIN
300 FEET OF LAKE SHORELINE
Figure IV-D-1. Lake phosphorus concentration due to on-site systems.
103
-------
z
UJ
o
u.
u.
UJ
o
o
z
o
\-
z
UJ
I-
uj
or.
(T
O
X
a
CO
o
a.
R = 0.426exp (-0.271 q) + 0.574 exp (-0.00949 q)
.6 -
.2 -
0
40 80 120 160
AREAL WATER LOAD, q(m/yr)
200
240
Figure IV-D-2. Relationship between areal water load, q,
and phosphorus retention, R. (Kirchner
and Dillon, 1975)
104
-------
2
o surface area of the lake in square meters (m ).
These data are then used in the following sequence:
o Areal water load, Q, is calculated by dividing flow by surface area.
o The lake's phosphorus retention coefficient, R, is estimated from Figure IV-D-2.
o The lake's hydromorphological constant, K = (1-R)/Q, is calculated and located
on the scaled diagonal in Figure IV-D-1.
o The K line is drawn perpendicular to the scaled diagonal through K.
o 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.
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 assumptions are suspected of
being inappropriate, field studies may be necessary.
EIS II-D-l-c 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 discharge 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 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 concen-
trations above background or of shallow groundwater samples above 1 mg/1 of phos-
phorus 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 developing nutri-
TRD XII-D ent budgets. Lacking this information, reasonable estimates can be developed using
methods based on the universal soil loss equation or National Eutrophication Survey
EIS IV-D-2-b 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.
105
-------
TRD II-D Direct stimulation of aquatic plants, especially the filamentous green algae
EIS VI-A-2 Cladophora, was apparent at plume emergence points studied in detail during pre-
paration 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 ground-
water 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 suf-
ficient justification for abandoning on-site systems. Some kinds of on-site up-
grading, such as filter field relocation, gray water/black water separation, 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 eutro-
phication. Abandonment of on-site systems adjacent 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 vulnerable to poor design or construction of on-site sys-
tems; filter field relocation or reorientation, gray water/black water separation,
or plume interception, as well as more common on-site upgrading, may be helpful.
E. FINANCIAL IMPACTS
1. ASSESSMENT OF MUNICIPAL FISCAL CAPABILITIES
EIS VI-C-2 Communities applying for U.S. EPA Construction Grants funds are required to demon-
strate in their facilities plans that they have the necessary financial resources
to insure the adequate construction, operation, and maintenance of the proposed
facilities (U.S. EPA, 1976b).
Municipal fiscal capabilities are determined by investigating the ability of a
community to pay for and maintain wastewater facilities. The term "communities" in
PRM 76-3 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 attri-
buted 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 maintenance costs. Indicators of municipal fiscal capa-
bility include property values, median family income, community growth charac-
teristics, and the revenues, expenditures, assets, and total outstanding indebted-
ness 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 community 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 obli-
gation 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
106
-------
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.
When evaluating a community's ability to meet bond payments, the financial com-
munity (credit-rating firms, investment bankers, and large institutional investors)
evaluates the following factors (Moak and Hillhouse, 1975):
o net direct and overlapping tax-supported debt per capita,
o percentage of current property tax delinquency,
o percentage of debt service on tax-supported debt to total revenues of the com-
munity's operating budget,
o average life of existing tax-supported debt in terms of general obligation
bonds,
o the ratio of projected revenues to the total annual debt service, and
o the ratio of the depreciated value of the community's revenue producing faci-
lities 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 com-
munity's past experience with bonded indebtedness. It is more difficult for a
community that has never incurred such debts to secure financing than those com-
munities 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 difficulty 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 finan-
cial resources and can recommend the types of financing available to the community.
107
-------
2. ASSESSMENT OF ECONOMIC IMPACTS FOR RESIDENTS
EIS VI-C-3 Expensive wastewater facilities may have a significant financial impact on users
II-F-4 who will pay the capital and operation and maintenance costs associated 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 ad-
verse effect on the finances of users (U.S. EPA, Facilities Planning, 1981, March,
1981). Under this guidance U.S. EPA considers projects expensive when the average
annual user charges (including debt retirement) are:
o 1% of median household incomes less than $10,000.
o 1.5% of median household incomes between $10,000 and $17,000.
o 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 compari-
son. 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 substantially 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 econo-
mic 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 construction of
centralized systems generally involves the use of contractors 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 community. For example, equipment for centralized waste-
108
-------
water facilities must usually be obtained directly from manufacturers and whole-
salers 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 alter-
natives 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 wastewater alternatives may partially offset any
negative economic impacts resulting from growth restrictions imposed by minimum lot
size restrictions and bans against room additions.
F. PUBLIC PARTICIPATION
TRD XIV-A Planning for wastewater facilities in rural and developing communities provides
opportunities for public participation not available normally in urbanized set-
tings. 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 ex-
plaining 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 surveys.
II-D-2-a 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 facilities re-
quired 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 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.
109
-------
Chapter V
Funding and Administering the Optimum Operation Alternative-
Mitigative Measures
United States
Environmental Protection Agency
Region V
-------
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 adminis-
trative 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 questions--both 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 eligibi-
lity of some on-site treatment systems under various special circumstances. Many
of these were resolved in the subsequent Program Requirements Memoranda (PRM's).
On some questions, however, individual states differed as to the precise meaning of
the PRM's, requiring regional guidance, or even clarification by Agency head-
quarters. 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
Seasonally occupied dwellings served by publicly owned collection and treatment
were eligible for Federal funding long before the 1977 amendments to the Clean
Water Act. The text of the 1977 amendment and the associated regulations (40 CFR
35.918 (a) (2)) 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 may 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.
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, monitor-
112
-------
ing, 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 Require-
ments Division Director, extended this equivalence to public ownership to access by
local or county ordinance (see below).
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. To-
gether they allow selection of the most cost-effective and environmentally sound
alternative.
