905R83106
    Region 5
ction   230 South Dearborn Street
    Chicago, IL 60604
           Environmental
           Impact Statement
               Final
           Indian Lake - Sister Lakes
           Wastewater Treatment
           System
           Berrien, Cass, and
           Van Buren Counties,
           Michigan

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For further information contact;

Charles A. Quinlan, III, Project Officer
US Environmental Protection Agency, Region V
Municipal Facilities Branch, Environmental Impact Section
230 South Dearborn Street
Chicago, Illinois  60604
(312) 886-0244
                                   ABSTRACT
     Indian  Lake,  Sister Lakes,  and Pipestone  Lake  have  long  been a summer
recreational  area  for families  from South  Bend  and  the Chicago metropolitan
area.   Now  many  of the  second  homes  are  becoming  permanent  residences for
retirees.   As a  result, people  have  become concerned  about  the  impact of
on-site systems on the water quality of the  lakes.  Efforts early in the  1970s
focused  on identification and  repair of failing on-site  systems  and then on
pursuing collection  and  treatment alternatives,  particularly for  Indian Lake
and Pipestone  Lake.   The Draft Facility Plan recommended collector sewers and
centralized  treatment facilities.   Concurrently,  the Cass  County  Board  of
Public Works applied for and obtained a commitment for a grant and a loan from
the  Farmers Home  Administration  (FmHA)  to  construct collection  system for
Indian Lake with treatment at Dowagiac.  The EIS  investigated both centralized
alternatives  and   decentralized   alternatives  (upgraded  on-site and  cluster
systems) for the area lakes and concluded that a  decentralized alternative was
the most  cost-effective  and environmentally acceptable.   Alternative 10, the
recommended  alternative, consists  of  upgraded  on-site  systems,  blackwater
holding tanks on some parcels, and 10 cluster systems.  No USEPA grant assist-
ance is  available  for this  project  at  the  present  time.  The FmHA has tenta-
tively  withdrawn  its commitment of  assistance because,  by interagency agree-
ment, FmHA funds projects that are consistent with an approved Facilities Plan
or EIS.

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                                    SUMMARY
( )  Draft Environmental Impact Statement
(X)  Final Environmental Impact Statement
US Environmental Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois  60604
1.   NAME OF ACTION
     Administrative (X)
     Legislative    ( )
2.   PURPOSE OF AND NEED FOR ACTION

     The Federal  Water Pollution  Control Act of  1972 (Public Law 92-500)
established a uniform, nationwide water pollution control program.  Section
201 of  the Act  established grants for  planning,  design,  and construction
for water  pollution control facilities.   At the request of lakeshore resi-
dents of  Indian Lake,  the Cass County Department  of  Public Works (CCDPW)
applied for a  facility  planning grant in 1975.  The Michigan Department of
Natural Resources (MDNR) delineated the facilities planning area to include
Indian  Lake,  the Sister  Lakes,  and Pipestone Lake.   The  CCDPW was desig-
nated the lead agency for the administration of grants.

     Concurrent with  the  facilities  planning  process,  the  CCDPW filed an
application with  the  Farmers Home Administration  (FmHA)  in  May 1976 for a
grant  and  loan  to construct  sewers  around  Indian  Lake only.   The FmHA
informed the CCLPW  in August 1976 that  the  grant and loan application was
approved,  with  the  condition that the facilities  planning documents would
be approved by MDNR.

     The preliminary  draft  of  the Indian Lake-Sister Lakes Facility Plan
was submitted  to MDNR  in  October 1977 by Gove Associates,  Inc.,  the con-
sulting engineer.   Collector sewers and centralized treatment was proposed
for the lake areas.  The  Facility Plan  was not approved  at  that time be-
cause of questions  regarding the potential impacts of the proposed sewers,
system  costs,  and whether  innovative/alternative  systems  might  be a feas-
ible alternative.
                                     ii

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     In October  1978,  USEPA issued a  Notice  of Intent to prepare  an  Envi-
ronmental  Impact  Statement (EIS).   The  major  considerations were  the  con-
tribution  of  present  on-site systems  to  lake water degradation,  the poten-
tial  for  improved treatment  by  existing systems  through  upgrading and
improving  maintenance,  the economic impact of  the proposed project alter-
natives, and the potential secondary impacts.

     The  Draft  EIS, published  in  August  1982,  contained an evaluation of
the  existing  wastewater-related problems  and  the  treatment  needs of the
facilities  planning area.   Centralized  collection and  treatment  alterna-
tives  were re-evaluated and decentralized  alternatives  were developed and
analyzed.   Considerable  emphasis was devoted to the decentralized  alterna-
tives  because the  potential to reduce costs was great.   The residences not
immediately adjacent to the lakes were not included in the analysis because
no need for improved sewage treatment was determined.

     Subsequent  to the  issuance of  the Draft  EIS,  a public  hearing was
convened at the Sister Lakes School on 28 September 1982.  This hearing was
conducted  to  gather comments  on information  presented  in  the  Draft  EIS.
The comment period was later held open to receive comments by letter.   This
Final  EIS  was  prepared  to respond to the comments received, to present the
analysis  of additional  data  gathered,  and  to describe a  new  wastewater
management alternative developed for the study area.

     One of the  most  significant comments on  the  Draft  was that more  data
was  required  to document  the  precise nature  of  water  quality and public
health problems and thus the need for improved wastewater management in the
study  area.   To  accomplish this, a supplementary  field study was conducted
in  October and  November  1982.   This  field  work consisted of  a limited
sanitary  survey  in targeted areas,  lake water  quality  and sediment  samp-
ling,  and a  limited  sampling  of  on-site wastewater  effluent  plumes in
groundwater.  As  a result  of  analysis  of the  collected data,  a  new EIS
Alternative 10 was  developed  to meet the needs of identified public health
and water quality problems.
                                    iii

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3.   ALTERNATIVES CONSIDERED

     Twelve wastewater  system  alternatives were evaluated in detail during
this study.   Six alternatives  include  collection of  sewage  from the lake
areas and transmission to various treatment sites where different treatment
processes would occur.  The other alternatives include the No Action Alter-
native and  the  various  on-site and cluster system (off-site) alternatives.
Each alternative  provides  service  to the  residences near  the lakes in the
study area  (except Keeler Lake).

     Alternative  1

     The No Action  Alternative presumes that neither  USEPA  nor FmEA would
provide  funds  to  build,  upgrade,  or  expand  existing on-site  treatment
systems,   although  local   health  authorities would  continue  to have  the
responsibility  for   improving  existing  systems that  cause  public health
problems.  No costs were calculated for this alternative.

     Alternative  2

     Alternative  2   proposes  construction  of   septic  tank  effluent  (STE)
pressure collection  sewers and  separate  treatment plants  for Indian Lake
and Sister  Lakes  with discharges to surface waters.   The  treatment plants
would  include  waste stabilization  ponds  with  9.5 months  of storage.  The
Sister Lakes treatment plant would discharge to Silver Creek and the Indian
Lake treatment plant would discharge to the Indian Lake outlet. The initial
capital  cost  of  this  alternative  is  $24,106,200  and the  initial annual
operation and maintenance costs are $261,700.

     Alternative  3

     Alternative  3  proposes  construction  of pressure collection sewers and
a regional  treatment  plant utilizing application of wastewater effluent to
land.   Pretreatment prior  to  land  application  would be  accomplished  by
waste stabilization ponds that incorporate 6 months of winter storage.  The
initial  capital  cost of  this alternative  is  $23,819,600 and  the  initial
annual operation and maintenance costs are $285,900.
                                    IV

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     Alternative 4

     This  alternative  proposes  construction  of  STE  pressure collection
sewers  and  a regional treatment  plant  utilizing waste stabilization ponds
for treatment.  The treatment plant is  proposed  to be  located  in Section  11
of Silver Creek  Township.   It would  incorporate 9.5 months of storage and
would  discharge  to Silver  Creek.  The  estimated  initial  capital  cost  is
$24,573,700  and the  estimated  initial annual  operation  and maintenance
costs are $252,500.

     Alternative 5A

     This alternative is  similar  to Alternative  4,   except  the  regional
treatment plant  would be  located near Indian  Lake  and would discharge  to
the Indian  Lake  outlet.   This alternative has an estimated initial capital
cost of  $23,614,200 and  estimated initial annual operation and maintenance
costs of $247,000.

     Alternative 5B

     This alternative  is  similar to  Alternative 5A,  except that  a conven-
tional  gravity  collection sewer  system would  be utilized  rather  than the
STE pressure  sewer  system.   This alternative is similar to the alternative
recommended   in the  Facilities Plan by Gove Associates, Inc.   The estimated
initial  capital  cost   is  $29,598,600  and the  initial  annual  operation and
maintenance  costs are $278,200.

     Alternative 6

     Alternative 6 proposes  construction of STE pressure collection sewers
and a  new  treatment   plant  for  the  Sister  Lakes  and utilization  of  the
Dowagiac  treatment  plant  for  Indian Lake  wastewater.  The  Sister Lakes
treatment plant would  consist of waste stabilization ponds with 9.5 months
of  storage   capacity  and would  discharge  to  Silver  Creek.   The  Dowagiac
treatment plant  would  not  be  expanded to  accommodate the  flow  from  the
Indian  Lake area.   The estimated initial capital cost  for  this alternative

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is  $23,487,400 and  the  initial  annual  operation  and  maintenance  costs,
including  the  treatment  charge  at  the  Dowagiac  treatment  plant,  are
$294,000.

     Alternative 7

     This  alternative  proposes  construction  of  STE pressure  collection
sewers and  transmission facilities to the  Dowagiac  treatment  plant.   This
alternative has an  estimated  initial capital cost of $22,457,200 and init-
ial annual operation and maintenance costs of $466,100.

     Alternative 8A

     This  alternative  includes  upgrading  on-site  systems where  a  subse-
quent, detailed inspection uncovers a need for upgrading and collecting STE
from  certain  critical  areas  where upgrading on-site  systems  is  not feas-
ible.  The  STE  would  be  treated  in common  cluster drain  fields.   This
alternative utilizes  STE pressure collection sewers for the critical areas.
The  estimated  initial  capital cost of this alternative  is $9,683,800 and
the  estimated  initial annual  operation and maintenance costs are $280,200.

     Alternative 8B

     This  alternative  is  similar  to Alternative  8A, except  STE gravity
sewers and lift stations and force mains would be utilized to convey STE to
the  cluster drain  fields.    The  estimated  initial  capital  cost of  this
alternative is $9,644,200 and the estimated initial  annual  operation and
maintenance costs are $265,700.

     Alternative 9

     This alternative consists of  upgrading on-site systems where a subse-
quent, detailed  inspection program uncovers a need  for  upgrading and in-
stalling low-flow toilets and blackwater holding tanks for those residences
for  which  on-site   upgrading  is  not  feasible.   The  graywater  would  be
handled by the existing or upgraded septic tank and soil absorption system.
                                    vi

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The  estimated  initial  capital cost is $3,710,600 and  the estimated  initial
annual operation and maintenance costs are $224,000.

     Alternative 10

     This alternative  consists of elements of  Alternatives  8A,  8B,  and 9.
Most of  the  shoreline  areas would have  their on-site systems upgraded and
low-flow toilets and blackwater holding  tanks would be installed on  parcels
with severe  site  limitations.   Graywater would be  handled  by the existing
or upgraded  septic tank and soil absorption systems.   Of the critical areas
10 shoreline segments  have unsuitable site conditions and numbers of resi-
dences  so  that STE  collection systems  and cluster  drain  fields are feas-
ible.  The estimated  initial  capital cost is  $5,664,750 and the estimated
initial annual operation and maintenance costs are $228.500.

     The total present  worth  costs of the major components of the alterna-
tives  and  their ranking  are  presented  in Table  1.   These  system alterna-
tives  can  be grouped  into three  design/cost  categories.   The centralized
comprehensive sewering alternatives (2,  3, 4, 5A, 5B,  6, and 7) are  highest
in cost;  upgraded on-site  systems with certain  critical areas  served by
cluster drainfields (Alternatives 8A, 8B, and 10) are  intermediate in cost;
and  upgraded on-site  systems  with blackwater holding  tanks  (Alternative 9)
are  lowest in cost.

4.  ENVIRONMENTAL CONSEQUENCES

     Construction Phase

     Major direct  impacts  from construction activities that would be asso-
ciated with  the alternatives  would be concentrated  along the  corridors of
the  collection sewers  and at  the  wastewater  treatment  facilities  sites.
Fugitive dust,  exhaust emissions  from construction  equipment,  noise,  de-
struction  of  vegetation,   accelerated   erosion,  disturbance  of  wildlife,
disturbance  of  streambeds and  lakebeds, and  interruption  of  traffic flow
and  patterns would  create short-term nuisance conditions and environmental
                                    vii

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damage  along the  sewer and  force  main routes.   The extent  and range  of
impacts  is  directly related  to the  lengths of  the  proposed sewers.   The
centralized  treatment  alternatives have potential for the greatest  number
of  impacts.   The  number  and extent of  impacts  would be considerably  less
for the  two alternatives with critical area  collection  systems and  cluster
drainfields.   Major impacts  on  the  environment  would  occur at  the  new
treatment plant  sites  because  each site  would  have  a waste  stabilization
lagoon  built on  it.   All  the sites  are  presently  used for agricultural
purposes, and  the  site  in Section  29 (near  Indian  Lake)  is mostly  prime
agricultural land  that  would be converted irretrievably  to treatment  plant
use.  The cluster  drainfield sites also would be  extensively  disturbed  for
drainfield trenching.  The three alternatives with upgraded on-site  systems
would involve extensive disturbance on individual  lots only.

     Alternative 9 would require the smallest commitment  of public capital.
The  local  share of the capital  cost is  lowest  with Alternative  9,  even
including some additional private homeowner  cost.

     Operational Phase

     The operation  of  the facilities  proposed  in the  alternatives  would
produce  some  significant  long-term impacts.  All  of  the alternatives  (ex-
cept the No  Action Alternative) would result  in slightly reduced nutrient
inputs  into  the  lakes;  the  greatest reductions could  be expected for  the
complete sewering  alternatives.  The data were  inconclusive  as to whether
the water  quality  of the  lakes would be  noticeably  improved  under any  of
the alternatives.   Under  the No Action Alternative lake  water quality  may
noticeably decline and  nuisance  algal blooms may increase in  extent  and
density.  Occasionally  failing  on-site systems would cause localized  water
quality  problems,  potential health risks, and  malodorous conditions.   The
soil absorption  systems  that would continue to  be used and those proposed
for construction  would affect  the  quality  of  groundwater  slightly.   Oc-
casional malfunctions  and power  outages within  the  wastewater collection
system could cause serious short-term impacts on  lake  water  quality.   The
treatment facilities for  the centralized  alternatives would  be capable  of
                                    ix

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meeting  the  discharge  requirements established by  MDNR.   Water quality in
the receiving  streams  would be altered, but not  seriously degraded during
the  annual  discharge   period.   The  land  application alternative should
result in minimal operating impacts because the infiltrated water should be
of comparatively high quality.

     Septage and holding tank waste hauling would result in minimal adverse
impacts.  Some ephemeral odors from the pumping operation would be detected
and truck traffic would be present.  Septage disposal would be conducted in
an environmentally compatible  way  with application  to agricultural lands.

5.   RECOMMENDED ACTION

     Alternative 10 - upgraded on-site systems and blackwater holding tanks
or  cluster  systems  in critical  areas,  is  the recommended  alternative.
Alternative  10 was  developed from Alternatives 8A,  8B,  and 9 by utilizing
the results  of  the  field work conducted in October and November 1982.  The
field  studies,  particularly the  Sanitary  Survey,  enabled a judgement be-
tween what areas  should be on cluster systems and what areas could utilize
upgraded  on-site  systems with some blackwater  holding tanks.  Alternative
10 could  be  implemented on  the  local level without  USEPA or FmHA funding
over an extended period  of time.  The  selection of  this alternative was
based on  provision  of  adequate wastewater treatment and cost-effectiveness
with protection of the water quality of the lakes being nearly equal.  This
alternative  provides for  the wastewater treatment needs of the area better
than Alternative  9  because cluster systems rather  than blackwater holding
tanks would  serve certain critical areas.   Alternatives  8A and 8B consist
of cluster systems in more areas than the documentation of needs warranted.
The centralized  alternatives,  including that  for  Indian  Lake alone, were
not  justified  considering  the high  cost  of  these  alternatives  and  the
adverse impacts to the environment.

     The  location and  the layout of the cluster systems for Alternative 10
are presented  in Figure  1.   The  upgraded  on-site  systems  and blackwater
holding  tanks  would  be distributed  throughout  the  lakeshore  areas.  The
estimated number  of  systems to be upgraded initially and over the project
planning period are included in Appendix D.

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                               TABLE OF CONTENTS
ABSTRACT 	 	
SUMMARY 	
TABLE OF CONTENTS 	 	
LIST OF APPENDICES 	
LIST OF TABLES 	 ,
LIST OF FIGURES 	
Page
	 i
	 ii
	 xii
	 xvi
	 xvii

L.O.   PURPOSE OF AND NEED FOR ACTION	   1-1
      l.L.  Project Background	   1-1
      1.2.  Legal Basic for Action and Project Need	   1-5
      1.3.  Study Process and Public Participation	   1-9
      1.4.  Issues	   1-8

2.0.   DISCUSSION OF WASTEWATER TREATMENT ALTERNATIVES	   2-1
      2.1.  Existing Wastewater Treatment Systems	   2-1
                                                                           2-1
                                                                           2-3
                                                                           2-3
                                                                           2-4
                                                                           2-6
                                                                           2-7
                                                                           2-10
                                                                           2-11
                                                                           2-12
                                                                           2-13
                                                                           2-14
                                                                           2-14
                                                                           2-15
                                                                           2-15
                                                                           2-17
                                                                           2-18
                                                                           2-21
      2.2.  Identification of Wastewater Treatment System Options	   2-26
                                                                           2-26
                                                                           2-30
                                                                           2-30
                                                                           2-31
                                                                           2-32
                                                                           2-32
                                                                           2-34
                                                                           2-34
                                                                           2-38
                                                                           2-39
                                                                           2-40
                                                                           2-44
                                      xii
Existing
2.1.1.
2.1.2.
2.1.3.
2.1.4.
2.1.5.
Identifi
2.2.1.
2.2.2.
2.2.3.
2.2.4.
Wastewater Treatment Systems 	
Existing On— site Systems 	 	
Summary of Data on Operation of Existing Systems....
2.1.2.1. Septic Leachate Survey 	
2.1.2.2. Aerial Survey 	
2.1.2.3. Mailed Questionnaire 	
2.1.2.4. Indian Lake Sanitary Surveys 	
2.1.2.5. Pipestone Lake Surveys 	 	
2.1.2.6. Targeted Sanitary Survey 	
2.1.2.7. Shallow Groundwater Study 	
Problems Caused by Existing Systems 	
2.1.3.1. Backups. 	 	 	
2.1.3.2. Ponding 	
2.1.3.3. Groundwater Contaminat ion 	
2.1.3.4. Surface Water Quality Problems 	

Identification of Problem Areas 	
Septage Disposal Practices 	
cation of Wastewater Treatment System Options 	
Design Factors 	 	 	
System Components 	
2.2.2.1. Flow and Waste Reduction 	
2.2.2.2. Collection System 	
2.2.2.3. Wastewater Treatment Processes 	
2.2.2.4. Effluent Disposal Options 	
2.2.2.5. Sludge Treatment and Disposal 	
2.2.2.6. On-site System 	
2.2.2.7. Cluster System 	
2.2.2.8. Septage Disposal 	
Centralized Collection System Alternatives 	
Centralized Wastewater Treatment Plant Alternatives.

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                         TABLE OF CONTENTS (continued)
     2.3.    System Alternatives	   2-44
            2.3.1.  Alternative 1 - No Action Alternative	   2-46
            2.3.2.  Alternative 2 - Pressure Collection Sewers and
                    Separate WWTPs for the Sister Lakes and Indian Lake
                    Areas with Discharge to Surface Waters	   2-47
            2.3.3.  Alternative 3 - Pressure Collection Sewers and
                    Regional Treatment and Land Treatment System	   2-47
            2.3.4.  Alternative 4 - Pressure Collection Sewers and
                    Regional WWTP located in Section 11	   2-51
            2.3.5.  Alternative 5A - Pressure Collection Sewers and a
                    Regional WWTP Located in Sections 29 and 32	   2-51
            2.3.6.  Alternative 5B - Gravity Collection Sewers and a
                    Regional WWTP Located in Sections 29 and 32	   2-51
            2.3.7.  Alternative 6 - Pressure Collection Sewers and
                    Existing Dowagiac WWTP for Indian Lake and new WWTP
                    for Sister Lakes	   2-54
            2.3.8.  Alternative 7 - Pressure Collection Sewers and
                    Existing Dowagiac WWTP	   2-54
            2.3.9.  Alternative 8A - On-Site Systems Upgrading and
                    Critical Areas Septic Tank Effluent Collected by
                    Pressure Sewers and Conveyed to Cluster Drain Fields   2-56
           2.3.10.  Alternative 8B - On-Site Systems Upgrading and
                    Critical Areas Septic Tank Effluent Collected by
                    Small Diameter Gravity Sewers and Conveyed to
                    Cluster Drain Fields	   2-56
           2.3.11.  Alternative 9 - On-Site Systems Upgrading and
                    Blackwater Holding Tanks	   2-59
           2.3.12.  Alternative 10 - On-Site Systems Upgrading, Black-
                    water Holding Tanks, and Critical Areas Septic Tank
                    Effluent Collected by Gravity or Pressure Sewers
                    and Conveyed to Cluster Drain Fields	   2-59
     2.4.   Flexibility and Reliability of System Alternatives	   2-61
     2.5.   Comparison of Alternatives and Selection of the Recommended
           Action	   2-62
            2.5.1,  Comparison of Alternatives	   2-62
                    2.5.1.1.  Project Costs	   2-62
                    2.5.1.2.  Environmental Impacts	   2-63
                    2.5.1.3.  Implementability	   2-66
            2.5.2.  Selection of Recommended Actions	   2-71
3.0.  AFFECTED ENVIRONMENT	   3-1
      3.1.  Natural Environment	   3-1
            3.1.1.  Atmosphere	   3-1
            3.1.2.  Land	   3-2
                    3.1.2.1.  Geology	   3-2
                    3.1.2.2.  Soils	   3-4
            3.1.3.  Water Resources	   3-8
                    3.1.3.1.  Surface Water	   3-8
                    3.1.3.2.  Ground Water	   3-21
            3.1.4.  Aquatic Biota	   3-22
                    3.1.4.1.  Phytoplankton	   3-22
                    3.1.4.2.  Mollusks	   3-27
                    3.1.4.3.  Fisheries	   3-27

                                     xiii

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                         TABLE OF CONTENTS (continued)
            3.1.5.   Terrestrial Biota	   3-27
                    3.1.5.1.  Amphibians and Reptiles	   3-27
                    3.1.5.2.  Birds	   3-29
                    3.1.5.3.  Mammals	   3-29
                    3.1.5.4.  Vegetation	   3-29
            3.1.6.   Wetlands	   3-30
     3.2.    Man-Made Environment	   3-31
            3.2.1.   Demography	   3-31
                    3.2.1.1.  Historic and Current Population	   3-31
                    3.2.1.2.  Service Area Population Estimates	   3-33
                    3.2.1.3.  Population Projections	   3-35
            3.2.2.   Land Use	   3-42
                    3.2.2.1.  Study Area Land Use Trends	   3-42
                    3.2.2.2.  Prime and Unique Farmland	   3-45
                    3.2.2.3.  Future Land Use	   3-47
                    3.2.2.4.  Development Potential	   3-47
            3.2.3.   Economics	   3-49
                    3.2.3.1.  Regional Employment Trends	   3-49
                    3.2.3.2.  Income	   3-50
                    3.2.3.3.  Unemployment	   3-50
            3.2.4.   Recreation and Tourism Resources	   3-51
                    3.2.4.1.  Public Facilities	   3-51
                    3.2.4.2.  Private Facilities	   3-52
            3.2.5.   Public Finance	   3-52
                    3.2.5.1.  Assessed Valuation and Market Value	   3-52
                    3.2.5.2.  Total Revenues	   3-54
                    3.2.5.3.  Debt, Debt Service, and Debt Limits	   3-54
            3.2.6.   Transportation	   3-56
            3.2.7.   Energy	   3-56
            3.2.8.   Cultural Resources	   3-56
                    3.2.8.1.  Early History	   3-56
                    3.2.8.2.  Archaeological Sites	   3-57
                    3.2.8.3.  Historic Sites	   3-58

4.0.   ENVIRONMENTAL CONSEQUENCES	   4-1
      4.1.   Primary Impacts	   4-2
            4.1.1.   Construction Impacts	   4-2
                                                                           4-2
                                                                           4-2
                                                                           4-3
                                                                           4-3
                                                                           4-3
                                                                           4-5
                                                                           4-7
                                                                           4-8
                                                                           4-8
                                                                           4-9
                                                                           4-9
                                                                           4-9

Construct:
4.1.1.1.
4.1.1.2.
4.1.1.3.
4.1.1.4.
4.1.1.5.
4.1.1.6.
4.1.1.7.
4.1.1.8.
4.1.1.9.
4.1.1.10.
4.1.1.11.
4.1.1.12.



