United States
Environmental Protection
Agency
6fh and Walnut Streets
Philadelphia, PA 19106
May 1980
PA
Final Environmental
r
903R80004
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v'/EPA
United States ,
Environmental Protection
Agency
,f__ELegion 3
6fh and Walnut Streets
Philadelphia, PA 19106
May 1980
_. . _ . . i 903R80004
Final Environmental
Impact Statement
Horsham-Warminster-
Warrington, Pennsylvania
Wastewater Treatment
Facilities
Region I!! Library
EMkinmtntal Protection Agency
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION III
6TH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
MAY ?
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement (EIS)
prepared by the U.S. Environmental Protection Agency (EPA) in conjunction
with wastewater treatment facilities plans and applications for Federal
construction grants jointly submitted by the Horsham Township Sewer
Authority, Montgomery County; Warrington Township Municipal Authority, Bucks
County; and the Warminster Township Municipal Authority, Bucks County within
the Commonwealth of Pennsylvania.
Pursuant to the National Environmental Policy Act of 1969 and regulations
promulgated by this Agency (40 CFR Part 6, November 6, 1979), this Final EIS
is submitted for your review. Comments or inquiries concerning this EIS
should be submitted to the above address, attention of the EIS Preparation
Section, by June 16, 1980.
EPA has determined that two alternatives are eligible for Federal funding.
The Agency's preferred project (Alternative 3) consists of the conveyance of
Horsham1s flows through Lower Gwynedd Township to the Ambler sewage treat-
ment plant (STP) and the use of community systems for Horsham Township.
EPA's second choice (Alternative 2) for funding eligibility would send the
flow from specific subareas in Horsham Township for treatment at the Ambler
STP. Either alternative endorses the same approach for the Warrington-
Warminister portion of the planning area; namely, the conveyance of waste-
water from Warrington Township via the Little Neshaminy interceptor to
Warminster STP. The Warminster STP would accordingly be expanded and
upgraded, if necessary, to treat this additional flow.
I wish to thank each applicant for the assistance they have provided to
EPA's staff during this EIS process. In addition, I wish to commend the
performance of the Central Contacts Committee which supplied guidance to EPA
on important technical decisions involving the evaluation of alternatives
for the planning area. Finally, I want to especially recognize the interest
demonstrated by the area's citizens. Their participation throughout this
EIS Process has greatly contributed to the development of acceptable solu-
tions to the sewage problems of the participating municipalities.
A public meeting regarding the Final EIS will be held on May 29, 1980 at
7:30 p.m. in the Keith Valley Middle School. Both the public and represent-
atives of organizations are encouraged to attend and expresss their comments
and opinions on EPA's recommendations.
Sincerely^y'qjurs,
A xftA -I If U.S. EPA Region III
cr^JllflKik - /' |t<, - Regional Center for Environmental
Jack J. Schramm Information
Regional Administrator 1650 Arch Street (3PM52)
Philadelphia, PA 19103
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FINAL ENVIRONMENTAL IMPACT STATEMENT
on
HORSHAM-WARMINSTER-WARRINGTON, PENNSYLVANIA
WASTEWATER TREATMENT FACILITIES
Prepared by
US Environmental Protection Agency
Region III
Philadelphia, Pennsylvania
Richard V. Pepino, Project Monitor
D. Jeffrey Barnett, Assistant Project Monitor
Prepared with the assistance of
WAPORA, Inc.
Berwyn, Pennsylvania
Robert A. Scott, Project Manager
Type of Action:
Legislative ( )
Administrative (x)
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SUMMARY
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The following Executive Summary is prepared to focus the reader's attention
on vital issues addressed by the Final Environmental Impact Statement (EIS).
The topics previewed in this summary merely highlight the more detailed
discussions presented in the Final EIS.
We encourage the reader not to formulate conclusions based on the Executive
Summary, but rather to read the expanded text in order to establish a sound
rationale for consideration of the recommended alternatives presented in the
Final EIS.
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EXECUTIVE SUMMARY
Grant Applications
Draft EIS
This Final Environmental Impact Statement (EIS) has been prepared by the US
Environmental Protection Agency (US-EPA). The Final EIS concerns applications
submitted to US-EPA for Federal wastewater treatment construction grants by the
following municipal authorities in the Commonwealth of Pennsylvania:
The Township of Horsham Sewer Authority
Warrington Township Municipal Authority
Warminster Township Municipal Authority
Federal funds were requested by the grant applicants for construction of a
regional interceptor and collector sewer system for areas primarily within the
Townships of Horsham, Warrington, and Warminster as well as for expansion of
the treatment capacity of the existing municipal sewage treatment plant in
Warminster Township.
On September 12, 1979 a Draft EIS on this project was issued by US-EPA. The
Draft EIS presented five alternative wastewater management systems which
incorporated elements of the applicants' proposed system as well as alternative
approaches for resolving wastewater treatment problems. The following chart
summarizes centralized and decentralized approaches, described in the Draft
EIS, which are suggested to satisfy Horsham Township's wastewater management
needs. Figure A indicates the division of the planning area into subareas.
Alternative
Centralized
Treatment
subareas 4,5,7 and
8 to Warminster STP
via Park Creek
interceptor
subareas 4,5,7, and
8 to Ambler STP via
force main and lift
station and conveyance
through Lower Gwynedd
Township
subareas 7 and 8 to
Ambler STP via force
main and lift station
and conveyance through
Lower Gwynedd Township
same as Alternative #3
construction of a 0.5
mgd tertiary treatment
discharging to Park Creek
at a point south of
Willow Grove NAS
Decentralized
Treatment
none
none
subareas 4 and 5 to
have community subsur-
face disposal systems
subareas 4 and 5 have
individual systems
none
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PLAMNMC AREA MUNOAMY
3UMMCA BOUNDARY
FIGURE A
SUBAREAS IN PLANNING AREA
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For Warrington and Warminster Townships, Alternatives 1 through 5 are basically
identical. Wastewater flows are proposed to be conveyed from Warrington
Township via the Little Neshaminy Interceptor for treatment at the Warminster
STP, which is proposed to have its treatment capacity expanded.
A primary purpose of the Draft EIS was to identify wastewater management
solutions which were implementable, cost-effective, environmentally sound, and
grant eligible. The Draft EIS made no specific recommendations concerning
preferred alternatives. Instead probable adverse and beneficial effects of
each approach were identified as well as the costs expected to be incurred.
Comments on Draft EIS
Written comments on the Draft EIS were received by US-EPA during a public
commenting period from September 12, 1979 to November 12, 1979. In addition,
oral testimony on the Draft EIS was received at the Public Hearing held on
October 23, 1979. Comments on the Draft EIS included questions, new
information, recommendations for improvements to the document and
recommendations for selecting alternatives. A total of 24 issues were raised
by governmental agencies or the public during the commenting period. The Final
EIS responds to each issue in detail. Among these issues, US-EPA considers the
following to be the most critical:
Key Comments
What effluent limitations will the PA Department of Environmental Resources
(PA-DER) require for the Warminster sewage treatment plant as well as for
plants which might discharge to the Park Creek in Horsham Township?
In estimating costs for alternative systems, did US-EPA account for initial
assessments to homeowners and other users, as well as capital contributions
from the Horsham Sewer Authority to the Lower Gwynedd Township Municipal
Authority?
In estimating costs for alternative systems, did US-EPA account for costs of
land acquisition and system maintenance?
Three of the alternatives presented by US-EPA require the conveyance of
wastewater from Horsham Township through Lower Gwynedd Township conveyance
systems to the Ambler STP. What is the capacity available to the Horsham
Sewer Authority in the Lower Gwynedd and Ambler systems?
t Two alternatives presented by US-EPA include the use of individual and
cluster treatment systems in subareas 4 and 5 in Horsham Township. What are
the necessary responsibilities of the management agency and homeowner in the
successful operation of such systems?
In both Warrington and Warminster Townships, infiltration and inflow to
existing wastewater collection systems is considered by the municipalities
and PA-DER to be excessive. What is the extent to which infiltration and
inflow can be reduced by the respective authorities and what effect will
this reduction have on the sizing and costs of the proposed expansion to the
Warminster STP?
The Wichard Sewer Company has received a Certificate of Public Convenience
from the Pennsylvania Public Utility Commission to provide wastewater
treatment services to the proposed Country Springs development in Horsham
Township. The Wichard Sewer Company also has received an NPDES permit from
PA-DER to discharge its effluent to the Park Creek. In light of these
actions by the Commonwealth of PA, what effect does the Wichard Sewer
Company proposal have on the alternatives presented by US-EPA?
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Final Evaluation of In the Final EIS, US-EPA evaluated the alternative wastewater management
Alternatives approaches with consideration given to individual and cumulative environmental
effects, public and governmental agency preferences, cost-effectiveness, and
potential for successful implementation.
As reported in the Draft EIS, the most adverse environmental effects of a
severe nature are associated with Alternatives 1 and 5. The most beneficial
environmental effects are associated with Alternatives 3, 4, and 2, in that
order. As reported in the Final EIS, public comments involving environmental
impacts centered upon these specific effects:
floodplain encroachment
availability of water supplies
erosion and sedimentation
loss of prime farmland.
After responding to public comments concerning environmental impacts of the
alternatives, the following clarification emerged. Alternatives 1 and 5
continued to be associated with the most adverse effects. Further examination
of potential floodplain encroachment (both primary and secondary impacts)
reinforced the probability of adverse effects of these two alternatives,
particularly in subareas 4 and 5 in Horsham Township.
Of the government agencies which have commented on the Draft EIS, only four
agencies registered specific preferences on the selection of alternative
systems. The four agencies included the US Department of the Navy, PA
Department of Environmental Resources, Delaware Valley Regional Planning
Commission, and Montgomery County Planning Commission.
The US Department of the Navy recommends adoption of either Alternative 3 or 4.
This conclusion was reached "in keeping with the findings of the DEIS, the
goals and objectives of the Navy's Air Installation Compatible Use Zone (AICUZ)
Plan, Federal guidelines, notably the General Services Administration's Federal
Management Circular 75-2, and the Horsham Township Land Management Plan"
(Department of the Navy, 1979). The Navy could not support Alternative 1 due
to its inducement for development in highly sensitive areas around the Naval
Air Station. Similarly, Alternative 5 would also induce growth in the vicinity
of the Naval Air Station, although to a somewhat lesser degree than Alternative
1.
PA-DER is willing to support Alternatives 3, 2, and 4, in that order. The
PA-DER found Alternative 1 to be unacceptable because of its adverse impacts
and Alternative 5 to be too costly.
The Delaware Valley Regional Planning Commission endorsed Alternatives 2, 3,
and 4, stating that these alternatives best fulfill the requirements of the
Federal Clean Water Act, the Pennsylvania Clean Streams Law, COWAMP/208, and
county and local plans. Alternatives 1 and 5 could not be supported by DVRPC
due to adverse environmental impacts and high cost.
Finally, the Montgomery County Planning Commission recommended selection of
Alternatives 3 or 4 as the most cost/beneficial with least environmental
impacts. According to the Planning Commission, these alternatives would be
most consistent with Township comprehensive planning and zoning; could provide
up to 85% Federal funding on alternative systems; and would solve the problems
in a manner consistent with environmental and land use planning goals.
Alternative 1 was described as a clearly unacceptable proposal; Alternatives 2
and 5 are considered potentially viable alternatives, but their environmental
impacts and the possible inducement of growth in the more rural portions of
Horsham Township make them less desirable alternatives.
IV
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Elimination of
Alternatives 1, 4, 5,
and 6
Endorsement of
Alternatives 2 and 3
Based on environmental impact comparisons, public input, and government agency
preferences, US-EPA eliminated Alternatives 1, 4, 5, and 6 from funding
consideration. Potential adverse environmental effects on prime agricultural
land, floodplains, forestland, wildlife habitats, aesthetic values, and
historic properties were most significant for Alternative 1, followed by
Alternative 5. Alternative 4 proposed the use of conventional and alternative
on-lot disposal systems for subareas 4 and 5 in Horsham Township. This
alternative was not supported by PA-DER, which questioned the use of holding
tanks on a long-term basis for lots unsuitable for septic tank-soil absorption
systems and sand mound-soil absorption systems. Although this alternative
ranked very high in terms of beneficial environmental effects, its lack of
support by the State was grounds for its elimination as a fundable
alternative.
Finally, Alternative 6 (no-action) was rejected by US-EPA because the
immediate need for suitable wastewater services in the planning area outweighed
any environmental benefits of postponing or rejecting all solutions.
US-EPA has determined that both Alternatives 2 and 3 are eligible for Federal
funding. Alternative 3 requires the conveyance of flows from subareas 7 and 8
through Lower Gwynedd Township to the Ambler STP; subareas 4 and 5 are proposed
to be serviced through community subsurface disposal systems. The use of
community systems in subareas 4 and 5 is considered to have minimal adverse
environmental effects, to be in conformance with municipal growth management
objectives, and to be supported by the US Navy. This wastewater management
approach is relatively new and as an alternative technology is eligible for 85%
Federal funding.
Alternative 2 also is endorsed and recommended by US-EPA as an eligible
alternative. However, this recommendation earmarks this alternative as the
Agency's second choice behind Alternative 3. The recommendation of this
alternative enables the Horsham Sewer Authority to have options in seeking an
implementable wastewater service solution for the Park Creek area. Alternative
2 may have adverse effects in subareas 4 and 5 in terms of the induced
conversion of undeveloped land to developed uses and marginal conformity with
growth management objectives of Horsham Township. These effects are judged to
be less severe than adverse effects projected under Alternatives 1 and 5 for
subareas 4 and 5. US-EPA recommends that the Horsham Township Council,
Planning Commission, and Sewer Authority carefully consider the ramification of
its choice of alternative system with respect to previously adopted growth
management objectives for this area.
For Harrington and Warminster Townships, their original proposal for conveyance
of wastewater from Warrington via the Little Neshaminy interceptor to the
Warminster STP (to be expanded) is fully endorsed by US-EPA for Federal
funding.
Funding of Alternatives
The responsibility for final decisionmaking on funding eligibility rests with
the US-EPA Regional Administrator. Following the close of the comment period
on the Final EIS, US-EPA will prepare a formal Record of Decision which will be
distributed to the public. This Record will set forth the conclusions of the
EIS process, the decisions made by US-EPA on the funding of alternatives, and
the actions to be undertaken by the grant applicants.
Final Public Meeting
A final public meeting to discuss the recommendations presented in the Final
EIS will be held in the planning area approximately thirty days after issuance
of this document. The site of the meeting will be the Keith Valley Middle
School in Horsham Township.
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Page
TABLE OF Executive Summary i
CONTENTS Table of Contents vii
List of Tables viii
List of Figures viii
List of Acronyms and Abbreviations ix
I Introduction 1
II Summary of Draft EIS 3
III Public and Agency Comments on Draft EIS 19
IV Final Evaluation of Alternatives 45
V Option Areas 51
VI Implementation of Recommended Alternatives 53
VII Public Participation 57
Final EIS Mailing List 59
Bibliography 65
Appendices
A Draft EIS A-l
B Comment Letters B-l
C Costs of Alternatives C-l
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LIST OF
TABLES
Page
2-1 Alternative wastewater management approaches proposed for
the planning area 6
2-2 Summary of adverse environmental effects 13
2-3 Summary of beneficial environmental effects 16
3-1 Comments on existing conditions and background information 20
3-2 Comments on the formulation of alternatives 21
3-3 Comments on environmental impacts 22
3-4 Year 2000 average design flow of subareas in Horsham Township,
with and without the Country Springs Development 25
3-5 Criteria for suitability of soils for slow rate land
application 28
3-6 Neshaminy "C" effluent limitations 29
3-7 Direct and indirect costs of a community treatment system 37
3-8 Comparison of Draft EIS population projections and Neshaminy
Creek Watershed project population projections 43
4-1 Comparison of costs for Alternatives 2 and 3, Horsham Township
share 47
4-2 Costs of Alternatives 2 and 3 for Warrington and Warminster
Township 48
4-3 Incremental costs (OOO's) of adding dechlorination and
denitrification facilities to the Warminster STP, apportioned
by municipality 49
LIST OF
FIGURES
2-1 Subareas
2-2 Alternative 1
2-3 Alternative 2
2-4 Alternative 3
2-5 Alternative 4
2-6 Alternative 5
3-1 Lower Gwynedd Township Municipal Authority wastewater
conveyance system
3-2 Community wastewater treatment system
3-3 Pump station and force main conveying wastewater to Upper
Moreland-Hatboro treatment system
5
7
8
9
10
11
32
35
38
vii 1
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LIST OF ACRONYMS
AND ABBREVIATIONS
AICUZ Air Installation Compatibility Use Zone
BCPC Bucks County Planning Commission
BOD Biochemical oxygen demand
CFR Code of Federal Regulations
CWA The Clean Water Act, also known as the Federal
Water Pollution Control Act, PL92-500, as amended
DEIS Draft Environmental Impact Statement
DRBC Delaware River Basin Commission
DVRPC Delaware Valley Regional Planning Commission
EIS Environmental Impact Statement
FEIS Final Environmental Impact Statement
FR Federal Register
FWPCA See CWA
GPCPD Gallons per capita per day
GPD Gallons per day
HC Hydrocarbons
I/I Infiltration/Inflow
MCPC Montgomery County Planning Commission
MGD Million gallons per day
MLD Million liters per day
NADC Naval Air Development Center
NAS Naval Air Station
NEPA National Environmental Policy Act of 1969
NPDES National Pollutant Discharge Elimination System
PA-DER Pennsylvania Department of Environmental Resources
PL Public Law (of the United States)
STP Sewage treatment plant
USC United States Code
USDA-SCS United States Department of Agriculture - Soil
Conservation Service
US-DOC United States Department of Commerce
US-EPA United States Environmental Protection Agency
US-HEW United States Department of Health, Education and
Welfare
US-HUD United States Department of Housing and Urban
Development
1x
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CHAPTER I
Introduction
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CHAPTER I This Final Environmental Impact Statement (EIS) has been prepared in
INTRODUCTION conjunction with wastewater facilities plans and applications for Federal
construction grants submitted to the US Environmental Protection Agency
(US-EPA) by the following municipal authorities in the Commonwealth of
Pennsylvania:
The Township of Horsham Sewer Authority, Montgomery County PA
(Grant Application No. 420880)
t Warrington Township Municipal Authority, Bucks County PA
(Grant Application No. 420881)
Warminster Township Municipal Authority, Bucks County PA
(Grant Application No. 421062)
The three grant applicants requested Federal funds to construct a regional
interceptor and collector sewer system for areas primarily within the Townships
of Horsham, Warrington, and Warminster, and also to expand the treatment
capacity of an existing sewage treatment plant (STP) in Warminster Township.
On January 13, 1978 US-EPA issued a Notice of Intent to prepare an EIS with
regard to these construction grant applications.
The decision to prepare the EIS was made in accordance with the National
Environmental Policy Act (NEPA) and US-EPA regulations governing EIS
preparation for wastewater facilities (40 CFR, Chapter I, Part 6). In March
1978, US-EPA initiated the EIS process by beginning preparation of a Draft EIS.
This document was distributed to the public and government agencies on
September 12, 1979. The Draft EIS is summarized in Section 2.0. of this Final
EIS. Aside from that summation, the contents of the Draft EIS is not repeated
in this document, but is included by reference as Appendix A. When necessary,
contents of the Draft EIS are herein referred to by page (i.e. DEIS, 4-2). The
Draft EIS is available for review at local and county libraries and municipal
offices. Copies of the Draft EIS have been distributed to 19 Federal agencies,
7 State agencies, 11 Federal and State elected officials, 45 local government
agencies, 26 environmental interest groups, 98 citizens, and numerous other
individuals and organizations.
A public hearing on the Draft EIS was conducted by US-EPA at the Keith Valley
Middle School in Horsham Township on October 23, 1979, at which time local and
county officials and other interested parties presented their comments and
recommendations concerning this project. Written comments also were received
by US-EPA during a public commenting period that commenced with the
distribution of the Draft EIS (September 12, 1979) and ended on November 12,
1979. Public and Agency comments on the Draft EIS are presented and addressed
in Chapter III of this document.
The primary purpose of the Final EIS is to evaluate and address questions,
comments, and recommendations received during the commenting period. By doing
so, the critical issues concerning this project are clarified, enabling US-EPA
to present its recommendations on alternatives eligible for funding by the
Agency. The responsibility for final decisionmaking on funding eligibility
rests with the US-EPA Regional Administrator. Following the close of the
comment period on the Final EIS, US-EPA will prepare a formal Record of
Decision which will be distributed to the public. This record will establish
the conclusions of the EIS process, the decisions made by US-EPA on the funding
of alternatives, and the actions to be undertaken by the grant applicants. The
final evaluation of alternatives is presented in Chapter VI of this document.
The Final EIS has two other purposes. First, it provides guidance concerning
wastewater service needs of areas which border the planning area. These areas
were identified in the Draft EIS as option areas, because of their potential
involvement with planning area wastewater management solutions.
Recommendations on the needs of option areas are addressed in Chapter V of this
document.
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Second, the Final EIS provides a program for the successful implementation of
recommended alternatives by the grant applicants, the State, and US-EPA. ,
Questions regarding the delineation of service areas, design capacity of
facilities, funding eligibility, State priority points, anticipated
negotiations, and management responsibilities are addressed in Chapter VI of
this document.
The Final EIS concludes with a summation of the project's public participation
program (Chapter VII) and a summation of final conclusions, recommendations,
and responsibilities (Chapter VIII).
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CHAPTER II
Summary of Draft EIS
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CHAPTER II
SUMMARY OF DRAFT EIS
This section addresses the key assumptions, alternatives, and conclusions of
the Draft EIS.
Assumptions
Assumption 1
Assumption 2
Assumption 3
Assumption 4
Assumption 5
Assumption 6
The Draft EIS addresses applications submitted to US-EPA for funds to construct
interceptor and collector sewer systems that would provide service to developed
and future growth areas through wastewater treatment provided at the Warminster
STP. At the outset of the EIS process US-EPA determined that the three grant
applications did not present a unified, feasible wastewater management system
and that revisions to the proposed system were required. These revisions were
embodied by US-EPA in Alternative 1, which is based on a treatment and
collection system basically similar in design to that orginally proposed by the
applicants but consistent with US-EPA regulations and requirements for facility
planning. In addition to this "revised" proposed action, US-EPA developed and
evaluated a range of additional collection/treatment systems as alternatives.
In total, five alternative wastewater management systems were presented in the
Draft EIS. These alternatives are summarized in the following section.
The Draft EIS was oriented to resolving many issues concerning this project.
Its objective was to identify solutions which are implementable,
cost-effective, environmentally sound, and grant eligible. Because the
document is issue-oriented, numerous assumptions were formulated by US-EPA to
resolve procedural and analytical questions which if left unanswered would have
further complicated and lenthened this decision-making process. The major
assumptions formulated by US-EPA for the Draft EIS are summarized below.
The Draft EIS focused on environmental impacts anticipated in Horsham and
Warrington, because the planned wastewater service areas are situated in
these two Townships
The Draft EIS emphasized the identification of alternative systems to serve
Horsham Township because public controversy had focused on the means for
solving wastewater problems in that area.
Because the grant applicants had invested considerable time and funds in
designing wastewater systems for specific areas of need in their Townships,
US-EPA focused its attention specifically on these same proposed service
areas. The planning area chosen for this Draft EIS represents this focus.
While the Draft EIS incorporated the necessary concepts, guidelines,
regulations, and organization which US-EPA seeks in approved facility plans,
it does not constitute by itself a wastewater facility plan. The primary
purpose of the EIS process is to formulate and recommend alternative actions
which are environmentally sound and which represent cost-effective use of
Federal funds. The grant applicant, in accepting Federal funds, is expected
to conform with EIS guidance as it implements construction grant program
requirements.
t The Draft EIS closely examined and presented both centralized and
decentralized approaches to wastewater treatment in the planning area. This
approach was in accordance with the provisions and intent of the Clean Water
Act of 1977 and other applicable regulations and guidance of US-EPA.
Effluent limitations for the Warminster STP and a Park Creek STP (as
identified in Alternative 5) were assumed to require nitrification and
dechlorination. Although these processes were not proposed originally by
the grant applicants, the possibility for their requirement had been
acknowledged by the Pennsylvania Department of Environmental Resources
(PA-DER) and assumed by US-EPA. Future requirements by PA-DER on
nitrification and dechlorination for discharges to the Little Neshaminy and
Park Creeks are dependent on PA-DER stream evaluation studies that are
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Assumption 7
Assumption 8
Assumption 9
Assumption 10
Assumption 11
currently in progress. While these effluent limitations were assumed in the
Draft EIS, the Final EIS acknowledges the indeterminate status of these
requirements at this time.
The amount of infiltration and inflow (I/I) which can be eliminated from the
existing Harrington and Warminster collection systems has not been
determined by the Warrington and Warminster Township Municipal authorities.
With advice from PA-DER, US-EPA has assumed, for purposes of this EIS, that
50 percent removal of I/I would be accomplished. Only after Sewer System
Evaluation Surveys are completed by the applicants can future I/I reduction
be defined.
Planning area population projections used in the Draft EIS for the
respective municipalities conform with projections established by the
Delaware Valley Regional Planning Commission and PA-DER for the COWAMP/208
areawide water quality management program. This conformance between 201
Facility plan projections and 208 projections is assumed by US-EPA to
satisfy requirements of the Clean Water Act. The municipal population
projections are consistent also with projections of the Montgomery and Bucks
County Planning Commission.
t The Wichard Sewer Company has obtained the necessary State certification and
permits to construct a wastewater treatment facility and to provide service
to the proposed Country Springs residential development in Horsham Township.
The efforts of the Wichard Sewer Company to obtain these approvals were
assumed by US-EPA to be independent and beyond the investigative scope of
the Draft EIS. US-EPA currently assumes that the wastewater service needs
of the Country Springs development will be provided entirely by the Wichard
Sewer Company and not by the Horsham Sewer Authority.
In estimating construction, operation, and maintenance costs for each of the
alternatives presented in the Draft EIS, US-EPA did not account for the
capital contributions or initial assessment charges which property owners
would provide to the respective authorities in exchange for wastewater
treatment services. These contributions were not included because the
amount and probability of their occurrance could not be substantiated by
US-EPA. The issue of capital contributions primarily affects Warrington
Township, in terms of assessments anticipated from new developments, and
Horsham Township, with regard to capital contributions which are required by
Lower Gwynedd Township under alternatives 2, 3, and 4.
US-EPA assumed that the comprehensive plans and growth management plans of
the affected municipalities represented the policies and objectives
practiced and sought by the municipalities in their efforts to guide future
growth. The alternative systems presented by US-EPA in the Draft EIS
therefore were assessed carefully to determine the extent of conformance
with these municipal policies.