2. INTERGENCY COORDINATION
a. Incorporation of Property Value Changes in Cost-Effectiveness Analysis
Property values can be affected by the adequacy of the wastewater facilities serv-
ing the property. The value-added concept is the amount of value added to a pro-
perty 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 public on-site wastewater
districts in the definition of public facilities.
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, regardless 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 decrease the way that property can be used. Property with these restric-
tions 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.
113
-------
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 contrac-
tors 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 construction 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 pre-
vailing 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 alter-
native can include large-scale urban wastewater treatment facilities that currently
are classified by DOL as "heavy construction projects."
Most of the companies that would be used to carry out the optimum operation alter-
native are small firms that have had little or no experience with Federal regula-
tions 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 bookkeeping
time each week for a small contractor Small contracting firms with little experi-
ence in dealing with U.S. EPA projects may be discouraged 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 DOL to establish a project wage determination based on indi-
vidual projects until enough data have been collected by DOL to establish general
wage guidelines for these types of projects. DOL 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
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. 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 ease-
ments 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
114
-------
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 wastewater district considerably easier. Access by ordinance
is also particularly useful when there is no Federal funding at all.
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 elimina-
tion 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 pre-
ferentially 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 defi-
nition 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 specifi-
cally 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
publiic health hazard. Grossly inadequate treatment 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 indentifiable need.
c. 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 is desirable. 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.
4. REGIONAL CONCERNS
b. Conventional Water Use
State 201 agencies, notably in Minnesota, have stressed the need for funded up-
graded 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.
115
-------
EIS II-A-5 Where 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 reduc-
tion devices; limitations on building additions; prohibitions on garbage grinders,
dishwashers, or clothes washers; subcode sized drainfields and/or advanced on-site
treatment (mounds, sand filters, dosing, etc.) replacement. 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 priori-
ties 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 the causes of malfunction and
the operability of the subcode systems.
b. Potential Failures
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 nonconforming 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 recognition 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 al-
ready failed. Similarity is measured by system design, usage, soil characteris-
tics, site limitations, site drainage, and groundwater hydrology, as appropriate.
c. Simplified Easement Forms
The access (at reasonable times) and control required for individual systems by
35.918-1(h) and extended to publicly owned single family systems by PRM 79-8 does
not need 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.I 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 devel-
oped lots will never successfully support on-site systems. Innovative and alter-
native 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
116
-------
Figure V.A.I
SEWER EASEMENT AND RIGHT OF WAY
(D(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:
-------
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 assess-
ment as indicated by partial sanitary surveys and representative sampling. Selec-
tion of an off-site facility as an alternative 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 eligi-
bility determinations for proposed off-site facilities will be contingent on com-
pletion of on-site sanitary inspections, detailed site analysis (where indicated),
and microscale cost-effectiveness analysis.
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 pertaining 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 con-
formance 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 reconsidered.
Rights to the continued use of systems should be specified, as well as when up-
grading 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 conditions 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 interpreta-
tion 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 management 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 systems
is a means for the management agency to obtain access to these systems. Methods of
TRD VIII-E obtaining access have already been discussed in Chapter II-F. Regulatory and insti-
tutional powers within each state should be reviewed and amended as appropriate to
provide management 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 requirements
118
-------
TRD VII-A 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.
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 activities normally
TRD XV-C 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 wastewater 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 com-
munities 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 reassess-
ment 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 (MA) for communities with popula-
tions over 200. These MNA's were less detailed than typical facilities plans, but
they did define and project communities' wastewater needs and provide recommenda-
tions 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 pollution sources. Such corrective mea-
sures may include the upgrading of existing wastewater facilities, including on-
site systems. In non-lake areas, regional and county assistance may also be uti-
EIS IV-A-1 lized in delineating rural areas with wastewater needs. Chapter IV, Section A.I.
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 cur-
rently 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 pollutants are not appropriate measures for problems in
EIS III-A-2 unsewered areas. Comparisons among predominantly unsewered areas would more equi-
tably be made 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 com-
munities.
3. STATE GRANT AND TECHNICAL ASSISTANCE
Small communities encounter many problems in participating in the Construction
Grants program. Lack of an effective administrative and management structure to
119
-------
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 com-
munities have with the Construction Grants process as:
o difficulty in meeting the program's administrative requirements,
o problems with managing consulting engineers,
o problems in dealing with U.S. EPA, the state, and the Corps of Engineers,
o problems in employing the environmental assessment process, and
o difficulty in meeting the accounting requirements for post-grant audits.
o 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 Construc-
tion 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 wastewater 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 contracts 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 responsi-
bility 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 corporation 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 con-
tracts.
120
-------
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 com-
munity 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 uti-
lized 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 regis-
tration programs that make assessment of total manpower difficult. Furthermore,
Wisconsin does not have a sanitarian classification as such involved in the regula-
tion 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 complaints. In some areas of
Region V, even these minimum regulatory services are not provided. Based on
assumptions developed and presented in the Technical Reference Document, Chapter
X-E.,
121
-------
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
Voluntarily registered
Voluntarily registered
Voluntarily registered
and unregistered sanitarians
and unregistered sanitarians
sanitarians
sanitarians
Certified plumbing inspectors and
3,000 certified soil
testers
TRD VI-D
EIS III-K
C. TRAINING
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.
Optimum operation alternatives will require manpower for initial implementation,
continuing operation and maintenance. During the implementation phase, personnel
will be required for planning (including needs documentation), design, and con-
struction. 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 con-
tractors, 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. Defini-
tive 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.
An effective small waste flows management program relies on competent personnel to
perform a myriad of tasks related to small waste flows management. 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 conven-
tional centralized wastewater technology. 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. Traditionally, 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 environ-
mental health science, which are often considered as sanitarian training programs,
do not normally extensively cover the topic of small waste flows technology. Few
of these programs incorporate the "hands-on" training necessary to train an indi-
vidual fully, and only one program at Ferris State College in Michigan was identi-
fied 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.