Soil Erosion and Sedimentation 	

Groundwater 	
Terrestrial Biota 	



Recreation and Tourism 	


Cultural Resources 	
                                      xiv

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                         TABLE OF CONTENTS (concluded)
            4.1.2.   Operation Impacts	   4-10
                    4.1.2.1.   Atmosphere	   4-10
                    4.1.2.2.   Soils	   4-12
                    4.1.2.3.   Surface Waters	   4-15
                    4.1.2.4.   Groundwater	   4-21
                    4.1.2.5.   Terrestrial Biota	   4-25
                    4.1.2.6.   Land Use Impacts	   4-25
                    4.1.2.7.   Demographics	   4-25
                    4.1.2.8.   Economics	   4-26
                    4.1.2.9.   Recreation and Tourism	   4-26
                    4.1.2.10. Transportation	   4-26
                    4.1.2.11. Energy	   4-27
            4.1.3.   Public Finance	   4-27
     4.2.    Secondary Impacts	   4-31
            4.2.1.   Demographics	   4-32
            4.2.2.   Land Use	   4-33
            4.2.3.   Surface Water	   4-33
            4.2.4.   Recreation and Tourism	   4-34
            4.2.5.   Economics	   4-35
            4.2.6.   Threatened and Endangered Species	   4-35
     4. 3.    Mitigation of Adverse Impacts	   4-35
            4.3.1.   Mitigation of Construction Impacts	   4-36
            4.3.2.   Mitigation of Operation Impacts	   4-39
            4.3.3.   Mitigation of Secondary Impacts	   4-41
     4.4.    Unavoidable Adverse Impacts	   4-41
     4.5.    Irretrievable and Irreversible Resource Commitments....	   4-42

5.0.  PUBLIC AND AGENCY COMMENTS	   5-1

6.0.  LITERATURE CITED	   6-1

7.0.  LIST OF PREPARERS	   7-1

8.0.  GLOSSARY OF TECHNICAL TERMS	   8-1

9.0.  INDEX	    9-1
                                      xv

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                             LIST OF APPENDICES







APPENDIX A - SANITARY SURVEY




APPENDIX B - WATER QUALITY SURVEY OF AREA LAKES




APPENDIX C - SHALLOW GROUNDWATER STUDY OF SOIL ABSORPTION SYSTEMS




APPENDIX D - PRELIMINARY COST ESTIMATES FOR ALTERNATIVE 10




APPENDIX E - LETTERS AND WRITTEN COMMENTS
                                      xv i

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                                LIST OF TABLES
1         Summary of all estimated costs of alternatives 	    viii

2-1       Number of active wastewater plumes and category and number
          of discernable on-site septic systems around the lakes in
          study area	     2-5

2-2       Partial results of 1978 sanitary questionnaire as
          tabulated by Gove Associates, Inc. for lakeshore
          areas in Cass County	    2-8

2-3       Results of pollution survey of Indian Lake   	    2-9

2-4       Description of site limitations and results of
          surveys pertinent to on-site systems for each
          district	    2-22

2-5       Wastewater load factors projected for Sister
          Lakes and Indian Lake, Michigan, for the year
          2000	    2-27

2-6       The service factor excluding interest during construction,
          applied to the construction cost to compute the capital
          cost	    2-29

2-7       Economic cost criteria	    2-29

2-8       Summary of all estimated costs of centralized
          collection system alternatives   	    2-43

2-9       Summary of all estimated costs of centralized wastewater
          plant (WWTP) alternatives  	    2-45

2-10      Summary of all estimated costs of alternatives 	    2-50

2-11      Summary of estimated costs of Indian Lake alternatives..    2-64

3-1       Soils series characteristics and ratings 	    3-9

3-2       Physical characteristics of major lakes in the study
          area	    3-12

3-3       Summary of dominant algal taxa, average Secchi disk depths,
          and stratification conditions from the 1979 sampling
          period	    3-14

3-4       Mean nutrient export from non-point sources by land use/
          cover type   	    3-18

3-5       Total phosphorus inputs by source  	    3-18
                                     xvii

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                          LIST OF TABLES (continued)

                                                                      Page

3-6       Comparison of water quality indicies and estimated phos-
          phorus loads for area lakes	    3-22

3-7       Results of groundwater survey	    3-25

3-8       Predominant species of fish in each of the study area
          lakes surveyed by MDNR	    3-28

3-y       Population growth in the four-township area, three-county
          area, and Michigan between 1950 and 1980	    3-32

3-10      Population growth in the four-township area,
          1970 to 1980   	    3-32

3-11      Population growth rates in the four-township area,
          three-county area, and Michigan,  1950 - 1980	    3-34

3-12      Comparison of counts of residential dwelling units
          in the service areas   	    3-36

3-13      Number of new residences constructed on undeveloped
          lots in the service areas	    3-37

3-14      Housing units and population by service area and town-
          ship, 1980	    3-38

3-15      Population projections by township 	    3-39

3-16      Service area permanent population projections  	    3-39

3-17      Service area total population, based on four methods
          for forecasting seasonal population	    3-41

3-18      Acres of each land use/cover type in the seven watersheds
          in the Indian Lake-Sister Lakes study area 	    3-44

3-19      Land use in the watershed by number of acres and by
          percentage of the total acreage	    3-45

3-2U      Per capital personal income by county	    3-50

3-21      Selected financial characteristics for Berrien, Cass, and
          Van Buren Counties	    3-53

3-22      County debt measures	    3-55

4-1       Comparison of phosphorus loading rates associated
          with the various alternatives to the current
          loading rates   	     4-16

4-2       Annual residential user costs   	     4-28
                                     xviii

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                          LIST OF TABLES (concluded)
4-3       Cass County debt as a percentage of state equalized
          assessed valuation under four local share capital
          cost scenarios	      4-29

4-4       Average annual user charges for the "build" alternatives
          expressed as a percentage of median household income for
          Berrien, Cass, and Van Buren Counties   	      4-31
                                            xix

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                                LIST OF FIGURES
                                                                           Page
1.         Alternative 10 - On-site systems upgrading, blackwater
          holding tanks on critical parcels, and septic tank effluent
          collected from critical areas and conveyed to cluster drain
          fields	   xi

1-1       Location and boundary of the Indian Lake-Sister Lakes
          Study Area	   1-2

2-1       Septic tank - soil absorption systems	   2-36

2-2       Septic tank - raised drain bed system	   2-37

2-3       Layout of gravity collection systems, both conventional
          (Cl) and septic tank effluent (C3)   	2-41

2-4       Layout of septic tank effluent pressure sewers with some
          gravity sewers (C2)	   2-42

2-5       Alternative 2 - Pressure collection sewers and separate
          WWTPs for the Sister Lakes and Indian Lake areas with
          discharge to surface waters 	  2-48

2-6       Alternative 3 - Pressure collection sewers and regional
          treatment and land treatment system   	  2-49

2-7       Alternative 4 - Pressure collection sewers and regional
          WWTP located in Section 11	2-52

2-8       Alternative 5A - Pressure collection sewers and Alternative
          5B - Gravity collection sewers and regional WWTP located
          in Sections 29 and 32   	2-53

2-9       Alternative 6 - Pressure collection sewers and existing
          Dowagiac WWTP for Indian Lake and a new WWTP for Sister Lakes  .  2-55

2-10      Alternative 7 - Pressure collection sewers and existing
          Dowagiac WWTP   	2-57

2-11      Alternative 8A - On-site systems upgrading and critical
          areas septic tank effluent collected by pressure sewers and
          conveyed to cluster drain fields    	  2-58

2-12      Alternative 10 - On-site systems upgrading, blackwater holding
          tanks on critical parcels, and septic tank effluent collected
          from critical areas and conveyed to cluster drain fields. .  .  .  2-60

3-1       Topography and physiography of the study area	3-3
                                         xx

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                         LIST OF FIGURES (concluded)


                                                                           Page


3-2       Surficial geology of the study area   	3-5

3-3       Soil associations in the study area   	3-6

3-4       Comparison of sediment NAI-P with algal density for study area
          lakes	3-16

3-5       Surface watersheds in the study area	3-17

3-6       Groundwater contours in the study area	3-23

3-7       Well sampling sites for groundwater survey  	  3-2A

3-8       Population growth, historic and projected, for the four-
          township area   	3-40

3-y       Spatial distribution of land use/cover  	  3-43

3-10      Prime farmland in areas where soil mapping is available ....  3-46

4-1       Future phosphorus loading conditions for the centralized
          wastewater management alternatives  	  4-18
                                      xxi

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1.0.  PURPOSE AND NEED FOR ACTION

1.1.  Project Background

     The study  area,  covering an area  of  approximately 50 square miles in
rural southwestern  Michigan includes the  southern  half of Keeler Township
in  Van  Buren  County, the  northern and western portions of  Silver Creek
Township  in Cass   County,   a small  portion of  Pokagon  Township  in Cass
County,   and the  southeastern portion  of  Bainbridge  Township  in Berrien
County  (Figure  1-1).   The most dominant geographical  features  are the six
Sister  Lakes  (Round  Lake,  Crooked  Lake,  Cable  Lake,  Magician Lake, Pipe-
stone Lake, and Dewey Lake),  Keeler Lake, and Indian Lake.

     On-site systems  are the predominant  means  of  wastewater treatment in
the study  area;  there is no centralized wastewater treatment or collection
system.   Water  quality  problems  have been observed in  some of these  lakes.
These problems  may  have  been influenced by  the  shoreline development that
has occurred around each  lake in the area.

     Until  the  1960s, public control over  septic  tank system installation
was nonexistent or only  advisory.   During  the  1960s  and 1970s,  the State
government  and  local health  departments formulated and implemented  proce-
dures for  preconstruction approval  of  septic tank systems.   These  proce-
dures and  standard  design  requirements  have   reduced the  occurrence  of
surface  malfunctions and  plumbing backups  for new systems.

     A  1970 Cass County  Health  Department  study of  Indian Lake concluded
that sewage was entering  the  lake from  on-site systems  and that as seasonal
dwellings  were   converted  to permanent houses  the  problem would   become
worse.  Small lot  sizes,  high groundwater tables, and  poor soils were con-
sidered   to be   factors  which contributed  to failures  and  malfunctions  of
on-site   systems.   The study  recommended that "an  engineering feasibility
study should  be conducted  to determine the cost and  public  support for a
public sewage system".
                                  1-1

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Figure  1-1.  Location and boundary of Indian Lake-Sister Lakes Study Area.
                                          1-2

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     The Michigan  Department of  Natural Resources  (MDNR),  Michigan Water
Resources Commission (MWRC) Staff Report  (1971) stated  that most  residences
around  Indian  Lake have  disposal systems located  too  close  to  the normal
groundwater table.   The MWRC did not have sufficient data in 1971 to recom-
mend action  to  cite Silver Creek Township  for allowing unlawful  pollution
to exist in the lake area.  The MWRC recommended that Silver Creek Township
proceed with a program to provide a central collection  and treatment system
for Indian Lake.

     Pipestone Lake community-wide programs to ascertain lake water quality
and to  upgrade  on-site  sewage disposal systems in order to gain  compliance
with  the Berrien  County  Sewage  Disposal  Regulations began  in  the   late
1960s.   A  1969 survey  conducted  by  the  Berrien County  Health  Department
(1971)  determined  that  as many as 41% of the  total residences on the north
side  of the  lake   and  25% of  the  residences  in  the  southern  region had
sewage  problems of  some  sort, requiring  immediate attention and  corrective
work.   In  1970, a  sanitary survey conducted  by the  MWRC reported direct
septic  system  discharges  on the north side of the lake.  Laboratory analy-
sis showed that three discharges were sources  of human  waste contamination.
In  1970 and  1971,  MWRC  follow-up studies  and Health Department surveys
located more direct discharges and drew attention to the Dakin-Peters Drain
which was shown to have high coliform levels (Berrien County Health Depart-
ment  1971).  A  1972 water pollution and nutrient source study of Pipestone
Lake conducted  by  the  MWRC Water Quality Division  concluded  that the  lake
was adversely affected  by local waste disposal  problems  (MDNR 1972).   The
MWRC then recommended construction of a municipal wastewater collection and
treatment system to protect public health and  lake aesthetics.

     In  1971,  Barger  Engineering completed an engineering  study  for Bain-
bridge Township that recommended construction  of a sewage collection system
and  aerated  lagoons.   Unavailability  of planning  and  construction grants
have scuttled these plans.

     A  limnological study of  Dewey Lake  conducted by Snow (1976)  concluded
that  Dewey  Lake  has  a  natural  potential  to be  mesotrophic   (moderately
enriched and productive) and that on-site systems contributed less than 10%
                                  1-3

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of  the  phosphorus load to  the  lake.   The study noted  that  a sewer system
would reduce the nutrient input slightly.

     Michigan DNR delineated  the  study area in  a  letter dated 20 February
1976.  Pipestone  Lake  was  added to the study area shortly afterward.  Cass
County Department of  Public Works (DPW)  is  the  lead applicant and the Van
Buren County Road Commission and Berrien County DPW have concurred.

     In  May 1976,  the Cass  County  Department  of  Public Works  filed an
application  with  the Farmers  Home Administration  (FmHA)  for a  grant and
loan  to  construct a  waste disposal system  around  Indian  Lake.   In August
1976,  Cass  County   was  notified  by  FmHA  that  a $900,000  grant and  a
$1,000,000  loan at  5% for 40 years was set  aside for the construction of a
waste  disposal  system.   In  April 1977,  an additional $300,000  in grant
monies were set aside by FmHA for  the Indian Lake project.

     In  October  1977, Gove  Associates,  Inc. presented  to  Cass  County the
preliminary draft of  the  Indian Lake - Sister Lakes Area Facility Plan.  A
collector  system  was  proposed to serve  populated portions  of  the study
area, and  treatment  alternatives  were evaluated as  to costs,  environmental
effects, and institutional feasibility.  Acceptance of the Facility Plan by
MDNR  and USEPA was  delayed because  of  questions  regarding  the potential
impacts  of the  proposed   new conveyance  lines,  system cost, and whether
innovative/alternative systems might be feasible.

     In  August  1978,  USEPA issued a Notice  of Intent to prepare a Environ-
mental Impact Statement (EIS).  WAPORA, Inc. (E1S consultant to USEPA) sub-
mitted an  initial plan of study to USEPA in November 1978 which specified
that  the EIS  would  be prepared in two  major phases.  Phase I was designed
as an  initial  data  collection and evaluation phase.  Phase II involved the
completion  of  the work requirements identified  in  Phase I, the analysis of
wastewater collection and treatment alternatives, and the production of the
EIS documents.  Phase I was completed in July 1979  with the publication of
the Affected Environment Chapter of the Preliminary  Draft EIS  (WAPORA, Inc.
1979).   Phase  II also  included a reanalysis  and  recosting of centralized
treatment  alternatives  by Gove Associates,  Inc.   WAPORA would incorporate
                                  1-4

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Gove  Associates,  Inc.  work  on centralized  alternatives and would  analyze
both  centralized  and decentralized alternatives  in  the preparation of the
EIS.

     In January  1980,  Gove Associates,  Inc.  submitted  a cost effectiveness
analysis of  a  proposed centralized treatment  system to USEPA.   USEPA pre-
sented review  comments on the cost effectiveness analysis prepared  by Gove
Associates,  Inc. in May 1980.  Gove Associates, Inc.  (1980)  submitted their
revised cost effectiveness analysis to USEPA  in October.

     USEPA directed WAPORA to reanalyze  the regional alternatives that were
proposed and costed  in the revised cost effectiveness  analysis.  This re-
analysis was necessary because  of deficiencies  in  the cost effectiveness
analysis. WAPORA  submitted  a supplemental proposal  to  USEPA in April 1981
delineating  the  scope  of  work required  to  perform  the  reanalysis.  Work
commenced on the reanalysis and completion of  the Draft EIS  in June  1981 by
WAPORA.

     WAPORA, Inc. submitted a preliminary Draft EIS  to USEPA in March 1982.
The Draft EIS  was subsequently published by  USEPA  in August.   Included in
the Draft  were preliminary analyses  of  cost-effectiveness  of  various cen-
tralized and decentralized alternatives  and  a recommendation  that  further
field work  be  conducted to better define project need and alternatives.  A
public hearing was  conducted on 28  September  1982  by USEPA  to  receive
comments on  the  Draft.  The Supplemental Plan of Study for the additional
fieldwork and  analyses was  approved in  October and  the fieldwork was com-
pleted in November.   The  fieldwork consisted  of a limited sanitary  survey,
lake water  and sediment  quality  sampling,  and  a limited  sampling of su-
spected effluent  plume in groundwater.   An  additional  alternative  (Alter-
native 10)  combining  elements  of  Alternatives 8A, 8B, and 9 was developed.

     Based on  the  cost-effective  alternative  in the Draft EIS, FmHA sent a
letter dated  4  November   1982  to  the  Cass  County  Board of  Public Works
(CCBPW) stating  that  they  were  deobligating  the commitment to  assist  in
funding the Indian  Lake  system.   The  CCBPW asked  for and was  granted  a
hearing on   the  termination  of the  grant.   The  hearing  was held  in Paw,
                                  1-5

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Michigan on  10 March  1983.   As a  result of  the  hearing,  FmHA  agreed to
extend the commitment of the grant and loan through September 1983, pending
the recommendation of the Final EIS.

1.2.  Legal Basis for Action and Project Need

     The National Environmental  Policy Act of 1969  (NEPA)  requires a Fed-
eral agency  to prepare  an  EIS on  "...major  Federal  actions significantly
affecting  the  quality  of  the  human  environment  ...".  In  addition,  the
Council on Environmental  Quality (CEQ) published regulations (40 CFR Parts
15GO-150b) to  guide  Federal agencies  in  determinations of  whether Federal
funds,  such as  those  that may be committed to the Indian Lake-Sister Lakes
project  through  the  Construction  Grants Program,  or  Federal  approvals,
would result in  a project that would significantly affect the environment.
USEPA developed  its  own regulations (40 CFR Part 6) for the implementation
of the EIS process.   Pursuant to these regulations,  USEPA  Region V deter-
mined that  an  EIS was required for the  proposed  Indian Lake-Sister Lakes
project.

     The Federal  Water Pollution  Control Act of  1972  (FWPCA,  Public  Law
92-500),  as  amended  in  1977  by the  Clean Water Act  (CWA,  Public Law 95-
217),  establishes a  uniform,  nationwide water  pollution  control program
within which all  water quality programs  operate.   MDNR has been delegated
the  responsibility  and authority  to administer this  program in Michigan,
subject to the  approval of USEPA.

     The dispersal  of  Federal  funds is  made  to local  applicants via the
Municipal Wastewater  Treatment Works  Construction  Grants Program adminis-
tered by USEPA.   Prior to the Amendments of 1981,  the program consisted of
a  three-step grant  process:   Step   1  included wastewater facilities plan-
ning; Step  2 involved  the  development of  detailed engineering  plans  and
specifications;  and  Step 3 covered construction of  the pollution control
system.

     The Municipal  Wastewater Treatment  Construction  Grants Amendments of
1981 became  law  (Public Law 97-217) on 29  December 1981, and changed sig-
                                  1-6

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nilicantly  the  procedural  and  administrative  aspects  of  the municipal
construction  grants program.   The  changes  reflected  in  these amendments
have  been  incorporated  into  Construction Grants  -  1982 (CG-82) Municipal
Wastewater  Treatment.   Under the  1981  Amendments,  separate Federal grants
are  no longer  provided  for  facilities  planning  and  design  of projects.
However, the previous designation of these activities as Step  1, facilities
planning,  and  Step  2,  design, are retained  in the CG-82.  The  term Step 3
grant  refers  to the  project  for  which grant assistance  will be awarded.
The  Step  3  grant  assistance  will include  an allowance  for  the planning
(Step  1) and design (Step 2) activities.

     The CG-82  states  that projects which received  a Step 1 and/or Step 2
grant  prior to  the  enactment of the 1981 amendments should be completed in
accordance with  the terms and conditions of their grant agreement.  Step 3
grant  assistance  will include  an  allowance for design for those projects
which  received  a Step  1  grant  prior to  29  December 1981.   A municipality
may be  eligible,  however, to receive an advance of the allowance for plan-
ning, and/or design  if  the population of  the community is under 25,000 and
the State reviewing agency (MDNR) determines that the municipality would be
unable  to complete  the facilities planning and design  to qualify for grant
assistance (Step 3).  The Indian Lake-Sister Lakes project has been in Step
1 since 1976.

     The State  of Michigan,  through the MDNR, administers the Federal Con-
struction Grants  Program at  the State  level.  State law also includes pro-
visions for  an additional 5% of the costs  for  planning,  design,  and con-
struction,   except  where  the  Federal  share is larger  than  75%.   No monies
for this purpose have been appropriated by the State legislature.

     Communities  may  choose  to  construct wastewater  treatment facilities
without financial support from the USEPA and State Grants Program.  In such
cases,  the  only  requirements are that  the design  be technically sound and
that the MDNR be satisfied that the facility will meet discharge standards.

     If a community chooses to construct a wastewater collection and treat-
ment system with USEPA grant assistance, the project must meet all require-
                                  1-7

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merits of the Grants Program.  The CWA stresses that the most cost-effective
alternative be  identified and selected.  USEPA  defines  the cost-effective
alternative as  the one  that  will  result  in minimum  total resource costs
over the  life of  the  project, yet  meet  Federal,  State,  and local require-
ments.   However,   the  cost-effective  alternative  is  not  necessarily  the
lowest cost proposal.   The  analysis for choosing the cost-effective alter-
native  is  based on both the  capital construction costs  and  the operation
and maintenance  costs  for a 20-year period,  although only the capital costs
are  funded.   Non-monetary costs also must be  considered,  including social
and environmental factors.

     Federal  funding  for wastewater  treatment  projects  is provided under
Section  201  of  the FWPCA.  The  USEPA will  fund 75% of  the grant eligible
costs  for  conventional  sewers  and treatment.   For  alternative collection
systems and treatment  systems (e.g.,  pressure sewers,  septic tank effluent
sewers,  septic   tanks,   and  soil  absorption systems),  the  funding level
increases to  85%  of  the eligible costs.  The costs for conventional sewers
that  USEFA will not  assist  in  funding for  are  land  and  easement costs,
sewers for which less  than two-thirds of the planned flow originates before
28  October  1972,  pipes  in  the street or easements  for  house connections,
and  building  sewers for connection to the system.   The  costs for alterna-
tive systems  that  the  USEPA will not  assist  in  funding are easement costs
and building sewers for connection to the septic tank.   The grant eligibil-
ity  of  the  on-site portions of  alternative  systems  varies  depending on
their  ownership and management.   Publicly and privately-owned systems con-
structed after 27 December 1977 are not eligible for Federal grants.

     Michigan was  required  by  the Federal law  to establish  water quality
standards  for lakes and  streams and  effluent  standards for  discharge to
them.   Federal  law  stipulates  that,  at a  minimum, discharges  must  meet
secondary  treatment  requirements.  In  some  cases,  even  stricter effluent
standards are subject  to USEPA approval and must conform to Federal guide-
lines.

     A  new  wastewater  treatment  facility also  is subject  to the require-
ments of Section 402 of the FWPCA, which established the National Pollutant
                                  1-8

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Discharge  Elimination  System  (NPDES)  permit  program.   Under  the  NPDES
regulations,  all  wastewater discharges to surface  waters  require an NPDES
permit and  must  meet the effluent standards identified in the permit.  The
USLPA has delegated  authority to establish effluent standards and to issue
discharge permits  to the  MDNR.   The USEPA, however,  maintains review au-
thority.   Any permit  proposed for issuance may be subject to a State hear-
ing  if  requested  by another  agency,  the applicant,  or other  groups  and
individuals.  The  hearing,  normally before a  State  Hearing  Examiner, pro-
vides the public  with the opportunity to  comment  on a proposed discharge,
including the location  of  the discharge and level  of  treatment.  Findings
and  recommendations   are  subject  to  review and  approval by  the Michigan
Water Resources Commission.

1.3.  Study Process and Public Participation

     The   major  efforts  in  the  preparation of this  EIS occurred  in  the
period between 1979  and 1983.  During this period,  WAPORA,  Inc. submitted
various  interim  reports  to  USEPA,  including  the  "Affected  Environment,
Preliminary  Draft  Chapter  of  the  Indian Lake-Sister  Lakes Environmental
Statement",  and   the Draft  EIS.   Participants in  the wastewater planning
process during the past five years have included: USEPA; WAPORA, Inc. (EIS
consultant); Gove Associates, Inc. (Facilities Planner); Cass County  (Gran-
tee);  Berrien County;  Van  Buren County;  Southwestern Michigan Regional
Planning   Commission   (now  Southwestern  Michigan Commission);  Michigan  De-
partment  of Natural Resources; and other Federal,  State, local, and private
agencies  and  organizations.   USEPA sponsored  3 public  meetings to facili-
tate public involvement during the preparation of the EIS.

1.4.  Issues

     Based  on a  review  of USEPA's Notice of Intent, the Directive of Work,
and  the  Facility  Plan, the  following issues  have  been determined  to  be
significant and require resolution in the Environmental Statement:

     •    Extent  of   the  present problems resulting from the  use of
          on-site wastewater treatment systems
                                  1-9

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Contribution made  to water  pollution  by  point  sources and
nonpoint  sources  other  than  on-site  wastewater  treatment
systems

Future  impacts  resulting  from  continued use  of  on-site
systems

Potential  for  improved  treatment  of wastewater  by existing
systems through improved maintenance and operation

Cost-effectiveness of various methods  of  wastewater treat-
ment, including alternative technologies

Potential  for  wastewater  treatment  projects  to  change the
rural character  of the  area by affecting wetlands and agri-
cultural lands

Economic impact  of the  capital and  monthly operating costs
of the project on local  citizens

Ability  of local  governments to  finance  the costs  of the
project

Impact  of  the  project  on environmentally sensitive areas
(e.g., habitats  of endangered and threatened  species, arch-
aeological  resources,  and  sections of  the  Dowagiac River
nominated as "natural" by Michigan)

Type  and  extent  of   secondary impacts  resulting  from the
project

Examination and  analysis  of  local  zoning and  subdivision
ordinances, and land  use regulations that could mitigate the
negative impacts of the  project

Secondary  impacts  that would result from the  implementation
ot all treatment alternatives

Commitment of  resources  including,  but not limited to: con-
struction  materials,  financial  resources,  and   labor  and
energy resources.
                        1-10

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2.0.  DISCUSSION OF WASTLWATER TREATMENT ALTERNATIVES

2.1.  Existing Wastewater Treatment Systems

     The  study  area  is  currently  served  almost  exclusively  by  on-site
systems that  include  soil absorption of the septic  tank effluent.   Infor-
mation on  existing  systems  was gathered from  the health department  records
in  the  respective  counties  and  was  developed  from  the  limited sanitary
survey.   Interviews  with health  department personnel  were also useful  in
assessing  the environmental conditions and  the  suitability of septic tank
soil absorption systems for treating wastewater.  A sanitary survey,  septic
leachate  detector  survey,  color infrared  aerial  photography,  a   mailed
questionnaire, previous  surveys,  and  a shallow groundwater study also were
used to assess the effectiveness of the existing treatment systems.

2.1.1.  Existing On-site  Systems

     Septic tanks and soil absorption systems  for individual residences are
utilized  almost  exclusively  for  wastewater treatment  and  disposal   in the
study area.   One noteworthy exception is the Old German Village area  on the
west  side  of  Indian  Lake.   A collection  system and  community septic tank
and drainfield serves 20  (or 21) residences.   While early septic tanks were
constructed of anything that would hold out  soil, a very high  percentage  of
the  septic tanks  in  use are  precast  concrete.  Soil  absorption  systems
consist primarily  of drain beds  and  dry wells.  Prior  to  1970,  the home-
owner and his contractor  could install any system they desired.  Since 1970
the health departments have  regulated the  design and installation   of on-
site  systems.  The records of the health  departments and  additional site
limitations are summarized in detail in Appendix A of  the Draft EIS.

     Each  county health  department utilizes  its  own  standards  for soil
absorption  systems.   The  Van  Buren County  Health  Department  permits block
trench and precast concrete dry wells for both replacement and new systems.
The Cass  County  Health Department requires drain beds for new and replace-
ment  systems  and  will permit  dry wells  for replacement systems where site
limitations prevent installation  of  drain beds.  The  Berrien  County  Health
                                    2-1

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Department employs  standards  similar  to those utilized  by  the Cass County
Health  Department.   Based  on homeowner  reports,  repairs  to  systems are
frequently completed  without health department  involvement.   In Van  Buren
County, additionally, dry  wells  can be "restoned"  when  flow  rates through
the gravel-soil  interface becomes  too slow  and  backups occur.  Restoning
involves excavation of  the gravel surrounding the dry well and replacement
with clean stone.

     Less than 10%  of  the soil absorption systems have been replaced  since
1970,  according to records of the health departments.  These records do not
indicate whether  systems are operating satisfactorily  or whether nutrient
enriched effluent is being discharged to the lakes.

     The  systems  that  were  replaced  were  primarily  dry wells  that were
undersized and sited with less than the required  distance  above the  water
table.  Lot  sizes and  shapes and land  slopes  are the major constraints to
installing soil  absorption systems  that  meet the  applicable  standards of
each county.

     Approximately  50%  of the  replacement  systems  have  been  dry wells or
block  trenches.   Some  were installed  because  lot configurations precluded
utilisation  ot  drain  beds  in  Cass  and  Berrien  Counties where  they are
preferred.

     The conventional drain  bed  accounted  for 25%  of  the replacements and
raised  drain  beds  (sand  mounds)  accounted  for  20%.  The  majority of the
raised drain beds were located in the Gilmore Beach  and Beechwood subdivis-
ions,   the  Polk  leases,  and  the Pipestone  Lake area.   Miscellaneous re-
placement systems comprised  the  remaining  5%.  These include  systems  where
only  the  septic  tank  was replaced, those for which no  design information
was available, and two holding tank systems.

     Regular  maintenance,  primarily  removal  of  solids  from  the tankage,
probably  is  the  major  factor in the  successful  operation  of  on-site sys-
tems.    In  addition  to  maintenance,  water  conservation practices  in the
homes  are essential  for the continued  successful  operation  of many of the
                                    2-2

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on-site  systems  that  have  extreme  site  limitations.    These  factors, in
conjunction with seasonal use, probably account  for  the successful opera-
tion  of  many  of the on-site  systems,  particularly  the  older,  undersized
systems.

2.1.2.  Summary of  Data on Operation of Existing Systems

     Operating data on the on-site systems must be obtained from individual
homeowners.   From  an operational viewpoint,  homeowners  could provide  some
data on regularity  of pumping and overloading of the soil absorption system
that  results  in  surface breakouts of effluent or backups in  the residence.
Data on the wastewater treatment capability of the systems are not general-
ly available  except  by way of limited well water quality testing performed
on samples  submitted  by concerned homeowners.  Operational data from indi-
vidual homeowners  have  been collected for targeted areas through a limited
sanitary survey.

     Four  surveys  for  evidence  of  failures  have been  conducted:  a septic
leachate survey (K-V Associates, Inc. 1980), an aerial survey (USEPA 1979),
a  questionnaire  prepared  and tabulated by  Gove Associates,  Inc.  (1978a,
1978b),  and a  targeted sanitary  survey  (Appendix A).   A failure  can be
positively  identified  by  evidence  of  recurring backups in  the  dwelling
resulting  from inadequate  seepage from the soil absorption system, surface
breakout of septic tank effluent over the  soil  absorption system, or  con-
tamination  of groundwaters  or  surface  waters  from inadequately  treated
effluent.  These surveys are discussed in the following sections.

2.1.2.1.  Septic Leachate Survey

     The  septic  leachate  survey  was  conducted by  K-V  Associates,   Inc.
(1980) and is  reproduced as Appendix B of the Draft EIS.  The components of
the  survey included  the  continuous  monitoring  of   the  shoreline by  the
recording leachate  instrument  (ENDECO Type 2100) and water quality analyses
of identified stream  or groundwater plume sources for evidence of domestic
wastewater  breakthrough of excessive nutrients  and  coliform  bacteria.   In
this  survey groundwater  plumes  have  been  classified  as  either  erupting
                                    2-3

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plumes  (breakthrough  of  organics and  inorganics,  principally chlorides,
sodium, and  other salts)  or  dormant plumes  (slow release  of  residual or-
ganics after  the  inorganic breakthrough has passed).  Stream source plumes
are those  surface inflows  that  have the  indicator  organics  present.   The
methodology and the results are  presented in Appendix  B of the Draft EIS.
It should  be noted that a total  of  12 miles (19  kilometers)  of shoreline
were not surveyed and  that only Keeler Lake was completely surveyed.

     A summary of  the  number of  active wastewater derived  plumes entering
the  lakes  from  groundwater sources  is given  in  Table 2-1.   In general,
Dewey, Cable, Lower Crooked, Round, and Keeler lakes have few or no active,
erupting plumes.  Magician, Indian, Upper Crooked, and Pipestone lakes have
significant numbers of wastewater plumes.