Draft EIS Alternatives
The following summary describes the alternatives that were presented in the
Draft EIS. The alternatives are described on a subarea basis. Figure 2-1
illustrates the division of the planning area into subareas. Alternatives 1
through 5 propose conveyance of flows from subareas 1, 2, 3 in Warrington
Township, most of Warminster Township and Ivyland Borough, and part of Warwick
Township to the Warminster STP. However, Alternative 1 proposes the conveyance
of additional flows from Horsham and Upper Dublin Townships to the Warminster
STP and is similar to the system proposed by the grant applicants. With
Alternative 1, the Warminster STP would be expanded by 3.8 mgd to a year 2000
design capacity of 8.4 mgd. Alternatives 2 through 5 would result in expansion
of the Warminster STP from the existing 4.56 mgd to 7.9 mgd design capacity.
Under all alternatives the Warminster STP would be upgraded to provide
facilities for dechlorination and biological nitrification.
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PLANNING AMEA nUNOAKT
SUBAMEA BOUNDARY
FIGURE 2-1
SUBAREAS
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The variety of alternatives available to Horsham Township was a major
consideration addressed by the Draft EIS. The following table summarizes
centralized and decentralized approaches, described in the Draft EIS, which are
suggested to satisfy Horsham's wastewater management needs.
Table 2-1. Alternative wastewater management approaches proposed for the
planning area.
Alternative
Centralized
Treatment
subareas 4,5,7 and
8 to Wanninster STP
via Park Creek inter-
ceptor
subareas 4,5,7, and
8 to Ambler STP via
force main and lift
station and conveyance
through Lower Gwynedd
Township
subareas 7 and 8 to
Ambler STP via force
main and lift station
and conveyance through
Lower Gwynedd Township
same as Alternative #3
construction of a 0.5
mgd tertiary treatment
dischargi ng to Park
Creek at a point south
of Willow Grove NAS
Decentralized
Treatment
None
None
Figure
Reference
2-2
2-3
subareas 4 and 5
to have community
subsurface disposal
systems
subareas 4 and 5 to
have individual
systems
None
2-4
2-5
2-6
Draft EIS Findings
Horsham's subareas 7 and 8 contain the Fox, Oak Terrace, and Hideway Hills
developments which are residential areas containing documented on-site disposal
system failures. Subareas 4 and 5 encompass the Davis Grove Road-Prospectville
area, which also is characterized by malfunctioning on-lot disposal systems.
Alternatives 1 through 5 propose centralized treatment for subarea 9 in Upper
Dublin Township.
If implemented, the alternative wastewater management systems identified in the
Draft EIS would have varying effects upon the existing and future environmental
setting in the planning area. The environmental categories which specifically
were addressed in the Draft EIS include:
land use
population growth
earth resources
water resources
air quality
noise 1evels
socioeconomic conditions
cultural resources
-------
PLANWNS AREA BOUNDARY
COLLECTOR SEWER
INTERCEPTOR SEWER
UPGRADED AW EXPANDED SEWAGE TREATMENT PLANT
| [ EXISTING SERVICE AREA
[ ] PLANNED SERVICE AREA
[ | POTENTIAL FUTURE SERVICE AREA
DIRECTION Of FLOW
FIGURE 2-2
ALTERNATIVE I
-------
\
PLANNING ARE* BOUNDARY
4|( LIFT STATION
UPGRADED AND EXPANDED SEWAfiE TREATMENT PLANT
^ INTERCEPTOR SEWER
COLLECTOR SEWER
___ FORCE MAM
| | EXISTING SERVICE AREA
I | PLANNED SERVICE AREA
f I POTENTIAL FUTURE SERVICE AREA
DIRECTION OF FLO*
FIGURE 2-3
ALTERNATIVE 2
-------
PLANNWM AREA KJUNOARY
| UPORADCD AND EXPANDED TREATMENT PLANT
jfr LIFT STATION
INTERCEPTOR SEWIR
COLLECTOR SEWCR
.._ FORCE MAM
[";."] COMMUNITY SOIL ABSORPTION FIELD
f I EXISTING SERVICE AREA
DIRECTION OF FLOW
^^ PLANNED SERVICE AREA [~ ' | POTENTIAL FUTURE SERVICE AREA 5
RWa PLANNED SERVICE AREA FOR r-J I POTENTIAL FUTURE SERVICE AREA F|(
E -'«' COMMUNITV SOIL AMOHPTION FIELD II COMMUN/Tr SOIL ABSORPTION FIELD
FIGURE 2-4
9
ALTERNATIVE 3
-------
PLAIHIHIC AREA BOUNDARY
UP6RADED AND EXPANDED SEWAGE TREATMENT PLANT
4t LIFT STATION
INTERCEPTOR SEWER
- COLLECTOR SEWER
FORCE MAM
| | INDIVIDUAL SYSTEMS MANMCMENT DISTRICT
[ j EXISTING SERVICE AREA
| ] PLANNED SERVICE AREA
[ J POTENTIAL FUTURE SERVICE AREA
FIGURE 2-fc
ALTERNATIVE 4
10
-------
PLANMNC AR£A MUNDARY
UPGRADED AMD EXMNDCD KVME TWATjeWT PLANT
£ NEW SCVMC TREATMENT PLANT
-^ UTtXCEFTOH SEWER
COLLECTOR SEWER
[ ^j EXISTING SERVICE AREA
Igy^j PLMHED SERVICE AREA
[ 1 POTEKTIAL FUTURE SERVICE AREA
DXECDON Of FLOW
FIGURE 2 - 6
ALTERNATIVE 5
11
-------
Tables 2-2 and 2-3 summarize the adverse and beneficial environmental impact
of the alternative waste management systems. These impacts are characterized
by directness of impact (primary or secondary), probability of occurrence, and
anticipated severity. Primary impacts are direct effects on the environment of
the construction and operation of the wastewater facilities. Secondary impacts
are indirect or induced changes in the environment resulting from the operation
and availability of the wastewater facility and wastewater treatment service.
Secondary impacts would include the induced changes in the pattern of land use,
population density and related effects on air and water quality or other
natural resources (US-EPA 1977).
12
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17
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CHAPTER III
Public and Agency Comments on Draft EIS
-------
CHAPTER III
PUBLIC AND AGENCY
COMMENTS ON DRAFT EIS
Key Comments
In accordance with the National Environmental Policy Act and US-EPA procedures
for the preparation of environmental impact statements, Federal, State, and
local agencies as well as the public were requested to comment on the Draft EIS
from September 12, 1979 to November 12, 1979. In addition, oral testimony on
the Draft EIS was received at the Public Hearing held on October 23, 1979.
Comments on the Draft EIS included questions, new information, recommendations
for improvements to the document, and recommendations for selecting
alternatives. Preferences for alternative systems are summarized in Chapter
IV. In total, written comments were received by US-EPA from ten Federal
agencies, two State agencies, two county agencies, two regional agencies, four
municipal authorities, and numerous citizens and interest groups. In addition,
testimony at the public hearing on the Draft EIS was made by representatives of
one Federal agency, one State agency, two County agencies, one regional agency,
and three municipal authorities as well as by seven citizens.
Comments received by US-EPA which posed the most relevant questions and
presented new useful information are summarized by commenting agency in Tables
3-1, 3-2, and 3-3. These tables list 24 comments, each of which is responded
to specifically in the following sections.
From the perspective of US-EPA, all comments concerning the Draft EIS were
beneficial in assisting the Agency to refine its analysis of this project and
in making final recommendations concerning fundable alternatives. From all the
comments received, however, the following questions are considered by US-EPA to
be among the most critical comments, based on the direct importance of the
issue to the Agency's decision-making responsibilities:
What effluent limitations will PA-DER require for the Warminster sewage
treatment plant as well as for plants which might discharge to the Park
Creek in Horsham Township?
t In estimating costs for alternative systems, did US-EPA account for initial
assessments to homeowners and other users, as well as capital contributions
from the Horsham Sewer Authority to the Lower Gwynedd Township Municipal
Authority?
In estimating costs for alternative systems, did US-EPA account for costs of
land acquisition and system maintenance?
t Three of the alternatives presented by US-EPA require the conveyance of
wastewater from Horsham Township through Lower Gwynedd Township conveyance
systems to the Ambler STP. What is the capacity available to the Horsham
Sewer Authority in the Lower Gwynedd and Ambler systems?
Two alternatives presented by US-EPA include the use of individual and
cluster treatment systems in subareas 4 and 5 in Horsham Township. What are
the necessary responsibilities of the management agency and homeowner in the
successful operation of such systems?
In both Warrington and Warminster Townships, infiltration and inflow to
existing wastewater collection systems is considered by the municipalities
and PA-DER to be excessive. What is the extent to which infiltration and
inflow can be reduced by the respective authorities and what effect will
this reduction have on the sizing and costs of the proposed expansion to the
Warminster STP?
The Wichard Sewer Company has received a Certificate of Public Convenience
from the Pennsylvania Public Utility Commission to provide wastewater
treatment services to the proposed Country Springs development in Horsham
Township. The Wichard Sewer Company also has received an NPDES permit from
PA-DER to discharge its effluent to the Park Creek. In light of these
actions by the Commonwealth of PA, what effect does the Wichard Sewer
Company proposal have on the alternatives presented by US-EPA?
19
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These questions and each of the issues identified in Tables 3-1, 3-2, and 3-3
are addressed in the following sections:
Response to comments on existing conditions.
Response to comments on the formulation of alternatives.
Response to comments on environmental impacts.
Because many of the comments and issues were addressed by more than one
organization or person, the comments that are discussed have been reformulated
by US-EPA to indicate the central concerns of the commenting parties. Sourc.s
of the comments can be ascertained from Tables 3-2, 3-2, and 3-3 as well as
from Appendix B, where the full text of comment letters is presented.
23
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EXISTING CONDITIONS:
COMMENTS AND RESPONSES
Issue 1
Response to Issue 1
Issue 2
Response to Issue 2
Each of the following comments and responses concern existing conditions and
issues in the planning area. These issues must be resolved in order to
finalize the alternatives and assess environmental impacts.
In both Harrington and Warminster Townships, infiltration and inflow (I/I) to
existing wastewater collection systems is considered by the municipal
authorities and PA-DER to be excessive. Sewer system evaluation studies
required by US-EPA and PA-DER for facility planning have yet to be completed by
the Harrington Township and Warminster Township Municipal Authorities and is
critical in arriving at the selected plant design for the Warminster STP. This
problem is especially critical for the larger collection system in Warminster
Township. In light of these facts, what is the current status of I/I studies
performed by the authorities, what remains to be accomplished, and how can I/I
reduction be estimated for purposes of this EIS?
Both Harrington Township and Warminster Township Municipal Authorities met with
PA-DER on January 4, 1980 to discuss I/I. Warrington Township previously has
submitted information to PA-DER on the extent of I/I, probable causes, and
means of reducing this extraneous flow. PA-DER has advised the applicant that
reorganization of previous submissions and additional cost-effectiveness
analysis of alternative solutions is required. When these steps are completed,
Warrington must prepare a Plan of Study for the Sewer System Evaluation Survey
(SSES) and submit it to PA-DER for their approval. Warminster Township must
also submit a Plan of Study for an SSES. Prior to doing so, however, PA-DER
has required Warminster to collect additional monitoring data to update their
flow records.
Because both Townships are not able to estimate I/I reduction at this time,
USEPA and PA-DER again have agreed (as in the Draft EIS) that this reduction
should be estimated at 50% for both Townships. The estimation of I/I reduction
at this juncture is more critical for Warminster Township than Warrington
Township. Warminster infiltration (after sewer system rehabilitation) was
estimated in the Draft EIS for the year 2000 at 3.820 mgd (average flow). In
contrast, Warrington infiltration (after rehabilitation, year 2000) was
estimated at 0.049 mgd in the Street Road collection system and 0.078 mgd in
the Valley Road collection system. As these numbers indicate, the accuracy of
the 50% reduction estimate is of considerably more consequence to Warminster
than Warrington in terms of the sizing of the Warminster STP.
The Wichard Sewer Company has received a Certificate of Public Convenience from
the Pennsylvania Public Utility Commission to provide wastewater treatment
services to the proposed Country Srings residential development in Horsham
Township. The Wichard Sewer Company also has received an NPDES permit from
PA-DER to discharge its effluent to the Park Creek. In light of these actions
by the Commonwealth of Pennsylvania what effect does the Wichard Sewer Company
proposal have on the Final EIS?
The Draft EIS acknowledged the PUC approval of the Wichard applications as of
July 1979. The Country Springs residential development, which is the service
area of the Wichard Sewer Company, also was discussed. At that time, Country
Springs had received final approval from Horsham Township on Phase One (225
single family units). The Wichard STP is proposed to service 648 residential
units of the proposed Country Springs development and to have a design capacity
of 0.227 mgd. Beyond the approved first phase of the development, US-EPA did
not recognize the additional 423 units yet to be approved by Horsham as
definite additions to the housing stock and as definite future wastewater
service needs.
In the final EIS, the wastewater service needs of the Country Springs
development is treated differently. It is now the position of US-EPA, based on
both PA-PUC and PA-DER approvals granted the Wichard Sewer Company, that the
solution to wastewater needs of the future County Springs area will be
accommodated independently of the service needs of the remainder of Horsham
Township. This position is acknowledged and agreed upon by the Wichard Sewer
24
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Company. Consequently, subarea 8 which included Country Springs, will now be
reduced in size to exclude the Country Springs area. Design flows from Horsham
Township are to be reduced to represent this reduction in service needs (see
Table 3-4). Also, the Country Springs area will be considered as an option
area and is so discussed in Chapter V of this document.
Table 3-4. Year 2000 average design flow of subareas in Horsham Township, with
and without the Country Springs development, in million gallons per day.
Subarea With Country Springs
4 0.098
5 0.105
7 0.091
8 0.129
Without Country Springs
0.098
0.105
0.091
0.076
Issue 3
Response to Issue 3
Issue 4
Both the Horsham Sewer Authority and the War-minster Township Municipal
Authority have commented to US-EPA concerning disparity between Draft EIS
population projections and projections used by the respective municipal
planning commissions. In its prepared comments on the Draft EIS, the Horsham
Sewer Authority noted "what appears to be a great disparity in the population
figures projected by the Horsham Township Planning Commission, Montgomery
County Planning Commission, Delaware Valley Regional Planning Commission, and
the existing 208 study."
Differences between the Draft EIS population projections and municipal planning
commission projections for Horsham and Warminster Townships do exist. In
preparing the EIS population projections, US-EPA examined existing projections
prepared by the Montgomery County and Bucks County Planning Commissions, DVRPC,
the municipal planning commissions, and consultants to the municipal
authorities. The County Planning Commission projections on a municipal basis
were consistent with the DVRPC projections. The DVRPC projections, in turn,
were the actual population projections for the COWAMP/208 Water Quality
Management Plan for Southeastern PA. US-EPA is required to accept for 201
facility planning only population projections which are consistent with state
and regional water quality management population projections.
The Bucks County and Montgomery County Planning Commissions have reviewed the
Draft EIS estimates and found them to be consistent with each of their official
projections for the affected municipalities. DVRPC considers the EIS
population estimates to be consistent with their year 2000 interim planning
projections.
It is the recommendation of US-EPA that the disparity in population projections
questioned by Horsham and Warminster Townships should be resolved at their
initiative with the County Planning Commissions and DVRPC, with the ultimate
objective of revising the DVRPC year 2000 projections if adjustments are
warranted. For the purposes of this EIS process, the projections employed are
considered to be reasonable and consistent with regional planning objectives.
As the Horsham and Warminster authorities proceed in their facility planning
steps, they will have ample time to request revision of the regional
projections and, if successful, may use revised population estimates for future
facility planning purposes.
The Draft EIS proposes, under Alternative 1, to expand the Warminster STP by
3.8 mgd, from 4.58 mgd to 8.4 mgd. According to PA-DER, however, the current
plant was originally rated at 3.8 mgd, but was temporarily rerated to 4.58 mgd
pending its expansion. At what size should the plant be rated in the Final
EIS?
25
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Response to Issue 4
The current rated capacity of the War-minster STP is 4.58 mgd. This is a
temporary rating pending its expansion. According to PA-DER, the design
capacity rating of the expanded Warminster STP should be derived in the
following manner. Average annual flow into the Warminster STP from December
1978 through November 1979 was 5.45 mgd. Dry weather flow into this plant
during this period was estimated to be 3.89 mgd. The difference between the
average annual flow and the dry weather flow represents infiltration and inflow
to the system under wet weather conditions. I/I contribution amounted to 1.56
mgd (5.45 - 3.89). Fifty percent removal of I/I would reduce this contribution
to 0.78 mgd.
The design capacity rating of the Warminster STP under Alternative 1 is
estimated as follows:
Average Annual Flow:
+ Projected Expansion:
- I/I Removal:
+ 5.45
+ 3.80
- 0.78
8.47
The design capacity rating of the Warminster STP under alternatives 2 through 5
is estimated as follows:
Average Annual Flow:
+ Projected Expansion:
- I/I Removal:
Issue 5
Response to Issue 5
Issue 6
Response to Issue 6
The Horsham Land Management Plan delineates planning districts within the
Township. How were these planning districts considered in delineating subareas
within the EIS planning area?
As discussed in Section 1.8 of the Draft EIS, the subareas were delineated on
the basis of hydrologic boundaries, municipal political boundaries, documented
problems of malfunctioning on-lot disposal systems, known areas of projected
development planning, and existing service area and development patterns. In
Horsham Township, information regarding projected development planning and
existing development patterns was gathered in part from the Horsham Land
Management Plan. The planning districts of that plan were an important
determinant in choosing subarea boundaries. Subareas 6 and 7 conform closely
to Land Management District 3 (1.5 unit/acre), subarea 5 is almost entirely
within Conservation District 1 (1.0 unit/acre district); and subarea 4 is
almost entirely in Conservation District 2 (0.5 unit/acre district). Subarea 8
is in both Land Management Districts 2 and 3.
In Warrington Township, the entire planning area is situated in a single
planning district with a proposed housing density of 2.0 units/acre.
Water authority officials in Bucks and Montgomery County face a groundwater
contamination and water supply problem reportedly traced to the presence of
trichloroethylene (TCE). Evidence of TCE has been found specifically in wells
in Warminster, Warrington, and Horsham Townships. What is the significance of
TCE contamination as reported recently and what effect would this problem have
on proposed wastewater facilities in the planning area?
Since May 1979, there has been an extensive effort by the Bucks County Health
Department (BCHD), PA-DER and the US-EPA to identify the causes and extent of
organic chemical contamination of groundwater in Bucks County. The primary
contaminants under consideration are trichloroethylene (TCE) and
perchloroethylene (PCE) both of which are commonly used industrial solvents.
Both organic chemicals are known carcinogens and toxic to humans. Guidelines
established by US-EPA indicate potential carcinogenicity at levels above 4.5
parts per billion (ppb) and acute toxicity at levels above 225 parts per
billion (ppb).
26
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Issue 7
Response to Issue 7
Sampling of all municipal water supplies as well as numerous private water
supplies for TCE/PCE was started in August 1979. The affected municipal water
supplies in the planning area were impacted as follows:
Horsham Township Authority: Eleven wells and a small surface source were
tested prior to October 2, 1979. All concentrations were less than 1.0 ppb TCE
and less than 3.0 ppb PCE.
Warrington Township Authority: Two of four municipal wells were taken off-line
from the distribution system with concentrations exceeding 120. ppb TCE and 0.9
ppb PCE. With two wells off-line, the Authority is purchasing water from
Warminster Township.
Warminster Township Authority: Six of fifteen municipal wells have been
iip
th
contaminated and three of these are now off-line. Those wells which are
contaminated and off-line have concentrations near 260 ppb of TCE and 250 ppb
of PCE. There may be a water quantity problem in the Warminster Township
Authority service area if demand increases in the spring of 1980.
Warminster Heights Authority: The authority operates two wells, both of which
are contaminated with TCE/PCE in concentrations greater than 20 ppb. Both of
the wells are still on line because there is no provision for connection to an
alternate source.
In summation, these four geographic areas have experienced contamination
problems. If the contaminated wells cannot be returned to service, then there
may be a number of water supply problems encountered in the planning area
during 1980.
A number of private water supplies in these areas also are contaminated. The
total number of wells with this conditions may exceed two hundred. If these
wells prove to be contaminated continually, then the private home owners may be
forced to consider connection to one of the available public water supplies,
which are already under the stress of diminished quantity. In addition, the
presence of TCE/PCE in the groundwater also may be indicative of more
widespread organic contamination and may present the possibility of further
decrease of quantity due to affected groundwater sources.
With respect to proposed wastewater facilities, the major issue centers on the
permanency of the problem. If augmented water supplies and water conservation
practices are sufficient to allow demand to be met adequately and safely, then
minimal effect on wastewater facilities would be anticipated. If stringent
water conservation practices were required and were successful in reducing
significantly the per capita water demand, then the sizing of wastewater
conveyance and treatment facilities as discussed here would exceed actual
need.
The Draft EIS addressed the suitability of soils on undeveloped lands for
on-lot treatment systems. These systems include conventional septic tank-soil
absorption systems and sand mound-soil absorption systems. Did US-EPA consider
the extent of soils suitable for land application of wastewater (i.e. spray
irrigation or overland flow) and if so is this means of wastewater treatment
feasible based on soil conditions?
US-EPA examined the suitability of soils for slow rate land application systems
in its analysis of subarea baseline conditions. Areas with suitable soils were
delineated on a USDA Soil Conservation Service (USDA-SCS) soils series map for
Montgomery County. Only those sites occurring in vacant undeveloped land areas
were considered as potential land application sites. The suitability of soils
27
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for slow rate land application was determined using the following criteria for
land treatment of wastewater:
Table 3-5. Criteria for suitability of soils for slow rate land application
(US-EPA 1977).
Suitable Marginal Unsuitable
Soil Property Soils Soils Soils
depth to bedrock >5 ft 3-5 ft <3 ft
depth to seasonal >5 ft 3-5 ft <3 ft
high water table
depth to water table >5 ft 3-5 ft <3 ft
slope 0-8% 8-15% >15%
permeability 0.2-6.0 in/hr 0.2-6.0 in/hr
SCS Drainage Classes - - all
Somewhat poorly, poorly,
very poorly
floodplain soils - - all
PA-DER Chapter 73 Classes - - all
1, 10, 12, 13, 15
coarse fragments >65% - - all
Based on these criteria, the only USDA-SCS soil series "suitable" for land
application was Lansdale silt loam 0-3 slope. This soil series meet minimal
criteria with respect to topography, soil texture, soil permeability, soil
depth, depth to groundwater, and depth to bedrock.
The amount of undeveloped land in the planning area meeting minimal suitability
criteria for land application was found to be less than the amount of land
suitable for on-lot or community "subsurface" disposal systems. In subareas 4
and 5 of Horsham Township, 61 acres and 53 acres respectively of undeveloped
land were estimated to be suitable for land application (the actual suitability
of soils must be field checked primarily for depth to bedrock, depth to
seasonal high water table, and occurance of soil layers which would impede the
downward infiltration of wastewater). Given the existing problems of area
soils in regard to the performance of on-lot systems, the alternative of slow
rate land application was omitted as a practical alternative in subareas 4 and
5 in favor other decentralized approaches employing subsurface disposal.
The primary consideration in deciding in favor of subsurface alternatives was
the amount of suitable land for primary and back-up disposal fields.
28
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FORMULATION OF
ALTERNATIVES:
COMMENTS AND RESPONSES
Issue 1
Response to Issue 1
Each of the following comments and responses concerns the formulation of
alternative wastewater management systems in the planning area. These issues
must be resolved to choose technically feasible, cost effective alternatives.
What effluent limitations will PA-DER require for the Warminster treatment
plant and for plants which might discharge to the Park Creek in Horsham
Township?
The effluent limitations required by PA-DER (as of 23 January 1980) for
wastewater treatment discharges to the Little Neshaminy and Park Creeks are
Neshaminy "C" criteria. These criteria are summarized in the following table.
Table 3-6.
Parameter
BOD5 (mg/1)
Neshaminy "C" effluent limitations.
Limitation
Suspended solids (mg/1, year round)
pH (pH units, year round)
Fecal coliform (organisms/milliliter,
year round)
Dissolved oxygen (mg/1, year round)
Total nitrogen (mg/1)
Ammonia-Nitrogen (NH3-N, mg/1)
During the period 1 May to 31
October:
£6 as monthly average
£9 as weekly average
£15 at anytime
During the period 1 November to 30
April:
£12 as monthly average
£18 as weekly average
£30 at anytime
£30 as monthly average
£45 as weekly average
£100 at anytime
6.0 - 9.0
£200 as monthly average
£400 as weekly average
>4.0
During the period 1 June to 31
October:
£8 as monthly average
£12 as weekly average
£16 at anytime
During the period 1 November to 31
May:
£24 as monthly average
£36 as weekly average
£48 at anytime
During the period 1 June to 31
October:
£1.5 as monthly average
£2.5 as weekly average
£3.0 at anytime
During the period 1 November to 31
May:
£3 as monthly average
£4.5 as weekly average
£9 at anytime
29
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Issue 2
Response to Issue 2
Issue 3
Response to Issue 3
Each of these effluent limitations currently are required for the Warminster
STP. However, US-EPA has requested that PA-DER reevaluate the requirements on
total nitrogen for the Uarminster STP, based on stream survey information
collected by PA-DER during the summer of 1979. Consequently, it is possible
that this plant may not be required to treat for total nitrogen removal. In
addition, PA-DER also will notify US-EPA and the Warminster Township Municipal
Authority regarding requirements for chlorination and dechlorination. In the
Draft EIS, the Warminster STP was described as including biological
nitrification as an upgraded treatment process. It presently is anticipated
that there will be substantial treatment cost differences depending on the
resolution of these effluent criteria. These cost differences are addressed in
detail in Chapter IV.
The Draft EIS identified "planned service areas" in Horsham and Warrington
Townships where new collector sewers would be installed. The location of
proposed collector sewers was based by US-EPA on information available in the
grant applications and updated to 1978 with assistance from the applicants.
Do the location of proposed collector sewers as presented in the Draft EIS
represent 1980 conditions and needs?
The planned service areas in Horsham and Warrington Townships has remained
relatively constant from mid-1977, when grant applications were submitted to
US-EPA, to 1980. There are minor exceptions in both Townships, however.
In Horsham Township, some residents in the Maple Glen area (which includes the
900 block of Welsh Road, between Limekiln and Butler Pikes, and the 700 block
of Butler Pike, between Welsh Road and Limekiln Pike) requested that US-EPA
reconsider the need to provide centralized wastewater treatment service to this
area in lieu of continued use or improvements to existing on-lot disposal
systems. To survey the attitudes of the thirteen property owners in this area,
the Horsham Sewer Authority on November 16, 1979 distributed a mail
questionaire. The results of this survey was a mixed response towards
receiving centralized wastewater services.
For the present, US-EPA has not omitted the Maple Glen area as a planned
service area for purposes of the Final EIS. The Agency has determined that the
decision as to whether or not to include this area as facility planning
proceeds in the future should rest more properly with the Horsham Sewer
Authority and the Maple Glen residents.
The Warrington Township Municipal Authority has advised US-EPA that their
planned service areas now should include residences on both Upper Harness Road
and Lower Barness Road. Further, properties on School Lane, Park Road, and
Brinkworth Avenue which originally were included in its grant application have
received sewer service and are no longer considered planned service areas.