122
-------
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 Work-
shops sponsored by the University of Minnesota Extension and the Minnesota Pollu-
tion 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, universities can develop and
disseminate valuable information concerning new technology and other matters re-
lated 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. Indiana also provides a 1-week orientation
session that includes about 8 hours of training in small waste flows technology.
The Ohio program is a model for this type of training program.
A final level of training that is often neglected involves homeowner education.
Homeowners need to be instructed in the proper maintenance procedures 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 educa-
tional brochures describing on-site systems that have been published by the Uni-
versity 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 infor-
mation related to on-site systems.
D. DOES ANYONE WANT THE SMALL WASTE FLOWS APPROACH?
There are many reasons why small communities seek Construction Grants funding for
TRD XVI-A 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:
o avoiding prosecution,
o malfunctioning septic tanks,
o residential and commercial growth, and
o 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
123
-------
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 oil-site systems. As has been dis-
cussed 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 com-
parison to conventional wastewater facilities. This practice has led to the sewer-
ing 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 asso-
ciated 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, particularly
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 com-
munity'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 devel-
opment.
Where communities wish to use sewer:, to promott 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 arid local policies for the use of
alternative systems may allow the development of land previously considered un-
developable. 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 tc 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 owa treatment capabilities, or other sources of
funding to improve wastewater facilities may be required.
124
-------
Chapter VI
Environmental and Social Consequences Of The Proposed Action
-------
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 management. If this is available, how-
ever, it can provide water quality improvements 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 determi-
nation 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 geo-
hydrologic conditions. An objective of the optimum operation alternative is to
detect and eliminate or upgrade sources of contamination. Totally unsatisfactory
systems can be replaced. Drainfields can be redesigned, rebuilt, or relocated to
minimize groundwater impacts. Gray water/black water separation can largely eli-
minate nitrate loadings to groundwater.
EIS III-H-1 The key to reducing impacts of existing discharges is adequate identification 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 septic tank
IV-D-1 effluent discharges to groundwater. At the housing densities and in the hydro-
geologic settings studied in the Seven Rural Lake EIS's, contamination of wells by
TRD II-A septic tank effluent was not shown to be a problem. The low density, linear devel-
XIII-A-C opment, 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.
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
127
-------
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:
o sampling of selected, properly protected wells previously found to exceed bac-
terial or nitrate standards and suspected of contamination by nearby on-site
systems,
o concurrent sampling of suspected wastewater sources, and
o 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 trichlo-
roethane) in certain kinds of on-site treatment systems (especially cesspools in-
stalled 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 Commis-
sion) deserve serious considerations.
C.
Information Needed for Assessment
2.
LAKES
In facilities planning areas characterized by linear, single- or double-tier devel-
opment in nonfractured and nonchanneled geology, description of groundwater re-
sources 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 groundwater. In other settings, the existence or
possibility of adverse impacts should be assessed by a professional geologist or
hydrogeologist.
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 con-
tribute a significant share to lake loading, and (2) whether the systems are pro-
perly designed or installed.
a. Bacterial
EIS II-D Bacterial contamination can be identified by available survey and sampling methods.
III-H-2 The most likely routes of bacterial contamination from existing on-site systems are
IV-D-1 direct discharges and overland runoff of surface malfunctions, almost all of which
are remediable under the optimum operation alternative. Groundwater transport of
TRD XII 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 pro-
ductivity of a lake as a whole and localized stimulation of plant growth. Loca-
lized 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, how-
ever, reduce or eliminate lake nutrient input resulting from direct discharges or
surface runoff.
EIS IV-D-2 Nutrient inputs to most lakes from on-site systems are generally small when 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
128
-------
abandoning the systems on lake trophic status will be small. Trophic status im-
provements alone will seldom be a supportable reason for abandoning on-site sys-
tems .
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. Eligibi-
lity of surface water sampling programs to develop nutrient budgets will be con-
sidered on a case-by-case basis but not until modeling exercises that can be com-
pleted without field data are prepared and submitted for review.
c. Nutrients - Local
EIS IV-D-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 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 aban-
donment 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 up-
grading and replacements may incidentally reduce this growth, and innovative tech-
niques 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.
B. ENVIRONMENTALLY SENSITIVE AREAS
EIS IV-C-2 In rural and developing communities, any form of wastewater treatment technology
will have some impact on environmentally sensitive areas. Historically, these
TRD VIII-A areas were protected by on-site sanitary code prohibitions and by the fact that on-
Xl-B-C 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
TRD IX-A impacts include construction in and development encroachment on floodplains, wet-
lands, 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 systems, but
limitations on the size of collection and absorption systems will also limit the
degree of impact. Innovative on-site technologies can circumvent site limitations
and may permit development in sensitive areas. Again, the degree of impact will
probably be less than with centralized systems.
1. FLOODPLAINS
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. However, proper erosion and sedimentation control mea-
sures 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.
129
-------
2. WETLANDS
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 anticipated to cause signi-
ficant impacts in wetland areas. Wetland site conditions usually will not permit
any form of on-site waste treatment. Construction 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 character. 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 devel-
opment codes that would prevent development. As a result, dredge and fill may
occur, buffers may be destroyed, and housing construction 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 agricultural 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 environmentally sensitive land such as wetlands,
floodplains, or prime agricultural 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 esti-
mated 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 agricultural 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 III-C-5 Because small waste flows result in more scattered low density residential devel-
opment patterns, this type of technology may result in more agricultural land being
devoted to residential uses. Often, zoning provisions permit higher density devel-
opment in areas provided with centralized wastewater treatment; thus, clustered
development may occur. As an example of this, the Seven Rural Lake EIS's estimated
that 40% more land would be required 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 methe-
moglobinemia 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 addi-
tional decentralized facilities. (40 CFR I49.10(a)).
130
-------
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 development on
steep slope areas. In those communities with significant development pressure this
would occur to a lesser extent with small waste flows systems than with centralized
facilities. Induced development may occur on unstable hillside areas with result-
ing erosion, sedimentation, and thus a probable increase in non-point source pollu-
tion.