     Plumes were tested for water quality parameters and for flow direction
and velocity.   Generally,  where  the groundwater velocity  was  high in the
direction  of  the lake,  numerous active plumes  were  identified.   These
vectors must  be  interpreted on an extremely  localized  basis  as conditions
existing at  one  point  in  time and must not  be  interpreted as generalized
groundwater flow vectors.

     Water  quality samples  collected  from  the  plumes were  analyzed for
orthophosphorus (reported as total phosphorus),  ammonia, and nitrate-nitro-
gen;  other  samples were analyzed for fecal  coliform.   Generally, the only
elevated fecal coliform  levels   measured  were  along  the  north  shore  of
Pipestone  Lake  where   several pipes  discharge into  the  lake.   Elevated
nutrient levels were measured, but in  few cases  were the levels excessive
enough to  identify any strong breakthroughs of nutrients from  soil absorp-
tion systems.

2.1.2.2.  Aerial Survey

     The USLPA  Environmental  Monitoring Systems Laboratory acquired aerial
color photography and multispectral scanner imagery of the study area on 16
May and  19  July 1979   (USEPA  1979).   The  color  photography was stereoscop-
ically  examined  for  apparent on-site  septic system malfunctions  and for
                                    2-4

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detection of. algal  blooms  in the lakes of the study area.  The photographs
also were  used to  update  a  land  use/cover survey  prepared  by the South-
western  Michigan  Regional  Planning Commission  (SMRPC  1978).   The multi-
spectral  scanner   imagery   was  computer-analyzed  to  assess  the  relative
temperatures of the lakes.

     The  technique  requires   detection  of  variations  in color  tones of
vegetation  resulting  from  septic  effluent  rising   to or  near  the  soil
surface.  The  majority  of  the deciduous  trees and  shrubs had  fully leafed
out, which  obscured the aerial view of many  of  the older residential lots
where  a greater  proportion  of  failures  would  likely occur.  The  16 May
photography  was  used  for  detecting septic  systems;  thus,  seasonal resi-
dences would likely show no failure characteristics.

     The analysis  categorized the  discernable  on-site  septic systems and
identified  these systems on enlarged photographs.  The category and number
of systems are presented in Table 2-1.   Only two systems were  identified as
probable  failures  and  62   systems  were  discernable  systems  that  may be
failing.   During  a  field   inspection,  25  of  the  identified  systems  were
inspected.  Of these,  two  had definitely failed  and 15 would  require fur-
ther testing and monitoring.

     Surface breakouts  of   septic  tank effluent  from permanent residences
occur rarely in the  study  area as  demonstrated  by  the aerial  photography.
Those that  do  occur  are repaired quickly.   Since  the photography that was
analyzed was obtained  in May, the study is much less  conclusive concerning
surface breakouts  from  seasonal  residences and from older residences under
tree canopies.

2.1.2.3.  Mailed Questionnaire

     In 1978 Gove  Associates, Inc. mailed questionnaires to property owners
in  Cass  County to  gather  information concerning on-site  systems and con-
cerning  attitudes  toward   the  proposed  sewage  collection  and   treatment
system.  The questionnaire  is included in Appendix E  of the Draft EIS.  (A
questionnaire  was  also  mailed to property  owners  in Van Buren County, but
                                    2-6

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the results  were  not tabulated.)  Generally,  the  results showed that  less
than  15% of  the  residents  on any  one  lake  returning  questionnaires had
problems with their on-site systems  (Table 2-2).  Within  the  10 years  prior
to  the questionnaire,  as  many  as  28% of  the residents  on  Magician  Lake
indicated  that  they  had  replaced part of  their  system.   Considering  that
design  standards  promulgated  by  the  county  health  departments  had  been
applied only since the  1970s,  it  is not surprising that the percentages are
what  they  are.   The  questionnaire results  also  indicated that apparently
many  residents  repair  their  on-site  systems  without the benefit  of the
design  and  inspection  services  of  county  sanitarians because  the county
records do not  indicate nearly as high a  percentage of  replacements.  For
this  reason  also,  it  is  not   surprising that continuing problems  are in
evidence.  Residents  are  apparently  trying to escape the costlier design
solutions  that  the sanitarians would  propose  by  conducting  repairs  inde-
pendent of them.

     For Magician and Indian Lakes, Gove Associates, Inc.  tabulated  the re-
sults by segments of  lakeshore.   Residents of  the Indian  Lake lakeshore re-
ported  varying  percentages  for  the  different  segments   (Table  2-2)  .  On
Magician Lake,  the southwest-west  shoreline  exhibited the  greatest  prob-
lems.  On Indian Lake, the southwest-west and  the east-southeast shorelines
appear to have more problems than do the other shoreline  areas.

2.1.2.4.  Indian Lake Sanitary  Surveys

     The Cass County  Health Department (1970)  conducted  a field survey of
on-site  systems around Indian  Lake  in an effort  to determine  whether the
systems  were operating properly.  Approximately 60% of  the  dwellings  were
surveyed and of these 75% were  seasonal residences  at that time.   Results
of  the survey are  summarized  in Table 2-3.   Approximately 20%  of   the re-
spondents  stated  that they  had discharges  to  the  lake or ground surface,
and yet  only 4% claimed  to  have a problem with their system.   The former
statistic must  not imply  what it purports to  reveal.   Responses to  ques-
tions  2,  3,  6,  7,  and  10 indicate that some  potential  for  lake pollution
exists, but is not proved.
                                    2-7

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Table 2-2,
Lakeshore
  Area
Partial results of 1978 sanitary questionnaire as tabulated by
Gove Associates, Inc. for lakeshore areas in Cass County  (Gove
Associates, Inc. 1978b).
         Number of
        Respondents
 Continuing
Problems with
   System
 Replacement of
 Part of System
in last 10 years
           Suitable Area
           for Expansion
             Available
bewey
Cable
Crooked
Magician
  North-northeast
  Northeast-east
  East-southeast
  Southeast-south
  South-southwest
  Southwest-west
  We s t- no r thwe s t
  Northwest-north
  Summary

Indian
  North-northeast
  Northeast-east
  East-southeast
  Southeast-south
  South-southwest
  SoutVi west-west
  West-northwest
  No r t h we s t- no r t h
  Summary
            78
            66
            37

            16
            20
            11
            33
            40
            52
            29
            43
           252
    7.7%
    4.5
   10.8

    6.3
   10
   18.2
    9
   10
   19.2
   10.3
   11.6
   12.6
29
9
37
22
22
20
34
47
232
20.7
22.2
18.9
9.1
9.1
15
11.8
14.9
14. 5
     20.5%
      6.1
     18.9
     25
     25
     18.2
     30
     20
     34.6
     24
     25.6
     28.2
1
                                            24.
                                            22.
                                            35.
                                            18.
                                            18.
                                            45
                                            23.5
                                            12.8
                                            24.6
                        ,1
                        ,2
                        .1
                        ,2
                        2
               70.5%
               66.7
               86.5
75
60
45.5
51
65
53.8
55.2
72.1
               58.4
                       65.5
                       33.3
                       51.4
                       45.4
                       63.6
                       70
                       70.6
                       53.2
                       55.2
                                       2-1

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Table 2-3.  Results of pollution survey of  Indian Lake  (Cass  County Health
            Department 1970).

                                                           Percent
Item                                                  Positive  Responses

1.   Owner knows size of sewage disposal  system                  31

2.   Sewage discharges to lake or ground  surface                 20

3.   Sewage disposal system is within 25  feet on lakeshore         9

4.   Property fronts on lake or channel                          85

5.   Sewage system is located on lake side  of house              30

6.   Sewage system is located less than 50  feet from  well        69

7.   Owner is having trouble with sewage  system                    4

8.   Replacement area for sewage disposal system is available    60

9.   Owner has septic tank pumped on schedule                    19

10.  Drain pipes are close to septic system                       4
                                       2-9

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     The 1971 MWRC  Staff Report (Gove Associates,  Inc.  1977)  is a summary
of a  field inspection report  for  Indian Lake.  When  the  field survey was
conducted, most  of  the  septic system failures identified the previous year
by the  Cass  County Health  Department  had  either  been corrected  or were
operating  properly  due  to changes  in the hydrologic conditions.  The clus-
ter septic tank and  drainfield  of  the  Old German  Village  area was still
malfunctioning.   The report states that insufficient data were available to
cite   Silver  Creek  Township  for  pollution  of the  surface waters  of  the
State.  The report  did  recommend construction of a  central collection and
treatment system in the area.

2.1.2.5.  Pipestone Lake Surveys

     An extensive  summary of  the  on-site  systems  surveys  and the actions
taken to upgrade  failing systems was prepared by the Berrien County Health
Department (1971).  The  first on-site inspection was  conducted in 1969 by
the Health Department.   The results  of  the  survey are not  presented in
their report.   The  following summer, another  survey was conducted and Lake
water samples were collected.   Total and  fecal coliform  counts were very
high  at  two  of  the five  locations  sampled.  In September 1970,  the MWRC
sampled  several  drainpipes   (Gove  Associates,  Inc.  1977).   Of  the four
sampled,  three  had extremely  high total  and  fecal coliform  counts.  The
following  year,  1971, the  MWRC  sampled ten locations  around  the  Lake and
found . that five  of the  ten  locations  had  high  total and  fecal  coliform
counts  (Gove  Associates,  Inc.  1977).   An  overall  sampling program for 13
stations  was  instituted  in  the  autumn   of   1971.    Phosphates,  dissolved
oxygen, and phosphorus  were  analyzed in addition to total  and fecal coli-
form.   Pollutant  levels  in the water samples were elevated to  the point of
constituting genuine  concern for  the public  health and  water quality as-
pects of the Lake.

     These conclusions were  presented in  the  Berrien County Health Depart-
ment  report for Pipestone Lake:

     •    Nutrients from the Sister Lakes Laundromat formerly signifi-
          cantly enriched the Lake with phosphorus
                                    2-10

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     •    Drainage  from  surrounding agricultural lands, particularly,
          leachate  from  the sandy  soils, animal  wastes,  and natural
          nutrients  from  the extensive wetland areas were the primary
          contributors to Lake water quality problems
     •    Septic tank effluent from certain residences were  contribut-
          ing to the Lake algae problem
     •    A  Lake  restoration program  consisting  of a central collec-
          tion and  treatment system and  application of an algicide to
          the Lake should be considered.
     The MWRC continued  sampling in 1972.  These  sample  results were  pub-
lished in the Facility  Plan (Gove Associates, Inc. 1977).   Elevated nutri-
ent  and  coliform  levels were  commonly  measured   in  these  water samples.
Approximately one-third  of  the  estimated phosphorus inputs  originated  from
tile outlets or ditches from residential  lots around Pipestone Lake.

     The  Berrien  County Health  Department  (Shipman  1977)  reviewed  and
updated  its  activities   concerning Pipestone  Lake.    In  March  1973,  the
Health Department  prepared   and  sent   to  residents  plans  for upgrading on-
site systems.  The  Sister Lakes Laundromat upgraded its system by abandon-
ing seepage  lagoons  and  incorporating waste stabilization lagoons.  In May
1973, Bainbridge Township officials conducted a hearing for  a final resolu-
tion of on-site  problems.   Upgrading  existing systems  was  selected  as the
appropriate  interim  approach while  an ultimate  solution  was pursued.   In
June 1973,  the Township building  inspector followed through with upgrading
the majority  of  the systems that violated the Sewage Disposal Regulations.

     A limnological  report   on  Pipestone Lake  (Banks  1977)  concludes  that
one  source,  the  Dakin-Peters  Drain   contributed  considerable  amounts  of
phosphorus  and coliform  to  the  Lake.  Animal wastes were primarily respon-
sible  for  the contamination.   The  residential  contribution of phosphorus
was estimated to  be  a very  small percentage, although the estimate was not
based on testing ot these sources.

2.1.2.6.   Targeted Sanitary  Survey

     A sanitary  survey of systems along  the shorelines of the lakes in the
project area  was  conducted  between October 28 and  November  17,  1982.  The
                                    2-11

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systems that were  surveyed  were located within the areas designated as the
service areas  for  cluster  drainfields  for Alternatives  8A and  8B.   The
survey was  conducted  when primarily permanent residents were present (83%)
and,  therefore,  does not  reflect  accurately the  conditions of  on-site
systems within the cluster system service areas.  However, it indicates the
performance of on-site systems  in year-round use and provides data on site
conditions  of  adjacent parcels.  The survey approach and  results  are pre-
sented in  Appendix A.

     With the  exception  of  1 privy, all  surveyed  residences are served by
septic tank and  soil  absorption systems.  Of  the  soil  absorption  systems,
50  were dry wells, 24 were drain  beds,  19 were dry wells  and drain beds,
and 12 were  raised drain beds.   Of the 120 surveys, 28 indicated that they
pump  their  septic tank  annually or have  pumped  it within  the last year.
Many  of  these  indicated  that  they pump annually  as a  regular maintenance
item.  Average  time  between pumpout  is 4 years,  well within  the normal
range.

     The number  of respondents  who have ongoing problems of seasonal back-
ups or  ponding  were  15   (9 around  Indian Lake of  the  23 surveyed).  Five
residents experienced seasonally wet ground over  the  soil  absorption sys-
tem.   The  majority  of  surveyed residents  said   that  they must  severely
restrict water use or backups occur during wet periods.

     The well  water  sampling  program  conducted  in conjunction  with  the
sanitary survey  identified  3  wells, 2 on Upper Crooked Lake and 1 on Lower
Crooked Lake,  that had  nitrate concentrations greater  than 10 mgN/1,  the
Federal drinking water  standard.  Wells that did not penetrate a restrict-
ing  layer  and  had elevated  chlorides  were more  likely to  have  elevated
nitrates,   indicating  that   the elevated  nitrates are  likely  related  to
septic tank effluent.

2.1.2.7.   Shallow  Groundwater Study

     A limited study  of the shallow groundwater between five drain beds and
the shoreline  was  conducted between October 28 and November 17, 1982.  The
study  is described in detail in Appendix  C.   One drain bed was located on
                                    2-12

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Round  Lake and  four  were  located  on  Indian  Lake.   No  significant dif-
ferences  were  noted between  sample locations.   The phosphorus concentra-
tions in the groundwater more than ten feet from  the soil absorption  system
were uniformly low.  Nitrates were not significantly elevated above natural
levels.   The  sampling was  conducted when  lake   levels  were  near historic
lows.  In addition, the groundwater levels were low because of a relatively
dry autumn.  Under these conditions, excellent treatment of the septic tank
effluent can be expected.  Louden and Fay (1982)  demonstrated that, as long
as  the water  table  remains  below  the drain  bed,  good treatment  of the
effluent would occur.  This data was inconclusive concerning the high water
table situation because that condition was not encountered.

2.1.3.  Problems Caused by Existing Systems

     The on-site  systems  that fail to  function properly result in backups
in household plumbing,  ponding  of effluent on  the  ground surface, ground-
water contamination that may affect water supplies, and  excessive nutrients
and coliform levels  in surface  water.  Region V  has prepared guidance that
recommends  procedures that  should  be  used  to  demonstrate  project need.
Since this  project  was initiated prior to distribution  of the USEPA  Region
V  guidance, entitled  "Site  Specific  Needs  Determination  and Alternative
Planning for Unsewered  Areas",  that guidance is  not being  applied to this
project.   However,  Program  Requirements  Memorandum  (PRM)  78-9  and 79-8
direct that documented pollution problems be  identified and tracked back to
the  causal factors.   Projects   would  be  funded  only  where  a significant
proportion of residences are documented as having or causing problems.  The
Region V staff interpret the regulations to mean  that eligibility for USEPA
grants be  limited to  those  systems  that  have direct  evidence of failure
such  as  surface  ponding.   However,  in recognition of  the  potential for
future failures,  eligibility  is  extended to  existing systems identified as
potential  failures  because of  obvious  underdesign  or  other  factors, pro-
vided  these systems   are  similar  to  systems  that  have  already  failed.
Similarity  is measured  by  system design, usage,  soil characteristics, site
limitations, site drainage, and groundwater hydrology.
                                    2-13

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2.1.3.1.  Backups

     Backups of sewage in household plumbing constitutes direct evidence if
the backups can be related directly to design or site problems.  Plugged or
broken pipes or full septic tanks would not constitute an evidence of need.
The mailed  questionnaire results  for Cass County  may  indirectly indicate
that residents  may  be  experiencing backups by responses to the question of
how often  their system  malfunctions.  Less than  10% indicated that their
system malfunctioned more frequently  than once every three years.  Specific
locations of these  respondents  were not identified.  The targeted sanitary
survey results  Indicate  that,  of the 120  surveyed,  15  experience seasonal
backups.   Most  of  these systems  were  located around  Indian  Lake  in  the
areas where organic soils and high water tables were identified.

2.1.3.2.  Ponding

     Ponding ot effluent above or around the soil absorption system consti-
tutes direct evidence  of a system failure.  The aerial photography was in-
tended to identify these systems, but problems with the photography limited
its interpretation.   The May  photographs  were examined  for  ponding, thus
ettectively  eliminating  seasonal  residences  from  the  analysis.   Also,
extensive  tree  cover  prevented  interpretation  in many  older residential
areas.   Only  one  system,  located on the  west shore  of Indian  Lake,  was
identified as exhibiting ponding.  Other sources,  though, indicate that the
ponding  problem has  been more  extensive.   The   1970  Cass  County  Health
Department  survey  of   Indian  Lake  noted  numerous  discharges  to  swamps,
particularly near the outlet drain from the Lake and along the  north shore.
Many of  these   systems  have  been  repaired  within  the  last  decade.   These
failures,  though,  are  indicative  of potential problems  with neighboring
systems  because high water  tables prevent proper  functioning of the soil
absorption  systems.   Lvidence  of ponding  around  other  lakes is limited,
although from replacement  records it could be  inferred  that  ponding would
be the principal factor  in replacing  soil absorption systems.   The sanitary
survey results  Indicate  that ponding  occurs infrequently within the project
area.  Of the 120 residents surveyed, 5 reported seasonally wet ground over
the soil absorption system.   A number of  others  had  wet  ground over the
                                    2-14

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soil  absorption  system but  considered it  more  a  function  of the organic
soils and the seasonally high water table than an evidence of a failed soil
absorption  system.   Most homeowners  surveyed were aware  of  the  site con-
straints  on their  property  and  did  not consider it  a  problem  with the
on-site system, even though it is evidence of a problem.

2.1.3.3.  Groundwater Contamination

     Contamination of  water  supply  wells constitutes direct evidence where
concentrations of nutrients greatly exceed the background  levels of ground-
waters  in the  area  or primary drinking water quality standards.   In order
for well  sampling data to qualify as direct evidence of failures, specific
well  information must be  collected,   such  as the  depth  of the  well,  its
orientation  with  respect  to  soil  absorption systems,  the presence  or ab-
sence of aquitard, and the degree of protection from surface contamination.
Contaminated groundwater  was identified  by the  groundwater  sampling pro-
grams  in  a  few locations  (Table  3-10 and Appendix A).  Most  of  the wells
sampled,  though,  were associated with permanent residences and  these are
more likely  to be of better construction and deeper than wells for seasonal
residences.   A  number of  wells  had concentrations of  chloride  that indi-
cated  that  septic tank  effluent  influenced  the  groundwater and  levels of
phosphorus,  nitrates,  and  ammonia  were somewhat  elevated.  This indicates
that adequate  treatment  of  effluent is occurring.  At most locations, high
levels  of nitrates  may originate from other  sources,  particularly natural
decay  of  organics and  fertilizer.   For example, the  high nitrates  in the
two  samples on  the  north  side  of Keeler  Lake appear  to be  from other
sources.  Other  data  sources of well water  quality indicate  that nitrates
in  some  wells  were  elevated above  background levels,  but did not violate
drinking  water  quality standards.   The  health  departments  of each county
provide well water testing services for residents.  These results were used
in  the  evaluation as  well  as water well  testing performed in conjunction
with the  septic  leachate  detector survey and the targeted sanitary survey.

2.1.3.4.  Surface Water Quality Problems

     Surface water  quality problems directly attributable to  on-site sys-
tems must be serious enough to warrant taking action.   Problems with public
                                    2-15

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health  implications,  that  is,  high  fecal colifonn  counts,  are  serious
enough to warrant  attention.   Nutrient inputs, though, must be analyzed in
terms  of  their contribution  to degradation of  water quality  and  whether
water  quality  would  be significantly improved by  a  project.   A variety of
means  for evaluating  the  contribution  of  septic tank effluent  to  water
quality problems are available and have been applied within the study area.

     The  septic  leachate detector survey  (Section 2.1.2.1.  and Appendix B
of the Draft  EIS)  was conducted to locate and quantify the nutrient inputs
from septic tank-soil  absorption systems.   When the septic leachate plumes
were located,  surface and  groundwater samples were  taken at  that point.
The  results   (Appendix  B of  the  Draft EIS) indicate  that most  plumes of
septic leachate had  low levels of phosphorus  and  nitrate  in them compared
to  the typical levels  in unattenuated  septic tank effluent.   Open  drain
pipes  found  in Pipestone  Lake had high levels of nutrients  and coliform.
Elsewhere,  coliform  counts  were  uniformly   low,  indicating  that public
health problems  (disease causing organisms) were  of  minimal  concern.  The
results indicate  that,  where the wetlands discharge  into the lakes, con-
siderable nutrients are contributed to the  lakes.

     Numerous  water  quality  surveys  have   been conducted  to locate failed
septic systems around  Pipestone  Lake.   None  of the  other lakes have been
analyzed  to   the  same  degree.   Pipestone  Lake  has  numerous  pipe drains
emptying  into  the  lake; these have been sampled  frequently by the Berrien
County  Health  Department  and  the  Michigan  Water  Resources Commission.
Several of  these have  been  shown to  be highly polluted  (with high fecal
coliform  counts).   According to the Health Department (Shipman 1977), the
offending systems  have been repaired and upgraded.  Subsequent sampling in
conjunction with  the septic  leachate detector survey, though, demonstrated
that elevated  fecal coliform  counts in some drain  pipes were  still present.
The  sanitary  survey  identified 3 residences that  had  draintile originating
from the  clotheswasher  or  from the  drain  bed that  emptied into the lake.
Others were reported to  be present also.

     The  limited  shallow groundwater  sampling program (Appendix C) showed
that the  on-site  systems contributed little phosphorus and nitrates to the
                                    2-16

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iakes when the lake level and water table were low, as they were during the
survey  period.   The  limited  testing  was  inadequate to  characterize the
contribution  to  the  lakes  when lake  level and  the  groundwater table are
high.

     Water quality  sampling on other lakes has  been  limited in scope.  In
general,  the  analyses have  centered  on open water for  the  purpose of de-
fining  the  trophic status  of  the lake.  The results of these studies are
presented in Section 3.1.3.  Depending on the sampling time and the classi-
fication  scheme  utilized, most  of the  study  area lakes  are eutrophic to
mesotrophic.   Effluent  from  septic  systems  is  typically implicated  as  a
nutrient  source, though  to what extent  it  is  a source  is a rough approxi-
mation.  Some specific water samples have been collected for the purpose of
assessing whether  public  health problems exist.  Where  failed systems have
been identified by sampling, most have been repaired.

     Lush growth of macrophytes, algae, and zooplankton  serve as indicators
of nutrient enrichment.   Landsat data prepared  for the  SMRPC shows quali-
tatively  where  the  greatest  enrichment has  occurred.    The  limnological
studies of Dewey Lake (Snow 1976) and  Pipestone Lake (Banks 1977) identi-
fied heavy  weed  patches  near  shoreline areas.   Mapping the aquatic biota
provides  a  general indication  of  the  level of  nutrient availability, but
numerous  nutrient  sources may  contribute   to productivity.   Specific con-
nections  between the  productive  areas  and septic  tank  effluent  must  be
identified  in order  to  determine the  need  for a  project.  None  of the
aquatic sampling programs have made those specific connections.

2.1.3.5.  Indirect Evidence

     Indirect evidence  that  correlates  with known failures  can  be  used as
an initial screening device for locating areas where  failures are probable.
Site limitations that infer failures are:

     •    Seasonal or permanent high water  table
     •    Lack of  isolation distances  for  water wells  (depending on
          well, depth and presence or absence of hydraulically limiting
          layers)
                                    2-17

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     •    Documented groundwater flow from a soil absorption system to
          a water well
     •    Slowly  permeable  soils with  percolation  rates greater than
          60 minutes per inch
     •    Bedrock  proximity  (within 3  feet  of  soil absorption system
          where bedrock is permeable)
     •    Rapidly  permeable  soil  with percolation rates less than 0.1
          minutes per inch
     •    Holding  tanks,  not  in itself,  but  as evidence  that site
          limitations prevent  installation  of  soil absorption systems
     •    On-site  treatment  systems  that  do not  conform  to accepted
          practices  or  current  sanitary  codes  including,  but  not
          limited to, cesspools, the "55 gallon drum" septic tank, and
          other inadequately sized components
     •    On-site  systems  in an area where local data indicate exces-
          sive failure rates or excessive maintenance costs.
These indirect evidences can be utilized to categorize residences as likely
failures  or  likely  to  be  operating  properly.   Because this  project  com-
menced before  the Region  V Guidance was developed, the needs documentation
relies heavily upon  the sanitary surveys, indirect evidences, and replace-
ment records for verification.
2.1.4.  Identification of Problem Areas

     Certain areas  around  the lakes exhibit a  combination of site limita-
tions, history  of  replacements,  and documented water quality problems that
appear to  require  off-site  treatment.   In general, these  areas are charac-
terized by a high water table, usually within 24 inches  (61 centimeters) of
the ground surface and soils of peat and marl interbedded  with sand.  These
areas  have  narrow  lakefront  lots  on which  insufficient area is available
for  construction of  raised  drain  beds  (mound soil  absorption systems).
These  areas  (where  the  septic  leachate  detector  survey  was  conducted)
typically show  several  active,  erupting plumes as  evidence of failed sys-
tems  and  have  higher  percentages  of replacement  systems installed in the
last  10 years  according to the mailed questionnaire and  the records of the
health departments.   Replacement  systems  usually do not  meet code require-
ments  for  depth to  groundwater and isolation  distance from wells.  These
                                    2-18

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site  conditions predominate  around  Pipestone Lake.   Also  a considerable
number  of  drains that  have high  coliform counts and  other water quality
parameters  characteristic of septic tank  effluent were found around Pipe-
stone  Lake.  None  of  the  other  lakes  had  surface drainage  outlets dis-
charging  septic tank  effluent.    The  sanitary survey  results  showed that
these areas  had a  greater proportion  of  problems as compared to the other
areas surveyed.  The  north and  south  ends of  Indian Lake, the Polks' Land-
ing and  Gilmore Beach Subdivision areas of Magician Lake, and the southern
peninsula  on Dewey  Lake  exhibited  these characteristics.   Other smaller
areas  on nearly all  the  lakes  had  high  water  tables and  organic  soils.

     Another  type  of  area  that  appears  to  need  off-site  treatment  are
steeply  sloping lots that  front on  the lake.  Usually the  lot  is narrow,
about 40 feet  wide  (12 meters)  and  the  house and  garage are constructed
adjacent to the road right-of-way.  The road elevation  may be anywhere from
15 to 40 feet  (4.5.  to  12  meters) above the  lake, and slopes of 18 to 40%
between  the  house  and  lake are  common.   Houses  are  usually  so  close to-
gether  that  construction  equipment  cannot  be moved between  them.   While
soil material and depth to groundwater are adequate for dry wells near the
road, frequently no room is available  for  the  excavation.  Placement of the
dry  well under  the  driveway  has been a  common "last  resort"  solution.
According to the Indian Lake Sanitary  Survey,  the targeted sanitary survey,
and  replacement records  of the  county  health   departments,  many of  the
systems  on  these lots  consist  of a  septic tank on the  lake  side  of the
house and a dry well or drain line at the base of the slope where the depth
to the  water table  is  inadequate.  Numerous  replacements have  been con-
structed on  these  types  of lots  because  the  soil  absorption  system fails
due  to  a high  water  table.  Compared  to areas with  organic  soils and high
water tables, though, fewer of these parcels appear to need off-site treat-
ment.

     Nearly all of the problem areas that appear  to need off-site treatment
are characterized by one  or  the  other  condition or a combination  of the
two.   Some  lots, particularly  in  the  Sister Lakes  commercial  area and the
Magician Bay  Park  Subdivision, are of  such  a  size that no  area  for  a re-
placement dry well is available.
                                    2-19

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     In addition  to those  areas  that  appear  to need  off-site treatment,
numerous  on-site  systems  appear  to  need  upgrading.   Direct  evidence of
failures  is  minimal,  but  considerable  indirect evidence  is present.  The
aerial photographic interpretation  analysis identified some possible fail-
ing  on-site  systems,  but  the  field  check  of these  revealed  that further
monitoring would be necessary  to  establish that they  were indeed failing.
The groundwater sampling results show that elevated nitrates are present in
some wells, but the exact source of those nitrates has not been identified.
On-site systems appear to be the most likely source in some locations.  The
septic leachate detector  survey  identified  occasional erupting and dormant
plumes in these areas  that were  verified by water  quality analyses.  The
information  received  from  the mailed questionnaire  for  Cass  County shows
that,  irrespective  of location,  no lakeshore area  is completely  free of
failure.    The  questionnaire, though, does  not specifically identify loca-
tions of  these failures.