These changes are not considered to affect significantly either the amount of
wastewater flow, the design of wastewater facilities, or the cost of proposed
improvements in Warrington Township.
For Federally-funded projects, as proposed by the grant applications,
seventy-five percent of eligible construction costs generally are contributed
by US-EPA. The remaining construction costs must be borne by the grant
applicant (in this case, the municipal authorities). In estimating the costs
of alternative systems, did US-EPA account for potential capital contributions
from land developers and industries to the respective municipal authorities?
Capital contributions are initial single payments generally contributed by land
developers or industries in return for the provision of wastewater services to
their site. For the type of facilities proposed by the grant applicants,
capital contributions from such parties could be an important source of funds.
This is particularly the case for Warrington Township, which has many proposed
residential developments which are awaiting the availability of sewage
facilities. In Horsham Township, fewer residential developments have been
proposed and capital contributions from developers are not expected to offset
30
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Issue 4
Response to Issue 4
significantly local government costs. On the other hand, however, the
Horsham Sewer Authority, under alternatives 2, 3, and 4, must contribute funds
to the Lower Gwynedd Township Municipal Authority for wastewater facilities to
be constructed in Lower Gwynedd through which Horsham wastewater would flow, as
well as to Ambler Borough, for a share of the construction costs of the Ambler
STP expansion.
For the Warminster Township Municipal Authority, capital contributions are not
anticipated to offset their local costs. Most of the expansion to the
Warminster STP includes treatment capacity for flows from Warrington and
Horsham Townships.
In estimating costs for the alternative systems in the Draft EIS, US-EPA did
not include capital contributions from developers, industries, and other
sources as local contributions. This was done for two reasons. First the
collections systems proposed in the Draft EIS for Warrington and Horsham
Townships do not include immediate collection sewer service to new or
anticipated land developments. In fact, in order to be eligible for Federal
funding of collector sewers, substantial human habitation of service areas is
required prior to October 18, 1972. Second, for contributions from other than
land development sources, it is very difficult to estimate the amount of the
contribution, which is generally subject to negotiation between the
municipality and the contributor.
Alternatives 2, 3, and 4 in the Draft EIS require the conveyance of wastewater
flows from Horsham Township through the Lower Gwynedd Township system for
treatment at the Ambler Borough STP. Is there sufficient capacity in the Lower
Gwynedd and Ambler systems to make this alternative feasible?
In considering the design capacity of wastewater systems, a distinction must be
drawn between the capacity of conveyance systems (interceptor and collector
systems, force mains, and pump stations) and the capacity of treatment
systems.
The Lower Gwynedd Township Municipal Authority operates a wastewater conveyance
system which conveys flow to the Ambler STP. This conveyance system currently
includes a system of gravity interceptor and collector sewers, pump stations,
and force mains in the area generally south of Sumneytown Pike - Norristown
Road. The primary sewer interceptor in Lower Gwynedd is the Willow Run
interceptor which extends from Sumneytown Pike to the Lower Gwynedd Township -
Whitpain Township border. At this point, it joins a Wissahickon interceptor
(along Wissahickon Creek) which leads to the Ambler STP.
Lower Gwynedd now is constructing additional wastewater facilities which would
convey flows from the northeastern portion of the Township via the Forest Manor
pump station and force main to the existing system. This pump station is
located to the east of McKean Road near Welsh Road and presently has sufficient
capacity to accept approximately 0.15 mgd, which corresponds closely to the
1985 flow requirements for subareas 7 and 8 in Horsham Township. Additional
conveyance capacity beyond this amount is not available now in Lower Gwynedd
Townshi p.
To accept flows in excess of 0.15 mgd, Lower Gwynedd would need to make a
series of changes in its conveyance system. These changes are indicated in
Figure 3-1 and include:
construction of a force main along McKean Road
construction of a Willow Run relief sewer parallel to the existing Willow
Run interceptor
construction of a Lower Wissahickon relief sewer parallel to the existing
Wissahickon interceptor "choke" section.
31
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FORCE MAIN
GRAVITY SEWER
PROPOSED LOWER 6WYNEDD WASTEWATER CONVEYANCE
SYSTEM IMPROVEMENTS
FIGURE 3-1
-------
Issue 5
Response to Issue 5
Issue 6
Response to Issue 6
These changes to the Lower Gwynedd conveyance system would satisfy existing
wastewater service needs in Lower Gywnedd Township, as well as providing a
solution for Horsham Township treatment needs.
In addition to resolving its own conveyance capacity problems, Lower Gwynedd is
very interested in assisting Horsham Township so that Federal funds for its own
conveyance system improvements could be received under the Horsham 201
construction grant from US-EPA.
With respect to treatment capacity, US-EPA determined that the Ambler Sewage
Treatment Plant has ample excess treatment capacity to meet the wastewater
service needs of the Horsham Township planning area. This determination was
derived through comparison of the current population and wastewater flow
projections of the current Ambler STP service area with the design capacity of
the plant. Total capacity in the plant has been allocated by agreement to
Ambler Borough, Montgomery County, and Lower Gwynedd, Upper Dublin, Whitemarsh,
and Whitpain Townships. In order for treatment capacity in the Ambler STP to
be obtained by the Horsham Sewer Authority, it must be obtained from one or
more of these entities. To date, interest in transferring treatment capacity
rights to Horsham Township has been obtained from Lower Gwynedd, Upper Dublin,
and Montgomery County, which together control over 70% of the allocated
capacity of the plant.
In summary, there is ample available treatment capacity in the Ambler plant to
accommodate year 2000 wastewater flows from subareas 4, 5, 7, and 8 in Horsham
Township. The rights to this treatment capacity must necessarily be negotiated
and received from either the Lower Gwynedd Township Municipal Authority, Upper
Dublin Township Municipal Authority, or Montgomery County. Conveyance of
present and year 2000 wastewater flows through the Lower Gwynedd conveyance
system can be accomplished, but additional sewer construction in Lower Gwynedd
is required to meet the long range needs of Horsham and Lower Gwynedd
Townships.
If alternatives 2, 3, and 4, are chosen by US-EPA as being among the final
fundable alternatives, what assurance is there that the Lower Gwynedd Township
Municipal Authority will be interested in working towards a solution with the
Horsham Sewer Authority?
US-EPA has met with representatives of the Lower Gwynedd Township Municipal
Authority since 1979 in efforts to gauge their interest in this project.
Meetings directly between Lower Gwynedd and Horsham began in mid-1979. The
outcome of these meetings is represented in LGTMA's letter of October 12, 1979,
assuring US-EPA that "if a solution is chosen which involves utilization of the
Lower Gwynedd system and treatment at the Ambler Plant, the Lower Gwynedd
Township Municipal Authority will cooperate with the appropriate local, State,
and Federal agencies to undertake and complete a mutually beneficial project."
The effect of the wastewater discharge of non-municipal STPs on overall water
quality in the planning area may be considerable. This is especially the case
for the Warrington Sewer Company STP in Warrington Township and the English
Village STP in Horsham Township. What are the alternatives for the
non-municipal treatment facilities in the planning region?
The grant applications received by PA-DER and US-EPA did not address the
inclusion of non-municipal STP service areas into a municipally-owned
centralized system. When US-EPA began its EIS process, the significance of
these facilities again were considered. At that time, focus was placed on
these facilities:
Warrington Sewer Company STP
English Village STP
Willow Grove Naval Air Station STP.
33
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Issue 7
Response to Issue 7A
Isrue 7B
Koponse to Issue 7B
Other smaller non-municipal plants, including the Christ's Home STP, Tamanend
Junior High School STP and Johnsville NADC STP were considered by US-EPA to be
of less significance.
US-EPA assured that inclusion of non-municipal STP service areas in wastewater
management solutions was dependent to a great extent on negotiations between
non-municipdl STP owners and the municipal authorities. Most recently,
discussions between the owners of English Village and Warrington Sewer Company
sewage treatment facilities and the respective township municipal authorities
have been unsuccessful in achieving resolution of existing problems. In an
effort to avoid further complication of the Horsham-Warrington-Warminster
facility planning problems US-EPA decided not to make the resolution of
non-municipd treatment plant problems a primary goal of the EIS process.
Instead, US-EPA identified and addressed these areas as "option areas", because
of their potential involvement with wastewater management solutions identified
as feasible for the planning area. Chapter V of the Final EIS addresses
further the possible inclusion of these option areas in final recommended
solutions.
The community wastewater disposal systems presented in alternative 3 for
subareas 4 and 5 of Horsham Township constitutes an alternative approach for
low density problem areas. Because this is not a conventional wastewater
service approach, further detail has been requested by commenting parties as to
the functions and management of these systems. What are the components of the
community sy.tem as presented in Alternative 3?
Figure 3-2 illustrates schematically the type of community wastewater disposal
system proposed in Alternative 3. As shown in Insert 2, sewage from the home
flows first to a standard septic tank. Precast concrete tanks with a capacity
of 1,000 gallons commonly are used for household systems. Solids are collected
and stored in the tank, forming sludge and scum layers. Anaerobic digestion (a
fermentation process in which several anaerobic and faculative organisms
assimilate ard breakdown organic matter) occurs in these layers, reducing the
overall volune. Effluent is discharged from the tank, flowing to a vault or
holding tank which houses the pressurization device, control sensors and
valves. The holding tank can be made of properly cured precast or
cast-in-place reinforced concrete, or molded fiberglass. Effluent is pumped
from the holding tank through a service line to the pressure sewer main.
Service connection lines are generally made of 1 to 2 inch PVC pipe. Pressure
sewer mains ere usually 2 to 12 inch diameter PVC pipe, depending on hydraulic
requirements. Pipes must only be buried deep enough to avoid freezing.
The effluent in the pressure main is conveyed then to the community soil
absorption field for subsurface disposal (see Insert 3). A soil absorption
field utilizes the soil for absorption of treated effluent. The system may
incorporate series of absorption trenches alternatively.
Many different designs may be used in laying out a subsurface disposal field.
In sloping areas, serial distribution can be employed with absorption trenches
by arranging the system so that each trench is utilized to its capacity before
liquid flows into the succeeding trench. A dosing tank can be used to obtain
proper sewage distribution throughout the disposal area and give the absorption
bed a chance to rest or dry out between dosings. Providing two separate
alternating beds is another method used to restore the infiltrative capacity of
a system.
Will the selected management agency for the community systems be responsible
for all phases of design, construction, operation, and maintenance?
To properly manage a community system, and to avoid problems which occur
ordinarily with on-site systems (improper installation, faulty design,
maintenance lags, etc.), the management agency should regulate and operate all
34
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TO COMMUNITY DISPOSAL FIELD
m (SEE INSERT 3]
INSERT
S»ptlc Tank """" Check Valve7
PRESSURE SEWER SERVICE CONNECTION SIMPLIFIED
INSERT 3.
TILE DRAINAGE LINE
ABSORPTION TRENCH
^ABSORPTION FIELD
.DIVERSION BOX
^^
SEWER
COMMUNITY SUBSURFACE DISPOSAL FIELD
COMMUNITY WASTEWATER TREATMENT SYSTEM
FIGURE 3-2
35
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Issue 7C
Response to Issue 7C
Issue 7D
Response to Issue 7D
Issue 7E
Response to Issue 7E
individual and jointly used disposal systems operating within the community
system service area. The management agency should be responsible for:
1. Design and construction of community treatment systems for existing and
future users. This responsibility extends to design and construction of
pressure sewers and community disposal fields
2. Obtaining rights to lands with soils suitable for subsurface disposal
setting aside sufficient additional area to accomodate future growth
needs
3. Operation and maintenance of all individual and joint systems, including
periodic pumping of all septic tanks. The management agency should operate
and maintain all components of the facility located on private land
commencing from the inlet of the septic tank
4. Monitoring groundwater and surface water quality to detect failing
systems
5. Repair or reconstruction of any failing systems
6. Establishment of a fair assessment and rate structure for users to pay for
cost of services.
Will all existing individual systems be connected to the community system, or
just those that currently are failing?
All residential and industrial units in subareas 4 and 5 proposed for
centralized service under the Horsham Sewer Authority grant application to
US-EPA would be connected also to the community system. This includes existing
units on portions of Davis Grove Road, Willowbrook Road, Evergreen Road,
Babylon Road, Caredean Drive, Midfield Drive, Park Road, Horsham Road, and
Limekiln Pike.
What are the responsibilities of the homeowner and industry which utilize the
community system?
The property owners' only responsibility will be to provide and maintain the
lateral drain from his home or establishment to the septic tank and any power
costs associated with lifting his effluent into the pressurized collection
sewer.
What types of costs are incurred with a community system and how are these
costs distributed among system users?
The following table describes direct and indirect costs which are anticipated
for the type of community system proposed in Alternative 3. The means of
distributing system costs among users is variable. One form of cost
distribution is described in Table 3-7.
The above cost system basically entails an averaging of all costs for all users
into a monthly or annual charge. Other cost distribution mechanisms which
could be used by the management agency include a proportional distribution of
all costs by flow metering or, alternatively, a component approach, with
separate frontage fee, connection fee, and user fee.
The debt service on borrowed capital includes payment of principal and interest
on money borrowed by the management agency to cover the 15% share of total
system costs not picked up by the Federal Government construction grant. These
costs included planning, design, and construction of the community system.
Construction costs include all elements of the system, from the septic tank to
the drainage field, excluding the lateral house drain.
36
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Table 3-7. Direct and indirect costs of a community treatment system.
DIRECT COSTS
Installation of lateral drain
from building to septic tank
t Power for pressuriration pumps
INDIRECT COSTS
Monthly or annual charge(s)
coveri ng:
- permitting and inspection by
management agency
- periodic (even 1-3 years or as
necessary) pumping of septic tank
by management agency
- rehabilitation or reconstruction
of on-lot equipment (septic tank,
effluent pump, and service line)
by the management agency
- rehabilitation or reconstruction
of community equipment (pressure
sewers, subsurface disposal
fields, and monitoring equipment)
by the management agency
- debt service on borrowed capital
- management agency administration
Issue 7F
Response to Issue 7F
Issue 7G
Response to Issue 7G
Issue 8
Response to Issue 8
Do the community systems utilize any gravity sewers, or will they be
exclusively pressure systems?
The community system proposed under Alternative 3 utilizes pressure sewers
exclusively. Compared to conventional gravity sewers, pressure sewer piping is
relatively inexpensive. This allows for sewerage service in extreme
topographical conditions or where homes are widely spaced. Because all of
subareas 4 and 5 is in planning districts proposed for 0.5 to 1.0 unit/acre
density, this type of infrastructure is well suited.
To ensure maintenance and proper operation of community systems, how does the
management agency acquire right-of-way onto private property?
Many of the facility components of the community system, such as septic tanks
and effluent pumps, will be located on private property. Since regular
maintenance of these components is necessary for their proper functioning,
permanent legal access to the properties must be obtained. Easements must be
obtained also for any collection pressure sewers which cross private property.
It is hoped that the necessary easements can be acquired voluntarily from the
property owners.
A portion of subarea 5 in Horsham Township currently is serviced by the Upper
Moreland-Hatboro STP via a pumping station and force main along Horsham Road
(see Figure 3-3). Given that a portion of the planning is serviced by this
municipal facility, could other parts of the planning area convey wastewater
for treatment at that facility?
US-EPA has discussed this issue with the Upper Moreland-Hatboro Joint Sewer
Authority. The authority is currently engaged in its own 201 facility planning
program and has indicated that they are not interested in discussing the
conveyance of any additional flow from Horsham Township until its 201 program
is completed. The 201 program is anticipated to be completed during 1981.
37
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V: x^ X " < p':li //."'« -"'"''i:
PUMP STATION
FORCE MAIN
PUMP STATION AND FORCE MAIN CONVEYING WASTEWATER
TO UPPER MORELAND-HATBORO TREATMENT SYSTEM
FIGURE 3-3
38
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ENVIRONMENTAL IMPACTS:
COMMENTS AND RESPONSES
Issue 1
Response to Issue 1
Issue 2
Response to Issue 2
Issue 3
Each of the following comments and responses concerns environmental impacts of
alternative wastewater management systems. The consideration of environmental
effects is a critical determinant in US-EPA's process of selecting fundable
alternatives.
The Federal Emergency Management Agency (FEMA) is the responsible Federal
agency overseeing implementation of the National Flood Insurance Program and
the Executive Order (No. 11988) on Floodplain Management. In its review of the
Draft EIS, FEMA questioned whether the expansion of the Warminster STP would
take place within a 100 or 500 year floodplain. Second, FEMA requested US-EPA
to present in more detail the probable secondary impacts of the alternatives on
floodplain areas.
The existing Warminster STP is situated within the 100 year floodplain and the
proposed expansion of this facility would also be within the 100 year
floodplain. In its grant application to US-EPA, however, the Warminster
Township Municipal Authority has proposed mitigative site and building measures
to protect against flooding.
With respect to secondary impacts on floodplain areas, there undoubtedly will
be residential and industrial development in the vicinity of floodplain areas
in Horsham and Warrington Townships. This occurrence cannot be corrected
directly through the location of wastewater facilities (treatment systems and
conveyance systems) in the planning area. By providing effective wastewater
services to specific areas of need (such as Oak Terrace, Hideaway Hills, Fox
Development, Neshaminy Gardens, and Neshaminy Valley) and simultaneously
providing sufficient treatment capacity for a reasonable degree of future
population increase, it is not possible to totally isolate floodplain areas
from secondary effects. A significant amount of vacant land remains both in
areas adjacent and nearby to floodplains and areas within the floodplain. All
projected population in the planning area municipalities can be accomodated on
floodprone-free developable land. However, this future situation is dependent
entirely on the decisions of the local government officials as they grant
decisions on land development proposals in their municipalities.
In Horsham Township, there is significant undeveloped floodplain area along the
Park Creek between the Fox and Oak Terrace developments. This area extends
roughly south from the intersection of Limekiln Pike and McKean Road to the
Horsham corporate boundary. Because this area is planned for a residential
density of 1.5 units/acre, it should be of most concern to Horsham Township in
terms of floodplain protection. Elsewhere in Horsham Township, there exists
undeveloped 100 year floodplain areas along a small tributary between Babylon
and Privet Roads in subarea 5. The planned density for this area is 1.0
unit/acre and much of the area is not closely accessible to the proposed
facilities, consequently there is a lesser probability of floodplain impact
there. Finally, the Park Creek floodplain area extends north of Horsham Road
through the Township where it is protected presently by recreational land uses.
Also, this area is proposed for future planned densities of 0.5 units/acre,
which should afford further protection.
In Warrington, the 100 year floodplain extends along the Little Neshaminy Creek
and includes undeveloped land areas south of Street Road between the Neshaminy
Gardens and Neshaminy Valley developments.
The US Department of Transportation has reviewed the Draft EIS and requested
that the Final EIS specifically address the consistency between wastewater
service alternatives and transportation plans.
The PA Department of Transportation has reviewed the Draft EIS and advised
US-EPA that there are no planned state transportation facilities which would be
affected adversely by the various alternatives.
The Draft EIS projected a groundwater deficit in Warminster Township of 1.31
mgd for the year 2000. Given the need for adequate water supply for wastewater
39
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Response to Issue 3
Issue 4
Response to Issue 4
disposal, drinking, and other domestic purposes, what is the availability of
new or augmented water supplies to accomodate projected growth?
The availability of groundwater in War-minster Township, as well as Warrington
Township and other areas of Bucks County, has become even more severe since
trichlorethylene was discovered in numerous municipal wells in 1979. The issue
of groundwater contamination (and ultimately water supply depletion) in these
areas is being investigated extensively by US-EPA independent of this EIS
process. Additionally, in 1980, the Delaware River Basin Commission (DRBC)
will act to delineate and declare a groundwater protected area encompassing
Chester and Montgomery Counties and major portions of Bucks County. The
Horsham-Warrington-Warminster planning area will be included. DRBC will
designate protected areas and establish regulations for management of limited
groundwater resources. It will be proposed that any project having a
relationship to further depletion of groundwater in a protected area will be
subject to special consideration and review beyond that given under Article 38
of the DRBC Compact.
Beyond further study and regulation, however, lies the continuing need for
Warminster Township to augment its existing water supplies. As noted in the
Draft EIS, Warminster currently is attempting to solve its water shortage by
drilling additional wells in the Township and securing supplementary water when
necessary from Upper Southampton Township. A long-range potential for water
supply lies with the Point Pleasant pumpover from the Delaware River to the
Schuylkill River for the Limerick Nuclear power station. If this project is
approved and implemented, Warminster Township and other Bucks and Montgomery
County municipalities would benefit by being able to receive water along the
conveyance route.
In addition to its current program of securing additional water sources,
Warminster Township should investigate carefully water demand reduction
techniques as described in the Draft EIS.
As construction begins for wastewater treatment and conveyance systems, what
are the temporary and permanent erosion and sediment control measures needed to
stabilize the construction area?
The proposed wastewater facilities should be made to fit the site with a
minimum of clearing and grading. Existing cover should be retained and
protected whenever possible. Critical areas, such as highly erodible soils,
steep slopes, stream banks, and drainageways, should be identified and
protected. When earth change and removal of vegetation are necessary, the area
and duration of exposure should be kept to a minimum. In the case of
conveyance systems, their construction can be phased in order to minimize
exposed areas. All other disturbed construction areas should have a good cover
of vegetation or mulch.
Disturbed areas may be stabilized by mechanical (or structural) methods and
vegetative methods, or by combinations of these approaches. The removal of
existing vegetative cover and the resulting increase in impermeable surface
area during construction will increase both the volume and velocity of runoff.
These increases must be considered when providing for erosion control. Slope
changes should be designed to keep slope length and gradient to a minimum.
Short slopes, low gradients, and the preservation of vegetative cover can keep
runoff velocities low, minimizing erosion hazards.
Measures can be utilized to prevent water from entering and running over
disturbed areas. Sediment can be retained by either filtering runoff as it
flows, or by detaining sediment-laden runoff for a period of time so that the
40
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Issue 5
Response to Issue 5
soil particles settle out. The best way to control sediment, though, is to
prevent erosion. Erosion control measures serve to:
Divert runoff from exposed soils and other vulnerable areas;
Safely convey runoff, either in surface or enclosed drainage systems by:
-- controlling runoff velocity
ensuring that all surface channels and outlet points are adequately
drained;
Control the volume and velocity of runoff discharge from the construction
area.
These measures can be either vegetative or mechanical. Vegetative measures
include the planting of grasses and other vegetation to stabilize inadequately
protected soil surfaces. Mechanical measures include control techniques which
involve the building of structures (for example, check dams, sediment basins,
diversions) or the operation of equipment to achieve compaction or surface
roughening. Vegetative and mechanical measures may be either temporary or
permanent.
Sedimentation control serves to:
Detain runoff for a period of time to allow soil particles which are in
suspension to settle out;
Filter runoff as it flows; and
Intercept runoff containing sediment before it leaves the construction
site.
Sedimentation control measures, like erosion control measures, may be either
vegetative or mechanical.
Vegetative and mechanical erosion and sedimentation control measures may be
classified either as temporary or permanent, depending on whether or not they
will remain in use after construction. Annual grasses, mulches, and netting,
for example, are temporary control measures, although they may remain in place
after construction has been completed. The planting of perennial grasses, sod,
shrubs, and trees are permanent vegetative control measures. Temporary
measures generally serve for one year or less (US-EPA 1977).
The Draft EIS identified prime farmlands in the planning area, identifying such
lands as being environmentally sensitive. What are the impacts of the
alternatives on prime farmland?
The amount of prime agricultural land which is undeveloped and adjacent to
planned service areas is most extensive under implementation of alternative 1
and includes:
t Horsham Township - 101 hectares (249 acres)
t Warrington Township - 24 hectares (59 acres)
Warminster Township - 0 hectares (0 acres)
The amount of prime agricultural land adjacent to proposed service areas under
implementation of alternatives 2 through 5 is equal to that under alternative
1, with the exclusion of 23 hectares (57 acres) in Horsham Township.
Alternative 6 (no-action) probably will have a short-term beneficial impact on
the preservation of prime agricultural land.
US-EPA recognizes the significance of prime agricultural land as an
environmental resource and consequently discourages the conversion of such land
to other uses. The loss of prime agricultural land may result in greater
41
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Issue 6
Response to Issue 6
reliance on marginally-productive farmlands, more extensive soil erosion,
increased fertilizer requirements, increased need for soil conservation
measures, and increased environmental damage. Farmland conversions to
non-agricultural uses also reduces the viability of fanning units and cause
secondary economic impacts on fanning enterprises (US-EPA 1978).
Prime agricultural farmland comprises 19% of all undeveloped land adjacent to
planned services under alternative 1 and 18% of undeveloped land under
alternatives 2 through 5. The potential adverse effects of alternatives 1
through 5 probably are not significant in terms of the amount of prime
agricultural land potentially affected by these wastewater service schemes.
However, when it is further considered that significant amounts of adjacent
undeveloped land exist, particularly in Horsham Township, and that the
population carrying capacity of this land exceeds projected population, the
need to preserve prime agricultural land becomes more apparent. For this
reason, alternative 1 through 5 are considered to have a long-term adverse
effect on the retention of prime agricultural land.
As part of the Neshaminy Creek Watershed Project, floodwater retarding dams
PA-610 and PA-614 have been proposed and are to be located in the EIS planning
area. What are the estimated effects of the proposed alternatives on these
floodwater retarding structures?
PA-610 is a proposed dam to be located in Horsham Township in the approximate
area where Cedar Hill Road crosses Park Creek. This 39 foot dam will control
runoff from a drainage area of 2.97 square miles.
PA-614 is a proposed dam to be located on Neshaminy Creek, approximately 1,000
feet upstream of Dark Hollow road in Warwick and Buckingham Townships (Bucks
County). The 56 foot high dam will control runoff from a drainage area of 58.6
square miles.
As part of the Neshaminy Creek Watershed project, Dam PA-611 has been installed
previously. This structure is a 45 foot high dam controlling runoff from a
drainage area of 1,092 square miles. It is located on the Little Neshaminy
Creek in Warrington Township on the outskirts and borders of the planning
area.
The three dams are not expected to be impacted by the proposed alternatives.
The proposed wastewater treatment facilities potentially would affect this
watershed protection program in two ways:
1. Increase in flows from discharges of municipal sewage treatment plants and
stream recharge from land based disposal systems
2. Increase in flows associated with increased urbanization (i.e. increased
impervious surface, decreased recharge, and increased land runoff)
In both cases, increases in stream discharge and land runoff are direct
functions of population increase. To ensure that the proposed alternatives
were not adverse to the objectives of the Neshaminy Creek Watershed Project,
the population projection used for both projects were compared (see Table 3-8).
It was determined that population and land use future envisioned by the Draft
EIS was substantially less urbanized (and less populated) than the estimated
future envisioned by the Neshaminy project. Consequently US-EPA has assumed
that the Neshaminy Creek floodwater retarding dams were designed consistent
with these population projections, and that each of the alternative wastewater
systems presented in the Draft EIS are compatible fully with flood prevention
objectives of the Neshaminy Creek Watershed project.
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Table 3-8. Comparison of Draft EIS population projections and Neshaminy Creek
Watershed Project Population Projections, 1975-1990.