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 adja-
cent 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 incor-
porate 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 de-
struction 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 137o of all on-site systems in Region V could be either sewered or
publicly managed under an optimum operation alternative. For these 430,000 systems
TRD X-E the estimated difference in present worths between the two approaches is $1.9
billion, an average of $4,436 per dwelling.
131
-------
Several assumptions on which these estimates were based cannot at present be veri-
fied. However, it is felt that local and state initiatives to improve rural sani-
tation will have more effect on the ultimate savings than will improvements in the
assumptions.
2. COUNTY AND MUNICIPAL GOVERNMENTS
EIS IV-E-1 The economic impacts of the optimum operation alternative will typically be less
severe than the impacts associated with conventional centralized wastewater faci-
lities. The capital costs of small waste flows technologies are less expensive
than the 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 cen-
tralized facilities. 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 alternatLves. Local govern-
ments 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 reduc-
tions but will generally be lower than with properly maintained conventional faci-
lities. As with conventional centralized facilities, operation and maintenance
costs associated with the optimal 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
some administrative costs, due to the increased role of local governments in sys-
tems management under the optimum operation alternative. Because of the flexi-
bility local governments have in the actual design of small flows management agen-
cies, they can match their costs to the actual severity of local water quality pro-
blems .
3. PRESENT PROPERTY OWNERS
EIS IV-E-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% con-
tribution toward planning. Other residents not receiving the subsidy may con-
tribute 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 rela-
tively low.
TRD VIII-B The actual economic burden placed on present property owners may vary from resi-
dence to residence depending on the manner in which capital, operation and main-
tenance, 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. Communi-
ties 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 de-
pending 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 facili-
132
-------
ties. The economic burden may be severe, regardless of income, for owners having
to pay high costs of site limitations.
4.
FUTURE 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 management 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.
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-E-3
D. LAND USE
EIS IV-C-2
TRD XI-A&B
TRD VIII-A
Use of small waste flows technologies in rural areas can have a positive 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. The conventional contractors'
objections to and unfamiliarity with small waste flows technologies may indicate
their inability to compete successfully with local firms. Competition for con-
tracts to construct and provide supplies for small waste flows systems is likely to
come from non-local firms that have established expertise with these technologies.
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 the meeting of Federal contracting regulations,
such as the Davis-Bacon Act, may be more than small rural area firms can handle.
Optimum operation alternatives may affect the amount, rate, and density of devel-
opment 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 require-
ments for new dwellings will probably not change as a result of adopting alterna-
tive on-site treatment technologies; water well-treatment system separation dis-
tances will be retained. 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 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 devel-
opment, and possibly into areas unsuitable for residential development. Multi-
family systems could have a positive impact where higher density planned devel-
opment 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 develop-
ment around lakeshore areas. Other rural areas depending on on-site technology are
also single-family units in small subdivisions or in dispersed low density pat-
terns. 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
133
-------
severely restrict the amount and distribution of developable land in lake areas.
Such restrictions may be counter to local development goals as well. Wastewater
EIS III-C-5 treatment planning offers local municipalities an important chance to save on land
planning concurrently with preparation of a facilities plan. 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.
E. RESIDENT PRIVACY AND INCONVENIENCE
1. INTRUSIONS ON PRIVACY
EIS II1-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 sancti-
ty of private property. The establishment of on-site permit requirements a genera-
tion 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 treat-
ment could be considered one measure of intrusion into people's lives. On this
basis, the optimum operation alternative 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 dwellings, 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 upgrading,
intrusions caused by detailed site analysis and construction will be roughly com-
parable to laying out and installing house sewers. Either could require modifica-
tion of interior plumbing that can be disruptive as well as annoying. Intrusions
resulting from on-site system construction 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, continuing
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 faci-
lities necessary to deal with site limitations; the more complex the facilities,
the more maintenance would be required.
134
-------
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 facili-
ties are not affordable.
135
-------
Chapter VII
Coordination
-------
CHAPTER VII
COORDINATION
List of those sent copy of Draft EIS.
U.S. SENATORS AND REPRESENTATIVES
Senator Allan J. Dixon
Senator Charles H. Percy
Senator Richard G. Lugal
Senator Dan Quayle
Senator Carl Levin
Senator Donald W. Riegle, Jr.
Senator Rudolph E. Boschivthy
Senator David Durenberger
Senator John Glenn
Senator Howard Metzenbaum
Senator Robert W. Kasten, Jr.
Senator William Proxmire
Illinois
Representative Harold Washington
Representative Gus Savage
Representative Martin A. Russo
Representative Edward J. Derwinski
Representative John G. Fary
Representative Henry J. Hyde
Representative Cardiss Collins
Representative Dan Rostenkowski
Representative Sidney R. Yates
Representative John Edward Porter
Representative Frank Annunzio
Representative Philip M. Crane
Representative Robert McClory
Representative John Erlenborn
Representative Tom Corcoran
Representative Lynn Marten
Representative George O'Brien
Representative Robert H. Michel
Representative Thomas F. Railsback
Representative Paul Findley
Representative Edward R. Madigan
Representative Daniel B. Crane
Representative Melvin Price
Representative Paul Simon
Indiana
Representative Adam Benjamin, Jr.
Representative Floyd J. Fithian
Representative John Hiler
Representative Dan Coats
Representative Elwood Hillis
Representative David W. Evans
Representative John T. Myers
Representative H. Joel Deckard
Representative Lee H. Hamilton
Representative Philip R. Sharp
Representative Andrew Jacobs, Jr.
Representative John Conyers, Jr.