     The  records of replacements and interviews with the county sanitarians
and  the   targeted  sanitary  survey  show  that  systems fail  primarily  from
inadequate construction.   For example, numerous cement  block  trenches for
disposal  of  effluent  that  were  installed on the northwest  side  of  Indian
Lake  are  experiencing structural  failure.  Dry  wells  installed within the
water table  commonly  fail.   Some  existing soil absorption systems consist-
ing  of  one  short  run of draintile  have  experienced failure,  particularly
when usage patterns extend beyond the typical seasonal usage.  The dry  well
soil absorption systems that predominate  in Van Buren County are subject to
frequent  failure.   The  Health  Department does not become  involved in  "re-
stoning"  the  dry well when  it no longer  accepts effluent  at a satisfactory
rate.  According to the  targeted  sanitary surveys, several of the restoned
dry welIs are  within  the water table where they would likely fail quickly.

     No lakeshore area has been identified where failures  are not probable,
based on  records of replacements.   The percentage of failures identified by
the  health department records  is not large, in part  because  numerous re-
pairs are not  noted on permits.  Elevated nitrate levels  in some wells and
the  contribution  of some  nutrients to  the  lakes appear  to be related to
on-site systems that fail to perform as intended.
                                    2-20

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     The available  information  on site limitations and  the  results of the
various surveys  (except  the targeted sanitary survey) are  summarized in a
generalized  fashion  in   Table  2-4.   Specific  information  that  has been
gathered  was  too  voluminous  for presentation.   Generally,  the  problems
indicated are  limited  to specific areas around  certain  lakes or are mini-
mal.

     The remainder of the study area away from the lakes was not studied in
detail.   Conversations   with  local  officials  and analysis  of preliminary
data  indicate  that the  sewage  treatment needs  are  too  minimal to justify
expending  further  efforts  to  quantify and  to  cost  feasible alternatives
that include the off-lake areas.  Keeler Lake water quality data and  shore-
line surveys did not  reveal any  evidence to  require  including the lake in
any  further  analyses.    Subsequent analyses within  this  report, therefore,
exclude these areas from further consideration for sewage treatment.

2.L.5.  Septage Disposal Practices

     Septic tanks are pumped when homeowners contract with a septage hauler
for service.   Numerous septage  haulers operate  in the area,  some of which
are  based  in  Indiana (By  telephone,  Mr. Lee Maager,   Cass  County Health
Department, to WAPORA,  Inc. 19  February 1982).   The  county  health depart-
ments  inspect  the  haulers'  equipment  for licensing.   The  State  code for
licensing is the basis for  these actions.

     The haulers dispose of septage either at sewage treatment plants or on
land.   host  haulers  dispose of  septage on   land,  although  the  Dowagiac
wastewater  treatment  plant receives some of  the septage.   Land  disposal
sites in Cass County must be approved by the sanitarians before septage can
be applied.  Approval  of a particular site is contingent  on whether nuis-
ance  conditions  would  likely   result,  either  to surface  waters  or from
odors.  Most  of the  application  areas are  former agricultural  land cur-
rently not under cultivation.   Periodically,  the hauler is responsible for
                                    2-21

-------
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discing or  plowing the  land so  that  nuisance conditions  do not develop.
There are  no standards  concerning  how much septage can  be  applied  to one
area.   Septage  pumped in  winter is also  land-applied  by certain haulers.
It is applied on the snow where it freezes.  As thaws occur the liquid from
the septage will infiltrate the ground surface.

2.2.  Identification of Wastewater Treatment System Options

2.2.1.  Design Factors

     Wastewater  flow  projections  for the  Indian Lake  and  Sister  Lakes
proposed sewer  service areas were developed based on a projected year 2000
design population  (Section 3.2.1.3.),  an average daily base  flow (ADBF) of
65 gallons per capita per day (gpcd),  and design infiltration of 10 gpcd. A
determination of the  design flow and  organic  loading  for the year 2000 is
shown in Table 2-5.
     MDNR has issued effluent limits for two surface water discharge points
within the  study area  (By  letter,  Richard Hinshon, MDNR,  to Cove Associ-
ates,  Inc.,  26 February 1980; Appendix  0 of the Draft  EIS)  to the Indian
Lake outlet  in  the  western half of  Section 32  and to Silver Creek in Sec-
tion  2,  Silver Creek Twp.  For  the two discharge  points,  the first recom-
mendation of MDNR is  land  application.  If  this  is not feasible, then the
recommendation is as follows:

     •    For  the  Indian Lake  outlet  in  the western  half of Section
          32,  Township  5  South,  Range  16 West,  an annual discharge
          from 1 March  to  15 May which will meet the following efflu-
          ent limits is allowed:
          Carbonaceous BOD

          Total suspended solids

          PH
          Dissolved oxygen
30  mg/1  as  a 30  day  average
45  mg/1  as  a  7  day  average
70 mg/1 as  a 30 day average
100 mg/1 as a 7 day average
6.0 to 9.0
5.0 mg/1 daily minimum
                                    2-26

-------
Table 2-5.
Parameters
Wastewater load factors projected for Sister Lakes and Indian
Lake, Michigan, for the year 2000.

                                                 Value
                              Units   Permanent  Seasonal  Total
gal
mgd
mgd
75
0.256
0.832
75
0.262
0.852
75
0.52
1.69
Sister Lakes Service Area

 Design year population                       —       3,415     3,470    6,885
 Average daily base flow (ADBF)              gpcd         65        65       65
 Design infiltration (based on               gpcd         10        10       10
  maximum permissible infiltration
  rate of 200 gal/inch-diameter/
  mile/day)
 Avtrage flow per capita per day
 Average daily design flow
 Peak flow (based on a peaking factor
  of 3.25)
 BOD  design loading (based on               Ib/d      583.6
  on50.17 Ib/c/d)
 BOD  influent concentration                 mg/1        271
 SS Design loading (based on 0.20 Ib/c/d)    Ib/d      686.6
 SS influent concentration                   mg/1        319

Indian Lake Service Area

 Design year population
 Average flow per capita per day
 Average daily design flow
 Peak flow (based on a peaking
  factor of 3.25)
 BOD  design loading (based on 0.1.7          Ib/d       176        129      305
  lb?c/d)
 BOb  influent concentration                 mg/1       264        258      261
 SS Design loading (based on                 Ib/d       207        152      359
  0.20 Ib/c/d)
 Sb influent concentration                   mg/1       310        304      307

Combined Sister Lakes - Indian
Lake Service Area
                                                  589.7  1,173.3

                                                    270      270
                                                  694.0  1,380.6
                                                    318      318
—
gal
mgd
mgd
1,031
75
0.08
0.26
760
75
0.06
0.20
1,791
75
0.14
0.46
 Design year population
 Average flow per capita per day
 Average daily design flow
 Peak flow
 BOD  design loading
 BUD  influent concentration
 SS design loading
 SS influent concentration
—
gal
mgd
mgd
Ib/d
mg/1
Ib/d
mg/1
4,446
75
0.336
1.09
759.6
270
893.6
317
4,230
75
0.322
1.05
718.9
268
846.0
315
8,676
75
0.66
2.14
1,478.5
269
1,739.6
316
                                    2-27

-------
     Total phosphorus as P
                                        At such time that technology
                                        provides  an economically  feasible
                                        means  of  removing  phosphorus  from
                                        stabilization  lagoons,  it  shall be
                                        required at this facility.
     During discharge,  the  ratio of wastewater flow  to  upstream flow
     shall be  as follows:  1.0  from 1  March to 31 March;  0.4  from 1
     April to 30 April; and 0.1 from 1  May to 15 May.

•    For Silver Creek in Section 2 of Silver Creek Township, an annual
     discharge  from  1 March  to 15 May which will meet  the following
     effluent limits is allowed:
     Carbonaceous BODr
     Total suspended solids
     pH

     Dissolved oxygen

     Total phosphorus as P
                                        30 mg/1 as a 30 day average
                                        45 mg/1 as a 7 day average

                                        70 mg/1 as a 30 day average
                                        100 mg/1 as a 7 day average

                                        6.0 to 9.0

                                        5.0 mg/1 daily minimum

                                        At such time that technology
                                        provides  an economically  feasible
                                        means  of  removing  phosphorus  from
                                        stabilization  lagoons,  it  shall be
                                        required of this facility.

     During discharge, the  ratio  of wastewater flow to upstream flow shall
     be as  follows:  1.0  from 1 March  to  31  March;  0.4 from  1  April  to 30
     April; and 0.1 from 1 May to 15 May.


     At the  present time  there  is no economically feasible  means of re-

moving  phosphorus  from  stabilization  lagoons.  Therefore,  phosphorus re-

moval  facilities  are  not  proposed  in any  of the  centralized wastewater

treatment   systems  that  have an  annual  discharge  to  the  surface waters.


     The capital (initial) cost includes the initial construction cost plus

a  service  factor  (Table  2-6).   The  economic cost  criteria  (Table  2-7)

includes all  the  other  factors  used  in  preparing  the  total present worth

costs.  The  total  present  worth  costs  include  the  initial construction

costs,  the  service  factor, annual operation  and  maintenance costs, future

construction costs,  and  an  allowance  for salvage value at  the  end of the

planning period.
                               2-28

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Table 2-6.  The service factor, excluding  interest during  construction,
            applied to the construction cost to compute  the capital  cost.
Item

Contingencies
Engineering
Legal & Administrative
Financing

  Total
                                     Pressure
       Conventional collection    sewer, cluster,
Units   and treatment system    and on-site systems
                 10
                 10
                  3
                 _4

                 27
15
13
 3
35
Table 2-7.  Economic cost criteria.
Item                                              jJnits

Amortization period                               years
Interest (discount) rate                            %
STP construction cost index - Detroit,
 June 1981
Sewer (CUSS) construction cost index - Detroit,
 June 1981
ENR - Construction cost index, June 1981

Service life
  Equipment                                       years
  Structures                                      years
  Conveyance facilities                           years
  Land                                            years

Salvage value
  Equipment                                         %
  Structures                                        %
  Conveyance structures                             %
  Land                                              %
                                         Value

                                            20
                                         7-5/8

                                         416.9

                                           223
                                         3,560
                                            20
                                            40
                                            50
                                         permanent
                                             0
                                            50
                                            60
                                           103
                                    2-29

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2.2.2.  System Components

2.2.2.1.  Flow and Waste Reduction

     Flow  and  waste reduction  can be  effective  in  reducing  the costs of
operating  and  constructing sewage treatment  and  disposal facilities.  The
methods of  flow  and waste reduction considered  for use include water con-
servation  measures, waste  segregation,  and  a  detergent  phosphorus ban.

     The residents  of  the area employ  many water conservation measures at
present as revealed in the sanitary surveys.  Some residents need to  employ
drastic water conservation measures during high water table periods or when
backups occur.   While  water  conservation practices are generally employed,
few  residences  are equipped  with  water conserving  fixtures.   The fixtures
that could be utilized include low flow toilets, reduced flow shower  heads,
and reduced-volume or recycle washers.

     Separation  of  toilet wastes from  the remainder  of the waste flows and
separate treatment can reduce the amount of nitrogen and phosphorus loading
on the  primary  disposal  system.   In many  cases,  the hydraulic loading can
be reduced sufficiently  to  enable the existing  onsite system to function
indefinitely.  The  toilet wastes can be handled  by holding tanks and off-
site  treatment,  incinerator  toilet,  composting  toilet,   privy,  or   closed
loop recycle toilet.

     A  ban  on  phosphorus in  detergents is currently  in effect in Michigan.
Based  on  a  survey of  58 major  wastewater  treatment  plants  in  Michigan,
influent and effluent  total  phosphorus concentrations decreased by 23% and
25%,  respectively  (Rartig and  Horvath  1982).    It  is likely that the phos-
phorus ban has reduced considerably the amount of phosphorus migrating from
the  soil   absorption   systems  to  the   groundwater  and subsequent  surface
waters, although it has not been confirmed by research.

     To reduce the waste  loads (flow volume and/or pollutant contributions)
generated  by  a  typical  household, an  extensive  array of techniques,  de-
vices,  and  systems  are available.  Because the  per capita amount of water
                                    2-30

-------
utilized  (approximately  65  gpcd)  in  the  study area  for  the centralized
treatment  alternatives is  relatively  small,  water  conservation measures
would be  marginally  effective in reducing wastewater flows for the centra-
lized alternatives.  However, on-site system alternatives (Alternatives 8A,
8B,  9,  and 10  described  in Section 2.3.  include separate  treatment stra-
tegies for the graywater and blackwater.  The proposed  treatment for black-
water and graywater is described  in Section 2.3.

2.2.2.2.  Collection System

     The  types  of collection  systems  that were evaluated  for cost-effec-
tiveness  were  conventional  gravity  system,  septic  tank effluent  (STE)
gravity system,  and  septic tank  effluent pump  (STEP)  and pressure sewers.

     A  conventional  gravity sewer system carries raw  sewage  and generally
consists  of gravity  sewers 8-inches diameter or larger,  pumping stations,
and force mains.

     A  STE gravity  sewer system carries clear  effluent from septic tanks.
Because the  liquid has  less  solids than  raw sewage,  the  minimum gravity
sewer pipe size  is 4-inch diameter, the minimum velocity required is less
(1.0 rather than 2.0 feet per sec), fewer access  points are required, pump-
ing stations do not require solids handling capability and force mains have
no minimum velocity requirements.  Because septic tank effluent is odorous,
special measures must be  taken to ensure  that  odors  are properly handled
and treated.

     A STEP pressure sewer system consists of a  pump at each septic tank or
close group of  septic  tanks which pumps clear septic tank effluent through
small diameter  pipes  (l^i-inch diameter minimum)  to the treatment facility,
a  gravity sewer, or  a pumping  station,  depending on  topography and dis-
tance.  Because  the  system operates under pressure rather than by gravity,
downgradient  pipe  slopes  do not  need  to  be  maintained and  the pressure
sewers can be  installed just below the  frost  line,  resulting in construc-
tion cost savings.   However,  the pumps provided  at each residence increase
operation and maintenance costs.
                                    2-31

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2.2.2.3.  Wastewater Treatment Processes

     A variety of treatment options were considered in the facilities  plan.
In   general, wastewater  treatment  options  include  conventional physical,
biological,  and  chemical  processes  and land  treatment.   The conventional
options  utilize  preliminary  treatment,  primary  sedimentation, secondary
treatment,  and  tertiary treatment  (including  chemical  addition) for  phos-
phorus removal.  These unit processes are followed by disinfection prior to
effluent  disposal.   Land  treatment  processes include  lagoons, slow-rate
infiltration or irrigation, overland  flow, and rapid infiltration.

     The degree of treatment required is dependent on the effluent disposal
option  selected  (Section  2.2.2.4.).  Where  disposal  of treated wastewater
is  by  effluent discharge  to surface waters,  effluent  quality  limitations
determined  by  MDNR establish the  required  level  of  treatment  (Section
2.2.1.).

2.2.2.4.  Effluent Disposal Options

     Effluent disposal options evaluted in the Draft EIS were: discharge to
receiving  water,  disposal on  land   (overland  flow,  crop irrigation,  rapid
infiltration, and wetland  discharge)  and reuse.  Based on the  conditions in
the  study  area, it  was concluded  that discharge to  receiving waters and
crop irrigation were the most technically feasible options.

jtream Discharge

     MDNR  issued  effluent limits  for  discharge  to  surface waters  at two
points:  Indian  Lake outlet  in the  western  half  of  Section 32 and Silver
Creek  in  Section  2,  both  in Silver  Creek  Township.   A secondary treatment
plant would  be  required to meet the  effluent  limitations (Section  2.2.1.)
for  discharge  into  Indian Lake outlet or Silver  Creek.   The discharge of
the  effluent at  these  two points is  only permitted from  1 March to  15 May.
Therefore,  y.5  months  of  effluent storage is  provided for all the alterna-
tives that  recommend discharge to the  surface waters  at the  two discharge
points.
                                    2-32

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Crop Irrigation

     In the slow-rate method partially treated wastewater is applied to the
land to enhance  the  growth of vegetation.  The vegetation performs a major
role in removing nutrients through vegetative growth.  Water is applied at
rates that may range from 0.5 to 4.0 inches per week.

     Land  in  the study  area is  generally  suitable  for  slow-rate or crop
irrigaton of effluent.  The sections west and south of Dewey Lake  (Sections
7, 8, 16 and 17) were selected for location of a slow-rate irrigation area.
The  selection  was based on  criteria  such as depth  to  water  table greater
that 15  f«et,  large  expanse of  nearly  level to  level  soils,  minimal or-
chards and wood lots,  and proximity to the Sister Lakes area.  MDNR requires
a  hydrogeological report  approved by the  groundwater section  that  shows
that no degradation  of  any usable aquifer would result from application of
wastewater  effluent  to the  site.   The  "rule  of  thumb"  for  an acceptable
application rate  is  approximately 2 inches per week, depending on the site
and  wastewater  constituents (By  telephone,  Mr. Thomas  Kampinnen,  MDNR to
WAPORA, Inc., 4 May 1982).

     Treatment of wastewater by the land irrigation process requires a con-
siderable  area of active  cropland soils that have a moderately rapid per-
meability.   Excellent removals  of all  pollutants,  except highly soluble
salts,  can  be  expected (BOD  and  SS,  99%;  phosphorus 95%  to  99%;  and ni-
trogen 70%  to  90%).   Based on an  application  rate of 2.0 inches per week,
an  annual application  period  of  26  weeks,  and a  flow  of 0.996  mgd,  an
irrigation area of 128.5 acres would be required.

     Artificial  drainage  may  be  required  on all sites unless  the  water
table is naturally Low.  Artificial drainage can be advantageous because it
allows control of the applied  effluent.   The outlet  point  can be designed
to minimize any excess seepage.

     During the  winter it  would be necessary to  store  the effluent.   The
storage pond   should  be  located  on  naturally  fine-textured  material  to
minimize  seepage.  Soil surveys  conducted in the  area  have not identified
                                    2-33

-------
any soils  that  could  function as a natural sealant.  A pond constructed in
this area would need to be artificially sealed.

2.2.2.5  Sludge Treatment and Disposal

     One of  the wastewater  treatment processes  considered  (the oxidation
ditch)  will  generate  sludge.   Sludge  thickening,  sludge  digestion,  de-
watering  and/or  drying  processes  (including  filter  press,  centrifuge,
vacuum filtration,  sludge  drying beds,  and sludge  lagoons),  and land dis-
posal of liquid or dried sludge are some of the processes suitable for this
project.   Based on  the processes  proposed  in  the  Facilities  Plan,  the
sludge drying beds  process was selected for further consideration with the
secondary  biological  processes that  require  sludge  dewatering.   The dried
sludge would be  disposed of by land application on farm land.  In the case
of waste stabilization ponds, the sludge would collect in the bottom of the
pond  and would  undergo anaerobic  digestion.   Inert  solids that  are not
biologically decomposed  would  remain  in the pond and  may  require cleanout
and removal once every 10 to 20 years.

2.2.2.6.  On-site Systems

     The on-site  systems proposed for use in the study area are  those that
are being utilized at the present time.   Some modifications of the existing
designs  are  suggested to  improve the  operation of on-site  systems.   The
presently  utilized  systems are  described  in  detail  in Appendix B of the
Draft EIS.

     The septic  tanks  presently being installed in the area are  considered
adequate both in  terms of construction and capacity.  The continued use of
750-gallon tanks for small residences and 1,000- and 1,500-gallon tanks for
larger  residences are  recommended.   Septic  tanks  should  have  an exposed
manhole or inspection port to monitor the contents of the tank.   If, during
pumpouts and  inspections,  certain  septic  tanks are found  to  be faulty or
seriously  undersized,  these  tanks would then be repaired or replaced.  The
number of  these  would be expected to be rather small because of  the design
code imposed on the tank manufacturers prior to  1950.
                                    2-34

-------
     The drain  beds  and drainfields  (Figure 2-1) currently being  installed
in   the  area could  have a  greater  than 20-year design  life,  if they are
installed according   to Code and maintained properly.  The 400 square  feet
of  drain bed  should be  adequate for  most  residences that  utilize water
conservation  practices.  Large residences and  those  that are not equipped
with flow conservation devices or utilize conservation measures may require
larger  drain beds.   If  the soil  material  contains  greater  than  normal
quantities of silt and clay, the drain bed must be larger or  the  finer-tex-
tured soil material  must be removed and replaced with sand.  Similarly, in
coarse-textured  soils  (coarse sand  and gravel), the  drain  bed  should be
over-excavated  and replaced  with 18 inches of fine sand.  Without the  sand
lining,   the  potential  for groundwater pollution is high  because  of inade-
quate treatment.

     The raised or  elevated drain  bed (Figure 2-2) is a variation of the
so-called  mound  system.   Mounds  are  constructed  according  to detailed
design standards to overcome limitations of limited soil permeability,  high
water table,  or  shallow bedrock.   The  design for  raised  drain  beds is
essentially  that  of  the standard drain bed elevated by fill  to achieve the
appropriate  depth  to groundwater.   Thus,  the elevation  of  the raised bed
can  be  highly  variable,  from 6  inches to  3  feet.   Some  utilize gravity
distribution  systems while   others  use  pumps  and  pressure distribution
systems.  In areas where the soils are peat and marl, the natural ground is
first excavated and replaced with sand.  Water-using appliances are usually
kept to  a minimum with these systems  in  order to  keep the  volume of  sand
fill to  a minimum.   It  has  been noted  (By interview,  Mr. Lee Maager,  Cass
County Health Department,  to WAPORA, Inc.,  16  December  1981) that the use
of  proper  materials  and  correct construction  techniques  is  essential for
these systems to operate satisfactorily.

     The dry  well  soil  absorption system  (Figure 2-1)  should be  used  only
as a "last resort" treatment system for existing residences.  The Van Buren
County Health  Department permits dry wells where  the depth to  the water
table is adequate.  Sufficient evidence has been accumulated  to demonstrate
that dry wells are more likely to pollute groundwater than drain beds.  Dry
wells consist  of  precast units  that  have  perforated  sidewalls and  are
                                    2-35

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2-36

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2-37

-------
backfilled with  clean  stone.   These units can be connected in series where
necessary so that sufficient sidewall area can be provided.

     Based strictly  on  a planning approach, no new soil absorption systems
should be permitted  on  the soils that  have  a  water table within  1 foot of
the  ground  surface  or  that  are formed  in  organic material.   This would
exclude  the Adrian,  Belleville,  Boots  (or  Napoleon),  Edwards,  Gilford,
Granby, Houghton, marsh, Palms, Pella,  Sebewa, and Tedrow soils.   The soils
that have a water  table within  1  to  6 feet of the ground surface can have
raised drain  beds  constructed  on them.   These  soils  are  Brady,  Bronson,
Kibbie, Morocco, Selfridge, and Thetford.

     Drain  beds and drain fields are appropriate for the other soils where
slopes allow construction activities.   Dry wells are appropriate only where
the depth to groundwater is adequate.

     Blackwater  holding  tanks  do not strictly constitute on-site  treatment
because  the  treatment  of  the  wastes must occur away  from the site.  Com-
ponents of  the  system  include a  low-flow toilet  (2.5 gallons per flush or
less), a  1000 gallon holding  tank for toilet wastes  only or all bathroom
wastes, and the  usual  septic tank-soil absorption system for  the  remainder
of the wastes.   These  systems are appropriate where  an existing  residence
has  a  failing on-site  system and no appropriate  location for an upgraded
system.  Most  residences  that  would require  holding  tanks are seasonally
occupied, requiring  approximately three pumpings annually.  The blackwater
holding tank systems are applicable where existing residences are on lots
that have soils unsuitable or too small for raised drain beds  or dry wells.

2.2.2.7.   Cluster System

     The cluster system  designates a common soil absorption system and the
treatment and  collection  facilities  for  a group  of  residences.   In the
study area, only a small percentage of  the area would have soils unsuitable
for  cluster drain  fields.   Thus, where individual  lots are unsuitable for
on-site systems, cluster drain fields are  typically feasible.
                                    2-38

-------
     Septic  tank  effluent  could  be  conveyed  by  small-diameter  gravity
sewers or  pressure  sewers from existing or replacement septic tanks to the
soil  absorption  system sites.   A dosing  system  is typically  required on
large  drain fields  in order  to achieve  good  distribution in  the field.
Cluster  drain  fields  are  usually designed with  three drain  fields.   Two
would  be dosed  on   a daily basis in  the summer  and  the third would be
rested for  an  annual period.  The drain  fields must be designed according
to the non-degradation of any usable aquifer policy of MDNR.   Preliminary
design criteria  indicate   that  133 square feet of  trench  bottom per resi-
dence  is required  for each drain  field.  In order  to  satisfy the  non-
degradation policy, though,  trench spacing may need  to be much greater than
the  standard  6  feet.  Further field investigations are  required  by  MDNR
before final designs  could proceed.   The  depth of  permeable  material  must
be determined  in order to show that groundwater mounding into  the drain-
field would not occur.

2.2.2.8.   Septage Disposal

     The  use  of  a  septic  system requires  periodic  maintenance  (3  to  5
years) that includes  pumping out the accumulated scum and sludge, which is
called septage.   Approximately  65 to  70 gallons  per  capita per  year of
septage  could  accumulate   in  a properly  functioning septic system  used by
permanent  residents  (USEPA  1977).   Septage is a  highly variable anaerobic
slurry that contains  large quantities of  grit and  grease; a  highly offen-
sive  odor;  the ability to  foam;  poor  settling and  dewatering  character-
istics; high solids  and organic content; and a minor accumulation of heavy
me tals.

     Septage disposal  regulations have  been  established  mainly  in states
with  areas  that  have  a  concentration of  septic  tanks.   Many  states,  in-
cluding  Michigan,  prohibit  certain  types of septage disposal,  but do not
prescribe acceptable disposal methods.  The general methods of septage dis-
posal  are:   land  disposal,  biological  and  physical  treatment,  chemical
treatment and  treatment in a wastewater  treatment plant.
                                    2-39

-------
     A detailed  cost-effectiveness analysis  for septage  and  holding tank
waste treatment and  disposal  was not performed.  The  advantage  and disad-
vantages of these septage disposal methods were presented  in the Draft EIS.
Greater control over the disposal of septage on land, especially during the
winter,  may  be  advisable.   Storage  facilities  during  inclement  weather
would  prevent  pollution of surface waters  from  contaminated  runoff.   Con-
cerns have  also  been expressed over possible pollution of groundwater from
excessive applications  of  septage.   Records of septage applications should
be  required so that  the  application  rates can be  monitored.   The  cost of
disposal is included in  the  operation and  maintenance of  the  septic and
holding tanks.

2.2.3.  Centralized Collection System Alternatives

     Three  centralized  collection  system  alternatives considered  in this
document are:

     •    Alternative Cl  - conventional  gravity sewers,  and  pumping
          stations and force mains collection system
     •    Alternative C2  -  septic tank  effluent  pumps  and  pressure
          sewers with some gravity sewers collection system
     •    Alternative C3  -  septic tank  effluent  gravity sewers and
          pumping stations and force mains collection system.
     The general  layout of  the  sewer system outlined  in  the  revised cost
effectiveness  analyses  (Gove  Associates,  Inc. 1980) was  used.   The design
of  the sewers  is based  on the year-2000 population  (Section 3.2.1.3).  The
layout and  sizes of  the  sewer  system are shown  in  Figure 2-3   and Figure
2-4 for  Alternatives Cl  and  C2,  respectively.  The  layout of  the  sewer
system for  Alternative C3 is similar to Alternative Cl.

     A cost comparison  of the centralized collection sewer system alterna-
tives is presented  in Table 2-8.  A detailed cost estimate for the various
components  of  the  three alternatives considered  is presented in Appendix D
of  the Draft  EIS.   Based on the  cost-effectiveness analysis,  a collection
system with septic  tank effluent pumps and  pressure sewers with some gra-
vity sewers is the  most cost-effective alternative.  Therefore, the septic
                                    2-40

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tank  effluent  pumps and  pressure sewers  with  some gravity  sewers system
alternative  (Alternative  C2) can  be used  in  all  the  system alternatives
except  Alternative  5B.  Alternatives 5B  includes the  conventional gravity
sewers, and pumping stations and force mains collection system (Alternative
Cl) so  that  this alternative is  similar  to the recommended alternative in
the Facilities Plan (Gove Associates, Inc.  1980).

2.2.4.  Centralized Wastewater Treatment Plant Alternatives

     Different types  of wastewater  treatment plant alternatives were con-
sidered  in  the revised cost effectiveness  analysis (Gove Associates, Inc.
1980).  The  revised  cost-effectiveness  analysis showed that in most of the
cases  studied  (regional and/or  subregional WWTP)  the  three most cost-ef-
fective  treatment  system  alternatives  are:   waste stabilization  ponds,
aerated lagoons  with  storage ponds, and  oxidation  ditch  and sludge drying
beds with storage ponds,

     A  screening  analysis  for  these three  component options compared three
sets of conditions:   a separate WWTP for  the  Indian Lake area, a separate
WWTP for the Sister Lakes area, and a regional WWTP  for the combined Indian
Lake and  Sister   Lakes  area. The design  factors  and effluent requirements
used in the analysis are given in Section 2.2.1.