Township
Neshaminy Creek Watershed
Project Population Projections^
W75 1980 1985 1990
Horsham
Warri ngton
Warminster
10,750
19,635
11,220
12,474
18,200
23,970
Township
Delaware Valley Regional Planning
Commission Interim Projection (1977)2
W5 1981519811990
Horsham
Warri ngton
Warminster
4,966
10,344
17,368
5,461
11,731
17,443
5,956
13,117
17,566
Issue 7
Response to Issue 7
^Includes only that portion of the Township within the Neshaminy Creek
Watershed.
2The DVRPC population projections for these watershed areas are consistent
with projections used by US-EPA in the Horsham-Warrington-Warminster EIS. The
actual EIS projections for these Townships and years are slightly less because
they do not include all parts of the watershed within these municipalities.
The Draft EIS identified historic and archaeologic sites which could be
impacted potentially by the alternatives. What responsibility does US-EPA have
in assuring the protection of these historic resources?
In August 1978, at the request of the State Historic Preservation officer,
WAPORA, Inc. performed for US-EPA a preliminary pedestrian archaeological
reconnaissance of a 40 foot-wide, 23.5 mile corridor of the interceptor and
collector system proposed by the grant applicants. As a result of the field
survey, three locations in the planning area were identified where recovery of
numerous prehistoric artifacts representative of several cultural groups
verified human occupation and utilization of the area over a long time span of
between 5,000 and 9,000 years in duration. Each of these three sites
potentially could be adversely impacted by alternatives 1 through 5.
Consequently US-EPA has recommended further tests by excavation of a series of
10 by 10 foot tests at these locations to determine whether prehistoric
archaeological sites which are eligible for listing in the National Register of
Historic places actually occur at these locations. US-EPA would require
further testing after its final recommendations on alternatives is presented to
the public.
On October 4, 1979, after review of the Draft EIS, the State Historic
Preservation Officer advised US-EPA that "the EIS would seem to have adequately
assessed the impact on known or potential areas of archaeological sites".
The Advisory Council on Historic Preservation has advised US-EPA that according
to 36 CFR Section 800.4(a) of the Council's regulations, no historic structures
or properties that are included in or that would be eligible for inclusion in
the National Register of Historic Places are to be located within the area of
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the proposed project's potential impact. The Draft EIS reported that no
"primary" adverse impacts on these resources are anticipated as a result of
construction or operation of facilities proposed in alternatives 1 through 5.
One exception was the potential impact of a Park Creek STP on a potential
historic district including 8 historic structures in the vicinity of Davis
Grove Road and Keith Valley Road east of the Willow Grove MAS. Because the
precise siting of a Park Creek STP was not undertaken in this EIS, specific
detailed discussion of primary adverse effects could not be provided.
Nevertheless, four historic structures in the approximate vicinity of the
potential Park Creek STP were identified and two of these properties (the Mrs.
Charles Heyer Smith House and the Kenderdine Mill) were described as possibly
being eligible for the National Register of Historic Places.
Secondary impacts which would adversely affect historic structures and
properties include population growth and the conversion of undeveloped land to
developed uses. Such impacts are listed in the Criteria of Adverse Effect for
structures eligible for the National Register as promulgated under ACHP
regulations (36 CFR Section 800.9). Twelve historic properties in Horsham
Township and 2 historic properties in Warrington Township would be impacted by
secondary effects of alternative 1, 2, and 5. Of these properties, the Keith
House at Graeme Park currently is listed on the National Registry.
As stated in the Draft EIS, it is difficult for US-EPA to provide adequate
mitigation for secondary adverse effects of privately funded land development
on historic properties. However, the US-EPA Regional Administrator will
carefully consider unmitigated adverse effects of this type in the
determination of fundable alternatives. When final alternatives are chosen by
the Regional Administrator, ACHP will be informed of the specific effects of
the selected undertakings on historic resources.
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CHAPTER IV
Final Evaluation of Alternatives
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CHAPTER IV
FINAL EVALUATION
OF ALTERNATIVES
Public Agency Preferences
Environmental Impact
Adjustments
Of the public agencies which have commented on the Draft EIS, only four
agencies registered specific preferences on the selection of alternative
wastewater service systems. The four agencies included the US Department of
the Navy, PA Department of Environmental Resources, Delaware Valley Regional
Planning Commission, and Montgomery County Planning Commission.
The US Department of the Navy recommends adoption of either Alternative 3 or 4.
This conclusion was reached "in keeping with the findings of the DEIS, the
goals and objectives of the Navy's Air Installation Compatible Use Zone (AICUZ)
Plan, Federal guidelines, notably the General Services Administration's Federal
Management Circular 75-2, and the Horsham Township Land Management Plan"
(Department of the Navy, 1979). The Navy could not support Alternative 1 due
to its inducement for development in highly sensitive areas around the Naval
Air Station. Similarly, Alternative 5 would also induce growth in the vicinity
of the Naval Air Station, although to a somewhat lesser degree than Alternative
1. The Navy has maintained a neutral position regarding the adoption of
Alternative 2.
The PA Department of Environmental Resources is willing to support Alternatives
3, 2, and 4, in that order. The PA DER found Alternative 1 to be unacceptable
because of its adverse impacts and Alternative 5 to be too costly.
The Delaware Valley Regional Planning Commission endorsed Alternatives 2, 3,
and 4, stating that these alternatives best fulfill the requirements of the
Federal Clean Water Act, the Pennsylvania Clean Streams Law, COWAMP/208, and
county and local plans. Alternatives 1 and 5 could not be supported by DVRPC
due to adverse environmental impacts and high cost.
Finally, the Montgomery County Planning Commission recommended selection of
Alternatives 3 or 4 as the most cost/beneficial with least environmental
impacts. According to the Planning Commission, these alternatives would be
most consistent with Township comprehensive planning and zoning; could provide
up to 85% Federal funding on alternative systems; and would solve the problems
in a manner consistent with environmental and land use planning goals.
Alternative 1 was described as a clearly unacceptable proposal; Alternatives 2
and 5 are considered potentially viable alternatives, but their environmental
impacts and the possible inducement of growth in the more rural portions of
Horsham Township make them less desirable alternatives.
The environmental impacts of the alternative systems have been summarized in
Chapter II. As the public comments in Chapter III indicate, questions
involving environmental impacts centered upon these specific effects:
flood plain encroachment
availability of water supplies
erosion and sedimentation
loss of prime farmland.
Based on these comments, only minimal adjustments are required to the
environmental impact assessment of the Draft EIS. As reported in the Draft
EIS, the most adverse environmental effects of a severe nature are associated
with Alternative 1, followed by Alternatives 5, 2, 3, and 4 (same), and 6, in
descending order. The most beneficial environmental effects were reported to
be associated with Alternatives 3 and 4, followed by 2, 1 and 5 (same) and 6,
in descending order.
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After responding to public comments concerning environmental impacts of the
alternatives, the following clarification emerged. Alternatives 1 and 5
continue to be associated with the most adverse effects. Further examination
of potential floodplain encroachment (both primary and secondary impacts) and
loss of prime farmland (only secondary impacts) reinforced the probability of
adverse effects of these two alternatives, particularly in subareas 4 and 5 in
Horsham Township.
In Harrington and Warminster Townships, the problem of water supply availa-
bility has become even more acute since the issuance of the Draft EIS. Detec-
tion of TCE in Township wells, in concentrations beyond drinking water
standards, has caused municipal officials to close some wells. Because long-
range groundwater deficits were projected for both Harrington and Warminster
Townships (the problem is more severe in Warminster), the need for augmented
water supplies has become more immediate and less future-oriented.
Alternatives Recommended In recommending wastewater service alternatives to be funded by the Agency,
by US-EPA US-EPA has considered individual and cumulative environmental effects, cost-
effectiveness, public and governmental agency preferences, and potential for
successful implementation. For Harrington and Warminster Township Municipal
Authorities, the wastewater treatment and service system which they have
proposed is considered to be environmentally sound, cost-effective, publicly
supported and endorsed, and readily implementable. While certain grant
requirements pertaining to analysis of infiltration and inflow have yet to be
fulfilled, US-EPA has informed both grant applicants that their approach is
eligible for 75% Federal funding and is recommended and encouraged by the
Agency.
The wastewater service problems of Horsham Township have been the focus of
attention of the EIS process since its inception in 1978. The Park Creek
drainage area of Horsham Township offers more constraints than opportunities
for the provision of wastewater facilities. Conventional on-lot disposal
systems are unsuitable in many parts of the area due to shallow depth to
bedrock, high water table, limited permeability of soils, and other factors.
The constraints of on-lot system usage is attested to by problems identified
with existing units of this type in the Township. Centralized treatment
systems pose a broad range of other problems, however, including adverse
impacts on prime agricultural land, floodplains, forestland, loss of wildlife
habitats, downstream flooding, aesthetic values, and historic properties.
Alternative 1 has the highest probability of inducing these effects followed by
Alternative 5. In addition, both centralized treatment alternatives were
determined to be incompatible with the continued operation of the Willow Grove
Naval Air Station. For these reasons, Alternatives 1 and 5 are not recommended
for funding eligibility.
Alternatives 2, 3, and 4 also require centralized treatment systems to varying
extents. For these alternatives, however, centralized treatment is proposed at
the Ambler Borough STP. Alternative 4 would require conveyance of flows from
subareas 7 and 8 through Lower Gwynedd Township to the Ambler STP. Subareas 4
and 5 under this alternative were proposed to be serviced through a management
district overseeing the use of conventional and alternative on-lot disposal
systems. This alternative was not supported by PA-DER, which questioned the
use of holding tanks on a long-term basis for lots unsuitable for septic tank-
soil absorption systems and sand mound-soil absorption systems. Although this
alternative ranked very high in terms of beneficial environmental effects, its
lack of support by the State was grounds for elimination as a fundable
alternative.
Alternative 3 addresses the needs of subareas 7 and 8 as described in Alterna-
tive 4. For subareas 4 and 5, the proposed community subsurface disposal
systems serve as an alternative which has minimal adverse effects, conformity
with municipal growth management objectives, and support of the US Navy. The
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approach is relatively new and as an alternative technology is eligible for 85%
Federal funding. US-EPA endorses this alternative and recommends that it be
eligible for Federal construction grant assistance.
Alternative 2 also is endorsed and recommended by US-EPA as an eligible
alternative. However this recommendation earmarks this alternative as the
Agency's second choice behind Alternative 3. The recommendation of this
alternative enables the Horsham Sewer Authority to have options in seeking an
implementable wastewater service solution for the Park Creek area. However,
Alternative 2 may have adverse effects in subareas 4 and 5 in terms of the
induced conversion of undeveloped land to developed uses and marginal
conformity with growth management objectives of Horsham Township. These
effects are judged to be less severe than adverse effects projected under
Alternatives 1 and 5 for subareas 4 and 5. US-EPA recommends that the Horsham
Township Council, Planning Commission, and Sewer Authority carefully consider
the ramification of its choice of alternative system with respect to previously
adopted growth management objectives for this area.
The recommendation of two Horsham Township alternatives for funding
consideration is considered purposeful and expedient in light of the complex
circumstances which have impeded previous resolution of this issue. If other
reasonable techniques would have been found suitable, more options would have
been presented for the Township's consideration.
Cost of Recommended The estimated costs of Alternatives 2 and 3 are summarized in Tables 4-1 and
Alternatives 4-2. A more detailed account of each of these costs is presented in Appendix
C. All costs are expressed as year 1980 dollars. The costs of alternatives as
presented in those tables are higher than the 1978 dollar estimates in the
Draft EIS, owing to the inflation of construction, operation and maintenance,
engineering, and other costs during the period from 1978 to 1980.
Table 4-1. Comparison of cost for Alternative 2 and 3, Horsham Township
share, in 1980 dollars.
ALTERNATIVE
2 3
Total Construction Costs (OOO's) 4,865.7 4,657.5
Federal Share of Construction Costs (OOO's) 3,412.3 3,530.0
Local Share of Construction Costs (OOO's) 1,453.2 1,146.7
Total Salvage Value (OOO's) 2,183.0 1,836.6
Annual Operation and Maintenance (OOO's) 145.3 84.2
Total Present Worth (OOO's) of Construction,
Salvage and Operation and Maintenance Costs 5,839.1 5,077.3
Annual Equivalent Cost (OOO's) 556.5 483.9
Annual Debt Service (OOO's) 98.3 81.5
@7 1/8%, 40 years
Equivalent Dwelling Units, year 1980 637 637
Debt Service/EDU/year 154.3 128.0
Operation and Maintenance/EDU/year 142.2 111.0
Total Cost/EDU/year 296.5 239.0
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Table 4-2. Costs for Alternatives 2 and 3 for Warrington and Warminster
Townships, in 1980 dollars.
Warrington Warminster
Total Construction Costs (OOO's) 5,362.2 7,057.7
- Warminster STP Expansion 2,732.0 4,098.1
Federal Share 2,049.0 3,073.5
Local Share 683.0 1,024.5
- Warminster STP Upgrade 588.6 1,970.8
Federal Share 441.5 1,478.1
Local Share 147.2 492.7
- Warrington Collection Systems 2,041.6
Federal Share 1,348.9
Local Share 692.7
- Warminster Sewer Rehabilitation -- 988.8
Federal Share -- 741.6
Local Share -- 247.2
Federal Share of Construction Costs (OOO's) 3,839.4 5,293.3
Local Share of Construction Costs (OOO's) 1,522.9 1,764.4
Total Salvage Value (OOO's) 888.8 1,580.0
Annual Operation and Maintenance (OOO's) 412.5 720.1
Total Present Worth (OOO's) 9,465.7 14,214.0
Annual Equivalent Cost (OOO's) 902.2 1,354.8
Annual Debt Service 108.0 134.3
@7 1/8%, 40 years
Equivalent Dwelling Units, year 1980 2,423 9,547
Debt Service/EDU/year 44.60 14.10
Operation and Maintenance/EDU/year 170.20 75.40
Total Cost/EDU/year 214.80 89.50
For Horsham Township, the total present worth cost of Alternative 3 is about
13% less than the cost of Alternative 2. This cost differential can be
attributed primarily to the annual operation and maintenance costs estimated
for Alternative 3, which are 42% less than for Alternative 2.
In terms of costs to be borne locally by Horsham Township, Alternative 3 offers
additional cost savings because only 15%, rather than 25%, of the construction
costs of community systems in subareas 4 and 5 must be paid by the local
government. This savings is due to the financial incentive which US-EPA offers
grant applicants to implement alternative wastewater treatment technologies.
The total cost of systems per equivalent dwelling unit (EDU) per year is 19%
less for Alternative 3 than Alternative 2, due primarily to the difference in
levels of Federal assistance as well as system operating costs.
For Warrington and Warminster Townships, the costs of improvements (both
expansion and upgrading) of the Warminster STP are estimated and allocated
based on actual flow projections attributed to the contributing municipalities.
The construction costs indicated in Table 4-2 for the Warminster STP do not
include costs for dechlorination and denitrification facilities. These costs
are presented as incremental values in Table 4-3. Addition of both processes
to the expanded STP would add slightly more than $1 million in total
construction costs to the project. The local government share of these
upgrading costs would be 25% of total construction costs. Of the additional
upgrade processes examined, denitrification is almost 15 times as costly as
dechlorination and represents almost 94% of the total upgrade construction
costs.
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Table 4-3. Incremental costs (OOO's) of adding dechlorination and
denitritrification facilities to the Warminster STP, apportioned by
municipality.
Dechlor- Denitri- Both Dechl orination
ination fication and Denitrification
Total Construction Costs 69.7 1,033.3 1,103.1
Grant Eligible Costs 52.3 775.0 827.3
Local Share of Costs 17.5 258.4 275.8
Warminster Twp. Share 13.5 199.0 212.4
Warrington Twp. Share 4.0 59.4 63.4
The estimated costs per equivalent dwelling unit for each alternative does not
include the cost of installing lateral drains from the dwelling unit to the
street sewer. This cost, which must be borne by the property owner, is
variable depending on factors such as lot size and slope. The cost of
installing house drains is expected to vary between $250 and $1,000. This
installation cost is required for all units connected to centralized systems.
It does not pertain to community systems as proposed under Alternative 3. For
these systems, on-lot facilities are considered an integral part of the
community system and are eligible costs for Federal funding at the 85% level.
User Charges for The total cost per equivalent dwelling unit (EDU) identified in Tables 4-1 and
Recommended Alternatives 4-2 includes both annual debt service and annual operation and maintenance
costs estimated on an EDU basis. The cost per EDU is not necessarily equal to
the annual rate charged to system users. This is due to the variable methods
by which sewer authorities and other management agencies finance construction
programs and collect revenues from system users.
In determining user charges, the amount of debt service on borrowed funds is a
factor which can be determined by the sewer authority. This amount can be
variable due to:
t terms and length of the bond issue
tap-in charges
front-foot assessments
future capital contributions.
For estimating the costs of alternative systems a 7 1/8% bond and 40 year
maturity date was assumed. This interest rate is higher than that used to
estimate costs in the Draft EIS (6 5/8%). The higher rate is recommended by
the US Water Resources Council for Federal agencies in the formulation of plans
for water and related land resources for the period October 1, 1979 through
September 30, 1980 (US-EPA 1979).
In Horsham Township, annual user charges in the first year of system operation
could be considerably less than $297 per EDU (as in Alternative 2) if either a
tap-in charge or front-foot assessment were applied to each property owner
using the system. In presently sewered areas, the Horsham Sewer Authority
currently assesses $270 as a tap-in charge for each new connection. Such a
charge, if paid for the initial 637 EDU's in the Park Creek drainage area,
would amount to initial revenues of $172,000 which could be earmarked for
payment of debt service of the new system. In this manner, annual debt service
payments per EDU could be reduced under Alternative 2 from $154 to $134.
As a substitute for tap-in charges, the Authority could consider an assessment
based on actual front footage of property to be serviced. This approach would
yield variable initial payments from users dependent on their lot size.
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Annualized debt service can be reduced in future years as new requests are made
for connection to the system. In the case of proposed residential developments
or industrial/commercial facilities, a lump sum capital contribution paid by
the developer or industry could be requested in place of individual tap-in
charges.
In Harrington Township, where the annual cost per EDU was estimated at $215,
the actual user charge will likely be determined by the Township Municipal
Authority employing a tap-in fee or front-foot assessment. The Warrington
Township Municipal Authority most recently has requested a tap-in fee of $550
per EDU. Initial tap-in charges as well as capital contributions from future
system users are expected to result over time in significantly reduced user
charges.
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CHAPTER V
Option Areas
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CHAPTER V
OPTION AREAS
Wichard Sewer Company
English Village
Warrington Sewer Co.
This chapter addresses the interface between option areas, as described in
Chapter V of the Draft EIS, and final recommended alternatives, as presented in
Chapter IV of this Final EIS.
US-EPA has concurred with the position of the Wichard Sewer Company that the
solution to the wastewater service needs of the proposed Country Springs
residential development should be accommodated by the Wichard Sewer Company
independently of the service needs of Horsham Township. Consequently, Country
Springs has been delineated in this Final EIS as an "option area".
The Wichard Sewer Company proposes to operate a .2268 mgd sewage treatment
plant capable of tertiary treatment. At its full development potential of 648
dwelling units, the Country Springs development is estimated to contribute a
wastewater flow to this plant of approximately .160 mgd (648 units x 3.5
persons/unit x 70 gallons per capita per day). This estimate is independent of
any groundwater infiltration to the conveyance system. The Wichard Sewer
Company STP is expected, then, to have excess treatment capacity of
approximately-07 mgd to .10 mgd. beyond Country Springs' needs.
An agreement of August 28, 1978 between the Horsham Sewer Authority and the
Wichard Sewer Company provides to the Authority, at any such time as the
Authority shall request, 100,000 gpd of treatment capacity in the Wichard STP.
Presently, no firm plans exist between the parties to specifically implement
this element of the agreement.
US-EPA recognizes that according to this agreement, the Horsham Sewer Authority
has an option, independent of alternatives recommended herein, for securing
wastewater treatment service in the planning area in the vicinity of the
Country Springs development. It is the position of US-EPA that the Agency
should not interfere in the agreement between these parties by placing
conditions on its funding grant tied to the use of the treatment capacity of
the Wichard STP. All existing treatment needs as well as reasonable growth
needs of Horsham Township in the planning area have been addressed solely by
the recommended alternatives.
Subarea 15 is the designation for the English Village option area. English
Village is a commercial and residential complex the wastewater disposal needs
of which are met through its own collection and treatment system (0.12 mgd
STP). The Horsham Sewer Authority and the ownership of English Village
previously have consulted concerning sale of the system to the municipal
authority. The two entities have been unable to reach an agreement.
As stated in the Draft EIS, the problems of the English Village System could be
resolved either through upgrading of the facility by the present operator or
through abandonment of the facility and transfer of the wastewater flow to a
municipal service system. Because agreement between the Horsham Sewer
Authority and English Village ownership is not imminent, and agreement between
the Lower Gwynedd Township Authority and the Horsham Sewer Authority may be
forthcoming, the likelihood of transferring English Village flows to the Ambler
STP currently appears very remote.
The Warrington Sewer Company is a privately-owned public utility which collects
and treats domestic wastewater from a residential community (subarea 13) in
Warrington Township. The problems of the Warrington Sewer Company system has
been detailed in the Draft EIS. Resolution of these problems could be achieved
through pruchase of the facilities by the Warrington Township Municipal
Authority. Such purchase is under serious consideration by the Authority.
US-EPA recommends that , if feasible, agreement between the Warrington Sewer
Company and the Authority be achieved. Sufficient time remains for making
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grant eligible the construction costs which would be incurred in conveying
flows from that system to the Warminster STP. This alteration in the Little
Neshaminy interceptor project would alter the flow from that described in this
document. However, the inclusion of expected flow of less than 20,000 gpd is
not expected to disrupt seriously the existing plans and designs now intended
by the Warrington and Warminster Authorities.
Willow Grove Naval The Willow Grove NAS operates a secondary STP (with trickling filter) which
Air Station discharges to the Park Creek at a point south of County Line Road in Horsham
Township. The plant serves only the NAS, which is identified as subarea 14.
Because this plant produces a satisfactory effluent and probably could be
operated by the NAS to the end of its design life, US-EPA does not recommend
its participation in the recommended Horsham Township alternatives.
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CHAPTER VI
Implementation of Recommended Alternatives
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CHAPTER VI
Implementation of Recommended Alternatives
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CHAPTER VI
IMPLEMENTATION OF
RECOMMENDED ALTERNATIVES
Delineation of Service
Areas
^ecommended Capacity
The altermitives recommended in this Final EIS by US-EPA represent the
culmination of almost two full years of discussions between US-EPA, the grant
applicants, county and regional planning agencies, State regulatory agencies,
adjacent municipalities, and interested citizens and interest groups. US-EPA
recognizes that a successful solution borne from this process is now more
dependent on the actions of the grant applicants than on US-EPA and the
previously involved parties.
This section addresses questions of implementation of the recommended
alternatives. These questions concern the delineation of service areas, and
the derivation of treatment capacity, funding levels, and priority points. The
Agency has described also an implementation program which if followed would
promote the successful completion of these projects.
Throughout the EIS process, the focus for proposed wastewater service has been
on existing developed areas originally identified for collector sewer service
by Horsham and Harrington Townships. US-EPA has endeavored in this EIS process
to follow its own guidance, provided in Program Requirements Memorandum 78-9,
concerning construction grant funding of sewage collection system projects.
This memorandum sets forth guidance for rigorous review of grant applications
to ensure that proposed projects meet the established requirements of the
Federal Water Pollution Control Act and Clean Water Act Amendments.
US-EPA is only permitted to provide Federal construction grant funds for
"eligible" areas. Eligibility for collector sewers is determined if each of
the following criteria is met:
t Systems currently in use for disposal of wastes from the existing population
(e.g. septic tanks or cesspools) are creating a public health problem,
contaminating groundwater, or violating the point source discharge
requirements of the Clean Water Act.
The community for which service is proposed was in existence on October 18,
1972, and two-thirds of the flow design capacity through the sewer system is
from the community in existence on that date.
In areas of 2.94 households per acre or less alternatives to collection
systems are found to be not cost-effective.
The responsibility for compliance with US-EPA collection system eligibility
requirements rests with the Horsham Sewer Authority and the Harrington Township
Municipal Authority.
In the course of the EIS process, both Horsham and Warrington Townships have
considered the provision of wastewater services to areas in addition to those
addressed by the Draft EIS. It is the position of US-EPA that future
submissions of facility plans by the applicants should address primarily the
areas originally intended for service. Other areas newly considered for
service can be incorporated in such plans but should not be of such a magnitude
as to be inconsistent with wastewater systems recommended by US-EPA in this
document. All newly considered service areas are likewise subject to
habitation, needs, and density requirements specified by US-EPA PRM 78-9.
The design capacity of recommended wastewater conveyance and treatment systems
should be based on population estimates used in the EIS process, and, where
applicable, by infiltration estimates determined by sewer system evaluation
surveys (SSES).
The proposed design capacity of the expanded Warminster STP was based in this
document on EIS population estimates for Warminster and Warrington Townships as
well as 50% removal of I/I from existing collection systems. US-EPA recognizes
that the eventual design sizing for the expansion of the Warminster STP will be
based on a different I/I removal goal established by future SSES studies.
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Funding Levels
5cate Priority Points
Remaining Implementation
Steps
Consequently, the proposed 7.97 mgd Warminster plant, which includes an
expansion of 3.30 mgd, could be downsized by the grant applicant if I/I removal
could cost-effectively be accomplished in excess of 50%.
The proposed capacity of community soil absorption systems in subareas 4 and 5
of Horsham Township were predicated on specific population estimates and dosage
rates. As noted in the Draft EIS, the suitability of soils for community
subsurface disposal systems must be field checked by the Authority as well as
by PA-DER. Based on field checking, the capacity of community subsurface
disposal systems could be altered to account for more liberal or conservative
dosage rates.
Eligible construction costs for conventional wastewater collection and
treatment facilities are funded to a 75% level by US-EPA. The remaining 25%
cost of eligible items, as well as non-eligible costs, must be paid by the
grant applicant. All eligible costs for Alternative 2 facilities in the
planning area, Lower Gwynedd Township, and Ambler Borough are recommended for
funding at the 75% level.
Eligible construction costs for alternative wastewater facilities are funded to
an 85% level by US-EPA. This applies specifically to elements of the community
subsurface disposal systems proposed under Alternative 3 for subareas 4 and 5
in Horsham Township.
The PA-DER is the responsible State agency for prioritizing official sewage
facility plans submitted by local governments. Such prioritization is the
basis for allocating Federal funds earmarked for wastewater facility
construction; PA-DER assigns priority points based on a system which considers
the distribution and density of population to be served (existing and future)
environmental health factors, current and anticipated patterns of urban growth,
and topographic and other natural features.