Representative Carl D. Pursell
Representative Howard E. Wolpe
Representative Dave A. Stockman
138
-------
Michigan--Continued
Representative Harold S. Sawyer
Representative Jim Dunn
Representative Dale E. Kildee
Representative Bob Traxler
Representative Guy Vander Jagt
Representative Donald J. Albosta
Representative Robert W. 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. Broorafield
Minnesota
Representative Arlen Erdahl
Representative Thomas M. 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 Gardison
Representative Thomas Luken
Representative Tony Hall
Representative Tennyson Guyer
Representative Delbert Latta
Representative Bob McEwen
Representative Clarence J. Brown
Representative Thomas Kindness
Representative Ed Weber
Representative Clarence Miller
Representative William Stanton
Representative Bob Shamansky
Representative Donald Pease
Representative John Seiberling
Representative Chalmers Wylie
Representative Ralph Regula
Representative John M. Ashbrook
Representative Douglas Applegate
Representative Lyle Williams
Representative Mary Rose Oaker
Representative Louis Stokes
Representative Dennis Eckart
Representative Ron Mottl
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.
139
-------
FEDERAL AGENCIES
Council on Environmental Quality
Department of Agricultural
Department of Commerce
Department of Health, Education, and Welfare
Department of Housing and Urban Development
Department of the Interior
U.S. Fish & Wildlife Service
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 Resources
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
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
140
-------
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 Energy
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.
141
-------
LIST OF PREPARERS
This 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 Docu-
ments 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 D. Hagarty
Environmental Engineer
Wu-Seng Lung
Highest Degree
M.S. Environmental Science
Registered Sanitarian
Draft EIS
I-A-c; II-C,E;
III-A,C,H,L
M.E.M. Environmental Management II-D,F; IV-A-2
M.S., Civil Engineering II-A,B; II1-F
E.I.T, Engineer in Training
PhD., Environmental Engineering
Water Resources Engineer Professional Engineer
M.S., Environmental Health
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
Hydrogeolegist
Gerald D. Lennson
Agricultural Engineer
Jerald D. Hitzemann
Demographer
Mirza H. Meghji
Sanitary Engineer
M.P.A., Environmental Policy
M.S., Environmental Science
M.R.P., Regional Planning
M.S. , Geology
M.S., Agricultural Engineering
M.C.P. , City Planning
PhD., Environmental Engineering
Professional Engineer
III-B,D,E,F,J,K;
V-B.C
III-I; IV-E
IV-A,B,C,F,H;
VI-B.D
Technical Reference
Documents
II-B, D,E,F,G; VII-C;
1X-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
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
II-K, III-B
X-A,B
IV-A; XII-B
-------
Technical Reference
Name Highest Degree Draft EIS Documents
Rhoda Granat M.A., Psychology
Librarian
Melissa Wieland B.A., Biology
Graphics Artist
Stephanie Davis B.A., English
Editor
Catherine Skintik M.A., English
Editor
CLEAN WATER FUND V-A,B; VII-E; XVI-E
Larry J. Silvermand L.L.D
Task Manager
Susan B. Grandis B.A. Legal Studies
Legal Researcher
Edward Hopkins M.A. History and Political Science
-------
INDEX
access considerations, 77-78
by acquisition of deeded rights, 77-78
by owner's permission, 77
by statutory grants of authority, 78
aerial photographic interpretation, 6, 23, 38, 42-43, 95
agency, 208 plans, 92-94, 119
201 plans, 113
agricultural lands, impacts of
proposed action, 130
aquifers, 22
recharge areas, impacts of
proposed action, 130-131
sampling, 80-81
archaeologic and historic sites, 98,
impacts of proposed action, 131
bacterial contamination, 22, 24, 80-81, 101-102, 127-129, 130-131
aquifers 22, 80-81, 130-131
contact waters, 101
drinking water, 101
groundwater, 24, 79-81, 127-128
lake water, 128-129
bids, competitive for on-site
systems, 53-54
black water, black water/gray water, 5, 30, 100, 106, 127, 131
centralized approaches, defined, 3
certification programs, as function
of management agency, 73
Clean Water Act, 4, 36, 67, 77, 84, 91, 114, 119, 123, 134
cluster systems, 49, 52, 55-56, 70, 81, 82, 92, 99, 100, 116, 133
collection systems (see off-site treatment; sewers)
for small scale off-site treatment, 33
for sewers, 33
community management, of small waste flows
systems, 67-86
cost, 82-84
involvement, 74-75
need for, 67-69
program design, 71-74
variances, 75-77
community management models, 69-71
combined management approaches, 70
comprehensive water quality management, 70-71
owner volunteer, 69
status quo alternative, 69
universal community management, 70
Construction Grants:
administration, 112-124
and Davis-Bacon Act, 117
eligibility, 63-64, 112-116
Federal concerns, 112-117
State concerns, 117-121
cost analysis, for small waste flows technologies, 54-63
cost curve analysis, 54, 59-61
cost-effectiveness analysis for small waste flows technologies, 61-62
cost variability study, 54-59
costs:
of conventional collection & treatment systems, 10-12
of on-site systems, 17-18
for homeowners, 62-63
local, defined, 82
local, recovery, 82-84
-------
Davis-Bacoa Act, 117, 133
and Construction Grants Program 117
application of, 117
demography, and facilities planning, 92-98
easements (See access considerations), 77
economic characteristics, of residents, 97-98
economic impacts of facilities planning, 106-109
for residents, 107-108
economic impacts, of proposed action, 131-133
on county and municipal governments, 132
on future owners, 133
on present owners, 132-133
on region, 131
on utility contractors and suppliers, 133
effluent plume, recovery, 31, 45, 75, 79
eligibility, of small waste flows systems, 112-116
for Contruction Grants, 112-116
conventional water use, 113
flow reduction devices, 113-115
needs documentation for alternative sewers, 115
off-site facilities, 116
pilot studies, 115
potential failures, 115
seasonal properties, 112
embayments, 105, 106, 128
empirical relationsnips, data, models, 25, 26, 46, 48, 102
enforcement, as management agency function, 67
environmental factors, 55, 129
environmental constraints, and facilities planning, 55-56, 59, 98-101
environmental impacts:
on collection and treatment facilities, 12-13
on on-site systems, 18, 21-31
on proposed action, 127-135
on sewers, 12-13
eutrophication of lakes, 41, 102-105
evaluation methods, existing on-site systems, 6
facilities planning, 89-109