     A cost comparison of the centralized WWTP alternatives is presented in
Table  2-y.   A detailed cost  estimate  for  the various  components  of the
three alternatives considered for the three sets of  conditions is presented
in Appendix  D  of the Draft  EIS.   Based  on the present worth analysis, the
waste stabilization ponds  WWTP is the most cost-effective treatment alter-
native  under all  three sets of conditions.  Therefore, waste stabilization
ponds are used in the system alternatives described  in Section 2.3.

2.3.  System Alternatives

     Feasible  and compatible sets of component  options  were combined into
system  alternatives.   The  system  alternatives represent  combinations  of
conveyance options  for various wastewater  flows, different treatment pro-
                                    2-44

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cesses,  siting  options, effluent  disposal options,  sludge  processing and
disposal options, and  on-site system options.  The alternatives include no
action,  independent treatment  systems for  Indian  Lake and  Sister Lakes,
regional  treatment   systems  serving  both Indian  Lake and  Sister Lakes,
treatment at  the  existing  Dowagiac WWTP,  and  on-site systems.   Ten poten-
tial  wastewater treatment  alternatives  were  developed and  evaluated for
technical  feasibility,  cost-effectiveness,  and  environmental  concerns.
These  alternatives,  including the  No Action  Alternative,  and  costs asso-
ciated with  each one  are  described  in the following  sections.   All cost
data  are  based  on  June 1981 price levels.  Detailed  costs for collection,
conveyance, treatment,  and  disposal components are presented in Appendix D
of the Draft EIS.

2.3.1.  Alternative 1 - No Action Alternative

     The EIS  process must  evaluate the consequences  of not taking action.
The No Action Alternative implies that neither USEPA nor FmHA would provide
funds  to  build, upgrade,  or  expand existing  wastewater treatment systems.
Wastewater would be treated in existing on-site systems and no new facility
would  be  built  except  to  replace  obviously  failed  systems.   This report
assumes,  however,  that the county health departments would assume respon-
sibility for  upgrading existing  systems  that  fail.   The  need for improved
wastewater  management   around Indian  Lake and  Sister Lakes  is  not  well
documented.   The  number of on-site systems  experiencing  serious  or recur-
rent malfunctions is  small.   The impacts  of  individual on-site systems on
the water  quality of  lakes are variable,  but,  taken  together,  the systems
have not been shown to adversely affect the lakes.

     With  the No Action Alternative, health  authorities  will  continue to
have  inadequate information  with which  to  design on-site  system repairs
appropriate to  the  problems  and their causes.   They  are  unlikely to have
the  time,  personnel,  or monitoring  capabilities  to  be  able to specify
innovative attempts to solve the problems.  The  result will be increasing
numbers of holding  tanks  on  small  lots  and  on lots with high groundwater.
If a  No  Action  Alternative is implemented, existing on-site systems in the
study  area  would continue  to be used  in their present conditions.  Also,
                                    2-46

-------
failure to correct the present  situation would  represent  a  disregard  of  not
only  the  natural environment,  but of the  spirit  and intent of Public  Law
92-500.

2.3.2.    Alternative 2 - Pressure Collection Sewers  and  Separate  WWTPs  for
          the  Sister  Lakes  and Indian Lake Areas  with  Discharge to Surface
          Waters

     This alternative consists  of a centralized collection  sewer system  and
separate WWTPs for the  Sister Lakes and  Indian  Lake areas.  The cost-ef-
fective collection system alternative  (Alternative C2,  Section 2.2.3.) that
includes pressure  sewers with  some  gravity  sewers  (Figure 2-4)   is  incor-
porated into  this  alternative.   Both the  WWTPs would include waste  stabi-
lization ponds  with  storage lagoons.  A storage  capacity of 9.5  months at
design flow  is provided at both WWTPs.  The WWTP  for the Sister Lakes area
would be located  in  Section 11 of Silver  Creek Township with discharge to
Silver Creek.   The WWTP for  the  Indian Lake area would  be in Sections 29
and 32 of  Silver  Creek Township with  discharge to the Indian Lake outlet.
The  approximate locations  of  the conveyance  sewers (interceptor sewer),
WWTPs, and  the outfall  sewers  for the both  proposed systems are  shown in
Figure 2-5.   The  present worth costs for  this  alternative  are presented in
Table 2-10.

2.3.3.  Alternative  3 - Pressure  Collection  Sewers  and  Regional  Treatment
        and Land Treatment System
     This  alternative consists  of  a  centralized collection sewer  system
with a regional pretreatment  facility and  land application  site located in
Section 8  ot  Silver  Creek  Township  that would serve both  the Indian Lake
and  Sister  Lakes  areas  (Figure  2-6).   The  centralized collection  sewer
system consists of pressure  sewers  with  some  gravity sewers (Alternative
C2, Section  2.2.3),  as  shown in Figure  2-4.   The wastewater from both the
Indian Lake  and the  Sister Lakes areas  would be  pumped  through conveyance
sewers to  the pretreatment facilities.  A waste  stabilization pond  system
would be used  for  pretreatment.  The effluent  from the waste stabilization
ponds would be sprayed on the land with center  pivot  systems.  At  an  appli-
cation rate  of 2.0  inches  per week and  a  6 months  per year application
                                    2-47

-------

                                                                LEGEND
                                                                   LIFT STATION
                                                                   FORCE MAIN
                                                                   TRANSMISSION LINE
                                                                —>- OUTFALL
                                                                D
PROPOSED TREATMENT
PLANT
Figure  2-5.  Alternative 2-Pressure collection sewers and separate  WWTPs for the
Sister Lakes  and Indian Lake  areas with discharge to surface waters.
                                       2-48

-------
                                             s
                                                                LEGEND
                                                                D
LIFT STATION

FORCE MAIN
TRANSMISSION LINE

PROPOSED
TREATMENT PLANT
Figure  2-6.  Alternative 3-^ressure collection sewers and regional treatment and
land  treatment system.
                                       2-49

-------
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period,  approximately 130 acres  of   land  would be  required for the  land
application site.  A  total of 255 acres would be needed  for  the  land  appli-
cation  site,  the waste  stabilization ponds, roadways,  and a buffer  zone.
It  was assumed  that  the  land  application site  would be  leased for  crop
production  during the  growing  season.   The present worth  costs of  this
alternative are presented in Table  2-10.

2.3.4.   Alternative  4 -  Pressure  Collection Sewers  and Regional WWTP  lo-
        cated in Section 11
     This alternative consists of a centralized  collection sewer  system and
a regional  WWTP serving both  the  Indian Lake and  Sister Lakes  area.   The
centralized collection  sewer system consists of pressure sewers with  some
gravity  sewers  (Alternative C2,  Section 2.2.3.),  as shown in Figure  2-4.
The  regional  WWTP would include  biological  treatment using waste stabili-
zation  ponds.   The  stabilization ponds and  the  additional storage lagoons
would  provide storage capacity for 9.5 months.  The  regional WWTP would be
located in Section 11 of the Silver Creek Township.   The  treated  wastewater
would  be  discharged  to  Silver Creek  from 1 March through  15 May of  each
year.   The  approximate location  of the  conveyance sewers,  regional WWTP,
and  the  outfall  sewer to Silver Creek is shown  in  Figure 2-7.  The present
worth costs of this alternative are presented in Table 2-10.

2.3.5.    Alternative 5A  - Pressure Collection  Sewers  and  a Regional  WWTP
          Located in  Sections 29 and 32
     This alternative is similiar to Alternative 4  except the regional  WWTP
would  be  located in  Sections  29 and  32 of Silver Creek Township and  the
treated  wastewater  would be  discharged  to  the  Indian  Lake  outlet  from  1
March  through 15  May of  every  year.  The  approximate locations  of  the
conveyance sewers, regional  WWTP, and the outfall  sewer  to  the Indian  Lake
outlet are shown  in  Figure 2-8.  The  present worth costs of this alterna-
tive are presented in Table 2-10.

2.3.6.  Alternative 5B - Gravity Collection Sewers  and a Regional WWTP
        Located in Sections 29 and  32
     This alternative is similar  to  Alternative 5A  except  that a conven-
tional  gravity  collection  sewer system  (Alternative Cl,  Section 2.2.3.)
                                    2-51

-------
                                                                 LEGEND
                                                                  D
LIFT STATION

FORCE MAIN
TRANSMISSION LINE

OUTFALL
PROPOSED
TREATMENT PLANT
Figure;  2t7.  Alternative 4-Pressure collection sewers and regional WWTP
               located in Section 11.         2_g2

-------
     *                       *
                                                                 LEGEND
                                                                     LIFT STATION

                                                                     FORCE MAIN
                                                                     TRANSMISSION LINE
                                                                     OUTFALL

                                                                     PROPOSED
                                                                     TREATMENT PLANT
Figure  2-e8.  Alternative 5A<-Pressure collection sewers and Alternative SB-Gravity
collection  sewers and regional WWTP located in Sections  29 and 32.

                                            2-53

-------
replaces  the  pressure  collection  sewer  system  (Alternative  C2,   Section
2.2.3.)-   This alternative resembles  the alternative  proposed in the re-
vised cost effectiveness analysis (Gove Associates, Inc.  1980).  The layout
of  the  collection sewer  system included  in  this alternative  is  shown in
Figure  2-3.   The approximate locations  of  the  conveyance sewers,  regional
WWTP, and  the  outfall sewer to the  Indian Lake outlet are shown in Figure
2-8.  The  present worth  costs  of this  alternative are presented  in Table
2-10.

2.3.7.   Alternative  6 -  Pressure Collection  Sewers  and Existing Dowagiac
        WWTP for Indian Lake and new WWTP for Sister Lakes
     This  alternative consists  of  centralized collection  sewer  systems,
construction of  a WWTP for the  Sister Lakes area in  Section 11 of Silver
Creek Township,  and  treatment  of wastewater from Indian Lake  area at the
existing Dowagiac  WWTP.   The centralized  collection  sewer system consists
of  pressure  sewers   with  some  gravity  sewers  (Alternative  C2,   Section
2.2.3.)  as  shown in  Figure 2-4.  The  approximate  layout of  the conveyance
sewers,   WWTP  for  Sister  Lakes  and  the  location of  the existing Dowagiac
WWTP is shown in Figure 2-9.

     The new  WWTP in  Silver  Creek  Township  would include  waste  stabili-
zation ponds with  additional  storage  lagoons.  A total storage capacity of
9.5  months is  provided at  design  flow.  The  treated  effluent  would be
discharged to Silver Creek from 1 March to 15 May of each year.

     The wastewater   from  Indian Lake area  would  be  pumped through  con-
veyance  sewers  for  treatment  at  the  existing Dowagiac WWTP.   The   user
charges and  the  other fees for hook ups  to the existing  Dowagiac WWTP  were
provided by  the  City of Dowagiac in a letter dated 19  January  1982  (Appen-
dix  D  of tVie  Draft  EIS) .  The present worth  costs of  this alternative are
presented in Table 2-10.

2.3.8.   Alternative  7 -  Pressure Collection  Sewers  and Existing Dowagiac
        WWTP
     This  alternative is  similar  to  Alternative  6  except that wastewater
from both  the Indian Lake and  the  Sister Lakes areas  would  be treated at
                                    2-54

-------
                                       1
                                                                  LEGEND

                                                                   •  LIFT STATION

                                                                   »  FORCE MAIN
                                                                      TRANSMISSION LINE

                                                                  —D— OUTFALL

                                                                      PROPOSED
                                                                      TREATMENT PLANT
                                                                  I	1
                                                                  LJ
TREATMENT PLANT

              L.-J
Figure  2-^9.  Alternative e-'Pressure collection sewers and existing Dowagiac WWTP
               for  Indian Lake and a new  WWTP for Sister Lakes.
                                              2-55

-------
the existing Dowagiac  WWTP.   The Layout of  the  collection system is shown
in  Figure  2-4.   The approximate layout of  the  conveyance sewers from the
Sister Lakes area  to  the Indian Lake  area  and the Indian Lake area to the
existing Dowagiac  WWTP and  the location of  the  existing Dowagiac WWTP are
shown  in  Figure 2-10.   The  present worth  costs  for  this alternative are
presented in Table 2-10.

2.3.9. Alternative 8A - On-site Systems Upgrading and Critical Areas Septic
       Tank Effluent  Collected by Pressure  Sewers and Conveyed to  Cluster
       Drain Fields
     Under  this  alternative  septic  tank effluent  would be collected from
the  critical areas  by pressure  sewers  for treatment  in  cluster  drain
fields.  All  other residences  would continue to  rely  on septic tanks and
soil  absorption  systems, many  of  which would be  upgraded.   The layout of
the  collection  sewers  and  the  tentative  locations  of  the  cluster  drain
fields are   shown  in  Figure  2-11.   The number and type of upgraded on-site
systems estimated  for this alternative and the conceptual  approach by which
they were estimated are presented in Appendix C of the Draft EIS.

     The cluster  systems would  consist of  septic  tank effluent pumps and
pressure sewers for collection, a dosing pump station (at  all but the small
cluster drain  fields),  and  three  alternating fields at the cluster drain
field site.  Two  fields could  be used alternately during  any one year; the
other  field would be  rested for a  year.  The present  worth costs of this
alternative are presented in Table 2-10.

2.3.10. Alternative 8B - On-site Systems Upgrading and Critical Areas
        Septic Tank Effluent  Collected by   Small Diameter Gravity Sewers
        and Conveyed to Cluster Drain Fields
     Under  this   alternative  septic tank  effluent would  be  collected by
small-diameter  gravity sewers  from the  critical  areas  that are  identified
in Alternative 8A and treated in cluster drain fields. All other  residences
would  continue  to  rely on  existing  and  upgraded  septic  tanks and soil
absorption  systems identical to  the systems  estimated in Alternative 8A.
The  layout of  the collection  sewers  and  the  tentative  locations  of the
cluster drain fields  are similar to those shown  in Figure 2-11.  The grav-
                                    2-56

-------
                                                                 LEGEND
                                                                     LIFT STATION
                                                                     FORCE MAIN
                                                                     TRANSMISSION LINE
                                                                 I   I TREATMENT PLANT
Figure 2-10.  Alternative 7-Pressure collection sewers and existing Dowagiac WWTP.

                                           2-57

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ity  sewers  require  the use of  pump  stations at the  low  points  in  the  area
served and force mains to the cluster drain  field sites.

     The  cluster systems  would  consist of  septic  tank effluent  gravity
sewers,  pump  stations  and  force  mains for  collection,  and  alternating
valves and  three alternating fields at  the  cluster drain field  sites.   One
field would  be  rested for a year  while  the other  two  would be  used on  an
alternate basis.  The present worth costs of this alternative  are presented
in Table 2-10.

2.3.11.  Alternative 9 - On-Site Systems Upgrading  and Blackwater   Holding
         Tanks
     This alternative  consists of  selectively upgrading the existing  on-
site systems  and future  on-site systems.  For residences where  the  on-site
system cannot be upgraded  because of site  limitations,  the  graywater  and
blackwater will  be separated.   Graywater would continue to be  treated  in
the  existing  septic  tank and soil absorption  system  that may be upgraded.
The  blackwater components  would include a new  low-flow  (2.5  gallon  flush)
toilet and  a holding tank.    Quantities  and  type  of  initial  and  future
systems  to  be upgraded  are  included  in  Appendix C of  the Draft EIS.   The
numbers  and  types of  upgraded systems  are  subject  to   redefinition after
further  field investigations.   The present worth costs of this  alternative
are  presented in Table 2-10.

2.3.12.  Alternative 10 - On-site Systems Upgrading, Blackwater  Holding
         Tanks,  and Critical Areas Septic Tank Effluent Collected by  Gra-
         vity or Pressure Sewers and Conveyed to Cluster  Drain Fields

     This alternative is  a combination of  Alternatives 8A,  8B,  and  9.
Under this alternative the  critical areas,  where  soil  and site conditions
prevent a high percentage of on-site systems from operating  properly, would
have either   blackwater  holding tanks or  septic tank  effluent  collection
systems  and  cluster  drain fields.   All  other  residences  would  continue  to
rely on  the  existing  or  upgraded system.   The  layout and the type  of col-
lection  sewers and  the tentative locations of the cluster drain fields  are
shown in Figure 2-12.   The  cluster systems would have  three  alternating
fields at  the drain  field  sites.  One  field would  be  rested  for a year
while the other two would be used on an alternate basis.
                                    2-59

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-------
     Residences  for which  the  on-site system  canaot be  upgraded  and no
cluster  system  is  feasible  would  have  graywater-blackwater  separation.
Only the  wastes  from a very  low volume toilet  (0.8 gallon  flush) would be
routed to  the  holding  tank while the remainder  of the water would continue
to the septic tank and soil absorption  system.   The quantities and costs of
this alternative  are  included  in Appendix D.   The  present worth costs of
this alternative are presented in Table 2-10.

2.4.  Flexibility and Reliability of System Alternatives

     Flexibility  measures  the  ability of  a  system to  accommodate future
growth and  depends on  the  ease  with  which an  existing  system  can be up-
graded or  modified.   The majority  of  the  alternatives  considered in  this
report generally  have  similar  flexibility for  future growth and/or plan-
n ing.

     Reliability measures the ability  of a system or  system components to
operate without failure  at  its designed level of efficiency.  It is parti-
cularly important  to have dependable operation  in situations where adverse
environmental or  economic  impacts  may result from  failure of the system.

     The  reliability  of  individual on-site  systems  is  considerably  less
than the  reliability of  centralized  collection  and  treatment systems.  A
failure  in  the centralized  system  is  more catastrophic  because the envi-
ronment is  less capable  of  mitigating the impacts.  The blackwater holding
tanks  exhibit  a  considerable  measure  of  unreliability.   The high pumping
cost could  induce homeowners to cause  spills of the wastes in  order to
lessen the volume to be pumped.  The septic tank and soil absorption system
on  those  parcels  would  be  marginal systems  subject  to  frequent failure.
The cluster systems would be  somewhat less reliable than individual on-site
systems because the  pumping units and piping would be subject to equipment
failure and power outages.
                                    2-61

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2.5.   Comparison  of Alternatives  and Selection  of  the Recommended Action

     The selection  of  the  most cost-effective, environmentally acceptable,
and  implementable  alternative(s)   through  the  E1S  process  involved  the
consideration  of  technical feasibility,  reliability,  costs, environmental
effects, public desirability, and the ability to comply with the applicable
design and effluent  discharge  standards for the State of Michigan.  Selec-
tion of the most cost-effective alternative also required identification of
trade-offs between costs and other relevant criteria.

2.5.1.  Comparison of Alternatives

2.5.1.1.  Project Costs

     Project  costs  were categorized  into capital expenses,  operation and
maintenance (O&M) expenses, and salvage values for the equipment and struc-
tures  for  each alternative.   The costs for the collection, conveyance, and
treatment  systems  for  each alternative were estimated  separately.  A sum-
mary  of the  estimated  present  worth  costs  of  project  alternatives  are
displayed  in  Table  2-10.  Appendix D of  the  Draft  EIS and Appendix D con-
tain a  description  of  the methodology and assumptions used in the analyses
as well as  the detailed costs for  each  alternative.   The capital cost for
the  selected  alternative may  be shared  by the  Federal government through
the Federal Construction Grants Program (75% of conventional systems or 85%
of innovative  and  alternative  wastewater collection and treatment systems)
and by  local  participants.   Annual O&M costs would be financed entirely by
the local users of the system.

     The system alternatives are  grouped into  four  categories — centra-
lized collection and treatment systems that will discharge to surface water
(Alternatives  2, 4, 5A,  5B, 6, and 7), centralized collection and  treatment
with  land  disposal  system (Alternative  3);  upgraded on-site  systems  and
service  of   certain  critical  areas  with off-site treatment  systems (Al-
ternatives  8A, 8B,  and  10);  and  upgraded  on-site systems  and blackwater
holding tanks  (Alternative 9).  Based on total present worth cost, upgraded
on-site systems  and  blackwater holding tanks (Alternative 9) is the lowest
                                    2-62

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cost  alternative.   Alternative  10 - upgraded  on-site  systems, blackwater
holding tanks, and critical area collection and drain fields, is the second
lowest  in  total  present  worth.   Alternatives  8A  and  8B,  which include
upgraded  on-site  systems  and  service of certain  critical  areas with col-
lection  systems  and  cluster  drain   fields,  are  ranked  fourth and  third
respectively, on the basis of  total present worth.   The other alternatives,
including  the centralized collection  and  treatment  systems,   are ranked
fifth  through eleventh  as shown  in Table 2-10.   Based on  total present
worth cost, Alternative 5B, which is  similar to the  recommended alternative
of  the  Facilities  Plan,  is   the most  expensive  (eleventh  ranking).   The
total present  worth  cost ranges from approximately  $6.6 million for Alter-
native 9 to approximately  $31.2 million for Alternative 5B.

     FmHA  had approved  a financial  assistance  package  for  centralized
collection  and conveyance and treatment at Dowagiac;  therefore,  the cost-
effectiveness of Indian Lake alternatives are presented in Table 2-11.  The
ranking of  these portions  of the alternatives are  similar  to  the project
alternatives.  Alternative 9  is  the lowest  cost,  followed by Alternative
10, 8B,  and 8A.  The total present worth cost  of the centralized collection
alternatives (Alternatives 2 and 6)  are about double the cost of the decen-
tralized alternatives.

2.5.1.2.  Environmental Impacts

     The No Action Alternative would entail almost no construction  impacts.
Construction of  any of  the "build"  alternatives, however,  will have pri-
marily  short-term  impacts on  the local environment  (Section 4.1.1.).   The
implementation of  Alternative  9 would  have   impacts  on those  lots  where
upgraded on-site systems  are  necessary.   These impacts may be considerable
on some lots but  overall they would be of limited extent.  The three alter-
natives  (8A,  8B,  and  10)  that  have  critical area  collection  systems  and
cluster drain  fields  would involve  construction  in  some  right-of-ways  and
on  the  drain field  sites in addition to on-site  upgrading.   The   combined
environmental  impacts  of these alternatives are  not significantly greater
than those that would occur under Alternative  9.
                                    2-63

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     The centralized  collection and treatment alternatives would have con-
siderable  impacts  on the right-of-ways where  sewage facilities are neces-
sary.  Many  right-of-ways are narrow and tree-lined, which makes construc-
tion within  them difficult.  Dewatering for deep sewer excavations and pump
stations could affect wells in  the vicinity.  The treatment plant sites for
waste stabilization  lagoons,  proposed for all centralized treatment alter-
natives except  Alternative  7, would have a  significant  effect on the par-
ticular  site.    All  three sites,  located  in Sections  8,  11, or  29,  are
presently  agricultural  land;  Section 29  is  mostly  prime agricultural land
that would be converted irretrievably to treatment plant use.

     The  operation of  the  facilities  proposed  in  the  alternatives would
produce some significant  long-term impacts at least  for some of the lakes
(Section 4.1.2.).   Water quality  impacts in  the  lakes would  be greatest
under  the  No  Action  Alternative  because  increasing phosphorus  loads  may
result in increased extent and density of nuisance algal blooms.  Excessive
nitrates in  wells  may also  increase as a  problem.   Local perceptions con-
cerning water  quality,  especially  at Indian Lake  and  Pipestone Lake,  are
that current problems warrant a "build" alternative and that these problems
will be exacerbated  unless  remedial action is taken.  The operation of the
four  alternatives  that  rely primarily  on  existing and  upgraded  on-site
systems (8A, 8B, 9, and 10)  would somewhat improve the water quality within
the lakes.   Some degradation of groundwater quality .below the cluster drain
fields  can be  anticipated,   but  the groundwater is expected  to  meet  the
drinking water quality standard.

     The centralized  collection and treatment alternatives  would  improve
water quality  in the lakes,  although the improvements  may  not be notice-
able.   Spills  of septic  tank effluent or  of raw  sewage  at pump stations
could occur  if  a malfunction or power failure were to occur.  The nutrient
load from  one  spill  could easily equal the current average annual nutrient
load.  Proper maintenance of the pumps and backup power sources for all the
pump stations would reduce the potential for such an impact.  The treatment
facilities for the centralized alternatives would be capable of meeting the
discharge requirements established by MDNR.  Water quality in the receiving
streams would be  altered,  but not seriously  degraded  during the discharge
                                    2-65

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period.  The  land  application alternative should result in minimal operat-
ing impacts because  the infiltrated water should be  of comparatively high
quality.   The alternatives that  include sewage  treatment  in the Dowagiac
WWTP would reduce the capacity for future growth in Dowagiac.

2.5.1.3.  Implementability

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

     Decentralized  systems  may  include  on-site  systems,   small  cluster
systems with  subsurface disposal,  and other small-scale technologies. They
can be  managed  by  a  wide variety of public or private entities or a combi-
nation  of  these  entities.   Public entities may include state, regional, or
local  agencies  and nonprofit  organizations;  private  entities  may include
private homeowner associations and private contractors.

     In this  section  the term "management agency"  refers  to the authority
responsible for managing the  systems.  A management  agency  need not be an
autonomous organization  devoted  solely to the management of these systems.
It may  in  fact  be charged with other duties, and may share systems manage-
ment responsibility through agreements with other agencies.

     USLPA  Construction Grants  Regulations  (USEPA  1982a)  which implement
the Municipal Wastewater Treatment Construction  Grants Amendments  of 1981
require an applicant  to meet a number  of  preconditions before a construc-
tion grant for individual and cluster wastewater systems may be made.  They
include:
     •    Certifying  that  a public  body will  be  responsible for the
          proper  installation,  operation,  and  maintenance  of  the
          funded systems
                                    2-66

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     •    Certifying that  such treatment works will be properly oper-
          ated and  maintained  and will comply with all other require-
          ments of  Section 204 of the Act.

     •    Obtaining  assurance  of unlimited  access  to each individual
          system  at all reasonable  times for inspection, monitoring,
          construction,   maintenance,    rehabilitation,   and   replacement.

     Regardless of  whether  the  selected alternative  is  primarily centra-

lized or  decentralized,  four aspects of the implementation program must be

addressed:
     •    There must be legal authority for a managing agency to exist
          and financial authority for it to operate

     •    The agency  must manage construction,  ownership,  and opera-
          tion of the sanitary district

     •    A choice must be made between the several types of long-term
          financing that  are  generally required in paying for capital
          expenditures associated with the project

     •    A system of  user charges  to retire capital  debts,  to cover
          expenditures for operation and maintenance, and to provide a
          reserve for contingencies must be established.


     In the following  sections,  these requirements are examined first with

respect  to centralized   systems  and  then with  respect to  decentralized

systems.
Centralized Systems


     The Indian Lake-Sister  Lakes Facility Plan identified the Cass County

Board of Commissioners  as  the legal authority  for  implementing the Plan's

Proposed Action.   The  Cass County Department of Public Works (CCDPW) would

be the  operating  division  that  would construct, operate  and maintain the

centralized wastewater  management system.   Under  Act  185 of the Michigan

Public Acts of  1957  as amended,  the county  has the authority to implement

this system and to contract with the villages  and  townships for services.

Cass County also  would  have to contract  with  Berrien County and Van Buren

County  for  services  to  the  parts of these counties  which are  included in

the study area.
                                    2-67

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     As  the  management  agency,  the  CCDPW  would construct,  maintain,  and
operate  the  centralized sewerage  facilities proposed  in  the Alternatives
2-7, except  those  parts ot Alternatives 6 and 7 that propose utilizing the
Dowagiac WWTP that is operated and maintained by the City of Dowagiac.  The
managerial capacity  of  the  CCDPW can be readily expanded  to provide man-
agerial  services  for the  proposed gravity  sewers and  the  WWTPs including
the land  disposal  site  in Alternatives 2-7.  There are several options for
septic tank effluent pumps connected to pressure sewers:
     •    The  station  may be designed  to  agency specifications, with
          the  responsibility  for  purchase,  maintenance, and ownership
          residing with the homeowner
     •    The  station  may be  specified and  purchased  by the agency,
          with the homeowner repurchasing and maintaining it
     •    The  station  may be  specified and  owned by  the agency, but
          purchased by the homeowner
     •    The  station  may be  specified,  purchased, and  owned by the
          agency.

Regardless,  however,  of  the option  selected,  all residences  are treated
eqtially.
     Capital expenses  associated  with a project may be financed by several
techniques which are  discussed  in detail in  Section  4.1.3.    User charges
are  set  at a level that  will provide for repayment  of  long-term debt and
cover operation  and maintenance  expenses.   The user  charges  for the dif-
ferent alternatives are  discussed in Section  4.1.3.   In  addition, prudent
management agencies frequently add an extra charge to provide a contingency
fund for extraordinary expenses and equipment  replacement.

Decentralized Systems

     Regulation  of  on-site sewage  systems  has  evolved to the point where
most new  facilities are  designed, permitted,  and inspected by local health
departments or other agencies.  After installation, the local agency has no
further  responsibility  for  these  systems  until  malfunctions  become evi-
dent.  In such  cases  the local  agency  may  inspect  and  issue permits for
                                    2-68

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repair of  the  systems.   The sole basis for governmental regulation in this
field has been its obligation to protect public health.

     Rarely have  governmental  obligations been interpreted more broadly to
include  monitoring  and control  of  other effects of  on-site  system use or
misuse.   The  general absence  of information  concerning  septic system im-
pacts on groundwater and surface water quality has been coupled with a lack
of knowledge of the operation of on-site systems.