The issue of priority point allocations to Horsham, Warrington, and Warminster
Townships has been of considerable concern to all parties actively engaged in
this planning process. As of the October 23, 1979 Public Hearing on the Draft
EIS, PA-DER reported that Warrington and Warminster Townships were rated at 73
priority points under all alternatives considered in the Draft EIS. For
Alternatives 2 through 5, Horsham Township was rated at 72 priority points. If
funding for these projects were to have been determined at that date, PA-DER
reported that all three municipalities would have sufficient points to receive
funding. However, monies for these projects will be subject instead to future
funding. The probability of funding at these priority point levels in the
future is dependent largely on the total allocation of Federal construction
grant monies to the Commonwealth of Pennsylvania.
With the completion of this EIS process, the grant applicants and US-EPA must
proceed to implement a recommended alternative according to regulations and
requirements governing the US-EPA wastewater facilities construction grants
program.
The next step for the respective sewer authorities is to prepare a STEP II
(Design) grant application which must be submitted to PA-DER. Important
elements of the STEP II grant application include letters from all parties
which ultimately will enter into formal agreements as part of the selected
solution. For Horsham Township, letters of intent are required from the Lower
Gwynedd Township Authority and those entities from which treatment capacity
will be purchased (such as Lower Gwynedd, Upper Dublin Township Authority, or
Montgomery County).
It is the responsibility of PA-DER to review the application to determine if
all application forms are in order, costs are fully substantiated, and
sufficient priority points exist to qualify for funding. PA-DER then can
certify the STEP II grant application for funding, after which it is submitted
54
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to US-EPA for its review. US-EPA will check the application for conformance
with the Draft and Final EIS and will review the engineering agreement. After
its review, US-EPA can offer a STEP II grant to the applicant. After its
formal acceptance of the grant, the applicant may then issue orders to its
engineering consultant to begin its design.
The time frame between completion of the EIS process and initiation of the
design phase typically varies depending on:
t the time required by the grant applicant to prepare the application (1-3
months)
the time required by PA-DER to certify the project (1-6 months)
the time required for US-EPA to review the application and offer the STEP II
grant (1-2 months).
The STEP II design phase can be expected to take from 6 months to 1 year
duration. Upon completion, design plans and specifications are submitted to
PA-DER, which reviews the material in terms of its NPDES discharge permit
requirements. Other reviews at this stage are performed by the US Army Corps
of Engineers, which checks plans and specifications for buildability and
constructability, and US-EPA, which determines if all remaining Federal
requirements are met. After STEP II approval by PA-DER and US-EPA, the
applicant then submits a STEP III application for construction of facilities.
Approval of the STEP III application results in a construction grant offer.
55
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CHAPTER VII
Public Participation
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CHAPTER VII
PUBLIC PARTICIPATION
History of Meetings
On January 13, 1978 US-EPA filed a Notice of Intent to prepare this
Environmental Impact Statement. Since that decision was made, countless
meetings have occurred involving the grant applicants, US-EPA, PA-DER,
officials of neighboring municipalities, US Navy, Montgomery and Bucks County
Planning Commissions, Delaware Valley Regional Planning Commission, and local
residents.
The following key meetings were conducted concerning this project:
April 5, 1978
May 8, 1978
May 31, 1978
June 12, 1979
September 18, 1979
October 11, 1979
October 22, 1979
October 23, 1979
November 12, 1979
March 20, 1980
April 1, 1980
Public Meeting No. 1 at the Keith Valley Middle
School in Horsham Township.
Central Contacts Committee Meeting No. 1 at
US-EPA, Philadelphia PA. Central Contacts
include representatives of US-EPA, PA-DER,
Montgomery and Bucks County Planning Commissions,
Delaware Valley Regional Planning Commission, and
US Navy. Subject of discussion was planning area
population estimates.
Public Meeting No. 2 at the Barclay Elementary
School in Warrington Township. Subject of
presentation was existing environmental
conditions in planning area.
Central Contacts Committee Meeting No. 2 at
US-EPA, Philadelphia PA. Subject of discussion
was the working draft of the Draft EIS.
Official release of the Draft EIS by US-EPA.
Central Contacts Committee Meeting No. 3 at
US-EPA, Philadelphia PA. Subject of discussion
was alternative wastewater conveyance and
treatment systems.
Central Contacts Committee Meeting No. 4, with
Horsham Sewer Authority, at US-EPA, Philadelphia
PA. Subject of discussion was specific
objections to alternative systems proposed for
Horsham Township.
Public Hearing on the Draft EIS at the Keith
Valley Middle School in Horsham Township.
Close of Comment Period on Draft EIS.
Representatives of Horsham Sewer Authority and
Lower Gwynedd Township Municipal Authority met to
review costs associated with alternatives
involving conveyance of flow through Lower
Gwynedd Township.
Central Contacts Committee Meeting No. 5 at
US-EPA, Philadelphia PA. Subject of discussion
was the review of the contents of the Final EIS,
particularly recommended alternatives. The
Committee was dissolved at the adjournment of the
meeting.
57
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Final Public Meeting A final public meeting to discuss the recommendations presented in the Final
EIS will be held in the planning area approximately thirty days after issuance
of this document. The site of the meeting will be the Keith Valley Middle
School in Horsham Township.
Comments on Final EIS Written comments on the Final EIS will be received by US-EPA during a 30 day
period after issuance of the Final EIS.
58
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FINAL EIS
MAILING LIST
Federal Agencies
Advisory Council on Historic Preservation
Council on Environmental Quality
Federal Emergency Management Agency
Office of Economic Opportunity
US Department of Agriculture
Forest. Service
Soil (onservation Service
US Department of Commerce
US Department of Defense
Army Corps of Engineers
US Navy
Philadelphia Naval Base
Warminster Naval Air Development Center
Willow Grove Naval Air Station
US Department of Energy
US Department of Housing and Urban Development
US Department of Health, Education and Welfare
Public Health Service
US Department of the Interior
Bureau of Outdoor Recreation
Fish and Wildlife Service
Geological Survey
National Park Service
US Department of Transportation
Federal Highway Administration
US Department of the Treasury
US General Services Administration
Pennsylvania
State Agencies
Department of Commerce
Harrisburg, PA
Department of Community Affairs
Philadelphia, PA
Department of Environmental Resources
Norristown, PA
Department of Health
Harrisburg, PA
Department of Transportation
Harrisburg, PA
Historical & Museum Commission
Harrisburg, PA
PA State Clearinghouse
Sewage Enforcement Officers
Fish Commission
Game Commission
Local Agencies
Horsham Township Council
Horsham Township Manager
Horsham Township Planning Commission
Horsham Township Sewer Authority
Horsham Township Solicitor
Ivyland Borough Council
Ivyland Borough Mayor
Ivyland Borough Planning commission
Ivyland Borough Zoning Hearing Board
Ivyland Borough Zoning Officer
59
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Local Age.icies Lower Gwynedd Township Board of Supervisors
(cont.) Lower Gwynedd Township Municipal Authority
Lower Gwynedd Township Planning Commission
Upper Moreland-Hatboro Joint Sewer Authority
Warminster Township Board of Supervisors
Warminster Township Chamber of Commerce
Warminster Township Municipal Authority
Warminster Township Municipal Authority Solicitor
Warminster Township Planning Commission
Warminster Township Solicitor
Warminster Township Special Solicitor
Warminster Township Transportation Commission
Warrington Township Board of Supervisors
Warrington Township Ecology Board
Warrington Township Manager
Warrington Township Municipal Authority
Warrington Township Municipal Authority Solicitor
Warrington Township Planning Commission
Warrington Township Zoning Hearing Board
Warwick T)wnship Board of Supervisors
Warwick Township Engineer
Warwick Township Manager
Warwick Township Planning Commission
Warwick Township Water and Sewer Authority
Bucks County Agricultural Extension Service
Bucks County Commissioners
Bucks County Health Department
Bucks County Historical Tourist Commission
Bucks County Planning Commission
Bucks County Water and Sewer Authority
Lower Bucks County Joint Municipal Authority
Montgomery County Commissioners
Montgomery County Engineer
Montgomery County Planning Commission
Montgomery County Sewer Authority
Delaware River Basin Commission
Trenton, NJ
Delaware Valley Regional Planning Commission
Philadelphia, PA
Upper Dublin Board of Commissioners
Upper Dublin Planning Commission
Upper Dublin Municipal Authority
Upper Dublin Township Manager
Upper Dublin Sewer Authority
Elected Officials Honorable Richard Thornburgh
Governor of Pennsylvania
Honorable Richard S. Schweiker
United States Senator
Honorable John M. Heinz III
United States Senator
Honorable Peter H. Kostmayer
United States House of Representatives
60
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Elected Officials
(cont.)
Honorable Lawrence Cough!in
United States House of Representatives
Honorable Richard T. Schulze
United States House of Representatives
Honorable Edward L. Howard
Senate of Pennsylvania, Doylestown
Honorable Margaret H. George
Pennsylvania House of Representatives, Doylestown
Honorable Vern Pyles
Pennsylvania House of Representatives, Dresher
Honorable Roy W. Cornell
Pennsylvania House of Representatives, Hatboro
Honorable Benjamin H. Wilson
Pennsylvania House of Representatives, Warminster
Honorable Stewart J. Greenleaf
Senate of Pennsylvania, Willow Grove
Newspapers
Intelligencer
Today's Spirit
Today's Post
Courier Times
Times Herald
Bulletin
Inquirer
Montgomery Publishing Co.
Evening Bulletin - Montgomery County Bureau
Libraries
Abington Free Library
Bucks County Free Library
Free Library of Warminster Township
Keith Valley Middle School
Melinda Cox Free Library
Montgomery County - Norristown
Union Library Company, Inc. of Hatboro
Upper Dublin Free Library
Upper Moreland Public Library
Wissahickon Valley Public Library
Citizens Groups
National Resources Defense Council, Inc.
Washington DC
America the Beautiful Fund
Washington DC
Audubon Naturalist Society of the Central Atlantic States, Inc.
Washington DC
National Parks & Conservation Association
Washi ngton DC
Rachel Carson Trust for the Living Environment, Inc.
Washington DC
Water Pollution Control Federation
Washington DC
Wilderness Society
Washington DC
The Wildlife Society
Washi ngton DC
Environmental Defense Fund
Washington DC
Montgomery County Historical Society
Norristown, PA
Pennypack Historical Society
Huntingdon Valley, PA
61
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Citizens Groups Wissahickon Valley Historical Society
(cont.) Ambler, PA
Hatboro BPW Club
Horsham, PA
Pioneers Retirees Club
Horsham, PA
Hatboro-Horsham Jaycees
Hatboro, PA
Sunnycrest Civic Association
Willow GrovsW Q'A
Hideaway Hills Civic Association
Ambler, PA
Citizens' Civic Association of Willow Grove
Willow Grove PA
Morewood Civic Association
Hatboro, PA
Fifth District Civic Association
Hatboro, PA
Upper Morel and Homeowners
Willow Grove, PA
Hillside Estates Civic Association
Horsham, PA
Ward #1 Civic Association (Upper Dublin)
Ambler, PA
AAUW-Glenside Branch
Willow Grove, PA
Ambler Jaycettes
Ambler, PA
Sierra Club - Pennsylvania Chapter
Philadelphia, PA
Air and Water Pollution Control
Ambler, PA
Air Pollution Control Association
Pittsburgh, PA
Bucks County Audubon Society
Doylestown, PA
Citizens Advisory Council to PA Department of Environmental Resources
Harrisburg, PA
Citizens Committee for Environmental Control
El kins Park, PA
Citizens Council of Montgomery County
Norristown, PA
Citizens Environmental Task Force
Pittsburgh, PA
League of Women Voters of Pennsylvania
Philadelphia, PA
National Audubon Society
Harrisburg, PA
Pennsylvania Environmental Council
Philadelphia, PA
The Pennsylvania Forestry Association
Mechanicsburg, PA
Pennsylvania Horticultural Society
Philadelphia, PA
Pennsylvania State Fish and Game Protective Association
Philadelphia, PA
Pennypack Watershed Association
Huntingdon Valley, PA
Project Karc
Blue Bell, PA
Tri-County Conservancy of the Brandywine, Inc.
Chadds Ford, PA
Trout Unlimited
Philadelphia, PA
62
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Citizens Groups
(cont.)
Water Resources Association of the Delaware River Basin
Valley Forge, PA
Wissahickon Valley Watershed Association
Ambler, PA
Women's Political Caucus
Warrington, PA
Wanninster Senior Citizens Association
Warminster, PA
Warrington Lions Club
Warrington, PA
Rotary Club of Warrington
Warrington, PA
Suburban Bucks Jaycees
Warminster, PA
Warrington Jaycees
Warrington, PA
Southampton Natural Resources Commission
Southampton, PA
Lower Bucks Canal Conservation
Bristol, PA
Churchville Outdoor Education Center
Southampton, PA
Bucks County Farmers Association
Ottsville, PA
Bucks County Fish and Game Association
Doylestown, PA
Bucks County Land Use Task Force
Buckingham, PA
Bucks County Historical Society
Doylestown, PA
Northampton Township Historical Society
Richboro, PA
Horsham Civic Association
Penllyn, PA
Citizens
Mr. and Mrs. Stuart Hughes
Mr. and Mrs. John Ruane
Mr. and Mrs. Canni ng
Mr. and Mrs. Tony Siott
Mr. and Mr,. Joseph Parker
Mr. and Mrs. Rich Richards
Marjory W. Richardson
Mr. and Mrs. Thomas McLaughlin
Mr. and Mrs. Paul Gianpa
Mrs. Doroth M. Vey
John E. Kauffeld
Mr. and Mrs. A. J. Vesneke
Mr. and Mrs. Jonathan Pera
Mr. and Mrs. Karl A. Isabel
Mr. and Mrs. William John, Jr.
Albert C. Barlow
Mrs. Alice Parker
Mr. Albert J. Keefe
Ms. Nellie Diehl
Mr. and Mrs. Albert McNeill
Mr. and Mrs. H. S. Glasby
Mr. and Mrs. D. Aley
Mr. Joseph Gigliotti
Mr. Thomas J. Timoney
Mr. Ronald Mintz
Mr. Eliot Glaser
Mr. Henry Bishop
Mr. Harry J. Nesbitt
63
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Citizens
(cont.)
Mr. and Mrs. Daniel A. Whitman
Mr. Don Shapiro
Mr. Julius H. Olita
Mr. Richard Mancini
Mr. and Mrs. James Steele
Mr. George Schaffer
Mr. George Pel bin
Mr. Al Korne
Mr. Michael H. Mai in
Mr. Chet Bradley
Others
Carrol Engineers
Warminster, PA
Wei don C. Harris & Associates
Fountainville, PA
Unitech Engineers
Cornwells Heights, PA
Gilbert Associates
Reading, PA
Eastern Montgomery County Board of Realtors
Jenkintown, PA
Bucks County Board of Realtors
Doylestown, PA
Montgomery County Bankers Association
Harleysville, PA
Office of Congressman Kostmayer
Mr. Michael Tabas
Mr. John Seager
Homebuilders Association of Bucks and Montgomery Counties
Willow Grove, PA
Warrington Sewer Company
Hatboro, PA
Bucks County Industrial Development Corp.
Mr. Alan Heddon, Exec. Dir.
English Village Apartments
North Wales, PA
Hatboro-Horsham Schools
Dr. Clifford Hendrickson, Jr., Supt.
House Republican Legal Staff
Ms. Maryann Cohen
Montgomery Elementary School
North Wales, PA
Municipal Environmental Associates
Warminster, PA
Turner Airport
Ambler, PA
Upper Dublin Schools
Dr. C. G. Brown, Supt.
Warrington Airport
Warrington, PA
Wissahickon School District
Dr. Wm. H. Stoutenburgh, Supt.
64
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BIBLIOGRAPHY Costle, Douglas M. undated. US-EPA policy to protect environmentally
significant agricultural lands. 7 p.
Delaware Valley Regional Planning Commission (DVRPC). 1977. Interim
projections report. Philadelphia, PA. 283 p.
Fabian, John, PA-DER. 1980. Telephone communication of January 23, 1980 with
Robert A. Scott, WAPORA, Inc. regarding Neshaminy Creek effluent
limitations.
Gilbert/Commonwealth Associates, Inc. 1977. Horsham Township land management
plan (Draft). Prepared by Gilbert/Commonwealth for Horsham Township
Planning Commission, 67 p.
Local Government Research Corporation. 1975. Warrington Township Growth
Impact Study, an update of the comprehensive plan, 1970. State College
PA, 109 p.
Peterson, Albert H. and Thomas J. McCaffery, Betz Converse Murdoch, Inc. 1980.
Letter of March 7, 1980 to Richard Pepino, US-EPA EIS Preparation Section
on project cost estimates. Plymouth Meeting, PA, unpaged.
Runowski, Robert C., US-EPA. 1980. Memorandum to Richard Pepino, US-EPA EIS
Preparation Section on contamination of groundwater in Bucks County,
Philadelphia, PA, 2 p.
SCS Engineers. 1979. Rural wastewater management in California, a guide to
alternative wastewater systems for rural and small communities. Long
Beach, CA, 48 p.
US Department of Agriculture - Soil Conservation Service (USDA-SCS). 1967.
Soil Survey Montgomery County PA. In cooperation with the Pennsylvania
State University, College of Agriculture and Agricultural Experiment
Station, and Pennsylvania Department of Agriculture State Soil and Water
Conservation Commission, 187 p.
US Department of Agriculture - Soil Conservation Service (USDA-SCS). 1976.
Neshaminy Creek Watershed, final environmental impact statement,
Harrisburg PA. 218 p.
US Department of Health, Education, and Welfare Public Health Service. 1969.
Manual of septic-tank practice. Rockville MD, 92 p.
US Department of Housing and Urban Development, Federal Insurance
Administration (US-HUD-FIA). 1978. Flood insurance rate maps for
Horsham, Warrington, and Warminster Townships. Variously paged.
US Environmental Protection Agency (US-EPA). 1977. Alternatives for small
wastewater treatment systems, pressure sewers/vacuum sewers. 97 p.
US Environmental Protection Agency (US-EPA). 1977. Alternatives for small
wastewater treatment systems, on-site disposal/septage treatment and
disposal. 90 p.
US Environmental Protection Agency (US-EPA). 1978. Less costly wastewater
treatment systems for small communities. Washington DC, 113 p.
US Environmental Protection Agency (US-EPA). 1977. Preventive approaches to
stormwater management. Washington DC, 207 p.
US Environmental Protection Agency (US-EPA). 1977. Process design manual for
land treatment of municipal wastewater. Washington DC, variously paged.
65
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US Environmental Protection Agency (US-EPA). 1978. Innovative and alternative
technology assessment manual (Draft). Office of Water Program Operations,
Washington DC, variously paged.
US Environmental Protection Agency (US-EPA). 1979. Draft environmental impact
statement, Horsham-Warminster-Warrington, Pennsylvania wastewater
treatment facilities. Philadelphia, PA, variously paged.
US Environmental Protection Agency (US-EPA). 1979.
Memorandum PRM No. 80-1. Washington DC. 2 p.
Program Requirements
66
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APPENDIX A
Draft EIS Included by Reference
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APPENDIX B
Comment Letters
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DEPARTMENT OF THE NAVY
NORTHERN DIVISION T.L.PHO*. NO.
NAVAL FACILITIES ENGINEERING COMMAND 755-4807
PHILADELPHIA. PENNSYLVANIA 191 IS
Code 2021.2
Mr. Oack J. Schram 30 OCT 1973
Regional Administrator
U. S. Environmental Protection Agency
Region III
Sixth and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schram:
The following comments concern the findings of the Draft Environmental
Impact Statement (DEIS) prepared for the Horsham, Warminster and Warrington.
Pennsylvania, Wastewater Treatment Facilities.
The DEIS addressees the impacts of five alternative wastewater treatment
systems. Since the Navy's foremost concern is the development potential
in the areas immediately surrounding the Naval Air Station, Willow Grove
in Horsham Township, and since all alternatives for wastewater treatment
in Warrington and Warminster Townships are the same, our comments will
be limited to the alternatives for wastewater treatment in Horsham Township.
The five alternatives presented in the DEIS include: Alternative 1,
essentially the Park Creek Interceptor System; Alternative 2, with
centralized treatment at the Ambler Sewage Treatment Plant (STP) for
all sub-areas in Horsham; Alternative 3, with centralized treatment for
sub-areas 7 and 8 at the Ambler STP and decentralized treatment (on-site
community disposal systems) for sub-areas 4 and 5; Alternative 4, with
centralized treatment at the Ambler STP for sub-areas 7 and 8 and individual
oh-site systems for sub-areas 4 and 5; and Alternative 5, with centralized
treatment for all sub-areas in a STP to be constructed in Horsham Township
with effluent discharging into Park Creek.
As noted, the Navy's primary concern with regard to the impacts of providing
wastewater treatment facilities in Horsham Township is, and always has
been, the potential of any solution to Induce or footer incompatible
(usually residential) growth in sensitive areas surrounding the Naval Air
Station. The noise impacts associated with flight operations, particularly
jet traffic, necessitate the -retention of open space in these high noise
zones surrounding the Air Station.
B-l
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Code 2021.2 30 OCT ij/g
The retention of open space in the areas surrounding the Naval Air Station,
particularly sub-areas 4 and 5, or the compatible development (with regard
to flight operations) of these areas, is considered paramount for the Navy
to continue its flight training and drills with minimum noise impact on
the local community.
Aside from the noise impacts associated with operations conducted at the
Station, the need to retain the current open space around the Naval Air
Station can be demonstrated by three air crashes that have occurred in the
vicinity of the Station over the last 12 months. These accidents are
tragic reminders of the fact that, even though the Navy maintains the
highest levels of flight safety, aircraft accidents can, and occasionally
do, happen. Aircraft operations, by their very nature, involve a certain
degree of risk both to the pilot and crew and to the general public that
are, or could be, located in critical areas with regard to flight operations.
Clearly then, to minimize these risks for all concerned, certain areas
around the Air Station should be kept in an undeveloped state or, if
developed, used for functions compatible with flight operations.
With regard to the proposal to install wastewater treatment facilities in
Horsham Township, the Navy recognizes the need to solve existing health
problems in the Township, and has suggested that the proposed solution;
i.e., the Park Creek Interceptor System, would cause significant problems
by fostering new population growth that might seriously affect Navy flight
operations as well as having detrimental impacts in other areas.
The findings of the DEIS indeed supported the Navy's viewpoint by indicating
that the most numerous adverse environmental effects are associated with
Alternative 1, followed by Alternatives 5, 2, 3, 4 and 6 (no action) in
descending order. Conversely, the most beneficial environmental effects
are associated with Alternatives 3 and 4, followed by Alternatives 2, 1,
5 and 6 in descending order.
The Navy concurs with the findings that the most adverse impacts are
associated with Alternative 1, particularly with regard to the inducement
of development in highly sensitive areas around the Naval Air Station that
would result from implementation of Alternative 1. Therefore, the Navy
considers Alternative 1 as an unacceptable solution to the wastewater
treatment needs of Horsham Township.
Similarly, Alternative 5 cannot be supported by the Navy as a viable plan
to provide wastewater treatment facilities in Horsham because of its
potential for induced growth in the vicinity of the Naval Air Station.
As noted in the DEIS, Alternative S has the potential to induce the conversion
of undeveloped land to developed uses although to a somewhat lesser degree
than Alternative 1. Additionally, Alternative 5, like Alternative 1, has
B-2
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Code 2021.2
the potential to induce population increases exceeding the levels projected
for reasonable growth. Increases in population, in turn, increases the
cjemand for housing and past experience has shown that housing developments
inevitably are proposed and built in areas incompatible with aircraft
operations. Comprehensive plans, zoning, ordinances, et cetera, in many
cases, may not be effective in control of such developments.
Alternative 2, while also having the potential to foster conversion of
undeveloped land to developed uses, differs from Alternative 5 in that
the centralized STP is located in Ambler, Pennsylvania. As such,
additional capacity to serve future developments in Horsham (beyond the
projected population growth) presumably would be more difficult to obtain
since two municipal authorities would be involved. Assuming that future
growth in Horsham Township would be limited by the available capacity in
the Ambler STP, this alternative would provide a reasonable solution to
the wastewater treatment of Horsham Township. However, the Navy does not
recommend or endorse this alternative, but merely does not object to this
proposal .
In keeping with the findings of the DEIS, the goals and objectives of the
Navy's Air Installation Compatible Use Zone (AICUZ) Plan, Federal guidelines,
notably the General Services Administration's Federal Management Circular
75-2, and the Horsham Township Land Management Plan, the Navy supports
and recommends adoption of either Alternative 3 or 4 as in the best interest
of all concerned. Either alternative would provide an adequate solution
to the wastewater treatment requirements of Horsham Township, provide
means to support a reasonable level of population growth in the Township,
and limit as far as practicable, incompatible developments in critical
areas around the Naval Air Station. The Navy, therefore, encourages the
Environmental Protection Agency to provide construction funds for either
Alternative 3 or 4.
CARNELL
CDR, CEC, U.S. NAVY
Acting
B-3
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FEDERAL EMERGENCY MANAGEMENT AGENCY
FEDERAL INSURANCE AND HAZARD MITIGATION
CURTIS BUILDING, SIXTH AND WALNUT STREETS
PHILADELPHIA. PENNSYLVANIA 19106
November 1, 1979
REGION III
IN REPLY REFER TO:
31
FLO-1
Mr. Richard V. Pepino
U.S. Environmental Protection
Agency, Region III
EIS Preparation Section
6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Pepino:
Thank yon for the opportunity to comment on the Draft Environmental Impact
Statement (DEIS) for the Horsham-Warminster-Warrington, Pennsylvania Waste-
water Treatment Facilities. In our review, we have focused on compliance with
the National Flood Insurance Program (NFIP) and Executive Order 11988,
Floodplain Management, dated May 24, 1977. Over the past year, the Insurance
and Mitigation Division of the Federal Emergency Management Agency (FEMA)
has been especially active in the implementation, of Executive Order 11988.
The FEMA has a key role in its implementation. FEMA's Flood Insurance
Studies and maps are its foundation, and its regulations provide the Order's
minimum standards for Federal construction and development. FEMA's shared
consultation role (pursuant to Section 2(d) of the Order) is the basis for
a major interagency effort. FEMA. has participated in the preparation of
over thirty agencies' procedures for implementing the Order. A major thrust
of this activity has been clarifying the manner in which the Order applies
to a specific agency's actions.
Executive Order 11988 distinguishes between primary and secondary impacts
on floodplains. A primary impact would be one resulting directly from the
siting of an action in a floodplain. Examples of actions with primary impacts
would be the placing of treatment plants, collector systems or land appli-:
cation sites in floodplains. A secondary impact would be one flowing from
an action that was made possible by another action located either in or out
of a floodplain. An example, in this case, of an action with secondary
impact would be the providing of infrastructure, i.e. central sewerage
facilities, that can help stimulate growth in floodplains. The DEIS
summary recognized the potential influence of this type of infrastructure
on environmentally sensitive areas (sections 6.3 and 6.4).
Because of the lack of sufficient data, it is difficult for our office to
ascertain whether there will be any primary impacts on the floodplain as
a result of the proposed project. For example, it is unclear exactly where
B-4
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Page 2
the proposed expansion to the Warminster STP is going to take place or should
a new Park Creek STP or additional lift stations be constructed, where they
would be located. Our office, is concerned as to whether these proposals
would be taking place within either a 100 or 500 year floodplain or whether
they would be located in a non-flood-prone area. If it is the former, have
all attempts been made to establish the plant(s) outside the floodplain?