area boundaries, 89-90
demography, 92-98
economic impacts, 97-98
environmental approach, 90
environmental constraints, 98-101
financial impacts, 106-109
identification, 90
jurisdictional approach, 89-90
and land use, 96, 98-101
mathematical projections, 96
and population estimates, 94-97
public participation, 109
ratio/snare, 96
recreational facilities, 92-94
and second-home development, 92-93
water resources, 101-106
financial impacts, of facilities planning, 106-109
local procurement of goods
and services, 108
for residents, 107-108
financial responsibilities, of management agency, 82-84
fixed film reactors, 35
floodpiains, impact of proposed action, 129
flow reduction devices, 5, 30, 70-71, 79, 113-115
-------
groundwater, 24, 47-48, 79-82, 127-128, 130-131
contamination 9, 22, 24, 25, 127, 130-131
effluents, 31, 45, 75, 79
future work, 127-128
hydrology 16, 17, 24
monitoring, 71-82
problems & solutions, 127
proposed action, consequences, 127-128
sampling, 47-48, 79-81
surveys, 81
historic and archaeologic sites, impacts of proposed action, 117
holding tanks, 31, 83, 84, 116, 132, 135
homeowner cost, average annual, for small waste flows techniques, 62-63
hypothetical relationships, 25, 26
impacts, environmental,
on-site systems 18, 21-31
proposed action, 127-135
sewers, 12-13
impacts, financial, of facilities planning, 106-109
industrial growth, sewers, 124
infiltration, percolation, 34
irrigation, 34
lakes:
bacterial contamination, 102, 128
eutrophication, 45, 102-105
nutrients, 128-129
plant growth, localized, 105-106
water quality, impacts of proposed action, 127-129
land application, 34
land use:
and environmental constraints, 98-101
and facilities planning, 98-101
impacts of proposed action, 133-134
planning, 99-101
treatment, 34-35
leachate, septic:
detection, 6, 38, 43-44, 81, 102
plumes, 102, 105, 131
management agency, 67
management agency personnel, 84-86
management programs:
design, 71-74
implementation, 74
feasibility for wastewater facilities, 72
ownership, of wastewater facilities, 72
public involvement, 74-75
responsibility for performance, 73
responsibility for services, 73-74
revision, 86
user charge structures, 82-83
maps, 41, 43, 48
monitoring, water quality, 79-82
municipal fiscal capabilities, assessment, 106-107
National Eutrophication Survey, 41, 105
National Pollution Discharge Elimination System, 12
nearshore plant surveys, 45
needs documentation:
analysis, 48-49
-------
and Construction Grants, 115
data, collection, 38-45
needs documentation methods, 38-49
aerial photographic interpretation, 42-43
data collection, 38-49
eutrophication modeling, 41, 45
maps, 41
nearshore plant surveys, 45
questionnaires, 44-45
representative samplings, 47-48
sanitary surveys, partial, 46-47
septic leachate detection, 43-44
use of available data, 38-41
windshield surveys, 41
needs documentation policies, 36-37
national, 36
Region V, 36
nitrates,
contamination, 22, 24, 30, 127, 128, 130
sampling, 80-81
non-point source, monitoring, 81, 105, 106, 129
nonsewer development constraints, 98-99
off-site treatment, small scale, 31-35
collection systems, 33
for Construction Grants Administration, 116
land treatment options, 34
septage disposal, 31-33
surface water discharge options, 35
treatment methods, 33-34
wetland systems, 35
on-site systems
community involvement, 68-69
costs, 13-14
evaluation methods, 6
failures (see on-site system failures)
history, 9
impacts, 18
noncomplying, 25
options available, 25-26, 27
options for difficult systems, 30-31
performance data, 6-7, 10
in Region V, 21
site analysis, 26
soils data, 25-26
technology selection, 26-30
types, 21
on-site systems failures, 21-25
contamination, 24
causes, 24
effects, 25
frequency, 22-24
survey, sampling, 51
types, 21-22
optimum operation alternatives, 49-54
alternative description, 51-52
bid documents, 53-54
cost analysis 51
designing, 52-53
and proposed action, 52
segment delineation, 50
systems selection 51
technology assumptions, 50-51
-------
performance data for on-site systems, collection, 6-7
performance of on-site systems, 5-6, 12
phosphorus loading to lakes,
photographic studies, aerial, 6, 23, 38, 42-43, 95
pilot studies,
eligibility for Construction Grants, 115
plumbing backup and codes, 23-24, 78-79
plant growth, localized, 105-106
population estimates, 93, 94-96
methodologies, 95-95
permanent & seasonal, 94, 112
present worth savings, proposed action, 131-132
proposed action, consequences, 127-135
on agricultural land, 130
on aquifer recharge areas, 130-131
economic impacts, 131-133
environmental, 127
on environmentally sensitive areas, 129-131
on floodplains, 129
future work, 127-128
governments, 132
on historic & archaeologic sites, 131
on land use, 133-134
present and future owners, 132-133
on rare & endangered species, 131
on resident privacy, 134-135
social, 127
on steep slopes, 131
suppliers, 133-134
water quality impacts, 127-129
on water use restrictions, 135
on wetlands, 130
prosecution, as reason for improving wastewater facilities, 123
public participation in facilities planning, 109
public participation in wastewater facilities, 8-9
rare & endangered species, impacts of proposed actions, 131
recreational facilities planning, 92-93
representative sampling, 47-51
resident privacy & inconvenience, impacts of proposed actions, 134-135
residential development, 123
residential economic characteristics, 97
restrictions on water use, 113, 135
reuse/recycle of treated wastewater, 31
rural population, definition, 14
sanitary codes, 99-100, 133
sanitary survey, 23, 46-47, 51
partial, 38, 45, 46-47, 51
seasonal properties, 94, 112
second-home, development, 92-93
segments, use of in facilities planning, 64
septage, disposal, 31-33
septic leachate, 6, 38, 43-44, 81, 109
septic systems, 9, 17, 18, 21, 29, 45, 47, 83, 100, 102, 113, 130
sewers:
alternative, eligibility for Construction Grants, 112-117
costs, 10-12, 13-14
drawbacks, 10-13
economic impacts, 13-14
environmental impacts, 12-13
-------
performance, 12
types, 33, 115
small waste flows:
approach, 123-124
facilities, 5-6
history, 9
planning & land use, 85-86, 99-101
technologies, 3, 21-64
soils data, 25-26
soils maps, 41
state grant & technical assistance, Construction Grants Administration, 119-121
circuit rider model, 120
contractor assistance model, 120-121
Maryland model, 120
New Hampshire model, 120
state planning activities:
for Construction Grants Administration, 118-119
for small communities, 118-119
state staffing, 121
steep slopes, impacts of proposed action, 131