     Michigan  presently  has no legislation  which  explicitly authorizes
governmental  entities  to  manage wastewater   facilities  other  than  those
connected  to  conventional collection  systems.   However,  Michigan Statutes
Sections  123.241  et  j>eq.  and 232.37 et  seq.  have been interpreted as pro-
viding counties,  townships,  villages,  and cities with sufficient powers to
manage decentralized facilities  (Otis and Stewart 1976).

     The  purpose  of  a decentralized  systems district  is to  balance  the
costs  of management  with  the  needs  of public  health and  environmental
quality.  Management of such a district  implies  formation  of a management
agency and  formulation  of  policies.  The concept of such an agency is new.
Community obligations for  management of private wastewater systems and six
community  management models  are presented  in  the Final-Generic  E1S  for
Wastewater Management in Rural Lake Areas (USEPA 1983).

     The  cluster  systems  (Alternative  8A, 8B, and  10)  could  be managed by
one of several agencies.  The CCDPW probably is best equipped at this point
to  assume  responsibility  for  these systems.   While  the  technologies  in-
volved may  be unusual  for  the  CCDPW,  no components are  involved  that  are
difficult  to  manage.   The  possibilities for  management  include different
authorization for the health department, a township board, another division
of  county government,   a  special district, or a  public  utility commission
(USEPA  1982b).   The system  itself  should be  simple  to manage.  The  resi-
dential  pumping units  use electrical power;  thus,  power  interruptions  may
result in operational  or  environmental problems.   Maintenance and repair
activities  are more  critical  for  this  system  than  for  gravity  sewers.
Regular cleaning of the septic tanks is essential for the system to operate
                                    2-69

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properly.  The  operation  of the drain field must be carefully monitored so
that the treatment aspect of the soil is not abrogated.  The billing of the
user charge  could be similar  to  the charge system set  up  for the conven-
tional gravity sewers and treatment plant.

     The management of on-site systems (Alternatives 8A, 8B, 9, and 10) can
be accomplished  in many  ways  (USEPA 1980c; USEPA  1982b).   The management
structure will  depend primarily  on State  law  and local  preference.   The
USEPA requires  a public  agency  to serve as grantee and to provide assur-
ances  that  the  systems   be constructed  properly  and  that  maintenance be
performed to  insure that  the  environmental laws  are  not  violated.   Many
different agencies  are presently  responsible  for  on-site  systems: health
departments,   sanitary  districts,  homeowners associations,  on-site manage-
ment  districts,  private  companies, and  county   government.   Management
responsibilities range from a detailed permit process to complete ownership
of all  facilities.   There are certain advantages with each type of manage-
ment and ownership option.  Complete control by the agency comes closest to
guaranteeing  that the  systems will be  operating  at  optimal  levels,  but
represents the most costly approach.  The least costly approach would be to
keep the  homeowner responsible  for all  maintenance activities and costs.
The homeowner then  would  be more inclined to utilize water-saving measures
and other methods  to  minimize maintenance costs.  However, as is currently
the case,  environmental   protection  suffers when the  homeowner is respon-
sible for maintenance.   Other factors also  should  be  considered.  Systems
for  residences  constructed  after  27  December  1977  are not  eligible for
Federal grants.   Having   the  homeowner  pay  for  installation constitutes a
considerable  expense  for  new residences that  the community may  wish to
employ  as  a means  of  discouraging  future on-site  systems.   The USEPA re-
quires the grantee to certify that public ownership is not implementable, a
policy that may be difficult to show.

          The agencies with the most experience with on-site systems in the
study area are  the  county health departments.   They have had no experience
in writing  and  implementing  contracts,   because their  primary role is is-
suing permits  and inspecting  construction.   The CCDPW  has the experience
with contracts  and  management of maintenance activities,  although it does
                                    2-70

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not have  experience  with on-site systems.  Experience with on-site systems
is crucial  for  the personnel responsible for the design, construction, and
inspection  of on-site  systems.   Thus, the consolidation of contracting and
billing  functions  with  the  CCDPW would result  in  an efficient operation.
It is  anticipated  that the most  cost-effective  managerial  system would be
implemented; health  department  personnel would be responsible for the sys-
tems and  the CCDPW  would provide contractual  and  billing expertise.  The
local  costs for  the  construction  of  new systems  and  rehabilitation  of
existing systems can be assessed to each user equally by a variety of means
or assigned to  the respective homeowner.  Operation and maintenance costs
also can  be handled  in the same way, based on public or private ownership.
The billing could  be similar to the billing used for a centralized system.

2.5.2.   Selection of Recommended Action

     The  selection  of the  most cost-effective  alternative  involved  the
consideration of  effectiveness  in  eliminating environmental  problems  and
complying  with  discharge  standards;  costs,  including  the local  share  of
capital  costs   and  the  O&M  cost;  environmental  impacts;  and  implement-
ability.  Selection of the most cost-effective alternative requires identi-
fication  of the   trade-offs  between  costs  and  other  relevant  criteria.

     The  No Action Alternative  (Alternative 1)  is  not  recommended because
it would  not resolve  existing  environmental problems  associated with the
on-site systems.   This alternative  would not resolve the issue of nutrient
inputs  to  the   lakes  from marginally  failing  on-site systems.   Also,  the
high cost  of operating some of  the on-site  systems would not be mitigated
unless  the  individual  homeowners initiate upgrading.  The areas where site
conditions  virtually  disallow   on-site  upgrading  would  have no  cluster
system implemented.  One of the "build" alternatives must be implemented to
eliminate the suspected environmental problems that are associated with the
No Action Alternative.  The centralized alternatives (Alternative 2-7) have
high costs  for  marginal  water  quality benefits in  the  lakes  of  the area.
The financial impact  of  these alternatives would have serious consequences
on the  budgets  of  low and fixed  income  families within the project areas.
                                    2-71

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Other impacts,  such  as construction of sewers, pump stations, force mains,
and  treatment   plants  would disturb  considerable  areas of  natural plant
materials.  Thus, these alternatives were not recommended.

     Alternatives 8A and 8B - upgraded on-site systems and cluster systems,
are  ranked  third and  fourth in  terms  of cost  alone.   These alternatives
differ only  in the  type  of collection  system and  the  method of effluent
distribution in the drain  fields.   These alternatives  are developed with
the approach that areas with high water tables and small, steep lots should
have  off-site   treatment.   These areas were  investigated  in  the sanitary
survey and it  was concluded that many of  these  areas only had a few indi-
vidual  residences  that  required  off-site   treatment.   This  alternative
provides a relatively  high  level of protection of the water quality of the
lake s.

     Alternative 9 - upgraded on-site systems and blackwater holding tanks,
has  the  lowest total  present  worth cost.  This  alternative  would  be mar-
ginally  effective  in  preventing  system  backups  and  severely  restricted
water use.   The systems  located in the  areas with  organic  soils and high
water  tables would  likely  require frequent  pumping of  the septic  tank
because groundwater  would  fill  the system and cause backups.   The conclu-
sions drawn  from  the sanitary survey and other sources of information were
that this alternative would not adequately provide for the sewage treatment
needs  of  the  area.   The  water  quality  of  the  lakes would  be protected
adequately with this alternative.

     Alternative  10  consists of  a combination  of  the most cost-effective
and  technically feasible  components  of  Alternatives  8A,  8B, and  9.   The
areas where  blackwater holding  tanks with existing  systems would not ade-
quately provide  for  the sewage treatment needs  would  be served by cluster
systems in those  areas where a  large number  of  these systems are present.
Blackwater holding  tanks  would  be utilized  in  those areas  where too few
systems  require off-site  treatment to justify  construction  of  a cluster
system.  Under  this  alternative  certain  residences  would require continued
use  of water conservation devices  and practices for the systems to operate
properly.  The  total  present  worth cost of  this  alternative lies between
Alternative 9 and 8B.
                                    2-72

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     Based on  the  costs of the alternatives, relative impacts, and accept-
able trade-offs, Alternative  10 was selected as the recommended wastewater
management plan  for  the Indian Lake-Sister Lakes  study  area.   The capital
costs of  this alternative  would  be higher  than Alternative  9  but better
service would  be provided  to certain  critical  areas.  Protection  of the
water quality  of the lakes would be more assured under Alternative 10 than
under Alternative  9.   The sanitary survey verified that off-site treatment
was  not  required  for  the areas  that  would be  served by  cluster  systems
under Alternatives 8A  or 8B.   Considering Indian  Lake alone did not alter
any conclusions concerning the most cost-effective alternative.
                                    2-73

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3.0.  AFFECTED ENVIRONMENT

3.1.  Natural Environment

3.1.1.  Atmosphere

     Elements  of  the  atmospheric  environment  that are  relevant  to  the
consideration  of the  proposed wastewater  treatment  alternatives include
temperature,  precipitation,  wind,  odor, and noise  levels.   Other than the
consideration  of  potential  odor and noise  generated by specific treatment
processes, air quality  is  not expected to be affected significantly and is
only described  briefly here.   For  further detail  see  Section  3.1.1.  and
Appendix F, both of the Draft EIS.

     The air  quality  in the study area  is  generally good.  Concentrations
of  total  suspended particulates  (TSP)  in  Cass  County  were  in  compliance
with  both  annual  and  maximum 24-hour  primary  (health-related)  National
Ambient Air  Quality  Standards (NAAQS)  from  1971  through  1976.  Although
violations  of the  maximum  24-hour  secondary  (welfare-related)  NAAQS  did
occur  (MDNR 1977a),   the  maximum  24-hour  TSP value  recorded  during  the
                                      2
6-year monitoring  period was 181  ug/m  , well below  the  primary  standard of
        3
260 ug/m  (Appendix F of the Draft EIS).

     Hydrocarbons, carbon  monoxide,  nitrogen oxide,  and sulfur  oxide con-
centrations were  not monitored in  the study area,  but  are  expected to be
low.   Although no information  on ozone levels is  available  for the study
area, it is likely that ozone standards are exceeded, particularily because
of  the  close  proximity of  large metropolitan centers.   The Lower Peninsula
of Michigan has  been designated as a non-attainment area for photochemical
oxidants (MDNR 1977a).

     There  are no  known major noise  sources in  the  study  area.   Noise
generated by  typical automobile  and  recreational  boat traffic  and gravel
quarry  operations  within the  study  area may  affect people  who live near
these noise sources.
                                  3-1

-------
     The  Air  Quality  Division  of MDNR has  not  recieved any complaints  of
odors in the study area  (By telephone, Mr. Dick Vandebunt, MDNR,  to  WAPORA,
Inc., 16 November 1978).  There  is an asphalt  plant  located  in  Silver  Creek
Township and reports have been made that people residing near the  plant are
being affected.

3.1.2.  Land

3.1.2.1.  Geology

3.1.2.1.1.  Topography and Physiography

     The landscape of  the Indian Lake-Sister Lakes study area is  character-
ized  by hummocky,  morainic  terrain  in  the northwestern  and  southwestern
parts and  by  nearly-level to gently-sloping outwash plains  in the  central
and  eastern parts  (See  Figure  3-1).  Numerous  lakes  and  wetlands  occur
within  the  study  area.  Although most of  the  major lakes are  concentrated
in the central part of the study area, at  least a dozen  smaller lakes  occur
in the study area.  Most of the surface waters of the study  area  drain into
the Dowagiac River through the Osborn Drain, Silver  Creek, an unnamed  creek
that  collects  excess water  from  Indian  Lake,  and  a  few   intermittent
streams.   A small part  of  the  study area,  near  Pipestone Lake,  drains  to
the southwest into the St. Joseph River through Pipestone  Creek.

3.1.2.1;2.  Bedrock and Surficial Geology

     The study area is located in the western portion of a large  structural
feature called the Michigan Basin.  The bedrock geology is characterized  by
a sequence  of northeasterly-dipping  Paleozoic strata  that  overlie a Pre-
cambrian basement  of crystalline rocks.   The  Coldwater Formation  (Missis-
sippian)  forms  the  bedrock surface  throughout  most  of  the  study  area.

     Overlying the  bedrock surface are unconsolidated  sediments  that were
deposited  during  the  Pleistocene  Epoch  by  glaciers and  by glacial  melt-
waters.   The  landforms and  the  surficial deposits  of  the study  area were
formed during the  Gary substage  of the Wisconsinan  stage  of glaciation and
                                  3-2

-------
^ v'! *O(''" ,1V  ^y/?^^'l' ^Sf^iil."0^''^' -'°! V-';




.,/./ ^i c'^.i'r'  . n*\"\\   '.')  '^'^^/^^n^rr^ri^^^^
                               I ;    i '- ^-V-
                              -4^,-V-lM-p-l-V




          Figure 3-1.  Topography and

          nhuoinnronHi. of ^pg study area.
                  o
-------
are  associated with  the  Lake  Michigan  lobe  of  the  Wisconsinan glacier
(Terwilliger  1954).   The  surficial  glacial  deposits  of  the  study area
(Figure  3-2)  consist predominantly  of terminal  moraines,  outwash plains,
and glacial  lakebed deposits.   The glacial till of these terminal moraines
contains  unsorted  mixtures of  gravel,  sand,  silt,  and  clay.  The strati-
graphic  and  hydrologic  characteristics are  complex  and can  change dras-
tically  within a  short distance.  Numerous  kames  (isolated  or  clustered
mounds of sand and gravel) are associated with  the terminal moraines  in the
study  area.    These  formations  constitute  valuable   sand  and  gravel  re-
sources.   The  major  deposits currently  being  mined  are  in  Section  31,
Keeler  Twp.,  southwest  of Round Lake, and in Section  10, Silver Creek Twp.
The  lakes in  the  study  area most   likely  developed  from  depressions  or
kettles that were formed when isolated blocks of ice were buried by glacial
drift.   When  the  ice  blocks  melted,  a  depression  remained  which  subse-
quently filled with water.

     The  majority  of  the  study  area  has  been  identified as  an outwash
plain.  These  outwash  deposits  consist of beds and lenses of gravel, sand,
silt,  and some  clay.  Glacial  deposits  throughout  most of the  area  are
overlain by  a  mantle  of loess (wind blown deposits of  silt and fine  sand).
Undrained  depressions,  marshes,  and  lake bottoms  within the area commonly
contain muck or peat.

3.1.2.2.  Soils

     The  soils  of  the  Indian Lake-Sister Lakes  area  are  described on an
association basis.  "Each map unit, or association, on  the general soil map
is a  unique  natural landscape.   Typically, an  association  consists of  one
or more  major  soils and  some  minor soils.   It  is  named for  the major
soils." (Soil Conservation Service [SCS] 1980b).  The  general soil or asso-
ciation map  (Figure 3-3)  is to be  used  for  a  general picture  of  soils  of
the  area;  the  soils of  a specific  parcel  must  be  seen on  the  detailed
(series level) soil maps.

     The  soil  association surrounding  the  Sister Lakes in  Cass County is
the  Kalamazoo-Oshtemo-Hillsdale.   This  association   is characterized  by
                                  3-4

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nsir^   end moraine
  ..........   drainageways



        study area
 Figure 3-2.   Surficial geology  of the  study area.
                                       3-5

-------
                     B4   VB3
Bl - Spinks,  Oakville,  Oshtemo
B4 - Riddles, Ockley>  Oshtemo
B6 - Pella, Kibble,  Lenawee
B8 - Ockley,  Oshtemo
VB3 - Riddles,  Ockley,  Oshtemo
VB6 - Kalamazoo, Oshtemo
VB9 - Spinks, Oakville, Oshtemo
VB11 - Boughton, Adrian, Palms
Cl - Kalamazoo
C4 - Oshtemo, Kalamazoo
C6 - Brady,  Gilford,
     Matherton,  Sebewa
C8 - Oshtemo, Spinks,
     Oakville
C9 - Kalamazoo, Oshtemo,
     Hillsdale
       Figure 3-3.   Soil associations in the study area.
                                         3-6

-------
deep, well-drained, undulating to rolling soils found on outwash plains and
moraines.   These  soils are  moderately coarse to  coarse  in texture.  Soil
absorption  systems can  be  designed  and  constructed on  the  major soils
within the  association,  except  where  steep  slopes  prohibit construction,
although  there  is  a  hazard of  groundwater degradation  because  of  poor
filter characteristics.

     The  soil  association surrounding  Indian Lake  is  the Oshtemo-Spinks-
Oakville.   This  association  is composed  of  deep,  well-drained, undulating
to  rolling  soils  found  on outwash plains and moraines.   These soils have
moderately  coarse  to  coarse  textures.   Soil-based treatment systems on the
major soils of the association may, because of poor filter characteristics,
result in groundwater degradation.

     The area immediately around and north of the Sister Lakes  in Van Buren
County is  the Kalamazoo-Oshtemo association.  The  adjacent association in
Cass  County is the Kalamazoo-Oshtemo-Hillsdale association.   The soils of
the  Kalamazoo-Oshtemo  association are  deep,  well-drained,  and rolling to
hilly. They are  located  on moraines,  outwash plains, and till  plains.  The
soil textures are  moderately coarse.   Soil absorption systems  on the major
soils of  the  association may result in degradation  of  groundwater  quality
because  of poor  filter  characteristics.   Some  moderately  fine  textured
soils require somewhat specialized designs for successful operation.  Steep
slopes limit construction activities in some areas.

     The soil association  in the vicinity of Pipestone Lake is the  Spinks-
Oakville-Oshtemo.   The  well-drained,  nearly level  to  steep  soils  were
formed on  moraines, till  plains,  outwash  plains,  and  beach  ridges.   The
subsoil  is  sandy  or  loamy,  and  overlies  sand  and gravelly  sand parent
material.   All of  the  soils  have rapid permeability and are droughty.  The
lakeshore  area  consists  of  minor  soils  within  the association  that  are
unsuitable  for  soil  absorption systems.    Soil  absorption  systems  on  the
major  soils within  the  association may  cause degradation  of groundwater
quality.
                                  3-7

-------
     Each individual soil series represents soils  that have  similar  charac-
teristics,  although  considerable variation may  be present within one  map-
ping unit on the detailed soil maps.  The  characteristics  of  the major  soil
series  that relate  to  soil-based  sewage  disposal are  presented  in Table
3-1.  The  SCS  has given the  soils  of the majority of the watershed area  a
severe rating for soil absorption systems.  The  various  soils,  though rated
as severe based on excessive  permeability, exhibit considerable variability
in texture,  ranging  from fine and medium  sands, that have no  limitations,
to coarse gravels, that have  poor filter characteristics.

     The  Sanitarians have  identified fine-textured  soils as a reason  for
the  failure oE standard  design soil absorption  systems  on certain lots.
Steep slopes are  also  identified as  a  limitation  for soil absorption  sys-
tems.  Within  any  mapping unit, considerable variation  in slope is  likely.
Building  sites with  steep  slopes  generally  have adequate  depths  to  the
water table so that a drywell absorption system  can be installed.

     High water table  and flooding or  ponding  are also  identified  as  rea-
sons for  severe  ratings for  soil absorption systems.  The high water table
is characteristic of some lakeshore areas and is frequently associated  with
organic  soils.   Many  soil  absorption  systems  in these  areas  have  been
constructed  within or  slightly above  the  water   table.   Soil absorption
systems that are within the water table are more likely  to fail because  the
organics in  the septic  tank effluent decompose  slowly,  resulting in clogs
in the system and surface breakout or backups.

3.1.3.   Water Resources

3.1.3.1.  Surface Water

     The study area,  situated within the  St.  Joseph  River Drainage  Basin,
contains eleven  lakes,  one  river,  several creeks,  and  numerous wetlands.
With the  exception  of  Indian Lake,  the lakes  are located in  the northern
section of  the study area.   The lakes that are  particularly  significant to
this discussion  are Cable  Lake,  Upper  Crooked Lake, Lower  Crooked Lake,
Dewey Lake,  Indian Lake,  Magician  Lake,  Pipestone Lake, and  Round Lake.
                                  3-i

-------










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     Rivers and Creeks

     The Dowagiac  River,  a tributary of the St. Joseph River, is the larg-
est stream  in  the  study area and  flows  in a southwesterly direction along
the eastern and  southern borders of the study area.  Mean flow recorded at
Sumnerville (approximately  4.5  miles south of the study area) from October
1978 to  September  1979 (USGS 1980) was  339  cubic feet per second (cfs) or
                                3
9.6 cubic  meters  per  second (m /s).  Average  dissolved  oxygen concentra-
tions  at M-62  are  above  the  State  standard  of  6  mg/1  (MDNR  1981),  but
concentrations of  fecal  coliform bacteria were higher  than  200 most prob-
able number/100 ml (MDNR 1978b; TenEch Environmental Engineers, Inc. 1980).
The Dowagiac River receives the flow of Dowagiac Creek which is the receiv-
ing stream for the Dowagiac sewage treatment plant.

     Three other creeks  are outlets to lakes in the area.  Pipestone Creek
flows  into and  is  the  outlet  for Pipestone  Lake;  then flows  south and
southwest to the  St. Joseph River, approximately  8 miles  (12.9 kilometers)
downstream.  Dissolved oxygen  concentrations  (MDNR 1978b)  exceeded State
standard for the  stream (6 mg/1).   Fecal  coliform counts (MDNR 1978b) ex-
ceeded the  standard  for total body  contact  recreation.   Silver Creek, the
outlet for  Magician Lake,  originates  at  the  eastern  tip of  the  lake and
flows  south to southeast  through the Dowagiac Swamp,  where  it enters the
Dowagiac River.  The Indian Lake outlet is an intermittent creek originat-
ing on the  east  side of the lake and flows easterly to its confluence with
the Dowagiac River.   Another creek, Osborn Drain,  originates  in the large
swamp one mile north of Magician Lake and  flows east to the Dowagiac River.
No  flow  data  are  available for  these  creeks.   Pipestone  Creek,  Dowagiac
Creek, and Osborn Drain have been designated as trout streams  (MDNR 1975a).

     Inland Lakes
     Physical  characteristics  for  each  of the  seven major  lakes  in  the
study are  presented in  Table  3-2.   Indian Lake has  the greatest surface
area  (481.5  acres),  the largest watershed  (4,148.5  acres),  and one of  the
higher watershed  to  lake surface ratios  (8.6:1).  Dewey  Lake has  the high-
est watershed to  surface area ratio  (9.9:1).  Crooked  Lake has  the greatest
recorded depth  (62  feet)  and  the  lowest watershed to  surface area ratio
                                  3-11

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(3.1:1).  Although Magician Lake has a lake surface area similar in size to
Indian Lake,  Magician  Lake has nearly twice  the  shoreline length compared
to Indian Lake.

     In the  last  3  years, 2 sampling programs have been conducted to char-
acterize the  water  quality and trophic status of  lakes in the study area.
The first sampling program characterized algal conditions  in early and late
summer.  Phytoplankton collections were conducted during the periods of 4-6
June  1979  and  4-6  September  1979.   Five to  ten sampling  stations were
distributed  evenly  throughout  each lake.   The  sampling station locations,
and the computer  printouts giving algal density and  percent  occurrence of
major groups are given in Appendix I of the Draft EIS.

     A  summary of  the  dominant  algal  taxa, average  Secchi  depths,  and
stratification  conditions are  given  in  Table 3-3.   In general terms Cry-
ptophyta  (blue-green algae),   followed by  Chlorophyta  (green  algae), were
the most  abundant  algae  in  most  of the  lakes  during the  June sampling
period.   During  the  September  sampling   period,  Cyanophyta  (blue-green
algae) was generally the most  abundant algae present.  Cable, Crooked, and
Indian Lakes exhibited the greatest algal density in June.

     The second sampling  program that was conducted in  October and November
1982 represents new  information collected and analyzed  since publication of
the Draft  EIS.   The results  (Appendix  B) showed  that the  lakes (except
Pipestone Lake  at  the early sampling date) had experienced complete mixing
typical with the  onset of cooler autumnal  weather.   Phosphorus,  nitrogen,
and chlorophyll a.  values were  low  for all  the  lakes due  to the decline in
algal  growth with the  transition in weather to  autumnal conditions.  The
greatest  Secchi disk  depths  were  measured  in  Lower  Crooked Lake.   The
lowest Secchi disk depths were measured in Indian Lake, Pipestone Lake, and
Dewey Lake.

     The analysis  of the lake sediments that were  collected  at  the water
sampling locations in  November indicated that the  lakes  have variable but
explicable results   (Appendix  B) .   The samples were  analyzed for non-apa-
titic  inorganic  phosphorus   (NAI-P),  chlorophyll  degradation  products,
                                  3-13

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organic  matter  content,  calcium carbonate content,  and  sand content.  The
values are highly  variable both within and  between  lakes.   The NAI-P is a
measure  of  the biologically available  phosphorus.   The  chlorophyll degra-
dation products and  organic matter are measures  of  past productivity that
has been subjected to decomposition.

     The differences  in NAI-P  between lakes may be an  indicator of lake
trophic  status.  The  sediments  of eutrophic lakes may release the NAI-P to
overlying water where  it may be available to  the phytoplankton.  In meso-
trophic  lakes the  NAI-P  may remain relatively immobile in the bottom sedi-
ments.   The  sediment  NAI-P was  compared to  the average  algal densities
measured in each of  the lakes during  the  June  and September 1979 sampling
periods  (figure 3-4).   The figure shows that Indian Lake,  Dewey Lake, and
Magician Lake appear  to  experience different intensities of nutrient cycl-
ing from the  sediments as compared to  the other lakes.   Pipestone Lake is
anomalous probably because of  the estimated high external loading of phos-
phorus.

     Eutrophication or increased productivity of a lake is generally caused
by an  increase in the input  of nutrients to a  lake.   For  most freshwater
bodies,  phosphorus is  the  key nutrient for  aquatic  plant growth.   In most
lakes, productivity of  the lakes can be reduced.   However,  the removal of
one  source  (septic  tank  effluents)  may  not change the water  quality of
these  lakes  significantly.   Water  quality  improvements  may  require  the
control of many sources in order to realize maximum benefits from a reduced
phosphorus load.

     To  estimate  the nutrient  inputs a "theoretical  loading" was derived
using  the  available   literature  values  for  contributions  from  nonpoint
sources, precipitation, and septic tank leachate.  Nutrient export coeffic-
ients  from USEPA  (1980b)  were used for nonpoint  source inputs  (Table 3-4).
Land use/land cover acreage in the seven study area watersheds  (Figure 3-5)
is presented  in  Section 3.2.2.1., Table 3-18.   Total phosphorus contribu-
tions  to the  lakes   from  direct  precipitation  were estimated  using 0.13
kg/ac/yr of lake surface (USEPA 1980b).
                                  3-15

-------
            4000-
            3000-
       O)
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       ~   2000H
       Q.
       i
            1000-
                                              Round Lk
                                Cable Lk
                            • Pipestone Lk
Up Crooked Lk
                          Lo Crooked Lk
                                          Indian Lk

                                         "s
                                                  Dewey Lk
                                                       Magician Lk
                              1^1^    T     •     1
                             1000       2000       3000       4000
                               ALGAL DENSITY   (number/ml)
Figure 3-4. Comparison of sediment NAI-P (Nov. 1982 samples) with algal density


           (Jun. and Sept. 1979 sampling times) for study area lakes.
                                       3-16

-------
No Scale
Figure 3-5.  Surface watersheds in the study area.




                                  3-17

-------
Table 3-4.  Mean nutrient  export  from  nonpoint sources  by land use/cover
            type (USEPA  1980b).
                                                          Total
                                                       Phosphorus
Land Use/Cover Type                                    (kg/acre/yr)

     Agricultural                                            0.26
     Residential                                             0.14
     Commercial                                              0.81
     Industrial                                              0.30
     Recreational areas                                      0.08
     Forest                                                  0.11
     Wetland                                                 0.06
     Several  different estimates  of phosphorus  loads in  septic  tank ef-

fluent have  been  reported:   0.8 kg per capita per year (kg/cap/yr)  (Dillon
and  Rigler  1975)  and  1.1-1.7  kg/cap/yr  (USEPA  1980a).   The  Dillon and

Rigler value  of  0.8 kg/cap/yr was utilized  as  a baseline  loading.  A soil

retention coefficient of 88% was used to estimate  the  percent of phosphorus

removed by soil  which is within the  range  used by USEPA  (1980b) and Jones
and Lee (1977).  Therefore, the values of 0.1 kg/cap/yr, similar to  the NES

value of  0.11 kg/cap/yr (USEPA 1974), was used to calculate the phosphorus

contributions from septic tanks to lake waters.  The nutrient loadings from

septic systems and  the other sources are presented in Table 3-5.  As indi-
cated, the nonpoint sources contribute a  significant  amount of phosphorus

to all the lakes.
Table 3-5.   Total phosphorus inputs by source.


            Nonpoint Source        Septic        Precipitation
Lake      (Land Cover) (kg/yr) System (kg/yr)       (kg/yr)      Total  (kg/yr)
Cable
v/rooked
Dewey
Indian
Magician
Pipestone
Round
59.4
96.2
392.7
659.6
410.3
493.4
112.6
29.0
103.0
52.0
122.0
160.0
19.0
52.0
9.9
29.5
28.5
65.9
58.6
16.5
25.1
98.3
228.7
473.2
847.4
628.9
528.9
189.7
                                  3-18

-------
     The  sources  of nutrient  inputs to  the  lakes are  dependent upon the
predominant  land  use/cover  type of the  watersheds.   Dewey  Lake,  Indian
Lake,  and Pipestone Lake  watersheds had  the highest  percentages of phos-
phorus inputs  from  nonpoint  sources, and  a significant  percentage of each
watershed was  used  for agricultural purposes.  The Crooked Lake watershed,
with the highest percentage of residential land, had the highest percentage
of phosphorus loadings from septic tank leachate.