If a floodplain location is the only practicable alternative, we would be
interested in the floodproofing specifications (as you are well aware EPA
requires STPs located in flood prone areas to be operational to the level
of the 25-year flood and completely watertight to the 100-year flood elevation)
and the impacts, if any, on the Little Neshaminy Creek, Park Creek (if ap-
plicable) and the adjacent floodway and floodway fringe.
It is also apparent that new, and possibly some replacement, sewer lines
are planned under this project. We assume that portions of these lines
would be located in flood hazard areas. If this is the case, once again
the issues of the impact on the floodplain and floodproofing of utilities
have not been adequately addressed.
The DEIS does address the issue of secondary impacts in Sections 2.8.3,
6.A.4 and 7.4.4. Although it is correct to state that all municipalities
involved in the project do prohibit structural development in flood-prone
areas as a permitted use, development could still occur by obtaining a
variance, a special exception or a conditional use permit. In addition,
it should be emphasized that as development pressures increase in the
future, these land use regulations could be revised to reflect the NTIP's
minimum floodplain management requirements and thus allow development to
occur. We have seen this occur in other areas of our region in the past
and thus we would like to raise this possibility for your consideration.
We would suggest that a more detailed picture of existing and potential
land use be developed in order to better assess the probable impacts
of the planning alternatives in floodplain areas.
In the event that further analysis indicates that floodplain development
would be supported by the various planning alternatives, strategies
for avoidance of these impacts should be discussed.
In summary, it is evident that the level of analysis of impacts relating to
NFIP regulations and E.G. 11988 has been in keeping with the preliminary
status of the DEIS. However, subsequent documents should include suffi-
ciently detailed data to address the key requirements of the Executive
Order: the identification of practicable alternatives that avoid floodplain
impacts or support floodplain development. If it is found that there are
no practicable alternatives to primary impacts, the documents should fully
address the Order's provisions for minimization of harm to, or within,
the floodplain and restoration and preservation of floodplain values.
If secondary impacts are inevitable, or probable, without intervention,
B-5
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Page 3
strategies for avoidance or minimization should be developed.
Please contact Richard Kinard of our office for any necessary clarifications
of our position. We would be pleased to provide any possible assistance
in addressing the requirements of the National Flood Insurance Program or
the Executive Order.
Sincerely yours,
t
Walter P. Pierson
Acting Director
Insurance and Mitigation
B~6
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DEPARTMENT OF TRANSPORTATION
REGIONAL REPRESENTATIVE OF THE SECRETARY
434 WALNUT STREET
PHILADELPHIA. PENNSYLVANIA 19106
November 6, 1979
REGION III
MEMORANDUM TO:
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Attn: EIS Preparation Section
SUBJECT: Draft Environmental Impact Statement for
Horsham-Warminster-Warrington, Pennsylvania
Wastewater Treatment Facilities
We have reviewed the subject draft EIS from the point
of view that our agency's primary area of expertise and
interest is the proposal's impact on the transportation
system.
It is clear that development of the project is being guided
by the local land use plans. Transportation improvements
are similarly planned and developed based on local plans.
It appears, by inference, that both the proposed project
and the transportation plan are based on the same local
plans, and hence are consistent with each other. However,
it would be preferable for us if the relationship was
specifically addressed in the Final EIS.
Sally H. Cooper
Regional Representative
of the Secretary
cc: R. Davino, FHWA
J. Canny, US DOT, 'P-22
B-7
It't * law w«
can liv* with.
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United States Department of the Interior
OFFICE OF THE SECRETARY
'"'"Northeast Region
15 State Street
ER-79/926 Boston, Massachusetts 02109
October 31, 1974
Mr. Jack J. Schramm
Regional Administrator
Environmental Protection Agency
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
This responds to your September 12, 1979, letter requesting our comments
on the draft environmental impact statement for Horsham-Warminster-
Warrington Wastewater Treatment Facilities, Bucks and Montgomery
Counties, Pennsylvania.
General Comments^
The draft statement adequately describes existing fish and wildlife
resources, and adequately discusses project-caused impacts to those
resources.
Detailed Comments^
6.3 and 7.3 Earth Resources
Although the geology of the area is briefly discussed and rocks in the
area are not of major economic importance, we believe the report should
include a brief statement acknowledging the commitment of in-the-ground
mineral resources (stone, sand and gravel, shale) for the sewer line
rights-of-way.
Summary Comments
Because of the high potential for adverse impacts to archeological and
historic resources, we urge the Environmental Protection Agency (EPA) to
fully comply with its responsibilities to protect these resources.
It is obvious that many of the historic sites located within the project
area will be eligible for listing in the National Register. Thus, EPA
B-8
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should immediately submit information on these sites to the State
Historic Preservation Officer (SHPO) so that these determinations may be
made. Pursuant to 36 CFR 800, EPA must allow the Advisory Council on
Historic Preservation (ACHP) an opportunity to comment on the potential
impacts that the wastewater facility will have on these sites. While
some of the structures themselves may not be impacted by the project,
loss of surrounding landscape may result in a loss of integrity for the
site.
Secondly, pursuant to Executive Order 11593, the three areas cited as
yielding potentially numerous archeological sites must also be surveyed
and inventoried so that they may be considered for listing in the National
Register for Historic Places. The draft states that there will be deep
excavation work done for the installation of utilities. These areas
must be carefully surveyed to assess what impacts this activity will
have on archeological resources. Because the various conveyance systems
may impact these areas, the ACHP must be afforded the opportunity to
comment on these impacts.
Finally, because of the potential for visual impacts and the potential
for impacts from future development, EPA must allow the ACHP to comment
on these considerations.
Sincerely yours,
William Patterson
Regional Environmental Officer
B-9
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DEPARTMENT OF HEALTH. EDUCATION, AND WELFARE
REGION III
3535 MARKET STREET
PHILADELPHIA, .PENNSYLVANIA
PUBLIC HEALTH SFRVICF
October 23, 1979
VAILING ADDHFSS
f O BOX 13710
PH1LAUF LPHIA
Pt N'-SVLVANI A 19101
Mr. Jack J. Schranun
Regional Administrator
Environmental Protection Agency
6th § Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schramm:
RE: DEIS on Horsham-Warminster-
Warrington, PA
Wastewater Treatment Facilities
Thank you for the opportunity to review the Draft Environmental Impact
Statement for the above referenced project.
It seems to us that the submission of the initial applications from
the communities could have been more productive if the applicants
were informed of the needed parameters. It is not clear what type
of technical assistance was provided. Why were the applicants allowed
to apply using unacceptable data (pages 3-7, 3-9) causing a delay of
over two years between application and DEIS?
We offer the following comments for your consideration in the preparation
of the Final EIS.
_ What arrangements will be made to provide financial assistance
to families that are unable to afford the costs of connecting to
the wastewater system? Can HUD get involved through its community
' assistance programs?
_ The EIS should include a statement addressed to the operation of
the wastewater system, e.g., technical and administrative. Will
it be administered by an umbrella institution that will enhance the
opportunity of providing increased operational expertise?
- Recognizing the current escalating inflation and the relative minor
differences in construction costs among the alternatives, we recommend
that the selection of the alternative choice be influenced by the
technical issues of: (1) capacity of the bodies of water to accept
increase volumes of effluents; (2) ability to accommodate anticipated
future population; (3) correction of the malfunctioning of the
individual on-site septic systems; and (4) the control of new land
use developments.
B-10
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Page 2
Mr. Jack J. Schranun 10/23/79
- The problem of the inadequate performance of the Warrington
sewer system (page 5-4) needs to be addressed. Who has the
responsibility for resolving the problems of excessive infiltration
and the inadequate performance of its STP? Is it due to lack of
expertise in operating the facility or obsolete equipment?
- The expected availability of an efficient wastewater system will
require the municipalities to revise their zoning ordinances and
growth management plans including responsibilities for thorough
planning. It appears that new land use developments need to be
controlled to minimize impact on forest lands. Local planners
need to address the problems related to the further urbanization
of the area and the issues of adequate water quality and supply.
- The Warminister STP should be upgraded to bring it in compliance
with the most recent effluent limitations for total nitrogen
(pages 6-25, 7-10). The techniques of dechlorinating with sulfur
dioxide should be researched and analyzed.
- The role of the non-municipal treatment facilities in the planning
region needs to be discussed. Their impact in the overall water
quality in the area is obvious (page 2-25).
- Some of the mitigating measures for water quality/conversation
seem difficult to implement (page 7-9). They require significant
modifications of our societal modus vivendi. We agree and endorse
those measures, but recognize that they are of a long range nature.
They require extensive educational efforts and are difficult to
enforce and monitor.
I am forwarding our copy of the DEIS to the Regional Office for Facilities
Engineering Construction (ROFEC) for a technical review based on their
expertise in the field of engineering. Should they decide to comment, they
will write directly to you.
Please send us a copy of the Final EIS.
cerely
H. McDonald Rimple, M.D.
Assistant Surgeon General
Regional Health Administrator
B-ll
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Advisory
Council On
Historic
Preservation
1522 K Street NW.
Washington D.C.
20005
October 30, 1979
Mr. Jack J. Schrairan
'Regional Administrator
Environmental Protection Agency
Region III, 6th & Walnut Streets
Philadelphia, Pennsylvania 19106
Dear Mr. Schramm:
We have received your request for comments on the draft environ-
mental impact statement for Horsham-Warminister-Warrington,
Pennsylvania Wastewater Treatment Facilities pursuant to Section
102(2)(c) of the National Environmental Policy Act of 1969. The
Council has determined that your draft environmental statement
mentions properties of cultural and historical significance, but
we need more information on the effects of the undertaking on
these resources. Please furnish documentation that you have
fulfilled the requirements set forth in 36 CFR Sec. 800.4(b) of
the Council's regulations, "Protection of Historic and Cultural
Properties" (Attached).
Please remember that compliance with Section 106 of the National
Historic Preservation Act of 1966 (16 U.S.C. 470f, as amended,
90 Stat. 1320); the Council's regulations, "Protection of
Historic and Cultural Properties" (36 CFR Part 800); and Executive
Order 11593 (May 13, 1971); are independent requirements of law
that must be fulfilled unless it has been determined in
accordance with 36 CFR Section 800.4(a) of the Council's
regulations that no properties that are included in or that would
be eligible for inclusion in the National Register of Historic
Places are located within the area of the undertaking's potential
impact and this finding is clearly set forth in the draft environ-
mental impact statement. Accordingly, you should coordinate NEPA
B-12
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compliance with these separate responsibilities as provided for in
36 CFR Section 800.9 of the Council's regulations and the final
environmental impact statement should contain the comments of the
Council obtained pursuant to 36 CFR Sec. 800.6 or 800.8 of the
Council's regulations.
Should you have any questions or need assistance please call Charlene
Dwin at 202-254-3967.
Sincerely,
Jordan E. Tannenbaum
Chief, Eastern Division
of Project Review
Enclosure
B-13
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Soil p- °- Box 985
Conservation Federal Square Station
Service Harrisburg, Pennsylvania 17108
yfV
/ \
November 7, 1979
Mr. Jack J. Schranm
Attention: EIS Preparation Section
Regional Administrator
U. S. EPA, Region III
6th & Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schramm:
The Soil Conservation Service has reviewed the draft environmental
impact statement for the Horsham-Warminster-Warrington, Pennsylvania,
Wastewater Treatment Facility. We suggest adding a discussion of each
of the following items:
1. Both the temporary and permanent erosion and sediment control
measures needed to stabilize the construction areas.
2. The impacts on the prime farmlands that are identified in the
draft EIS.
3. The protection and redistribution of stockpiled topsoil.
4. The proposed project's effects on PA-610 and PA-614, flood-
wat'er retarding dams, within the Neshaminy Creek Watershed project.
All other items of concern to the Soil Conservation Service have been
adequately addressed.
Sincerely,
Graham T. Munkittrick - ^
State Conservationist
cc:
Director, Office of Federal Activities (Mail Code A-104), EPA, Room 537,
West Tower, 401 M Street, SW, Washington, DC 20460 (5)
Norman Berg, Administrator, SCS, Washington, DC
Cletus J. Gillman, Director, SCS, NTSC, Broomall, PA
B-14
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DEPARTMENT OF THE TREASURY
WASHINGTON. D.C. 20220
September 26, 1979
Dear Mr. Schrarrm:
Thank you for forwarding a copy of the draft
environmental impact statement for the Horsham-
Warminster-Warrington, Pennsylvania Wastewater
Treatment Facilities. This Department has no
comment on the Statement.
Sincen
Anthony V. DiSilvestre
Assistant Director7(Environmental Programs)
Office of Administrative Programs
Mr. Jack J. Schratrm
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
B-15
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UNITED STATES OF AMERICA
GENERAL SERVICES ADMINISTRATION
Public Buildings Service
Washington, D.C. 20405
Mr. Jack J. Schramm
Regional Administrator
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schramm:
The General Services Administration has reviewed the
draft environmental impact statement on Horsham-Warminster-
Warrington, Pennsylvania, Wastewater Treatment Facilities,
and have no substantive comments to make.
Thank you for the opportunity to comment.
Sincerely,
CARL W. PENLAND " ""'" ~~
'Acting Director
Environmental Affairs Division
Keep Freedom in Your Future With U.S. Savings Bondi
B-16
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COMMONWEALTH OF PENNSYLVANIA
PENNSYLVANIA HISTORICAL AND MUSEUM COMMISSION
WILLIAM PENN MEMORIAL MUSEUM AND ARCHIVES BUILDING
BOX 1D26
HARRISBURQ. PENNSYLVANIA 1712O
October 4, 1979
Jack J. Schramm
Regional Administrator
U.S. Environmental Protection Agency
Region in
6th and Walnut Streets
Philadelphia, PA 19106
Dear Mr. Schramm:
The Office of Historic Preservation has reviewed the Draft Environmental Statement
on Horsham-Warminster Warrington, Bucks and Montgomery Counties, PA Wastewater
Treatment Facilities Project.
Dr. Barry Kent states that he believes that the BIS would seem to have adequately
assessed the impact on known or potential areas of archeological sites and no further comment
is necessary.
Sincerely,
Barbara Phil{.
Office of Historic Preservation
717-787-4363
BP:jek
B-17
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ea*
Commonwealth
of
Pennsylvania
GOVERNOR'S OFFICE
FICE OF THE BUDGET
P.O. BOX 1323 - HARRISBURG. PA. 17120 - (717) 787-8046
783-3133
RE: PSC-SAIS
APPLICANT: <£
PROJECT:
LOCATION:
' Enclosed with this letter please find the comments of the
following State Agencies relative to the project identified above:
Please consider these the comments of the Pennsylvania State
Clearinghouse at this time.
Thank you for your cooperation.
Sincerely,
J^W^y /A",
Richard A. Heiss/
Supervisor
r
B-18
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
TO:
The Secretary
October 30, 1979
SUBJECT: Review and Evaluation of PSCH No.:
Richard Heiss, Supervisor
Pennsylvania State Clearinghouse
5-79-09-007
DEIS Horsham-Warminister-Warrington
Wastewater Treatment Facilities
Bucks County
FROM: CLIFFORD L. JONES
Secretary of EnvironmentalsResources
The Pennsylvania Department of Environmental Resources has
reviewed the above mentioned draft environmental impact statement. The
Department wishes to offer the following comments on this report.
The Environmental Impact Statement appears to have addressed the
main issues in sufficient detail to allow local officials and concerned
citizens to prioritize the alternatives.
The Department encourages local governments in the project area
to impletnent the recommendations in Section 7.1 (Conversion of Undeveloped
Land), 7.3.1 (Loss of Prime Agricultural Land), 7.3.2 (Loss of Forest Land),
and 7.3.3 (Loss of Wildlife Habitats). Recommendations in these sections
will minimize the adverse secondary environmental iitpacts associated with
the construction of wastewater treatment and collection facilities.
Alternatives 2, 3 and 4 involve the interbasin transfer of
wastewater from a portion of the planning area in.Horsham Township,
Montgomery County/ to the Ambler Sewage Treatment Plant. The Environmental
Impact Statement should address the environmental effect of this transfer.
Permits will be required-for all stream crossings and for facilities
located in the 100-year floodplain. The applicant may contact Gilbert Kyle,
Director, Bureau of Dams and Waterway Management, 407 South Cameron Street,
Harrisburg, PA 17120, 717-783-1384 for further information.
B-19
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FIRST STAGE REVIEW
Preapplication/Notification of Intent
- AGENCY REVIEW COMMENTS
Draft - EIS . ;.
Montgomery ar.d Bucks Counties
Horshaia-Warmnster-VZarrington
Wastavater Treatment ";;
Facilities -.'-'.'
INSTRUCTIONS: To be completed by review agency and returned to State Clearinghouse. Check one or more appropriate boxes.
. Indicate comments below. Return copy 1,2 and 3 to the State Clearinghouse. Retain copy 4 for your official
. . ,' records. Attach triplicate sheets if necessary. . -'j .'...',-.'.' ,. '..,.' ".- ^vi'' '
''"" '*" ''
PART I: Declaration of Interest '"'"' ', : ''-.-. . , . .
^1 No Interest Declared-Complete Part V and "'..:"' Kl Interest Declared - Complete Parts II, III. IV and V and
return copy 1 and copy 2 to State Clearinghouse. " '".-"- , -, return copy 1 and copy 2 to State Clearinghouse. ' '
PART II: Identification of Agency Review Criteria (Agency plans, programs, policies and/or laws) ". .
Departr.cnt of Trar.~fortation Policies and Plans
PART III: COMMENTS (Include results of preliminary contact made with applicant and suggestions for improving project proposal)
There arc- no planned state transportation facilities which would b« adversely affected
by the subject project. However, portions of the proposed project will involve construction
activities on the ri'jht-of-way of state legislative routes. It will be necessary to
coordinate the planned project with cur Engineering District Office in St. Davids e.rA
cV.taJn the proper permits before any v.orlc can be done.
PART IV: Recommended State Clearinghouse Action (This action will not be honored by the State Clearinghouse unless Part II and
with the above Part III above have been completed)
t,.J Recommend Approval conditions. I 1 Request the opportunity to review final application. . "-
[ ] Recommend Disapproval
[ ] Request the opportunity to review environmental impact statement.
PART V: Certification
Authorized Agency Signature
Agency
Depart* '-n1: o
Date
Oct. 10, 1979
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COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF ENVIRONMENTAL RESOURCES
1875 New Hope Street
Norristown, PA 19401
215 631-2426
November 16, 1979
Mr. Richard Pepino
U.S. Environmental Protection Agency
Region III
EIS Preparation Section (3IR60)
Sixth and Walnut Streets
Philadelphia, PA 19106
Re: Horsham, Warminster and Warrington
Draft Environmental Impact Statement
Dear Rich:
The following are comments expressed by us concerning this Draft EIS. First, I
do not understand the reference to the Warminster STP being upgraded to provide
chlorination as both the existing and proposed treatment plants have this
feature. The Current STP project (Contact Stabilization activated Sludge and
Filtration) is not an upgrade but rather an expansion of the existing STP as
previously proposed and approved by the DER. No nitrification or denitrifica-
tion is included in the current project. Is it the recommendation of the Draft
EIS to provide for nitrification-denitrification which would require complete
redesign and increased costs? What level of treatment was used in the Cost
Effectiveness Analysis? The Draft EIS indicates a need for dechlorination,
while this may be true it would be a design change as it is not included in the
original proposal.
According 'to the Draft EIS, under Alternative 1 the Warminster STP would be
expanded by 3.8 mgd to 8.4 mgd. The current plant was originally rated at
3.8 mgd, but was temporarily rerated to 4.58 mgd pending its expansion. Any
expansion to the plant should be on top of the 3.8 mgd that the plant was origi-
nally rated at.
The Phase II I/I work for Warminster and Warrington is yet to be done and is
critical in arriving at the selected plant design for the Warminster STP, espe-
cially for the large Warminster Collection System. Can this Phase II program be
the first component of the Step II work, or does it have to be done prior to
Step II work? This could be important from the standpoint of the April 1, 1980
deadline for past planning funding.
B-21
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What are the alternatives for the following existing STP's: English Village,
Warrington SewerCompany, Christ's Home, Tamanend Jr. High School, Johnsville
NADC and Willow Grove MAS?
Is there adequate capacity in the Lower Gwynedd and/or Upper Dublin sewer lines
to handle Horsham's flows for the extent of the planning period?
In section 4, certain costs figures do not appear to agree between Tables 4-9
and 4-11. For example under Alternative 4, Horsham's cost according to 4.9
would be $1,445,000. Table 4-11 lists Horsham's federal and local shares as
$1,027,200 and $1,119,200, respectively. This adds up to $2,146,400. Using this
$2,146,400 figure this gives Horsham only a 48% federal grant according to 4-11.
Evaluating the alternatives, the Department would be willing to support
Alternatives 3, 4 and 2, in that order. Alternative 1 is unacceptable because
of its adverse impacts and Alternative 5 appears to be too costly. It should be
noted here that before going ahead with any work under Alternaties 3 or 4 prior
approval from our soil scientist and geologist should be obtained.
If you have any quesitons, please feel free to call me at 631-2426.
Very truly yours,
y^k»v i -fa
John F. Fabian
Project Manager
JFF:smc
cc: Wapor.a, Inc.
Montg'omery County Planning Commission
Delaware Valley Regional Planning Commission
Bucks County Planning Commission
Horsham Township Sewer Authority
Warrington Township Sewer Authority
Warminster Township Sewer Authority
Willow Grove Naval Air Station
Grants File
Ce 30
W261/.1
B-22
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'-. \V -.}{.}. \~ M.l KY . / '
I v : X i! < >N A K J'I. A N N I ? ( , ('( ! ' ' \ !.- S ' > "s
Penn Towers Building, 1819 J. F. Kennedy Blvd., Philadelphia, Penna. 191O3 LOcust 7-3OOO
TESTIMONY PRESENTED
BY THE
DELAWARE VALLEY REGIONAL PLANNING COMMISSION
ON THE
DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR WASTEWATER TREATMENT FACILITIES
IN
HORSHAM, WARMINSTER AND WARRINGTON TOWNSHIPS
I am J. Robert Gallagher, Chief, Water Resources Planning for the Delaware
Valley Regional Planning Commission (DVRPC). I am here tonight to present
testimony regarding the draft Environmental Impact Statement for Wastewater
Treatment Facilities in Horsham, Warminster and Warrington townships.
DVRPC is the official regional planning agency for the Trenton-Camden-
Philadelphia Metropolitan region, which encompasses Bucks, Chester, Delaware,
Montgomery and Philadelphia counties in Pennsylvania and Burlington, Camden
^
Gloucester and Mercer counties in New Jersey.
DVRPC, which began its existence in 1965 was established by an Interstate
Compact enacted by the Legislatures and approved by the Governors of Pennsyl-
vania and New Jersey. Its 18 member governing Board is appointed by the chief
elected officials of the counties and cities of the region and the Governors of the
two States. Mr. Blase Ravikio is currently the Chairman of the DVRPC Board.
B-23
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DVRPC's present comprehensive planning program includes the following
.elements: land use, recreation and open space, water pollution control, water
supply, storm drainage, flood control, highways, public transportation and housing.
DVRPC's job is to prepare plans for needed facilities and to coordinate the many
governmental actions that lead to implementation of those plans.
In addition, DVRPC is the officially recognized review agency for federal
grants which fund local projects involving land acquisition or construction. We are
required to review applications for such grants and advise federal officials as to
whether these projects are consistent with regional plans and regional needs as
determined by the DVRPC Board.
The DVRPC has adopted a series of plans for this region including a Water
Supply and Water Pollution Control Plan, Land Use Plan, Transportation Plan, Open
Space Plan and a Housing Allocation Plan. Our plans are subject to continuous
refinement and amendment, and are updated each year. The purpose in all efforts
is to achieve a better coordinated and more efficient and socially desirable pattern
of development for the benefit of all five million residents of the region. All of the
water pollution control planning we have accomplished to date has been
undertaken within this context.
On July 1, 1975, DVRPC became the areawide waste treatment management
planning agency for its nine-county planning area. Section 208 of the Water Pollu-
tion Control Act Amendments of 1972 (Public Law 92-500) requires that DVRPC
investigate point and non-point sources of water pollution, evaluate wastewater
treatment alternatives, and develop a 20-year waste treatment management plan
for the region.
B-24
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The 208 Plan for Bucks, Chester, Delaware, Montgomery and Philadelphia
counties was officially adopted by the DVRPC Board on September 21, 1978 and is
presently under review by DER pending certification by Governor Richard Thorn-
burgh.
DVRPC's staff has been extensively involved in the planning process with the
communities of Horsham, Warminster and Warrington to find a solution to their
wastewater treatment and water quality problems. Our efforts have been
undertaken in a spirit of cooperation to devise and implement a cost effective
solution to the problems confronting these three townships while providing
maximum protection for the environment. It is in this same spirit that we offer our
comments tonight.
Planning for wastewater treatment facilities in Horsham, vVarminster and
Warrington was underway prior to the initiation of DVRPC's COWAMP/208 Plan
and continued in parallel with our efforts. As such, it was the policy of
COWAMP/208 to utilize the results of this local planning effort when it was
completed and the associated Environmental Impact Statement (EIS) finalized.
i
The five alternatives presented in this EIS (barring the no action alternative
which is unacceptable) all provide varying degrees of relief which will meet the
wastewater management needs of these communities. DVRPC staff has thoroughly
reviewed each of five alternatives and based on the availability of federal funds
feels that Alternatives 2, 3, and t best fulfill the requirements of PL 92-500, the
Pennsylvania Clean Stream Law, COWAMP/208 and county and local plans. We
B-25
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would find difficulty in supporting Alternatives 1 or 5 based on the fact that the
draft EIS rates Alternative 5 as the most costly with Alternative 1 as the second
most costly. This fact coupled with the adverse environmental impacts associated
with Alternatives 1 and 5 makes support of either of these alternatives question-
able.
There are, however, other factors that have come to light since the initiation
of the preparation of the draft EIS of which EPA should be cognizant and which
should be addressed before the preparation of the final EIS. The recent application
for a NPDES permit for the privately owned Wichard Sewer Company has serious
consequences in terms of population served, availability of treatment capacity, and
water quality for Park Creek.
The questions surrounding the proposed 600 unit development to be served by
the Wichard SewerCompany must be resolved before final approval of a wastewater
treatment system for Horsham Township is given. By the same token, barring the
possibility that Alternative 1 is selected, the treatment configuration for
Warrington and Warminster recommending upgrading and expansion of the
Warminster STP to service the needs of these two communities is common to all
other alternatives. As such, satisfying the needs of Warrington and Warminster
townships should proceed independently of any Horsham decision and application
for federal funds made as soon as possible to get the Warminster expansion and
upgrading underway.
Many long years and meetings have passed since planning for wastewater
treatment was begun in this area of Bucks and Montgomery counties. During this
time, there have been many hard decisions to be made, but the hardest decision is
now before us. This decision will ultimately be made by the authority members and
elected officials of Horsham, Warminster and Warrington townships.