surface drainage, 6
surface failures, 24, 25
surface waters discharges, 33, 35
surveys, 46-47, 51
system design, 5
as management agency function, 71-72
system maintenance, 5
system ownership & liability, 72
systems selection, 51
system usage, 5
training programs, as function of Construction Grants Agency, 121-123
treatment methods, small-scale
off-site systems, 31-35
land application, 34
surface water discharge, 34
wetland discharge, 34
unincorporated places, defined, 14
urban population, defined, 14
user charge systems, 14,-15, 52, 82-83
variances, 75-77
waste stream, segregation of, 30
wastewater management, role of state, 8
public agencies, 84
wastewater treatment technologies, off-site, 33
water conservation programs, 78-79
water, contamination, 9, 22, 24, 25, 101-104, 105
water quality impacts of proposed action, 127-129
water resources, 101-106
bacterial contamination, 101-102
eutrophication, 102
localized plant growth, 105-106
water use, 113, 135
wetlands, impacts of proposed actions, 34
windshield surveys, 41, 95
-------
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 Environmental 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
groundwater 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
treatment plant operations. Referenced in "Improving compliance of existing
municipal Wastewater treatment facilities," a preliminary concept paper pre-
pared 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. Environ-
mental 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 norunetropolitan
living: Evaluation, behaviors, and expectations of northern Michigan resi-
dents. 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 re-
creational 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 treat-
ment. 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
treatment: An engineering assessment. Draft, University of California, Davis
CA, and Gulp, 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. Govern-
ment Printing Office, Washington, D.C.
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 Preser-
vation. 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. I976a. Land treatment of municipal waste-
water 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. ]977a. Alternatives for small wastewater
treatment systems. Vol. 1: On-sitc 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. I978a. 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 tech-
nology assessment manual. EPA-430/7-78-009. Office of Water Program Opera-
tions. U.S. Government Printing Office, Washington B.C., variously paged.
U.S. Environmental Protection Agency. 1980d. Options for third-party management
of Construction 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 ,
251p.
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 .
-------
APPENDIX A
EPA REGION V GUIDANCE -
SITE SPECIFIC NEEDS DETERMINATION and
ALTERNATIVE PLANNING FOR UNSEWERED AREAS
-------
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 instal-led 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
-------
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
-------
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
arid 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 grounawater 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 ori-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
-------
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
-------
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
-------
(M
4>
^
(M
-------
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, rodding 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 and
affected parties.
The requirement for consulting with the public set forth in 40 CFR
35.917-5(b)(5) will be considered satisfied if questionnaires are
submitted by individuals on the "mailing list."
A-ll
-------
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.
A-12
-------
APPENDIX B
ON-SITE SANITARY INSPECTION FORM
-------
SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
Resident: Study Area:
Owner: Surveyor/Date:
Address of Weather:
Property:
Lot Location: Approximate Lot Dimensions:
Tax Map Designation: feet by feet
Preliminary Resident Interview
Age of Dwelling: years Age of sewage disposal system: years
Type of Sewage Disposal System:
Maintenance: years since septic tank pumped. Reason for pumping:
years since sewage system repairs (Describe below)
Accessibility of septic tank manholes (Describe below)
Dwelling Use: Number of Bedrooms: actual, potential, Planned
Permanent Residents: adults, children
Seasonal Residents: , length of stay
Typical Number of Guests: , length of stay
If seasonal only, plan to become permanent residents: In how many years?
Water Using Fixtures (Note "w.c." if designed to conserve water):
Shower Heads Kitchen Lavoratories Clothes Washing Machine
Bathtubs Garbage Grinder Water Softener
Bathroom Lavoratories Dishwasher Utility Sink
Toilets Other Kitchen Other Utilities
Plans for Changes:
Problems Recognized by Resident:
Resident Will Allow Follow-Up Engineering Studies: Soil Borings Groundwater
Well Water Sample
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
Salvage
Values
Present
Worth
User
Charges
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 (l/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 @ $325/day - 51 days/yr. (% day rentals -
see cost calculations
50 year useful life for ST's; 20 years for all else
6 5/8%, 20 years
Eligibility - 100% of site analysis and replacement system charge
Federal funding - 85% of site analysis; replacements
State funding - 6% of these items
Debt retirement - 6 7/8%, 30 years, 1980 capital
Debt reserve - 20% of debt retirement
Alternative Costs
Existing Systems:
Replace 2086 ST's
Replace 417 ST-SAS's
Pump 1043 ST's/yr.
H0 83 DF's/yr.
($
Capital
Costs
552.8
782.7
-0-
-0-
1,335.5
x 1000)
O&M
Costs
-0-
-0-
62.58/yr.
33.20/yr.
95.78/yr.
Salvage
Value
Future systems:
Add 2025 ST-SAS's
190.05/yr.
190.05/yr.
1.52/yr./yr. 429.3
1.52/yr./yr. 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/958 (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 Add 389 access pipes to ST's
Replace 525 ST's
Add 25 flow reductions + dosed SM's
176 Cesspools 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
73 HT'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)
Labor 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)
Future Systems*
Operation &
Maintenance
(O&M) Costs
$
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
Salaries
Costs
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.