     The  nonpoint source  load  to the lakes does not differentiate the load
contributed by  surface runoff  and groundwater.   Indian Lake and the Sister
Lakes  are primarily  seepage  lakes  and  do  not  have any  major tributary
inlets or stream linkages  between  lakes.  The  lakes  are  fed primarily by
groundwater  recharge.   Water  balance  estimates and  well  water  chemical
analysis  for Pipestone Lake  indicated that groundwater is the major source
of phosphorus  to  the  lake (National Biocentric  Inc.  1978).   Similar water
balance data for  the  other lakes are not available.   However,  the concen-
tration  of  total  phosphorus  in the  groundwater  surrounding  the  lakes,
except Pipestone Lake, is relatively low.

     The  amount  of  phosphorus  that actually enters  the  lake  from septic
tanks  would  depend  on the  ability  of drain field  soils  to immobilize the
phosphorus.  When subsurface  disposal  systems are built on proper soil and
are  located  at proper distances from the  receiving water body,  nearly 100%
of the phosphorus from septic tank  effluent  is  removed  by the  soil  (Jones
and Lee 1977).   However, when the distances between the disposal system and
lake are  limited or when the drain field has failed, a higher proportion of
the  phosphorus  from the system may  move  into the groundwater.   The shallow
groundwater study (Appendix  C)  attempted  to quantify the nutrients contri-
buted  to  the  lake  from selected septic  tank and  soil absorption systems.
The  results  indicated  that,  for the systems  studies,  little phosphorus or
nitrates  moved to  the  lake.   That  result  may  be expected  because lake
levels  and the groundwater  table were  lower than at  any  time in recent
history.
                                  3-19

-------
     To evaluate  the  nutrient contribution of septic tanks to the  lakes, a
comprehensive septic leachate survey of Indian Lake and  Sister Lakes shore-
lines  was  performed in  October 1979  by  K-V Associates,  Inc.  The septic

leachate survey  included  a continuous scan of sections  of the shoreline of

all the lakes by a recording  leachate detector instrument  (Septic Snooper).

Water  quality analyses  of identified stream or groundwater plumes  detected

by  the septic leachate  detector supplied  evidence  of domestic wastewater

infiltration  into the  lakes.   In  October groundwater  plumes originating

from  permanent  residences should have been detected.   Most seasonal resi-

dences  were  vacated by  October; therefore,  some  seasonal residences that

may have been emitting erupting  plumes were not detected at the time of the

septic leachate detector survey.  The following conclusions were drawn from

the survey:


     •    A total of 31 locations exhibited noticeable erupting ground-
          water   plume  characteristics,   specifically  occurring  on
          Crooked  Lake,  Magician  Lake,   Indian  Lake,  and  Pipestone
          Lake.    The other   lakes  had fewer  potential  point source
          problem  sites  and  had water quality  influenced  by the sur-
          rounding land use.

     •    From the  31 erupting  groundwater  plumes,  nearshore ground-
          water samples were collected and analyzed from 11 locations.
          Only  2 of  the  samples had  nitrate-nitrogen  concentrations
          greater  than  0.1  mg/1 and  none of  the samples  had  total
          phosphorus concentrations greater  than  0.04 mg/1.  Maximum
          values were 6.8  mg/1  for NO  and 0.88  mg/1 for total phos-
          phorus.

     •    Only on Pipestone Lake were consistently  high ammonia con-
          centrations  measured   (greater  than  1  mg/1)  which is   in-
          dicative  of  anaerobic conditions  that  favor  movement  of
          phosphorus through groundwater.


     In  summary,  the  different  phosphorus  loads to  Indian  Lake  and  the

Sister  Lakes  is  an important  factor  affecting  the  water quality of  the
lakes.  The  relationship between theoretical nutrient  loading,  lake water

quality, and  trophic status  is  shown  in Table 3-6.   A  general  lake model

which  predicts the  current phosphorus loading rate as well as the  expected

changes that may occur with implementation of the various wastewater alter-

natives is given in Section 4.1.2.3.
                                  3-20

-------
Table 3-6.  Comparison of water quality indices and estimated phosphorus
            loads for area lakes.
Lake

Pipestone
Indian
Dewey
Magician

Round
Upper Crooked
Lower Crooked
Cable
Autumn 1982
 Sampling

Eutrophic
Eutrophic
Eutrophic
Mesotrophic
 to eutrophic
Mesotrophic
Mesotrophic
Mesotrophic
Mesotrophic
    Secchi Disk
(MDNR Classification)3

Eutrophic
Eutrophic
Mesotrophic (eutrophic )
Mesotrophic

Mesotrophic
Mesotrophic
Mesotrophic
Oligotrophic
 Theoretical
  Phosphorus
 Loading Rate
(g/m  of lake)

    1.03
    0.41
    0.53
    0.35

    0.24
    0.25
    0.25
    0.28
 MDNR classification is based on Secchi disk measurements or chlorophyll 4.6
                    Chlorophyll
                      >10 mg/1
                     4-10
                       <4
 Dewey Lake has been classified as eutrophic based on Secchi disk measure-
       ments recorded as part of the Inland Lake Self-Help Program in 1974,
       1975, 1976, and 1977  (MDNR 1975b, 1976b, 1977b, 1978a).
     The results of the various indices show that the lakes of the area are

either in an  advanced mesotrophic state or in a low eutrophic state  (Table

3-6).  This conclusion was substantiated further by the existence of moder-

ate to heavy  aquatic  vascular plant growth  in  the  lakes and the dissolved

oxygen readings  of  less than 2.0 ppm  in  the deeper sections of six of the

lakes.   The  reduced  Secchi  disc  transparency  readings  for Pipestone Lake

also  indicate greater algal  productivity  (biomass)  and  turbidity compared

to the other  lakes.


3.1.3.2.  Groundwater in the  Study Area


     Water supplies in the study area are obtained from groundwater sources

associated with  the glacial geology.  Outwash deposits constitute the most
                                  3-21

-------
productive aquifers in the study area.  The stratified sands and gravels of
these deposits  may be  highly permeable,  continuous over great distances,
and readily recharged by precipitation  (Giroux and others  1972).

     The  regional  water table  in  the  study  area is  shown  in Figure 3-6.
This map  was constructed  on the basis of  information obtained from  topo-
graphic maps  and  water  well  records.  In general, groundwater  is recharged
in the uplands and is discharged to the Dowagiac River, its tributaries and
to Pipestone  Creek.   However, because the lakes in  this area  intercept the
unconfined water  table, groundwater  constitutes  an  important and undeter-
mined part of the hydrologic  budget in these lakes.

     Drinking water quality surveys of the project area have been conducted
by WAPORA in June  1979 and  November 1982.   A  total  of  sixty residential
wells  located around  the lakes were selected  for  sampling  in  the  first
survey  (Figure 3-7).  The  second survey included 48 wells.  Results of the
nutrient  and  coliform  analysis of   the water  samples collected  from the
wells are  shown  in Table 3-7 and in  Appendix A.  The nitrate-nitrogen data
indicated  that  the groundwater  was   contaminated  in localized areas.  The
majority of wells sampled (74%) had nitrate-nitrogen concentrations of less
than 1  mg/1.   Twenty eight  wells  (26% of total  well  samples) had concen-
trations  greater than 1 mg/1; and 8  out of  these 28 wells had nitrate-ni-
trogen concentrations greater than  the 10 mg/1 criteria for domestic water
supply.    The  data  also  indicated that most of  the higher nitrate-nitrogen
concentrations  are associated  with  higher  concentrations  of chlorides.
Thus one  possible  source of  nitrate  contamination of these localized wells
appears to be the effluent from septic tanks.

3.1.4.   Aquatic Biota

3.1.4.1.  Phytoplankton

     Information on phytoplankton  for the  lakes  in  the  study area is dis-
cussed  in Section 3.1.  Appendix I of the Draft EIS contains summary tables
of the species lists and densities.
                                  3-22

-------
Figure 3-6.  Groundwater contours in the study area.



                               3-23

-------
                                                         -fe.'yr>/'ig-'-'MyA lf" rO /PCI.
Figure 3-7.   Well sampling sites for the groundwater  survey
                                  3-24

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3.1.4.2.  Mollusks

     No  data  are available  on mollusk populations  in  the  study area.  No
threatened or endangered species are believed to exist locally.

3.1.4.3.  Fisheries

     Bodies of water that are classified as coldwater lakes by MDNR  (1976a)
are deep,  thermally stratified,  and support or are capable  of supporting
one or  more  coldwater  fish species.  Indian  Lake,  Cable Lake, Dewey Lake,
and Magician  Lake are  so  classified.   Pipestone  Lake  is  classified as a
trout lake (By telephone, William McClay, MDNR, to WAPORA, Inc. 26 February
1979)   and  has  salmonid fishes  within  it  during  the  spawning  and smolt
periods.   Bodies of  water  classified  as  warm  water  lakes  are typically
shallow, do not  become  stratified, and are not capable  of supporting cold-
water  fisheries.  The remaining  lakes in the study  area are  classified as
warm  water lakes.   No  species of  fish that have  been designated  by the
State  of Michigan as  endangered  or  threatened  are known  to occur in the
Indian  Lake-Sister Lakes study area.  The predominant game fish species in
the study area lakes are presented in Table 3-8.

3.1.5.  Terrestrial Biota

3.1.5.1.  Amphibians and Reptiles

     Three species of amphibians and 5 species of reptiles have been desig-
nated  as endangered or  threatened by  the  State of Michigan (MDNR  1980).
Three  of these  species,  the marbled salamander, the  black rat snake, and
the eastern  box  turtle have  distribution ranges  that include  the study
area.   No  data  are  available  specifically for the  study  area which docu-
ments the presence and/or absence of any of these species.

3.1.5.2.  Birds

     The diverse habitats that  occur within  the  study area support many
species  of birds and make  it a prime waterfowl site.   A total of  109 spe-
                                  3-27

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Table 3-8.  Predominant species of fish in each of the study area lakes
            surveyed by MDNR (survey year is in parentheses).
Lake
Cable (1941)
Crooked (1965)
Dewey (1963)
Indian (1964)
Magician (1963)
Pipestone (no
 date)
Round (1977)
Common Name

Blue Gill
Perch
Largemouth Bass
Yellow Perch
Blue Gill
Crappie
Largemouth Bass
Pumpkinseed
Mud Pickerel
Bullhead
Sucker
Crappie
Pumpkinseed
Largemouth Bass
Smallmouth Bass
Blue Gill
Pumpkinseed
Black Crappie
Largemouth Bass
Bullhead
Northern Pike
Carp
Crappie
Pumpkinseed
Largemouth Bass
Smallmouth Bass

Blue Gill
Pumpkinseed
Crappie
Yellow Perch
Largemouth Bass
Carp
Chubsucker
Warmouth
Bullhead
Lake Chubsucker
Spotted Sucker
White Sucker
Alewife
Gizzard Shad
Chinook Salmon
Coho Salmon
Hybird Blue Gill Sunfish
Rainbow Trout
Largemouth Bass
Tiger Muskie
jcientific Name

Lepomis macrochirus
Perca fluviatilis
Micropterus salmoides
Perca flavescens
Lepomis macrochirus
Pomoxis sp.
Micropterus salmoides
Lepomis gibbosus
Esox vermiculatus
Ictaluridae sp.
Catastomidae sp.
Pomoxis sp.
Lepomis gibbosus
Micropterus j>almoides
Micropterus dolomieui
Lepomis macrochirus
Lepomis gibbosus
Pomoxis nigromaculatus
Micropterus salmoides
Ictaluridae sp.
Esox lucius L.
Cyprinus carpio
Pomoxis sp.
Lepomis gibbosus
Micropterus salmoides
Micropterus dolomieui

Lepomis macrochirus
Lepomis gibbosus
Pomoxis sp.
Perca flavescens
Micropterus salmoides
Cyprinus carpio
Cprinidae sp.
Lepomis gulosus
Ictaluridae sp.
Cyprinidae sp.
Minytrema melanops
Catostomus commersoni
Alosa pseudoharengus
Dorosoma cepedianum
Oncorhynchus tschawytscha
Oncorhynchus kisutch
Lepomis macrochirus
Salmo gairdneri
Micropterus salmoides
Esox masguinongy
                                  3-28

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cies of grassland birds, woodland birds and waterfowl have been recorded in
Cass  County  (Gove  Associates,   Inc.  1977).   Twelve  species of  birds are
considered  by  the  State of Michigan to be  endangered or threatened  (Table
3-11  of  the  Draft  EIS).   Several  of  the  species  listed,  including the
Peregrine Falcon,  the  Bald Eagle, and Kirtland's  Warbler,  may  utilize the
study area,  but sufficient  data are not available to  document their pre-
sence.

3.1.5.3.   Mammals

     Within  the  Great  Lakes  Region,  transitions  occur between the  boreal
forest, the  southern coastal plain,  and the western grassland  zones.  This
diversity of major vegetation zones,  and the abundance  of lakes have  signi-
ficantly influenced  the number  and distribution of mammals in  this region.
Seventy-eight  species  of  mammals are  known to  occur  in  the  Great Lakes
Region.   Approximately  42  species  of  mammals have  ranges that  include
Berrien County, Cass County, and Van Buren County  (Cooley 1979).

     The  State  of  Michigan  has identified  5  species  of  mammals known to
inhabit the State  as  endangered or  threatened species (Table  3-16 of the
Draft  EIS).   Of these  species,  the  Indiana bat,  the pygmy shrew,  and the
southern  bog  lemming  have  ranges  that  encompass the study  area.   Data
indicating  the presence  or  absence  of  endangered  or threatened  species
within the  study area are not available.

3.1.5.4.   Vegetation

     The presettlement  vegetation of Berrien,  Cass, and Van Buren  Counties
included beech-maple and oak-hickory  forests   (Braun  1950;  Kenoyer  1930).
Small  areas of prairie also were present  in  the  three counties (Transeau
1936).  A  total  of 38 species of  plants  (mostly native  herbaceous) are
listed as  endangered or  threatened  in  Berrien County  (Appendix J of the
Draft EIS, Table J-l).  Six of these are designated as  endangered or  threa-
tened  at  the  federal  level  (Ayensu and  De Filipps  1978).  These include
white  lady's-slipper,  prairie   fringed  orchid,  smaller  whorled  pogonia,
Pitcher's thistle,  and  rosinweed.  The small whorled pogonia is  the  rarest
orchid in the United States.
                                  3-29

-------
     In  Cass  County,  a. total of 25 species of  plants  (mostly  native  herba-
ceous)  are  listed as  endangered,  threatened,  or rare  (Appendix J  of  the
Draft EIS, Table J-2).  Of  these, two  threatened  and one  endangered species
also are  included  on the federal list:  the  tubercled orchid, ginseng,  and
rosinweod (Ayensu and De Filipps 1978).

     In Van  Buren  County,   26 species  of  plants  (mostly  native herbaceous)
are  classified  as endangered  or threatened  (Appendix  J  of the Draft EIS,
Table J-3).  Included in this total are three threatened  and one  endangered
species  that  are  on  the federal list:  the tubercled orchid,  ginseng, Pit-
cher's thistle, and rosinweed  (Ayensu  and  De  Filipps 1978).

3.1.6.  Wetlands

     Wetlands  can  be defined  in general  terms as "lands where  saturation
with water is  the  dominant factor determining  the nature of  soil develop-
ment and  the  types of plant and animal  communities living in the soil  and
on its  surface"  (Cowardin  and others  1979).  Such lands  comprise 7%  of  the
four-township area.  The majority of the wetlands are located  in  Keeler  and
Silver Creek Townships.

     Wetlands in the  study area were  mapped  at a scale  of 1:36,000  by  the
USEPA,  Environmental  Monitoring System   Laboratory  (USEPA  1979).   Three
types of wetlands were identified:

     •    Wooded swamp
     •    Shrub swamp
     •    Non-forested (non-wooded)  wetlands  (marsh).

     Most  of  the  wetland   areas  mapped  by   the  USEPA  are located  in  the
northern  half  of  the study area.   Many small  wooded and shrub  swamps  are
located  between  Magician  Lake  and  Keeler  Lake.  Large areas  of   wooded
swamps also  are  located along  the  shores of Cable and Dewey  Lakes  and in
Bainbridge Township,  north  of Pipestone Lake.
                                  3-30

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3.2.  Man-made Environment

3.2.1.  Demography

3.2.1.1.  Historic and Current Population

     Historic  and current  population  trends  were  analyzed  for  the four
townships  (Bainbridge,  Keeler,  Pokagon, and Silver  Creek)  and three coun-
ties  (Berrien,  Cass,  and  Van Buren)  in  which the  study  area is located.
The  townships are  the  smallest  geographic  units for  which  comprehensive
demographic data are available.

     Each of  the  four townships has experienced continuous permanent popu-
lation  growth since  1950  (Table 3-9).   The  four townships  combined per-
centage increase  in  population during  the 30-year period from 1950 to 1980
was 63.4%.   The  four-township area has experienced more rapid growth since
1950 than  the surrounding area and  the state  (Table 3-9).  The more rapid
rate of growth probably can be attributed to tourism and recreation-related
development,  although this  market  segment has  not experienced  growth in
recent years.

     Growth  rates for  the four  townships  varied considerably  during the
30-year period.   The increases  ranged from a  low  of  31.2%  in Bainbridge
Township  to  89.6% in  Silver Creek  Township.   The  rapid  growth in  Silver
Creek Township also  is  noteworthy because of  the  high proportion of town-
ship residents who live in the study area.

     From  1970 to 1980  the  population of the  four  townships increased by
1,179 (US Bureau of the Census 1982).   Keeler Township recorded the highest
rate of increase,  18.1%,  but Silver Creek Township,  which includes  a con-
siderable  amount  of  development  around the Sister  Lakes,  also recorded a
high growth  rate  (16.5%).   Population  data for the four-township area from
1970 to 1980 are summarized in Table 3-10.
                                  3-31

-------
Table 3-9. Population growth in the four-township area,  three-county  area,
             and in Michigan between  1950 and  1980  (US Bureau  of  the  Census
             1952, 1963, 1973, 1982).
Township
Bainbridge
Keeler
Pokagon
Silver Creek
Total
County
Cass
Van Buren
Berrien
Total
Michigan
1950
2,194
1,414
1,518
1,773
6,899
28,185
39,184
115,702
183,071
6,371,766
1960
2,503
2,109
1,935
2,108
8,655
36,932
48,395
149,865
235,192
7,823,194
1970
2,784
2,234
2,189
2,886
10,093
43,312
56,173
163,940
263,425
8,881,826
1980
2,879
2,638
2,394
3,361
11,272
49,499
66,814
171,276
287,589
9,258,344
Percent
Change
1950-1980
31.2%
86.6
57.7
89.6
63.4
75.6%
70.5
48.0
57.1
45.3
Table 3-10.  Population growth in the four-township area,  1970 to  1980  (US
             Bureau of the Census 1973,  1982).
                                                        Population  Change
                                                           1970 - 1980
          Township            1970           1980          No. Percent
Bainbridge
Keeler
Pokagon
Silver Creek
Total
2,784
2,234
2,189
2,886
10,093
2,879
2,638
2,394
3,361
11,272
95
404
205
475
1,179
3.4%
18.1
9.4
16.5
11.7
     Although  the  rate of  growth in  the  four-township area generally ex-

ceeded the  rate of growth  in  the three-county area  and  in the state, the
growth rates  have declined  over time.   Peak population  growth  rates oc-

curred, in  all three  situations, during the  1950s  (Table  3-11).  The  four-
township  area grew  by 25.5%  from  1950 to  1960.   This  rate  of increase

declined  in  the last  decade to  11.7%.   In  addition,  Bainbridge Township

grew at a slower rate from  1970  to  1980,  3.4%, than did  the State  (4.2%).

                                  3-32

-------
Table 3-11.  Population growth rates in the four-township area, three-
             county area, and in Michigan between 1950 and 1980 (US Bureau
             of the Census 1952, 1963, 1973, 1982).
     Township       1950-1960      1960-1970      1970-1980      1950-1980
Bainbridge
Keeler
Pokagon
Silver Creek
Four Township
Area
County
Cass
Van Buren
Berrien
Three-County
Area
Michigan
14.1%
49.2
27.5
18.9

25.5

31.0
23.5
29.5

28.5
22.8
11.2%
5.9
13.1
36.9

16.6

17.3
16.1
9.4

12.0
13.5
3.4%
18.1
9.4
16.5

11.7

14.3
18.9
4.5

9.2
4.2
31.2%
86.6
57.7
89.6

63.4

75.6
70.5
48.0

57.1
45.3
     In spite of the low rate of growth in Bainbridge Township, the overall
growth rate in the four-township area from 1970 to 1980 exceeded the growth
rate of the  three-county area and the  State  of Michigan.  This more rapid
growth parallels  trends in  rural,  non-metropolitan  areas  nationwide.  It
also may reflect the area's economic links to non-manufacturing industries,
which were more stable during the 1970s than manufacturing industries were.

3.2.1.2.   Service Area Population Estimates

     Gove Associates,  Inc. developed  service area  populations  based on a
house count and the 1970 average household size for the four-township area.
Seasonal  and  permanent population estimates  were  developed  from estimates
by  local  officials  and area residents.  In 1979,   Gove  Associates,  Inc.
prepared  an  updated  house  count based on revised land use maps (Gove Asso-
ciates, Inc.  1980).    Seasonal  and  permanent  residence  identification was
based on  the address of the landowner in the  tax records.

     Subsequent to that count it was recognized that numerous problems were
encountered  in  differentiating  between residences and outbuildings.  Also,
                                  3-33

-------
numerous  seasonal  residences were noted as being permanent residences.   In
1979, WAPORA counted dwelling units from updated maps but, in this count, a
larger  area than  that  designated  as the  service  area  was  included.   In
1981,  WAPORA completed  another  count  of  the dwelling  units  within the
designated  service area using final  inspection  records for septic systems
and partial  field  checks of the  maps.   The  identification of seasonal and
permanent residences was made from addresses  on  the 1978 tax rolls and  on
interviews for the major leaseholds and resorts.  Because the 1977 and 1978
tax  rolls were used,  the 1981  permanent  population probably  is underes-
timated.

     A  comparison of  the results  of these  house  counts  is  presented  in
Table  3-12.   The  major  discrepancy  between  the  Gove and  WAPORA counts
occurs  for  Pipestone  Lake.   These dwelling units were  counted from aerial
photographs and problems in distinguishing residences and outbuildings were
encountered.

     Gove Associates identified on the eligibility maps the residences con-
structed  after  1972 with information from building permit records.  WAPORA
made  some corrections  to  this   count  based   on  septic  tank installation
records.   The   numbers   of  new  dwelling  units  are given  in Table  3-13.
According to  the  septic tank records  examined,  the number  of  residences
constructed from  1972  to 1977 may have been underestimated in the Facility
Plan  by approximately 40  residences.  A large number  of building permits
for residences  were granted  in  1972 prior to the  October  cutoff date for
grant eligibility determination.  These residences may  have been construct-
ed and  inhabited  in  subsequent years; thus,  the  final  inspection dates on
the septic  tank records  would indicate the  later  habitation.   These data
show  that fewer  new  dwelling  units  on undeveloped   lots are  being  con-
structed  than during  the middle  of the  decade.   Most   of the new dwellings
are probably permanent residences although the addresses of the owners show
more  seasonal  than permanent residences.  The owner's  address may reflect
his former address rather than his present one.

     Determining the average household size for seasonal residences is more
problematic.  No conclusive data are available for this area and no generic
                                  3-34

-------
Table 3-12.  Comparison of counts of residential dwelling units within the
             Indian Lake-Sister Lakes service areas by Gove Associates,
             Inc. (1978a, 1980) and WAPORA, Inc. (1979, 1981).
                                                                   WAPORA
Service Area             Gove 1977      Gove 1979   WAPORA 1979&    1981
Indian Lake
Permanent
Seasonal
% seasonal
Total
Pipestone Lake
Permanent
Seasonal
% seasonal
Total
Sister Lakes
Permanent
Seasonal
% seasonal
Total
Total
Permanent
Seasonal
% seasonal
Total
a
Includes some

332
221
40
553

45
30
40
75

949
949
50
1,898

1,326
1,200
47
2,526
dwelling units outside

298
200
40
498

87
16
16
103

958
872
48
1,830

1,343
1,098
45
2,431
the service

221
299
57
520

65
22
25
87

816
1,064
57
1,880

1,102
1,385
56
2,487
area.

203
338
62
541

42
26
38
68

746
1,180
61
1,926

991
1,544
61
2,535

factors  have  been developed.   Also,  the  average  seasonal  use  probably
differs  significantly  from the  peak one-day seasonal use.   For  lack of a
well-defined rate,  the factor  proposed is 3.5  persons  per dwelling unit.
This factor may be low in accounting for the one-day peak, but high for the
seasonal average.

     The  1980  population estimates  for the  service  areas were calculated
from the  house  count  from maps prepared by  Gove Associates and updated by
WAPORA in 1981.  Two methods were employed to calculate current population.
One  used  the permanent  and  seasonal  determination  based on  addresses of
owners and  the other  used the  seasonal  and permanent  percentages  recom-
mended by the  planning directors, township supervisors, and realtors.  The
                                  3-35

-------
Table 3-13.  Number of new residences constructed on  undeveloped  lots  in
             the Indian Lake-Sister Lakes service areas.
Service Area                       1972-1977      1977-1980       1972-1980
Indian Lake
Permanent
Seasonal
Total
Pipestone Lake
Permanent
Seasonal
Total
Sister Lakes
Permanent
Seasonal
Total
Total Service Area
Permanent
Seasonal
Total
Average per year

28
11
39

1
1
2

48
68
116

77
80
157
31

3
3
6

0
0
0

14
15
29

17
18
35
12

31
14
45

1
1
2

62
83
145

94
98
192
24
1980 service  area populations  based on  household size  factors  were then
calculated by WAPORA (Table 3-14).

     It should be noted that while there has been  virtually no new building
activity around any  of  the lakes in  the  last few years, the conversion of
seasonal homes  to permanent  dwellings  continues.   It is not  possible to
calculate the number of  conversions being made,  or  in which areas, but it
can be  theorized  that  as the proportion of permanent  to  seasonal homes in-
creases, the wide range in the population fr""n summer  to  winter will dimin-
ish.  Again,  there  are  no conclusive data available  to verify or quantify
these apparent trends.
                                  3-36

-------






































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3.2.1.3.  Population Projections

     SMRPC developed  permanent population projections  in  1978 for  the  four
townships for  1985,  1990 and  2000  (Table  3-15 and Figure 3-8).  The SMRPC
will  not revise  these population  projections until  more complete census
data are available.

     The  expected population decline in Bainbridge  Township is related  to
its  distance  from urban centers  and  lack  of  recreational  facilities.
Growth  in the  three  other  townships is  occurring  more  rapidly  than ex-
pected.   SMRPC  projected a  1985 population  for Silver Creek  Township  of
3,228; The 1980  population reported by the US Census  however, exceeded the
1985  projection.   In  Keeler and  Pokagon  Township,  current  growth trends
also indicate that the projections are probably  somewhat low.

     The  permanent population projections  for  the  service areas (Table
3-16) were calculated  from the population growth  rates  (Table 3-15) and the
1980 populations  (Table  3-14).  The  1980  populations  that were calculated
from the  house  count  and the  recommended percentages  for  permanent popula-
tions  were  used  in  developing  the  population  projections.  Although the
1980 census  data  indicate  that  township  projected  growth  rates  were ex-
ceeded  in the  past  decade,  there has been  a  considerable  slackening  in
building  activity.   Within  these  townships,  much of  the  increase  in per-
manent population also may be occurring outside the service areas.
Table  3-15.   Population projections,  anticipated  growth rates,  and 1980
             Bureau  of  the Census  population by  township  (SMRPC 1978;  US
             Bureau of the Census 1982).
                                                       Anticipated Growth
               1980 Census      SMRPC Projections             Rate
Township       Population       1985   1990   2000        1970 - 2000
Bainbridge     2,879            2,650  2,600  2,500           -10.2%
Keeler         2,638            2,708  2,884  3,200            43.2%
Pokagon        2,394            2,440  2,552  2,731            24.8%
Silver Creek   3,361            3,228  3,363  3,601            24.8%

                                  3-38

-------
    3,500
    3,000
    2,50*
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   1,500
    1,000.
     500
                                                                      „* Silver  Creek
                                                                  .'-'     Twp.
                                                                         Keeler  Twp.
                                                          »ii
                                                                  "ii
                                                                         Pokagon Twp.
                                                        ""Bainbridge Twp,
Data sources:
  1950, 1960, 1970, 1980-US Bureau of the Census  (1952,  1963,
    1973, 1981)
  1976 - P-25 Series Current Population Reports  (US  Bureau of  the
    Census 1979)
  1985, 1990, 2000 - SMRPC Projections, from  1970 base year,
    (1978)
        1950
        1960
1970
1980
                                                         1990
                                                          2000
          Figure 3-8.  Population growth, historic and projected,  for  the  four-
                       township area.
                                   3-39

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Table 3-16.  Service area permanent population projections  for  1985,  1990,
             and 2000, and estimated  1980 permanent  populations.
                                   1980       1985       1990      2000
Indian Lake Service Area
Pokagon Township
Silver Creek Township
Totals
Sister Lakes Service Area
Bainbrid^e Township
Keeler Township
Silver Creek Township
Totals
Combined Total

33
867
900

117
1,357
1,404
2,878
3,778

34
894
928

117
1,438
1,452
3,007
3,935

36
931
967

117
1,529
1,508
3,154
4,121

38
993
1,031

117
1,691
1,607
3,415
4,446
     Four  methods  were developed  for  projecting seasonal population, each
based on  a different assumption.  Method  1  assumed that the ratio of sea-
sonal residents  to  permanent  residents would  remain constant (i.e., that
both  components  would  grow  at the same rate).  Method  2 assumed that  the
rate of seasonal population growth would be only half that of the permanent
population growth.   In Method 3 the seasonal  population was held constant
for the projection  period (1980-2000).  Method  4  was based on the assump-
tion by Gove Associates, Inc.  (1977) that  the seasonal population, taken to
mean residences, as  a percentage of the total population, would decline by
50% by the year 2000.  The results of  these four methods were combined with
the  permanent  population projections and  are presented  in  Table  3-17.