B-26
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The decision reached should provide the wastewater management solution
that is the most cost effective and environmentally sound.
In closing, DVRPC would like to commend the EIS Branch of EPA and their
consultant Wapora, Inc. for a fine draft EIS, for the attention given to this study
and for the commitment to seeing it through to a final resolution.
Thank you.
B-27
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GERALD M. HANSLEH
EXECUTIVE DIRECTOR
DELAWARE RIVER BASIN COMMISSION
P. D. BOX 736D
WEST TRENTON,NEW JERSEY QB6ZB
(BD3) BB3-35OD
November 2, 1979
HEADQUARTERS LOCATION
25 STATE POLICE DRIVE
WEST TRENTON, N J
Mr. Jock J. Schramm, Regional Administrator
United States Environmental Protection Agency, Region III
6th and Walnut Streets
Philadelphia, Pennsylvania 19106
Attention: E|S Preparation Section
<3^^
Dear Mr.JJduamm:
Subject: Draft Environmental Impact Statement, Horsham-
Warmlnister-Warrington, Pennsylvania Wastewater
Treatment Facilities.
We have reviewed the subject DEIS with a primary focus on the relationship
of the proposed regional sewage facilities to the water resources of the Delaware River
Basin.
The Delaware River Basin Commission is concerned with existing and future
ground-water quantity and quality conditions in Bucks and Montgomery Counties . We
anticipate that soon after the first of the year, following public notice and hearing,
the Commission will act to delineate and declare a ground water protected area en-
compassing Chester and Montgomery Counties, major portions of Bucks County, and
portions'of Berks County, Pennsylvania. (Also delineated will be portions of Hunterdon
and Mercer Counties in New Jersey.) The Horsham-Warminster-Warrington study area
would be included. This action is contemplated in response to a general consensus at
public meetings that the Commission utilize its authority under Article 10 of the Delaware
Basin Compact to designate protected areas and establish regulations for management of
the limited ground-water resources. It will be proposed that any project having a re-
lationship to further depletion of ground water in the protected area will be subject to
special consideration and review beyond that given under Commission review under
Article 3.8 of the Compact.
Related to this proposed action is the Commission's three-year ground water
study which was initiated in May, 1979. The study purposes are to develop a sound
basis for the management and allocation of ground-water resources to avoid over-
commitment, environmental damage, and general controversy. The study will cover
the entire Delaware Basin, but will focus on problem areas such as the Triassic and
Carbonate geologic formation found in the Horsham-Warminster-Warrington sewage
study area.
B-28
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Mr. Jack J. Schramm -2-
The foregoing indicqtes that while the Draft Environmental Impact Statement
has identified and considered many of the environmental aspects of a proposed regional
sewerage system, it has not fully considered the overall water resource problems. While
we recognize that the DEIS cannot consider and resolve all water resources problems in
the region, it seems inadequate to acknowledge known and probable ground-water deficits
without consideration of availability of new or augmented water supplies to accommodate
projected growth.
We appreciate the opportunity to review and comment on this DEIS.
Sincerely,
Gerald M. Hansler
B-29
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MONTGOMERY COUNTY PLANNING COMMISSION
courthouse norristown, Pennsylvania 19404 "215-278-3722
October 26, 1979
Mr. Richard V. Peppino
United States EPA - Region III
6th and Walnut Street
Philadelphia, Pennsylvania 19106
Dear Mr. Peppino:
Enclosed for your record is a copy of the Montgomery County Planning Commission
statement regarding the Horsham-Warrington-Warminster EIS. This is the statement
I gave at the public hearing on Tuesday.
Also enclosed, please find a list of technical comments on the EIS document
prepared by staff. I trust you will find these two documents helpful in pre-
paring the final EIS document.
Sincerely,
Gregory E. Prowant
Senior Planner
GEP/de
Enclosures
B-30
Offices. One Montgomery P/.ico, Su'cde and Airy Streets, \orristou-n
-------
MCPC Statement
to the EPA
Regarding the Park Creek EIS
October 23, 1979
My name is Gregory Prowant. I am a Senior Planner with the
Montgomery County Planning Commission.
I would like to commend EPA and their consultant, Wapora, for
preparing a very professional document on a very complex project.
The EIS: provides a good technical review of the issues; has
allowed for input by the agencies, municipalities, and concerned
individuals; and provided for a dialogue on the issues in meetings
such as this one tonight.
In reviewing the original Park Creek interceptor proposal, our
perspective was on the environmental and land use impacts. We
feel the EIS has.firmly documented that the environmental impacts
of the Interceptor proposal (Alt. #1) are clearly unacceptable.
The EIS provides a series of viable alternatives to the inter-
ceptor and provides a comparison of the environmental impacts and
fiscal costs of each alternative. We have reviewed the given
alternatives and recommend the following:
1. Alt* #1.- The Park Creek -Interceptor, should be rejected as
unacceptable.
2. That Warminster and Warrington be allowed to proceed with
their project without Horsham flows.
3. That Horsham proceed with an alternative to the interceptor
thai; has the least environmental impacts and is most cost
beneficial. The MCFC recommends that Alt. S3 and Alt. #4
are the most cost beneficial alternatives.
Alt. #3 and Alt. H are:
A. Most consistent with township comprehensive planning
and zoning.
R. Would provide 85% federal funding on innovative systems.
C. Would solve the problems in a way consistent with environ-
mental and land use planning goals.
It the township is hesitant to accept alternatives with innovative
systems we would point out that such systems are working elsewhere
in this region.
We would be willing to discuss such innovative systems with repre-
sentatives of the township.
B-31
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Page 2
' i *
- MCPC Statement to the EPA - continued
Alternatives #2 and #5 are potentially viable alternatives, but '
their environmental impacts and the possible inducement of growth
in the more rural portions of the township make them less desirable
alternatives. In addition, Alternative #5 is financially a much
more costly alternative to the township and the residents.
We, therefore, recommend selection of Alternatives #3 or #4 as the
most cost/beneficial with least environmental impacts, and stand
ready to assist the township in implementing the final alternative.
To conclude my statement I V?ould like to point out one key issue that
the EIS does not address: "The Wichard Sewer Co. Facility."
We feel it must be considered in the final.EIS document because:
1, It has municipal approvals.
2. PUC order for franchise is complete.
3. It is now awaiting DER approvals for 537 and NPDES permit.
4, It will significantly impact the Park Creek solution.
Wichard .Facility provides some obvious opportunities to the Township.
1. The developer will build a plant.
2. This could serve a significant portion of subarea 8, in addition
to Country Springs.
3. The developer could turn the plant over to the Township.
t
4. The Township has a written agreement to the above. Unfortunately,
this opportunity for Township may jeopardize any hope for a
federal grant;
> _ _
- a private facility and anything it serves will not be
fundable by EPA;
- the project area population will be reduced thereby reducing
the DER project priority points;
-* the reduced area and population will change all cost estimates.
We urge EPA to consider this important issue in the final EIS document,
and DER consider it in reviewing the Wichard Sewer Facility Application.
Thank you!
GPmp
B-32
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County Commissioners
G. ROGER BOWERS. Esq., Chairman
GEORGE M. METZGER
JOHN T. WELSH
COUNTY OF BUCKS
BUCKS COUNTY PLANNING COMMISSION
Cross Keys Office Center
Doylestown, Pa. 18901
A. Katherine Lattomus
Vice Chairman
Harold 0. Gross, Jr.
Ralph R. Pisani
Elinore R. Ridge
Box 12 4259 Swamp Road
215-348-2911
Daniel K. Cook
Chairman
Robert E. Moore
Executive Director
Michael S. Morrison
Secretary
Anna C. Simons
William R. Snyder
Frank B. Uphoff
October 24, 1979
Richard V. Pepino, Project Monitor
U.S. Environmental Protection Agency
6th & Walnut Streets
Philadelphia, PA 19106
Dear Mr. Pepino:
The Bucks County Planning Commission has reviewed the Draft
Environmental Impact Statement for the Horsham-Warminster-Warrington
Wastewater Treatment Facilities. Our analysis indicates that with
the exception of the no action alternative (alternative 6), all the
alternatives propose relatively similar actions for Bucks County.
In general, they propose a substantial upgrading and expansion of
the Warminster Sewage Treatment Plant and that all areas in the
Bucks County portion of the study area be sewered by that plant.
Because of the similarity of the alternatives, there does not
appear to be a substantial difference between the environmental
advantages and disadvantages and the economic costs of the alter-
natives as they relate to Bucks County.
Because there are only small differences in the impacts of
the altarnatives on Bucks County, the Bucks County Planning Commis-
sion supports whichever alternative can be implemented with the
minimum of delay. At the present time there are pressing needs in
Bucks County in areas presently served by malfunctioning on-site
systems and in areas served by small package treatment plants that
have difficulty meeting stream discharge and plant operation stan-
dards. In addition, there are a number of proposed developments
that have received all of the necessary municipal planning appro-
vals but which cannot proceed because of a lack of sewage treatment
capacity.
If the Bucks County Planning Commission can be of any assis-
tance in moving this project toward completion, please do not
hesitate to contact me.
Sincerely
REM/TK/tlm
Robert E. MooH?
Executive Director
B-33
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PREPARED COMMENTS OF THE TOWNSHIP OF HORSHAM
SEWER AUTHORITY ON THE DRAFT ENVIRONMENTAL
IMPACT STATEMENT PREPARED BY THE UNITED
STATED ENVIRONMENTAL PROTECTION AGENCY, REGION III
On Page 5 of the Draft Environmental Impact Statement,
under the heading "On-site Disposal System Failures", there is
an all too brief summary of some of the reasons why a sanitary
sewer system was proposed for construction in certain areas of
Horsham Township. In addition to reports of on-site septic
failures, confirmed cases of hepatitis and similar health problems
were brought to the attention of the Township of Horsham Sewer
Authority. In response to this, the Township of Horsham Sewer
Authority, in 1967, submitted an application to construct a small
Waste Water Treatment Plant on the Park Creek. Plans were submitted
vto appropriate review agencies and after considerable study, it vTas
determined that the proper method of insuring high standards of
sewage treatment for effluent to be discharged into the Neshaminy
Creek was to formulate a regional plan of waste water treatment for
the area in question. The Pennsylvania Department of Environmental
Resources decreed that the Townships of Warminster, Warrington and
Horsham should form a committee to develop a regional approach to
waste water management. After many years of study and following
many meetings which were attended by representatives from various
planning and regulatory agencies, a regional plan, consistent with
the then current Sewage Facilities Plan published by the Montgomery
County Planning Commission, was devised whereby sewage would be
conveyed from portions of Upper Dublin, Lower Gwynedd and Horsham
Townships, through Warrington Township, into an expanded sewage
plant to be constructed in Warminster Township. The Horsham portion
of this proposal was certified by the Pennsylvania Department of
Environmental Resources for federal assistance on May 22, 1977.
s
The original Park Creek Project consisted of a system of
gravity sewage collectors and an interceptor transmitting flows to
a small plant located on the Park Creek. The regional plan
directed by the Department of Environmental Resources changed this
concept to what has been commonly called "The Big Inch", a large
interceptor designed to transmit sewage flows out of the Township
of Horsham and into a Warminster Township Treatment Plant. Following
directives of appropriate regulatory and planning agencies, the
Township of Horsham Sewer Authority.submitted what is now referred
to as the "Proposed Action" or as Alternative I in the Draft
Environmental Impact Statement.
Unfortunately, this "Proposed Action" appears no longer
viable due to escalated construction costs and the likelihood of
appeals from citizens' groups and the United States Navy, both
groups seeking to prevent its implementation. In addition, the
"about face" taken by state and federal agencies in looking toward
innovative technology" instead of regional sewage treatment plants,
would appear to militate against the proposed action. Fortunately,
it appears that most, if not all, of the engineering design prepared
B-34
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to implement a regional sewer system is still useful in implementing
any of the other four alternatives. It is suggested that if
Alternative I is not deemed fundable by the Environmental Protection
Agency, that Agency should direct a redesign in order to implement
any of the other fundable alternatives. If this is done, the
maximum amount of engineering fees can be recovered through a
federal grant.
In reviewing other alternatives, the Authority must first
express its concern as to the feasibility of implementing what have
been labeled Alternatives III and IV. An initial look at these
two alternatives would seem to indicate that the cost factor is one
consideration heavily weighing in their favor. After careful
review, it appears that there are several cost factors which may
not have been considered, including:
A. Land Acquisition;
B. Board of View;
C. Source of Revenue for Maintenance
and System Replacement;
D. Items listed later in discussions
of Alternative II.
Further study of both Alternatives III and IV generate
additional questions and comments, such as:
A. Do the proposed community systems utilize any
gravity collection or will they be exclusively
pressure systems requiring grinders, pumps, etc.;
B. Has a method for providing a right-of-entry onto
private property to insure maintenance and proper
operation of the systems been discussed;
s
C. Has possible adverse home owner reaction to a
management group imposing "sewer rentals" in
order to provide revenues for maintenance and
operation of the system been evaluated;
D. In suggesting the types of systems set forth in
Alternatives III and IV, has the Environmental
Protection Agency considered the possibility of
unanticipated growth in other areas of the
Township where soils may be equally suitable for
this type of system;
E. Have the costs of land acquisition, Boards of
View, etc. been included in the Project Cost
deemed eligible for funding;
F. Has a source of revenue to replace the systems
after the expiration of the "two year free
replacement" period been included in the
Project Cost;
B-35
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G. Does the Environmental Protection Agency consider
Alternative IV a temporary solution, given the
discussion contained in Paragraph 1 of
Section 4.3.3.4 of the Draft Environmental Impact
Statement;
H. Since there have been many documented cases of
TCE and PCE pollution of ground water supplies
caused by discharges from on-site systems in the
study area, and since a large number of home
owners in sub-areas 4 and 5 make use of indivi-
dual wells as a source of water supply, can the
use of individual on-site or community on-site
systems now be considered environmentally safe.
The Authority feels that Alternative IV is totally unwork-
able for reasons previously set forth. In addition, the Township
of Horsham Sewer Authority must express great reservation as to the
ultimate feasibility of Alternative III as well. Unless the
questions concerning management, funding, maintenance, operation,
and questions of potable ground water supply can be adequately
answered, it would appear that Alternative III is as non-viable as
is Alternative IV.
Alternative V suggests construction of a small treatment
plant located on the Park Creek. In effect, this is almost "full
circle" back to 1967. Rather than comment on this alternative, the
Township of Horsham Sewer Authority prefers to raise the following
questions, which it feels must be addressed by the Environmental
Protection Agency prior to the Authority attempting to make comment
on this alternative:
A. What effluent criteria and process design data
were used to compute the costs of this Alternative;
B. Is the inclusion of certain sections of Upper
' Dublin Township realistic when evaluating this
Alternative;
C. It appears in suggesting a 500,000 g.p.d. plant,
the Environmental Protection Agency has computed
flows at 230 g.p.d. per equivalent dwelling unit.
It should be noted that the Department of
Environmental Resources requires design flows of
350 g.p.d. per equivalent dwelling unit.
Assuming that the Department of Environmental
Resources standards prevailed, it would seem that
the plant capacity would be adequate to serve
only 66% of the population projected as using
it in the Draft Environmental Impact Statement.
If 7-vlternative V is to be adquately evaluated, the
final Environmental Impact Statement must consider the effect of
the Wichard Sewage Treatment Plant and the proximity of the
Country Springs Development. It should be noted that despite the
language of Sections 2.8.1.1 of the Draft Environmental Impact
Statement, the Township of Horsham Sewer Authority did not approve
the Wichard Sewage Treatment Plant. There is an existing Agreement
with the Wichard Sewer Company whereby the Township of Horsham
B-36
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Sewer Authority has certain alternatives should a Certificate of
Convenience be granted to the Wichard Sewer Company by the
Pennsylvania Public Utility Commission. The Agreement between Wichard and
the Township of Horsham Sewer Authority allows "purchase" of the plant afte
construction, and also provides the ability to purchase "treatment
capacity" in that plant. Another avenue open to the Sewer Authority
would be purchasing the Wichard plant design prior to construction
and constructing the plant to service sub-areas 4 and 5 as delineated
in the Draft Environmental Impact Statement.
Until the effects of the Country Springs Development and
alternatives provided by the Agreement with the Wichard Sewer
Company are included in the Environmental Impact Statement, the
true viability of Alternative V's solution can not be adequately
evaluated. Equally, if not more important, is the question of
which Authority costs relating to the Wichard Sewage Treatment Plant
would be eligible for federal funding should the Authority elect
to build the plant, buy the plant or purchase plant capacity.
Alternative II, transmitting flows through Lower Gwynedd
Township to the Ambler Sewage Treatment Plant, appears to be a
reasonable approach, but still presents several unanswered questions,
such as:
A. Is sufficient capacity presently available in
the Ambler Plant, Lower Gwynedd Force Main and
Pump Station, to adequately serve Horsham's needs;
B. Have costs of land acquisition, pump station,
and a presumed capital contribution to both
Ambler and Lower Gwynedd been included in
determining the cost figures contained in the
Draft Environmental Impact Statement;
C. Is the capital contribution presumed necessary
to acquire both plant and line capacity from
Ambler and Lower Gwynedd respectively, eligible
for funding;
D. Can Horsham Township Treatment Areas 7 and 8
be separated from Treatment Areas 4 and 5 and
set forth on a separate grant application in
order to obtain immediate funding;
E. Has the cost of presumably increasing the pipe
size in Lower Gwynedd Township been included in
the financial considerations comprising this
Alternative.
The Township of Horsham Sewer Authority notes in passing
what appears to be great disparity in the population figures pro-
jected by the Horsham Township Planning Commission, Montgomery
County Planning Commission, Delaware Valley Regional Planning
Commission, and the existing 208 Study. It is requested that the
answers to this and all questions raised in this Testimony be
included in the final Environmental Impact Statement.
B-37
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In conclusion, the Township of Horsham Sewer Authority
urges the Environmental Protection Agency to fund alternatives which
alleviate existing health problems, serve the greatest areas in need
of service and can be implemented rapidly. The concern of the
Township of Horsham Sewer Authority has always been, and is now, a
desire to service areas which are drastically in need of sanitary
sewer service. Recent rainfalls have more than amply demonstrated
that the problem still exists and is only becoming worse as time
passes. It is respectfully suggested that the time for gathering
comment has long since passed, and the time to solve existing
environmental problems is more than at hand.
Respectfully submitted,
TOWNSHIP OF HORSHAM SEWER AUTHORITY
BY
L> jrcoas
Chairman
B-38
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1108 Limekiln Pike
Box 67
Maple Glen, PA 19002
November 14, 1979
U. S. Environmental Protection Authority
Region 3 (SIR60)
6th & Walnut Street
Philadelphia, PA 19106
ATTENTION: Mr. Richard V. Pepino
Project Monitor
Gentlemen:
I have had a chance to review the draft environmental impact statement on
Horsham-Warminster-Warrington, Pennsylvania and was an interested attendee at
the public hearing held on October 23, 1979. At that time I did not testify but would
like to make the following statements regarding my own situation.
I have lived in an old farmhouse on 36 acres on the southeast corner of
Limekiln and Horsham Roads for 24 years and have had a constant problem with my
sanitary system at this location. I called in a civil engineer 10 years ago, brought
in a backhoe to do perculation tests, constructed a second septic tank and installed
an extensive tile field in the supposed "best" depth and still have a severe problem
with proper drainage of wastes. Fortunately, this area is downhill and downwind of
my home which makes it fairly tenable.
I believe it is vitally important that you people recommend a solution which
may not look economically feasible currently but which will solve the problems on a
long term basis. Because of the buildup around this section of Horsham Township
great pressures will develop for this area to be inhabited more densely and any-
thing that we do at this time should be adequate to take care of this. In any event,
the most important thing is to solve the myriad of problems that those living in the
township have had for many years.
Very truly yours, /
Daniel S. Whiteman, Jr. /
B-39
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' BEFORE EPA - October 23, 1979
It gives mo graat pleasure to praise the in depth study the EPA
has presented to us in tho form of the £15. Either Alternatives 3 or 4
would be very acceptable means of caring for thg sewer problems in Horsham
Township. I rsalizs this tnok a tremsndous amount of work and cooperation
of the various government agencies to compile this information, lf for
one, am most appreciative of your efforts.
One section of the EIS deals with the proposed package sewer plant
for Wichnrd Sewer Co. Some of the event^leading up to the approval of
this package plant fill me with grave concern regarding the legality and
far reaching financial affects of actions taken by Horsham Council.
.. . , ^ > ?:<2cJ-~&~J^t~^&.J. ''*--*-£. Ji"*--? rf-LC^ (U^.tnA.TAT-:3^??:^6^5S^fe^e. applied to the PUC for
approval. Five residents and the Montgomery County Planning Commission
requested a public hearing to present testimony regarding why approval
should not be granted. Basically we were worried about the affect this
would hove upon the end results of the EIS, the possibility of losing
federal funding, not enough ground water to supply this projected growth,
making an individual rather than a municipal sewer authority in charge
of sewaring a large portion of western Horsh.-m Area "D" Sewer District.
The Township Council &. Sower Authority were represented by Solicitor,
Mark Jonas, who stated the Township wa-'j remaining neutral.
HER Testified at the hearings anu said that it was their fooling
that in the event of a sewer intercept r by 1903 they saw nothing in
the agrsement betwscn V.'ichard Sewer Co. &. I' :rsh :.n Sewer Authority that
would make the developer hook into the in1, top,or at any tima. This
would le-^VQ a small number of ;-.' jple t f.. 1 th interceptor and oven
with federal funding could be b^uk. >.,, . i,:,,
No word was heard by tho residents until July 1979, at which time
the PUC granted approval of tha Wichnrd Sawcr Pnckagg Planto
We felt hopsful that HER would djny thlu request in viow of their
past position, and it was not until Ssptarnhnr 1979 that I contacted DER
to sea if l/ichard Sev/er Co. had appliad far ,i,j,. roval, und found that DEfl
had received ths application in February 1979, but had not rendored a
Under tho "right to know" law I received a copy of their file with tho
exception of the rv.p showing tha nrea to be inclydod in tho Uich^-rd Sis
B-40
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-2.
System. ,
Included in the packet wes a letter addressed^ Mr. Richard Drown,
Twp, Mgr* from the Department of Environmental Resources regarding
the proposed Wichard Sewer Company package plant.which readst
Dear Mr*
Tha advisory review has bean completed for the copies of the planning
modules for land development for the above referenced project*
Tha following items are provided for your informations
1* The P.U.C. approval was denied*
2* T^a Bureau of Water Quality Management questions the suitability of
tha water supply for this project*
3* Sinca your Township has not accepted this project for review and has
forwarded no comments to that effect, the Department of Environmental
.oa-tM^-cT
Resources cannot accept this j££^*et for review for approval or danial*
The developer should be notified of the Department's decision, by your
Township*
If I can annwsr any qusstions, please feal frca to contact me*
SRMSSXVXX Very truly yours,
Michael C. Duck, R.5*
Sanitarian
Montgomery County
MCB/JM
cci Mr. James Rudolf
Hay 8, 1979, by Resolution^ tha Horshom Council at only a public
meeting voted to amend the sewer facilitioa map to allow Wichard Sewer
Company to take over a portion of Area "DH with a package treatment plant
to dischnrge into Park Creek, Hughes- voted against - Nesbitt was absent.
Thia action of Council is of questionable legality, because thay were
amending an Ordinance with a mara resolution or motion*, with no publication
in the newspapers or public hearing, Horsham's Home Rule Charter myndstea
a public hearing end ordinance on land development and l;;nd usa regulations*
B-41
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-3-
Furthsrmor38 Ordinenca 201, changed to Ord, 6000, establishing a System of
Sewers In Horaham and rules and regulations regarding tham states in
Section 3 "The location of eewara or any extension thereof shall ba
designated by ORDINANCE and said ordinance shall incorporated by reference
the general provisions of this ordinanca and any amendments thereto,"
Every change in the Sewer Facilities Plan up until April 10, 1979,
had been enoctsd by Ordinance after e public hearing had been held*
Ordinance 6310, which defines Area "D" as a sawer district (which includes
most of western Horsbam from Norristown Rd. to tower State- from Welsh Rd.
to County Line Rd.) - clearly states in the heading of the Ordinance
"To be served by an extension af the sewer system to be constructed by the
TOWNSHIP OF HDRSHAM SEb'ER AUTHORITY".
Wichard Sewer Company according to the resolution takes a section of
Area "D" from under the protection of th2 Horsham Sewer Authority and puts
it in ths hands of an individual* Therefore, according to Ord. 6010,
allowing an individual to construct a package sewer plant in Area "D" ia
WITHOUT AUTHORITY.
I have tried to sacura a copy of the map showing the area taken out
of Area "D" and placed under the Jurisdiction of Wichard Sewer Co« without
success* Normally it is attached as a map along with the Ordinance.
In order to secure approval from tha PUC, Wichard Sewer Company had
to show need* Obviously they could not show a problem on vacant oraundo JUT^^
--t<4j_ p^-f&n-t t*~ pu<-+f^t^.y- /^.-~> x^j-^-,.
One member of a government branch told me that -At'COM^cod Country Springs ^
and tho Fox DevelopmRibt. Should this be the case, and if tha Rosolution
ware legal, the Fox Development would bs out of ths jurisdiction of tho
EPA *s EIS for federal funding. It would then appear, in order to shew
need so that a developer could erect a package eewar plant*. ouw awn citizens
who have Buffered with sower difficultieo will be made to pay FULL PRICE
for sewero in accordance with costs £»nd rotes established by Wichard Scswsr
Company while other nay pay only 25£ of the cost for thnir cowers - assuming
we get fednrol funding with this large segment of tha area delated.
To the bout of ny knowledge DER hc-s not votod on b'ichsrd Suwor Plant.
Haw that thay aro awars of those irregularities. .let us hope they will
vote against this plant and the iosuo will bo dcad^^X" l< *~J/<
It was after the DER letter of April 4, 1979jj thst HorshamCouncil
changsd its nautral position and took a positive stand by giving its
A. 6 */
-------
-4-
Wichard Sew er Package Plant complicates both tha EPA solution and
the federal funding aejimtk far SBWBI installations in Horoham,
It also indicates that explosive growth will occur end the danger
of crowding the Naval Air Station out as well as not having enough
ground water for our people will be very reel*
Elizabeth H.
U
B-43
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721 Butler Pike
Maple Glen, Pa. 19002
Mi 6-3873
Oct. 14, 1979
Mr. Richard Pepino, Project Monitor
EIS Preparation Section
U.S. EPA, Region III
6th and Walnut Streets
Phila., Pa. 19106
Dear Mr. Pepino:
In compliance with Mr. Schramm'a requirements I am hereby
' submitting to you a copy of my proposed testimony to be presented
at the Oct. 23rd hearing at the Keith Valley Middle School in
regard to the Draft EIS.
I know you appreciate our sense of pleasure and relief to receive
the long awaited Draft EIS after these years of anguish over the
fear of imposed sewers and unresolved sewage problems. If rational
and unselfish minds prevail there need be no further suffering.