$25,000/yr Sanitarian's
$12,000/yr Secretary's
$12,000/yr surveyor's
$325/day Soil Scientists
Capital
Item Costs
+20% fringe benefits
($ x 1,000)
O&M*
Costs
Salvage
Value
Existing Systems:
389 ST/SAS's - Add Hatches 38.9
524 ST/SAS's - Replace ST's 235.8
25 ST/SAS's - Add Flow Redl, SM's 235.3
71 Cesspools - ST/SAS's 90.2
35 Cesspools - ST/shallow DF's 44.4
35 Cesspools - ST/dosed sh. DF's 114.5
35 Cesspools - ST/dosed SM's 309.8
13 HT's - Add Flow Reduction 13.1
8 HT's - Add Flow Reduction +
ST/Shallow DF 18.2
26 HT's - Add Flow Reduction +
ST/dosed shallow DF 111.3
26 HT's - Add Flow Reduction +
ST/dosed SM 256.4
81 EDU ST/Cluster Systems 426.2
Subtotal 1,894.1
Future Systems:
361 ST/SAS's 22.92/yr
115 ST/dosed shallow DF's 18.80/yr
114 ST/dosed SM's 50.44/yr
46 EDU ST/Cluster Systems 12.30/yr
Subtotal 104.5/yr
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
130.0
41.4
41.0
97.7
310.1
* 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 @ $300/mo x 12
Office supplies, telephone, etc.
Van lease, gas & oil
Small motorboat - 4 wks/yr
Subtotal
-0-
-0-
-0-
-0-
-0-
-0-
25.00/yr
5.54/yr
6.00/yr
36.54/yr
7.31/yr
43.85/yr
-0
-0-
-0
-0
-0-
-0
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
4.88/yr -0-
2.50/yr -0-
0.05/yr/yr -0-
2.25/yr -0-
4.75.yr -0-
0.05/yr/yr
3.60/yr
2.00/yr
6.00/yr
0.40/yr
12.00/yr
-0-
-0-
-0-
-0-
-0-
E&A Costs:
Contingencies - 9% of 1980 costs
Site Analysis
Cluster System Design*
170.5
431.3
70.0
671.8
-0-
-0-
-0-
-0-
-0-
-0-
-0-
-0-
Total - As of 1980
- Increment 1980 - 2000
Present Worth
2565.9
104.5/yr
105.4/yr 396.3
1.27/yr/yr 310.1
($ 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 1/8%
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 -r 4/person/day)
person-days (47 businesses and resorts 4- 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 -r 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
Step 4--
Disposal unit
inspection
Step 5--
Well water
Meters
364
364
40
243
283
44
44
person-days (60% x 1,214 systems -f 4/2 persons/day)
person-days (soil scientist 189, surveyor 175)
person-days (13% x 938 systems -r 3/supervisor/day)
person-days (13% x 938 systems -r \ persons/day)
person-days (Sanitarian 40, laborers 243)
person-days (15% x 1,181 wells
inspections/person/day)
person-days (Surveyor 44)
x 6 inspections -r 24
Total number of systems minus number of septic systems (107) certified
according to the County Office of Land & Water Resource permits minus
number of other problem systems.
D-6
-------
Additional costs - Meter installation @ $175/meter x 177
Step 6—
Shallow
Groundwater
Sampling
20 person-days (10 days x 2 persons for scan)
80 person-days (80 plumes T 2 plumes/day x 2 persons)
100 person-days (Sanitarian 25, W.Q. Scientist 50,
Surveyor 25)
Additional cost - Nutrient analyses @ $15/series x 5/plumes
x 80 plumes
Step 7-- 40
Shore ground- 40
water hydro-
logy survey
Step 8-- 260
Supervision,
documentation,
clerical
Labor Summary
Sanitarian
Sr. Engineer
Jr. Engineer
Soil Scientist
W.Q. Scientist
Surveyors
Laborers
Secretary
OTCDLRM* Costs
Salaries
person-days (5 days/survey x 2 persons x 4 surveys)
person-days (Sanitarian 20, W.Q. Scientist 5,
Surveyor 15)
Work-days (Sanitarian @ 100% including above time,
Sr. Engineer @ 25% + 20 days to prepare report,
Secretary @ 100%)
Person-Days Per Step
123
23
23
23 150
13 189
21
205 175
308 150 364
Sanitarian @ $25,000/yr
Surveyors @ $ll,000/yr 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 Costs—Continued
Service Contracts
Equipment &
Sampling
Summary
Consultant Costs
Direct Labor
Other Direct
Costs
Travel
Summary
Total Costs
OTCDLRM
Consultant
Well sample analysis @ $5/sample x 1,181 $ 5,905
Septic tank inspection - $450/day x 150 67,500
- $20/tank x 900 18,000
Well water meters @ $175/meter x 177 30,975
Plume sample analyses @ $15 x 5 x 80 6,000
Fluorescent meter $14,000
Groundwater flow meter 4,000
Field sampling equipment 2,000
Paper supplies 2,000
Cameras & film for documentation 3,000
2 vans @ ($350/mo + $120 gas-oil/mo) x 12 11,280
Salaries $ 81,414
Rent 3,600
Contracts 128,380
Equipment & Supplies 36,280
Total OTCDLRM $249,674
Sr. Engineer @ $35,000/yr x 85 days $11,440
Jr. Engineer @ $20,000/yr x 173 days 13,310
Soil Scientist @ 25,000/yr x 202 days 19,420
W.Q. Scientist @ 25,000/yr x 76 days 7,310
$51,480
Report & Reproduction 150
Communication 1,000
Graphics, report preparation 1,500
$27650
House rental for office, sleeping x 12 mo's 6,000
Other per diem @ $20/day x 536" 10,720
65 RT x 250 miles x $0.20/mile 3,250
$19,970
Direct labor x 3.0
Other direct costs x 1.2
Travel x 1.2
Total consultant
Total
154,440
3,180
23,964
$181,584
$249,674
181,584
$431,258
* Assuming that the consultants work 5 days/week.
D-8
U.S. Government Printing Office: 1981/752-512
------- |