As you know, I have studied the Draft EIS carefully just as I
have studied all documents and articles relating to the proposal
for the last four years. You will recall that I have attended all
public meetings and several "closed" EPA and DER meetings relating
to the proposal when few if any township officials bothered to
do so. 'My study of the many scientific, technological and economic
advances that have been madeii -on-site wastewater treatment in
recent years gives me the confidence that I can make an informed
analysis and evaluation of the Draft EIS.
My overall evaluation and comments will be brief because it is
imperative that I concentrate on a single (readily correctible)
flaw in this Draft version of the EIS.
Alternative number 1 may be immediately dismissed because it
is so similar to the original proposal which brought about so
much opposition from many quarters with volumes of documentation of
its faults, that are unnecessary to repeat here. ;:ost of us were
confident that it would be shown not to be cost effective and
highly environmentally and socially damaging.
B-44
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-2-
Alternative 2 is only slightly better since it still includes
far too many homes that should not be sewered.
Alternative 6 would have been appropriate 10 years ago had
Horsham and the DER vigorously pursued a program of upgrading
on-site alternatives and improving drainage patterns. Today it
is obviously unacceptable. Alternative 5 is far too costly.
Alternatives 3 and 4 will apparently meet with the least amount
of citizen opposition in Horsham since the Draft EIS indicates
. them to be the most cost effective, least burdensome to the
individual home-owner, and most environmentally sound while still
adequately addressing the problems.
Alternative 3 would probably be acceptable (with modification)
but I am disturbed that it would apparently cost almost twice as
much in Horsham as alternative 4 even though the local share would
be slightly less. Also, a typical family of four would pay $304
in annual charges for alternative 3 but only $182 for alternative 4,
Alternative 4 also appears more attractive because the emphasis
is on the appropriate technology for each individual area or
household, an approach more in keeping with modern EPA philosophy,
energy conservation, congressional mandate and good environmental
sense (Krishnan, 1978). Alternative 4 makes it implicit , though
not stated, that over a 20 year planning horizon on-site technology
and scientific testing will advance at an ever accelerating rate
so that'upgrading can proceed ever faster on an individual basis
at less expense and more readily than on a community-wide basis.
Certainly it would be unwise to limit the alternatives to only
sandmounds or conventional types of septic systems when better and
better approaches continue to be available. In that light, it seems
unrealistic to expect much use of holding tanks. The enormous
amount of experience of the last 30 years in all parts of the
developed world with blackv/aste separation and greyv/ater treatment
can be considered within the present DER regulations and in the
required 4% set-aside for innovative alternatives. It provides
an ideal opportunity for the DER to use the torsham experience
to initiate the district management agency concept which it is,
after all, mandated to do at an 85% federal cost share.
B-45
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-3-
As we all know, residents have in many cases delayed taking
appropriate action to correct septic problems because of the
threat of sewers. With that threat lifted, an enlightened, progressive
and aggressive program of preventive maintenance may be instituted
along with the remedial measures. The Horsham Sanitary Board
will be freed of any constraints in aiding the Sewage Enforcement
Officer in swift correction of septic problems. The district
management body would function in education of the public in
methods of maintenance, water conservation and grease and solids
reduction. It would oversee periodic septage removal by various
means such as a periodic permit renewal and inspections. (Klshnan,
1978).
The Horsham Sanitary Board would be particularly interested in
the appropriate on-site solutions because "the home-site itself
is a kind of self-quarantine and does not carry the health risks
associated with multiple-home collection sewers" (Calif. State
Water Resources Control Board, 1977).
The flaw in the Draft EIS to which I earlier alluded relates
only to the Maple Glen triangle but moat particularly Welsh Road
(between Limekiln and Butler Pikes) and Butler Pike (between
Welsh Rd. and Limekiln Pike). As you are aware, the people in
this area have vigorously opposed their inclusion in any sewering
scheme from the first announcement of the original proposal while
;
supporting rapid . action . for those desiring solution to septic
problems. Enclosed is a copy of a petition requesting that all of
the Maple Glen residences (including a part of Limekiln Pike) be
excluded. Hov;ever, my remarks will refer only to V/elsh Road and
Butler Pike. I will let the people of Limekiln Pike speak for
themselves. The three fourths of a mile of these two roads has
15 houses. Four of the houses are -beyond 150 feet from the road
and would not have to hook into any sewer although they would have to
pay front footage.
None of these residences have septic problems that could not
be solved by conventional means. Unlike the areas where problems
have arisen, e.g., the Fox development, the houses are widely
spaced with considerable acreage and the drainage is reasonably <-;ood.
B-46
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-4-
It should be noted that the 1978 aerial imagery survey indicated
no problems there. Horsham Clinic gravity flows to Limekiln Pike
or Tennis Avenue and is soon to be connected to the Upper Dublin
sewer system.
What would an interceptor line along VJelsh Road and Butler
Pike accomplish?
1. It would not solve present septic problems if they don't exist.
Many so-called failures are nothing of the kind. "The definition
of on-site system failure has never been agreed upon by any
administrative, regulatory, academic, or scientific authority"
(Calif, State V/ater Resources Board, 1977). Any repairable
drainfield that is simply neglected or temporarily broken
is not a failure. Almost all reported "failures" in health
department or private surveys are simply a matter of neglect
or ignorance. Even though the "failure" is repairable, these
surveys call them failures as if they could never again be
made to work (V/arshall, 1979). Symptoms indicate the need
for repair or corrective action. Unfortunately, the threat of
sewers has prevented corrective action in far too many instances.
2. The four homes beyond 150 feet would continue with their
septic systems as usual and sev/ers would prevent no problems
there should they ever be allowed to develop.
3. Cost to homeowners for sewers would vary greatly at $10/front
foot + $270 connection fee + cost of hook-up line to house
(assuming also about $10/foot), destruction to landscape,
etc. Costs would probably range from $2,000 to $10,000 or
nore per household. As an example, the Hughes residence:
Front footage =300 feet x $10 = $3,000
Connection fee = 270
Pipe to house 145 ft x $10+ = 1,500
First year sewage treatment
fees ($137-0444) average $230 = 230
$5,000
Other costs of "construction" of interceptor lines such as
noise, inconvenience, pollution, erosion, and eventual stumulus
of subdivision are not easily quantifiable. Uniform front
footage fees which have been suggested would benefit those
such as the Hughes' but would put an added burden on those with
B-47
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-5-
less frontage and would probably not be sustained in court.
It should be noted that since we own an adjoining lot,
a sewer line would just make it easier to build on it
and we would come out ahead financially. The interceptor
costs could force us to sell out but further subdivision
would not be in the best interests of the community.
4. Costs to other taxpayers would be unnecessarily greater if
these streets were sewered. For example, since the federal
government pays 75% of the pipeline costs, taxpayers are
actually paying an additional $30 per front foot above what
the residents pay.
5. These burdensome costs may have several social effects.
There is a greater likelihood of subdivision. This
would mean loss of forest or agriculture, more impervious
surfaces, more flooding, more water withdrawn from wells,
etc. Four of our families may be considered senior '
citizens on fixed incomes and may not be able to absorb
this financial burden. Others may have to borrow and take
years to pay back the loan with interest.
6. Tremendous energy will be wasted in "construction" and
pumping and at the sewage treatment plant at a time when
we desperately need to find ways to conserve all the energy
we c an.
i 7.'The public law 92-500 requirements to investigate possible
means of reuse and recycling of water on Butler Pike and
Welsh Roads will not be satisfied since water there is
presently being recycled and, to some extent, being reused
after greywater treatment.
The total cost of the interceptor scheme along V/elsh Road and
Butler Pike will be at least $40,000 front footage ($40,000 x
4,000 feet of front footage) plus: $2,970 connection fees
10,000 hook-up costs
2.530 1st year fee (230 x 11)
55,500
$120,000 other taxpayer's share ($30 x
$175,500 4,000 ft. fnt. ftg only)
Thus it will cost approximately $15,000 as an absolute minimum per
household to reduce the quality of life for the residents with, on
B-48
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-6-
balance, an environmental deterioration.
As a means of comparison, it cost only $150,000 to construct
the sev/age treatment facility at Neshaminy Village in Montgomery
Township for 600 homes!
In summation it would be a considerable saving of taxpayer's
money, a further safeguarding of our environment and energy, resources,
and a salvation to our less affluent citizens if that portion of
Welsh Road and Butler Pike were simply removed from all the
alternatives. Since these roads are at the very beginning of the
collection system, they are not needed for conveyance to other
areas. To include these roads would only cause delay for those in
need. To include them when much more cost-effective alternatives
exist would be socially, environmentally and fiscally unconscionable.
Sincerely,
,,/)
Stuart W. Hughes
References
California State Water Resources Control Board, Rural Waste water
Disposal Alternatives, Final Report - Phase 1_, Sept., 1977, p. 37
Krishnan, S. Bala, EPA Sanitary Engineer, Washington D.C.,
"An Approach to Concept and Design of Wastewater Treatment
Facilities for Rural and Semirural Communities and Fringe
Areas of Cities," Individual Onsite Wastewater Systems,
Proceedings of the Fifth National Conference 1978, Ann Arbor
Science Pub. Inc., 1979, p. 74
Marshall, Peter, Sen tic Tank Practices, Anchor Press, 1979, pp. 142-
143
P.S. I assume you found the just-released DRBC water resources
study quite interesting. In regard to their statement that water
consumption in the four state area must be reduced by 15%, may I
again point out that our highly successful composting toilet has
saved us 40%. They also reiterate that one source of water waste
has been regional sev/age treatment plants sunplanting the aquifer
recharge from septic systems.
B-49
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721 Butler Pike
Maple Glen, Pa. 19002
November 9, 1979
Mr, Richard Pepino
EIS Preparation Branch
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pa. 19106
Dear Mr. Pepino:
As you well know, my Immediate concern is the extrication from
any of the alternatives, of the 14 residences on Butler Pike and!
V.'elsh Road. However, as a member of the Horsham Township Sanitary
Board and because of my professional interests, I feel a responsibility
to make a few final points about th« prepared comments of the Horsham
Sewer Authority which were not read by Mr, Maxwell at the hearing.
You may wish to investigate who drafted the comments (I believe
Mr. Maxwell) and determine whether it was approved before hand by
all the Authority members.
It is the following paragraph which is most disconcerting and
demands comment;
"The Authority feels that Alternative IV is totally unworkable
for^reasons previously set forth. In addition, ,the Township of
Horsham Sewer Authority must express great reservation as to
the ultimate feasibility of Alternative III as well.,.."
The statement claims to set forth reasons but is not preceded by
reasons, only questions, each of which I would like to ansv;er.
It appears that Mr. Maxwell, and perhaps some members of the Authority,
assume that if Alt. IV v/ere recommended the responsibility for
establishment of the Management District would necessarily fall to
the Sev/er Authority. I would question this, on legal, technical
and socially practical grounds.
If no sev/erage is installed in the Hit. Dist. and all solutions
involve on-site methods, I susoect the Sewer Authority has, at
present, no legal authorization to administer the program there.
As you know, Pennsylvania has a rather unique system of state-local
control over on-site v.-astev/ater treatment through state-certified
!33V/a',je enforcement officers who are chosen and employed by the
B-50
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- 2 -
township. He is authorized to perform site evaluations, system
f.or
<3P Signs and installations, inspections and citationsvnoncompliance .
In Horsham his duties are legally reinforced by the Sanitary Board
which must have at least one physician, and operates under the joint
authorization of the DER and State Board of Health. The point of this
is that it seems much more logical that the Mgt. Dist. would legally
fall within the purview of the sewage enforcement officer and
the Sanitary Board, not the Sewer Authority. I might add that I
anticipate taking the sewage enforcement officer training program
in order that I might better aid Mr. Fell (our s.e.o.).
The Horsham Sewer Authority cannot be expected to have the experience,
expertise or motivation to make on-site systems work. Apparently,
judging from the questions he posed, Mr. Maxwell is not familiar
with some of the presently existing management district programs
in Acton, Ma,; Marin Co., Ca. ; Georgetown, Ca. ; Stinson Beach, Ca. ;
Fairfax Co., Va.; Port Charlotte, Fl , , etc.
L'*e fcL'Lo'? ;r . ; comments refer specifically to the questions posed
on pp. 'e. c r.cl '' -jf the prepared comments of the Sewer Authority.
Question B. Right of entry procedure; for the sewage enforcement
officer are already in position. Hon.iov.'mi ,- are nuner,-": ly anxious
to cooperate.
Question C. Maintenance financing may be worked out in various \iay^.
but with consultation of the involved residents. The Horsham Sewer
Authority has yet to recognize the value of seeking public input.
Costs v,-ill certainly be lower than sew&r rates in neighboring areas, -
another reason why residents should favor the management district
concept .
Question D. Mr. Maxwell's comment about the possible stimulation
of growth in other areas of the township is ludicrous. It's sewers
that stimulate growth. Alt. IV proposes nothing that cannot presently
be installed in the rest of the township. Flew construction v/ould not
be subsidized. There is no reduction in lot size requirements or
son in." changes.
E. Alternative IV does not require land acquisition.
Question F. If the systems function well after the two year free
replacement period, the cost of furbher maintenance would and should
be tne responsibility of the howr,ov;ners just as it is with any
B-51
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- 3 -
on-site system. The two year period should be sufficient to find
a workable solution. Local revenue would certainly be needed to
maintain sewers.
Question G. The 20 year planning horizon suggested for Alt. IV may
be reasonable but the increasing use of holding tanks suggested
in paragraph 2, p. 4-38 of the DEIS seems unrealistic when you
consider that the Township will continue and probably accelerate
drainage improvements which will alleviate many of the seasonal
high water problems associated with most of Horsham's on-site
problems. Most disturbing is the suggestion in the DEIS that
the residents are limited to three options and apparently would not
even be offered the best, most reliable, most pleasing blackv/aste
separation and greywater treatment and reuse systems. I hope this
option may be provided in the final EIS. I am confident that, with
education, some will opt for such systems.
Question H. I believe there are no bona fide cases of TCE or PCE
pollution in the well water in subareas 3 and 4 .(or 8). TCE use
in septic systems and any such toxic or carcinogenic substance can
be prevented from further contamination by a vigorous program of
education in the care and feeding of on-site systems as would be
undertaken by the management district.
With these thoughts in mind perhaps we can move forward with
this opportunity to solve Horsham's problem with the most cost
effective alternative.
Sincerely yours,
Stuart V/. Hughes
B-52
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j (A^n^/c^n' "
s-dj-y/f/
BT53
-------
'*K9^
B_54
-------
Jonathan Pera
918 Welsh Rd
Maple Glen, PA 19002
10/19/79
EIS Preparation Section
EPA Region III
6th & Walnut Sts
Phila Pa 19106
Gentlemen:
I'm writing this letter in hope that you will reconsider proposed plans
for a sewer line along Welsh Rd. and Butler Pike North of Limekiln Pike.
I'm a senior citzen living on a fixed income. The cost alone is enough
to wipe out the meager savings I have. Only my wife and I live alone with
no children, so the amount of waste produced from our household is minimal.
During the last twenty years that we have lived at 918 Welsh Rd our spetic
system had to be cleaned only twice. This would indicate that our system
is certainly capable of handling our needs. Should this sewer system be in-
stalled, I would probably have to explore the possibility of subdiving my
present lot so I could realize the needed money to pay for the sewer line.
I fervently hope that you will consider my plan, as I feel that the benefit
to me and my neighbors would be minimal.
Sincerely,
t) JZ
Jonathan Pera
cc: Mr. Hughs
721 Butler Pike
Maple Glen, Pa 19002
B-55
-------
717 Eutler Pike
Kaple Glen, Pa. 19002
October .">~, 1?79
EIS Preparation Section
EPA, Region III
6th and Walnut Street
Philadelphia, Pa. 191O6
Gentlemen:
We are enclosing a copy of a letter which we have
sent to Stuart Hughes regarding the sewer project
for Horsham Township.
The letter is self explanatory but we would like
to know why Butler Pike is being included in your
recommendations?
Very truly yours,
'' « >/ V..
'
George/ E. Shaffer
B-56
-------
717 Butler Pike
Maple Glen, Pa. 19002
October 15, 1979
Mr. Stuart Hughes
721 Butler Pike
Maple Glen, Pa. 19002
Dear Stuart:
Grace and I would like to thank"you for the many hours you have
spent studying the sewerage problems in our area. We know that
you are more qualified along these lines than anyone else in this
area and it means a great deal to us to have you looking after
all our interests.
As you know, we have lived here for over twenty-five years and
never have had any trouble with our cesspool.
There are only six homes along Butler Pike that
would be tying into the sewer and the cost of providing sewerage
for these six homes would be prohibitive. Of these six homes, we
do not know of any that are having cesspool problems. We all
have good drainage and you never see signs of water laying around
except after a heavy rain. If there was a real need for sewers
along Butler Pike we could understand it but why should we have
to suffer when there really isn't any problem in our area? I
grant you, there are some sections in the township that really
have problems and we are in accord that something should be done
to take care of them but we cannot understand why the large outlay
of money where it is not warranted both to the individual home-
owner and to all the other taxpayers in the township?
As you realize, we have 315 feet on Butler Pike which is only a
headache ^for us. We cann6t do anything with this ground as our
lot is only three sided and we cannot build or sell off any of
this frontage. I am over 72 years of age, working part time in
order to try to maintain our standard of living without drawing on
our savings. The cost of putting in sewerage would itiore than I
get a year from Social Security. What does the township expect
you to live on? The cost of living has gone sky high - we try to
conserve on fuel, electricity and food. Where else can you cut
comers in order to make ends meet.? To borrow money for this
sewerage project would be ridiculous. If we have trouble making
ends meet now, how can we ever expect to pay off a loan, plus
sewerage rent, otc? We have tried to live within our income and
felt reasonably sure that we would be able to keep on living in our
home but with this in mind how, we really don't know which way to
turn. There seems to be no solution as we can't live anywhere any
cheaper than where we are.
Again let us say thank you for all that you have done for the
community and we trust that someone along the line will listen to
you.
Sincerely,
B-57 , .f . - ._, / , ' ^
' *
Go or."'* ar.d Graco Shaffor
-------
HIDEAWAY HILLS CIVIC ASSOCIATION
HORSHAM TOWNSHIP
AMBLER, PENNSYLVANIA 19002
12 Oct. 1979
SPA-Region III
6th & ~>lnut Streets
Philadelphia, Pa,
Dear- Sirs:
As President of the Hideavray J3.11& Civic Association,
Horsham Tovmship, flontgonery County, Pa., I vrf.sh to testify at
the Public Hearing scheduled for 7:30 PIJ on 23 October 197?.
J'y presentation "will not exceed the five minute time limit and
rail be limited to statements concerning the follo-.ving:
1. A statement to the effect that a need for public sev/er
service has existed in Hideor/ay Hills for many years and that
this need has beeerne even more critical in recent years.
2. That because of our neighborhood topography and poor soil
conditions many of the On-Site disposal systems do not function
properly. This condition adversely effects the health, safety
and v/elfare of all the residents.
3. That for a period of ^ppro>rimately ten years, the residents
of Hidea.vay Hills has appealed to the appropriate governmental
of Ticials for the construction of' a public v.tvste-.vater collection
' system* That because of this lengthly delay, the residents have
been exposed to a very unhealthy environment. Furthermore,
property values are declining as the situition becomes vrarse and
-.vorse.
h» "re, the residents, thorpfore most stronglLy urge- a prompt snd
favorable decision for the construction of a public vr^stewiter
collection system. Vfe further request thit tfiis system be
financed at the minijmun possible cost to tho property ovmer.
Sincerely,
N. R. Chnrlqo
12?1 Joseph
Anbler, Pa.
B-58
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APPENDIX C
Cost of Alternatives
-------
Table C-1.
Summary of Alternative 2 costs apportioned by municipality, adjusted to 1980.
Municipality
Horsham
Warminster (1)
(2)
Warrington (1)
(2)
(3)
(4)
Total
Construction Costs
4,865.5
7,057.
7,111.
7,853.
7,907.1
5,362.2
5,378.3
5,600.0
5,616.0
Federal
Share
3,412.3
5,293.
5,333.
5,889.
5,930.
3,839.4
3,851.4
4,017.7
4,029.7
Local
Share
1,453.2
1,764.4
1,777.9
1,963.4
1,976.8
1,522.9
1,526.9
1,582.3
1,586.3
Total
(1)
(2)
(3)
(4)
17,285.4
17,355.2
18,318.8
18,388.6
12,545.0
12,597.2
13,319.9
13,372.3
4,740.5
4,758.0
4,998.9
5,016.3
(1) baseline STP expansion only
(2) baseline STP expansion with dechlorination facilities
(3) baseline STP expansion with denitrification facilities
(4) baseline STP expansion with dechlorination and denitrification facilities
Table C-2.
Summary of Alternative 3 costs apportioned by municipality, adjusted to 1980.
Municipality
Horsham
Warminster (1)
(2)
(3)
(4)
Warrington
(1)
(2)
(3)
(4)
Total
Construction Costs
4,657.5
7,057.
7,111.
7,853.
7,907.1
5,362.2
5,378.3
5,600.0
5,616.0
Federal
Share
3,530.0
5,293.3
5,333.5
5,889.9
5,930.3
3,839.4
3,851.4
4,017.7
4,029.7
Local
Share
1,146.7
1,764.4
1,777.9
1,963.4
1,976.8
1,522.9
1,526.9
1,582.3
1,586.3
Total
(D
(2)
(3)
(4)
17,077.4
17,147.2
18,110.8
18,180.6
12,622.7
12,714.9
13,437.6
13,490.0
4,414.7
4,432.3
4,673.2
4,690.6
(1) baseline STP expansion only
(2) baseline STP expansion with dechlorination facilities
(3) baseline STP expansion with denitrification facilities
(4) baseline STP expansion with dechlorination and denitrification facilities
C-1
-------
Table C-3.
Cost of Alternative 2 wastewater facilities to be located in Horsham Township,
by subarea, adjusted to 1980. GS indicates gravity sewer. Costs are in
thousands of dollars.
Subarea
Contingencies
Total Costs
Cost Item
21,540'-8"GS
6,540'-6"GS
0.2 mgd lift station
5,800'-8"force main
9,72T-8"GS
2,400'-6"GS
12,700'-8"GS
5,500'-6"GS
0.4 mgd lift station
2, 500 '-6" force main
4,700'-10"force main
17,000'-8"GS
5,480'-6"GS
0.075 mgd lift station
2,500'-6"force main
:ration, and
Capital
577.8
84.2
66.1
161.8
260.7
31.0
340.7
70.8
107.6
59.0
161.4
456.0
70.6
33.0
59.0
685.8
Grant
Eligible Local
Capital Share
433.4
23.2
49.6
121.4
195.5
8.5
255.5
29.2
80.7
44.3
121.0
342.1
29.1
24.8
44.3
486.7
3,225.5
2,289.3
936.2
Table C-4.
Cost of Alternative 2 wastewater facilities to be located in Lower Gwynedd
Township, adjusted to 1980. Capital costs indicated are that portion
of total capital costs assigned to Horsham Township. Costs are in thousands of
dollars.
Cost Item
10,000'-10" force main
12,600'-10", 12", 21"GS
7,500'-24"GS
Engineering, Administration, and
Contingencies
Total Costs
Capital
383.0
707.0
129.0
Grant
Eligible
Capital
287.3
530.3
96.8
Horsham Twp
Local
Share
421.0
1,640.0
208.6
1,123.0
546.03
alncludes capital contribution for Wissahickon Interceptor.
C-2
-------
Table C-5.
Cost of A ternative 3 wastewater facilities to be located in Horsham Township
by subare-i, adjusted to 1980. Costs are in thousands of dollars.
Subarea
Engineering,
Administration,
& Contingencies
Total Costs
Cost Item
21,540' pressure sewer
system
0.16 mgd community soil
absorption systems
12,121' pressure sewer
system
12,700'-8"GS
5,500'-6"GS
0.17 mgd lift station
2,500'-6"force main
4, 700 '-8" force main
17,000'-8"GS
5,480'-6"GS
0.075 mgd lift station
2,500'-6"force main
Capital
492.1
717.8
206.4
340.7
70.8
56.2
59.0
131.1
456.0
70.6
33.0
59.0
727.1
Grant
Eligible Local
Capital Share
418.3
610.2
175.5
255.5
29.2
42.2
44.3
98.3
342.0
29.1
24.8
44.3
570.7
3,419.8
2,684.3
735.5
Table C-6.
Cost of Alternative 3 wastewater facilities to be located in Lower Gwynedd
Township, adjusted to 1980. Capital costs indicated are that portion of total
capital costs assigned to Horsham Township. Costs are in thousands of
dollars.
Cost Item
10,000'-8" force main
59.0% Share of Cost of
Willow Run Relief Sewer
7.4% Share of Cost of Lower
Wissahickon Relief Sewer
Engineering, Administration, and
Contingencies
Capital
260.0
592.7
63.7
Grant
Eligible
Capital
195.0
444.5
47.8
Horsham Twp
Local
Share
321.3
Total Costs
1,237.7
158.4
845.7
411.2a
alncludes capital contribution for Wissahickon Interceptor.
C-3
-------
Table C-7.
Cost of Alternative 2/3 wastewater facilities to be located in War-minster
Township, by subarea, adjusted to 1980. Costs are in thousands of
dollars.
Subarea Cost Item
11 4.1 mgd Expansion of the
Warminster STP:
- Preliminary Treatment
- Aeration
- Final Clarification
- Activated Carbon:
storage, feed, mix and floe
- Filtration
- Aerobic Digestion
- Sludge Dewatering
- Electrical Instrumentation
and Controls
7.9 mgd Upgrading of the
Warminster STP:
- Chlorination
- Biological Nitrification
- Lab Facilities
50% I /I Reduction
(Warminster Sewer System)
Engineering, Administration and
Contingencies
Total Costs
Capital
106.6
1,202.7
442.8
. 178.8
897.9
964
531.7
1,053.4
5,378.0
187.8
1,627.3
200.3
2,015.3
778.6
2,206.4
10,378.3
Grant
Eligible
Capital
79.9
902.0
332.1
134.1
673.5
723.0
398.8
790.1
4,033.5
140.9
1,220.4
150.2
1,511.5
583.9
1,654.8
7,783.7
Local Share
Wamvin-
Warrington ster
537.8 806.7
115.9 387.9
194.6
176.5 375.1
830.2 1,764.3
Table C-8.
Cost of Alternative 2/3 wastewater facilities to be located in Warrington
Township by subarea, adjusted to 1980. GS indicates gravity sewer. Costs
are in thousands of dollars.
Subarea
2
11
Cost Item
3,493'-20"GS
7,373'-12"GS
4,459'-18"GS
20,960'-8"GS
15,200'-6"GS
80% I /I Reduction
(Valley Road STP
Sewer System
Engineering, Administration, and
Contingencies
Capital
228.7
261.1
224.9
562.3
195.7
135.0
434.0
Grant
Eligible
Capital
171.5
195.8
168.7
421.7
80.7
101.3
325.5
Local
Share
Total Costs
2,041.6
1,465.2
576.4
C-4
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