     Methods  1 and  2 produced final projections  that exceed the assimila-
tive  capacity of the  service area,  based on  the limited  amounts  of  un-
developed  lakeshore,  current  zoning restrictions  and development controls,
and recent declines in  tourism.  Method  4  yielded  a  projection that  ap-
peared to  be  unrealistically low;  it  forecasted a  seasonal population loss
so substantial that it was not offset by gains in  the permanent population.
                                  3-40

-------
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Method  3  provided  the  most reasonable  projections,  indicating a  constant
seasonal  population with  an  equilibrium between  growth  in  the  seasonal
housing stock and  the  conversion of  existing  seasonal units to permanent
homes.  If  the  occupancy rates continue  to  remain  the same, approximately
220 new dwelling units would be required  to house the expanding population.
By  comparison,  septic  tank installation  records  indicate  that  about  220
residences were constructed in the 1970s.

3.2.2.  Land Use

3.2.2.1.  Study Area Land Use Trends

     Land use in the  study area  is  very similar to  land  use  in  the sur-
rounding  four-township  area.  Agricultural  land,  orchards, deciduous for-
ests, water,  and wooded  swamps  constitute  approximately 87% of  the land
use/cover.  Approximately  12%  of  land use in  the  study area watersheds is
residentially developed.

     Land use data were collected and analyzed by watershed  for each of  the
seven major  lakes  (Cable,  Crooked, Dewey, Indian,  Magician, Pipestone and
Round)  in the  study  area.   In total, these watersheds extend  over 13,252
acres of  land.   The spatial distribution  of the  land use/cover categories
in the area watersheds is presented in Figure 3-9.

     Land use/cover types  were identified and planimetered  for each of the
seven watersheds  (Tables  3-18  and 3-19).  In  1977,  agricultural land con-
stituted 6,354 acres (2,571 hectares), or approximately 48%  of the  area and
was the predominant land use/cover type.  The Dewey Lake and Pipestone Lake
watersheds contained 52%  of the  total agricultural land.  Nearly one-third
of the  agricultural  land  (1,999  acres or  809  hectares) was categorized as
orchards.   Most  of  the  orchards  (69%) were located  in the Pipestone Lake
and Indian Lake watersheds.

     Forest land  was the  second  largest  land  use/cover category,  consti-
tuting 14.% of the total watershed area.  The Indian Lake watershed had the
greatest  amount  of  forest,  with  16%  of  the watershed  area classified as
                                  3-42

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-------
Table  3-1-8 .    Acres of each  land use/cover  type in the seven watersheds
                 in  the  Indian  Lake-Sister Lakes  study area.
   Land Use/Cover Type
 3
 
-------
Table 3-19.  Land use/cover types in the seven watersheds by number of
             acres and by percent of the total acreage.
                                                     Percent of Total
Land Use/Cover                Number of Acres            Acreage
Agricultural
Residential
Commercial
Industrial
Open space
Forest
Wetland
Water
Total
6,354.3
1,543.1
34.6
20.0
137.1
1,841.0
1,614.3
1,708.0
13,252.4
48
12
0.3
0.2
1.0
14
12
13
100.0
deciduous forest.  Water  was the next  largest  category (13%), followed by
wetland  (12%).   The Pipestone  Lake watershed  included 62%  of  all of the
wetlands in the watersheds, primarily wooded swamps.

     Rural and low density housing stock dominated the  residential  land use
sector.   Development was  located  primarily  along  the  shorelines of the
seven  lakes.  Nearly 12%  of the watershed  area was classified as  residen-
tial.  Magician Lake had  the most  acres  of residential development  (445.7
or 180 hectares) and Crooked Lake had the largest percentage  of residential
development  (39%).  Commercial-institutional uses  were concentrated north-
east of  Round Lake, and  included  a school, a  church,  and  a small conven-
ience  shopping  area.  The  only industrial uses  were  gravel pits, located
southwest of Round Lake.

3.2.2.2.  Prime and Unique Farmland in  the  Study Area

     Prime farmland  in the study area where detailed soil mapping is avail-
able is  presented  in Figure 3-10.  The mapped  areas were based on the de-
tailed soils  mapping and  the list of prime farmland units in Michigan  (SCS
1980a).   Unique  farmland is not  shown  on any  map  because  it has  not been
identified in a  consistent manner between  counties.  The areas in  orchards
and  small fruits  comprise much  of the  unique farmland within  the study
area.
                                  3-45

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 LEGEND

• mi  Boundary of available  j
     soil mapping
      Figure 3-10.   Prime farmland in the areas where soil mapping is available.

                                                3-46

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3.2.2.3.  Future Land Use

     The  rural  recreational  character  of  the  study area,  combined with
state and national economic conditions will affect the patterns of land use
that emerge  in the  study area.  Residential infill  and  the conversion of
seasonal housing  to  permanent  housing along the  lakeshores  is expected to
continue.  The  land  use pattern will not be affected significantly by this
phenomenon because  of  the  limited  number of developable  lake front lots.
If interest  rates decline and the state and local economies improve, resi-
dential development  can be  expected to expand into the back lots along the
lakes and other areas.  The residential development which would occur would
likely be to  provide bedroom communities for persons working in Dowagiac,
Benton harbor,  or Niles who are attracted  to  the study area  for its rural
and recreational amenities.  If residential development does increase, some
commercial development would occur to provide services for new residents in
the area.

3.2.2.4.  Development Potential

3.2.2.4.1.  Natural Constraints

     The three  predominant  natural  constraints on development in the study
area are steep  slopes,  high water table, and soils that are unsuitable for
building  construction  and  for  on-site sewage  treatment  systems.   These
natural  constraints   also  provide  the  basis  for many  of  the  legal con-
straints  that  attempt  to  regulate  development  in  sensitive areas charac-
terized by  one or  more of  the  above  features.  A  description  of. natural
constraints is presented in Section 3.1.2.2.

3.2.2.4.2.  Man-made  Constraints

Zoning Ordinances and Sanitary Codes

     The State of Michigan has extended statutory authority  to the counties
to establish planning  commissions,  enact  regulations, and regulate land
use.    However,  Berrien, Cass,  and  Van  Buren  counties have deferred this
                                  3-47

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responsibility  to  the townships.   Zoning  ordinances have been promulgated
by  each of  the four  townships  that include  the study  area.   Lot sizes,
building  setbacks  and heights,  planned  unit development requirements, and
agricultural districts are  among the provisions  found in these ordinances.
Zoning constraints are not likely to limit housing growth in the area  since
the  lakeshore  is extensively developed  and  considerable backlot areas are
available.

     The health departments of each county have been assigned the responsi-
bility of  enforcing  sanitary codes under  the  Michigan State Public Health
Act  of  1965.   All  three counties  have  adopted  sanitary codes which have
provisions  governing on-site sewage disposal  systems.   Enforcement of the
sanitary  codes  restricts development   where  lot  characteristics  do not
permit  adequate distances  between  drainfields  and structures,  wells,  or
natural bodies of water; where soils have extremely high percolation rates;
where tight soils  inhibit  infiltration  or  are  saturated;  and  where  soils
have a less than acceptable minimum depth to bedrock or to the water table.
Away from the already extensively developed  lakeshore, these lot character-
istics rarely limit  installation of on-site  systems.

Subdivision Regulations

     The  State  of  Michigan  enacted the  Subdivision Control Act  in  1967.
Under the terms of  this act, any land that has been subdivided into five or
more parcels  which  are  10  acres or  less in  size,  or  land  that has been
divided successively  over a  10-year period, must be  surveyed  and platted.
The plats are subject to the approval of the County Drain Commissioner, the
County  Health  Department,  and  the  governing  body  of  the local  unit  of
government  that  is  affected.   Enforcement  authority  is  given to  the At-
torney General or to the County Prosecuting Attorney.

Other Constraints

     The  Farmland  and Open  Space  Preservation Act of  1974  (Act  116)  pro-
motes the  preservation of farmland and open areas through the execution of
agreements  that reserve the development rights for the public in perpetuity
                                  3-48

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or  for  a specified term  of  not  less than 10 years.   However,  very little
land in the study area is protected under these covenents.

     Executive Order  11990,  Protection  of  Wetlands, was  issued  on 24 May
1977  (Federal  Register 42:26961).   The  terras of  Order require  USEPA and
other Federal  agencies  to avoid  adverse affects on  wetlands wherever pos-
sible, to minimize destruction of wetlands,  and to preserve and enhance the
natural  and  beneficial values of  such  areas  during the  discharge of the
agency's  responsibilities related   to   the  construction  and  improvements
undertaken by, financed  by,  or assisted by the Federal Government, such as
wastewater treatment  facilities.   The  State  of Michigan  passed  a wetland
protection act (Act No.  203 of the  Public Acts of  1979)  that  became ef-
fective 1 October 1980.  This act places restrictions on the development or
drainage of wetlands greater than five acres in size.

3.2.3.  Economics

3.2.3.1.  Regional Employment Trends

     The  early economic history  of  Cass, Berrien,  and Van Buren counties
was dominated  by agriculture.   As  agriculture  flourished,  the  industries
associated with  agriculture  prospered.   The  first  industries  to develop
were  shipbuilding,  flour milling, and   sawmilling.   These industries were
followed by firms that manufactured primary metals, machinery and household
appliances.  By  1970,  the area's  economy had shifted  from agriculture to
industry.  In  1970, manufacturing  comprised  nearly  half  of the  total em-
ployment and  was by far the largest employment sector.

     The  economic  future  of  the  study area may  be shaped by the increased
conversion of  the  lake areas into bedroom communities  for Dowagiac, Benton
Harbor-St. Joseph, and Niles.  Small retail and service businesses would be
expected  to  appear as  this  conversion  continues.   No major  expansion of
economic  activity  in  the study area is  expected  in the near future.  How-
ever,  better  transportation, increased  opportunities  in  the  nearby major
employment centers,  and  improved  community services  could stimulate some
additional local growth.
                                  3-49

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3.2.3.2.  Income

     Per  capita  income  levels  in Berrien,  Cass,  and  Van Buren  counties
consistently  were below the  state level  during  the 6-year period  between
1974  and 1980  (Table  3-20).   Growth  of  per  capita income  in the  three
counties  during this  same  period also  was less rapid  than the statewide
average.  Moreover,  per capita income in  Cass  County decreased  from $8,137
in  1979  to $7,169  in  1980.   The low levels of  income  and slow growth of
income may  reflect the out-migration of  high-income individuals from  Ber-
rien and Cass counties during recent years  (By  telephone, Mr. Steve  Harris,
Michigan  Municipal  Finance  Commission to  WAPORA,  Inc.,  9 October  1981).
Table 3-20.  Per capita personal income  in dollars  in  Berrien, Cass, and
             VanBuren counties and the State of Michigan.
Berrien
Cass
Van Buren
Michigan
19743
5,486
4,961
4,690
5,687
19753
5,646
5,230
4,836
6,008
1976a
6,026
5,979
5,334
6,760
a
1977
6,751
6,508
5,897
7,603
19783
7,596
7,479
6,764
8,507
a
1979
8,271
8,137
7,499
9,381
1980
9'156b
7,169°
8,316
10,647°
a
 By telephone, Ms. Jan Hanson, Michigan Employment  Security Commission,
 to WAPORA, Inc., January  1982.
b
 By telephone, Mr. Peter Elliott, SMRPC, to WAPORA,  Inc., January  1982.
 By telephone, Mr. William Rice, US Department of Labor, to WAPORA Inc.,
 January 1982.  Average per capita personal income  for  the State of Michi-
 gan was calculated by multiplying Michigan's 1979  per  capita income by
 the annual average increase of the US Consumer Price Index (CPI)  for  1980.
 The CPI has historically been a reliable parameter  for calculating income
 estimates.  The CPI is derived from the rate of inflation of consumer
 goods and services which may differ from real increases or decreases  in
 personal incomes.
3.2.3.3.  Unemployment

     Unemployment trends  in  Berrien,  Cass, and Van Buren counties parallel
national  cycles  of  business  activity.   During the  1970s,  the highest un-
employment  rates recorded by  the three counties  occurred  during the  1975
                                  3-50

-------
recession.  Unemployment  rose  sharply again during 1980 surpassing, at the
state, level, the unemployment figures for 1975.  The 1980 unemployment rate
in Van  Buren County was  10.3%  or  2.3% lower  than  the  state average.  Un-
employment  rates  in Berrien  and  Cass  counties  were 13.2%  and 13.1%, re-
spectively.  The  relatively  high  unemployment rates  in  the  three counties
for  1980  reflects  the  problems in the automobile industry and a continuing
loss of  industry  and jobs to states  in the south and southwest (By telep-
hone, Mr.  Stephen  Harris, Michigan Municipal Finance Commission to WAPORA,
Inc. 9 October 1981).

3.2.4.   Recreation and Tourism Resources

     Although the  contributions of the recreation  and  tourism industry to
employment and income in the three counties are significant,  the importance
of this  industry  has declined in the study area since the 1930s and 1940s.
This decline can be attributed to outmoded resort facilities, conversion of
seasonal  housing  units to  year-round homes,  and  the  development  of other
recreation areas in northern Michigan.  An examination of recent trends in-
dicated  that vacationers  travel longer distances and frequently bypass the
study area (By  telephone,  Mr.  Tom Hufnagel,  Michigan Department  of Com-
merce, to ViAPURA, Inc. 26 February 1979).

     The  future of the recreation and tourism industry in the study area is
uncertain  at  this  time.   While  land  development proposals  that provide
recreational and  open space  areas are encouraged  throughout southwestern
Michigan,  open  space in the four  townships  is projected to decrease by 44
acres by  the  year 2000 (SMRPC  1978).  Many of the resorts and housekeeping
cottages  in the study area have been  sold to individuals and the conversion
of seasonal homes to  year-round  homes is  expected to  continue.  However,
fuel costs and  reduced  travel time  could  result  in  increased spending of
recreation  and  tourism dollars  in the  study  area by  residents of nearby
Chicago and South Bend, Indiana.

3.2.4.1.  Public Facilities

     The  SMRPC has identified 316 acres of open space in Bainbridge, Keeler
Pokagon,  and  Silver  Creek townships.   This  land  includes  parks, recrea-
                                   3-51

-------
tional  developments,   fairgrounds,   outdoor  public  assembly  areas,  ceme-
teries, and vacant  urban land (SMRPC  1978).   This  accounted for only 0.4%
of  the total land  area.   Public  access is maintained  at  two lakes in the
service area.   One  is located on the north side of Magician  Lake in Silver
Creek Township, and the other is located on the north side of Round Lake in
Keeler Township.

3.2.4.2.  Private Facilities

     The private  recreational  facilities in the study  area  serve both the
year-round population and the seasonal population.  There are 135 overnight
units  at  the  four resorts and 47 camping  and  trailer  sites  in the service
areas.

3.2.5.  Public Finance

     A  variety of  community  services are provided  for  the residents  of
Berrien, Cass,  and  Van Buren counties.  Among  them  are health and welfare
services, transportation  facilities,  police protection, recreation facil-
ities, wastewater collection  and  treatment,  and tax collection.  The abil-
ity  to maintain  and  improve  these  services is dependent  on the continued
ability of county residents  to finance them.   Income and employment levels
can be used to measure a community's ability to support  community services.
Market value  and  assessed valuation of property directly  affect  tax reve-
nues  collected by  local  governments and,  consequently,  their  financial
capabilities.

3.2.5.1.  Assessed Valuation and Market Value

     The  1980 state  equalized valuations  (SEV) of real and personal pro-
perty  for  each county and  the market values of property  are presented  in
Table  3-21.   The  SEV for  Berrien   County,  the  most  populated  county  in
southwestern  Michigan, was  nearly twice the SEV of  the remaining counties
combined.  The  ratio  of  the  state  equalized valuation to market value  is
0.5 in Michigan.
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Table 3-21.  Selected financial characteristics for Berrien, Cass, and Van
             Buren Counties (By telephone, Mr. Hark Patzer, Berrien County
             Treasurer's Office; Ms. Candy Cooper, Cass County Treasurer's
             Office; Mrs. Stephayn, Van Buren County Treasurer's Office, to
             WAPURA, Inc. 28 December 1981).
Total revenues
Total state equalized
assessed valuation
Market value
Debt
Debt service
General obligation debt
limit

Berrien
$ 13,525,818
1,676,427,415
3,352,854,830
57,920,000
6,073,649
108,967,781
County
Cass
$ 3,902,076
420,747,938
841,495,876
1,335,000
87,410
42,074,793

Van Buren
$ 4,598,116
475,947,554
951,895,108
2,045,000
242,032
47,594,755
3.2.5.2.  Total Revenues

     Intergovernmental  transfers,  special assessments,  taxes,  and charges
for services  were the  primary  sources of revenue  for  the three counties.
In  1980,   Berrien County  collected revenues  totalling  $13,528,818.   The
combined total revenues  collected  by Cass and Van  Buren counties for 1980
were 63% of Berrien County (Table 3-21) .

3.2.5.3.  Debt, Debt Service, and Debt Limits

     The  general  obligation bonding  authority  of  local  governments  in
Michigan is  limited  to 10% of the  SEV.   Berrien  County has a self-imposed
debt limit  of  65% of the 10% state required debt limit.   The general obli-
gation debt  limit and  levels of debt  and debt  service  for each county are
presented in Table 3-21.
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     In 1980  Berrien  County had a debt  level of $57,920,000 or 53% of  its
debt limit.   Cass  County had a debt  level  of $1,335,000 or 3% of its debt
limit.   Van Buren County debt level was $2,045,000 or 4% of its debt limit.
The combined debt of Cass and Van Buren Counties was 6% of Berrien County's
total  debt.   None of  the three  counties  is near its  state  or local debt
limit.

     The three  counties  pay debt service primarily  on  bonds  which support
public  works projects.  A small percentage of total debt service is paid to
support county-owned  housing and land.  Berrien County's  debt service  for
1980 was $6,073,649.  Cass and Van Buren Counties combined debt service was
5% of Berrien County's total debt service.

     Criteria for  prudent  fiscal  management have been developed by several
authors.   Whether  a  county  can incur additional debt  safely  can be esti-
mated  by  applying three  common debt measures adapted  from Moak and Hill-
house  (1975).  As shown in Table 3-22, Berrien,  Cass and Van Buren Counties
are  rated  as being  below all  of  the standard  upper debt  limits and can,
according to these limits, increase their level  of debt.  None of the three
counties is near the state general obligation debt limit.  Berrien County's
total debt has reached only 53% of its self-imposed debt limit.

3.2.6.   Transportation

3.2.6.1.  Highways

     No major highways pass through the study area.  Interstate 94, located
15 miles west and  11 miles north of the study area, provides direct access
from the   study  area to  all major  metropolitan areas except  South Bend,
Indiana.  South  Bend  is accessible  from the  study  area via  1-33.   State
routes  M-51,  M-62,  M-140 and M-152 are located  in or adjacent to the study
area.   Traffic  volumes  in  the  four township area are  growing (By letter,
Mr.  Bill Camburn,  Van Buren County Road Commission, to WAPORA, Inc., March
1979).   Amtrack provides  daily  passenger train  service  to  Dowagiac  and to
Niles.   The nearest intercity bus station serving the study area is located
in Dowagiac.   Each of  the  three counties  has  a  county-wide  rural public
transportation system that serves the elderly and the handicapped.
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Table  3-22.   County  debt  measures (Adapted from  Moak  and Htllhouse 1975).
                       Standard Upper             _
                           Limits          Berrien   Cass   Van Buren

Debt/Total market
 value                 10% of current      1.7%        .2%      .2%
                        market value
Debt service/Total
 revenue               25% of total        4.5%       2.2%     5.3%
                       revenues

Debt/State equal-      10% of state equal-
 ized assessed         ized assessed valu-
 valuation             ation               3.5%        .3%      .4%

Debt/Per capita per-   7%                  3.7%        .4%      .4%
 so rial income
 The general obligation bonding authority of local governments in Michigan
2is listed to 10% of the SEV.
 Berrien County has a self imposed debt limit of 65% of the 10% state re-
,.quired debt limit.
 The calculations for deriving the counties debt per capital income ratio
-are presented in Appendix L of the Draft EIS.
 Not an upper limit but a national average in 1970.


3.2.7.  Energy


     The  fuel  types available for  residential,  commercial,  and industrial

heating in  the  three-county  area are fuel oil, coal, natural gas, propane,
butane, and electricity.   Fuel  oil is  the  predominant  energy  source  for
residential heating within  the four-township area followed by natural gas,
propane,  butane,  electricity,  wood and  coal.   Within  the  service area,

natural gas was the predominant energy source, followed by fuel oil.
3.2.8.  Cultural Resources


3.2.8.1.  Early History


     The  three counties  in  the  study  area were  inhabited  by Miami and

Pottowatomi Indians at  the  time of initial French exploration in 1675.   In
that year, Father Marquette traveled along the eastern shore of  Lake Michi-
gan and down the River of Miami (St. Joseph River) (Ellis 1880). Four years

                                  3-55

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later,  the French  explorer  LaSalle  established  a  fort  near  Niles  that
served as  a vital military post until  the  1760s.   Fort Miami,  later known
as  Fort St.  Joseph,  passed  into  Spanish,  English,  and  finally  American
hands as political fortunes changed on the early western frontier.

     During the  period of white settlement, the dominant Pottowatomi tribe
was divided into three bands led by Chiefs Pokagon, Weesaw, and  Sharehead.
Through a series of treaties executed between 1821 and  1833, they ceded all
of their land  to the US  and  were  transported  to areas west of  the Missis-
sippi River.   However,  Chief  Pokagon,  a prominent local historical figure,
refused to  sign or  consent  to  any treaties until  his fellow Catholic In-
dians received guarantees that they would be allowed to remain in Michigan.
Although forced  to  leave  his native site in Berrien  County,  he purchased
750 acres of land in Cass County (Silver Creek Township) and established an
Indian settlement  there.   In  1838, Chief Pokagon  built the first  Catholic
church in Silver Creek Township.

3.2.8.2.  Archaeological Sites

     The Michigan  History Division of  the Michigan Department of State has
a considerable amount  of  information on the prehistory of  the  study area;
these data are unprocessed,  however,  and not readily available  (By letter,
Martha M.  Bigelow,  Director,  Michigan History Division and State  Historic
Preservation  Officer,  to  WAPORA,   Inc.,  January  1979).   A search of  the
files of the  Michigan  History Division revealed the  existence of a regis-
tered Indian  site  in the study area.  This site is located in Section 7 of
Silver Creek Township  (T5S,  R16W).  It is likely  that additional,  undocu-
mented sites are present  on high ground near streams,  lakes, and rivers in
the study area (By telephone, Dr.  John Halsey,  Michigan Visitors Division,
to WAPORA, Inc.,  April 1979).  The following sections may  contain prehis-
torical sites, based on an analysis of topographic maps:

     •    Bainbridge Township (T4S, 17W), Section 25
     •    Bainbridge Township, Section 26
     •    Keeler Township (T4S,  16W), Section 31
     •    Keeler Township, Section 32
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          Silver Creek Township (T4S, R16W) Section 2
          Silver Creek Township, Section 3
          Silver Creek Township, Section 4
          Silver Creek Township, Section 6
          Silver Creek Township, Section 30
          Silver Creek Township, Section 31
          Silver Creek Township, Section 32.

     Undocumented  archaeological  sites also  may  exist  along meandering
parts of Highway M-152 in Bainbridge Township, where the highway follows an
old Indian  trail.   In addition, a site in Section 14 of Silver Creek Town-
ship  was  a temporary home for  Chief Pokagon's  tribe  from  1836  to 1838,
before  their  relocation to Sections  21 and 22,  which  are adjacent to the
study area  (Claspy 1966) .

3.2.8.3.  Historic Sites

     There  are  no  sites in the study area that are listed on  the National
Register of Historic  Places.   However a survey  for  eligible  sites has not
been  conducted  (By  telephone,  Mr.  Bob Christensen, Michigan History Divis-
ion to  WAPORA,  Inc.   4 January  1982).  Three  structures in the study area
are listed on the Michigan Register of Historic Sites.  The Sacred Heart of
Mary  Catholic Church  was  constructed by Chief Pokagon  in  1838  and has been
rebuilt twice.   It  stands  on the  grave of Chief Pokagon and is the oldest
Catholic church  still in  use  in southwestern  Michigan.  The  second struc-
ture, the Gushing  Corner  School,  is a  one-room schoolhouse that was built
in  1873.   It  has local historical significance and is one of  the few old
buildings in the area that has not been modified.  The  third structure, the
Sprague House,  is  a  simple clapboard frame house that  was built in  1868 on
the Old Orchard Farm.  The farmstead has been  listed as a "Centennial Farm"
by the Michigan History Division.

     WAPORA personnel  conducted  a  brief  field  survey of the study area
during  February 1979 and  identified 14 additional  sites of architectural
significance.  These are:

      •    Franz House
     •    Tudor Revival style bungalow
      •    Barn
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Italianate style house
Gingerbread style house
Halfert House and Barn
Genung House
Jeru House
Queen Anne style house
House
Keeler United Methodist Church
Silver Creek Methodist Church
Schoolhouse
Indian Lake School.
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4.0.  ENVIRONMENTAL CONSEQUENCES

     The  potential  environmental  consequences  of  the  system alternatives
that are described in Section 2.3. are discussed in the following sections.
The  impacts resulting  from  the  construction  and operation  of  some  the
alternatives may be beneficial, some adverse, and some may vary in duration
(either short-term or long-term) and significance.  The significant impacts
of each alternative are summarized by topic.

     Environmental effects  are classified  as either  primary or secondary
impacts.   Primary impacts  result  directly  from  the  construction  and/or
operation  of  the proposed  project.   Short-term  primary  impacts generally
occur during construction.   Long-term primary impacts occur throughout the
life of the project.

     Secondary impacts are indirect effects of the project, such as changes
in  demographic  and  other socioeconomic  characteristics.   As  these changes
occur,  associated  impacts  (e.g.,  air and  water  pollution, demand for ex-
panded  public  infrastructure,  increased  development pressure  on  agri-
cultural lands can result.  Secondary impacts also may be either short-term
or  long-term.   Short-term secondary impacts, for  example,  can result from
disruption of the environment that occurs during the construction of secon-
dary  development.   Long-term  secondary  impacts  can  result,  for  example,
from  urban runoff  that occurs  indefinitely  after  development of agricult-
ural land or other undeveloped areas.

     Possible  mitigative measures  also are  discussed  in  this  chapter.
Adverse  impacts  can  be  controlled and  many  should be  of short duration.
Possible mitigative  measures include  planning  activities and construction
techniques that  reduce  the  severity of  both  primary  and  secondary adverse
impacts.   Plans  and  specifications,  which are to be developed by the Coun-
ty, must include mitigative measures.
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4.1.  Primary Impacts

4.1.1.  Construction Impacts

     Each of the alternatives, excluding the No Action Alternative,  involve
some  construction  initially;  thus,  these  are  called "build" alternatives
throughout  the  impact analyses.   The No  Action  Alternative includes  some
construction  of new  on-site  systems  and  upgraded  systems  throughout the
life  of  the  project  and  is  discussed under  operation  impacts  (Section
4.1.2.).  The impacts  are  addressed in the  following subsections for  each
of the major categories of the natural and man-made  environments.

4.1.1.1.  Atmosphere

     Construction  activities  associated  with the   "build"  alternatives,
including cluster drainfields, and on-site systems,  will produce short-term
adverse  impacts  to   local   air  quality.   Clearing,  grading,  excavating,
backfilling, and other  related construction activities will generate  fugi-
tive dust, noise, and odors.   Emission of fumes and  noise from construction
equipment will  be a  temporary nuisance to  residents  living  near the  con-
struction sites.

4.1.1.2.  Soil Erosion and Sedimentation

     Soils  exposed  during  construction will  be   subjected  to  accelerated
erosion until the soil surtace is protected by revegetation or other means.
Most of the  sewers and force  mains  will be  laid  within road right-of-ways
where runoff  tends to  concentrate in roadside drainageways.  Most rainfall
events do not result  in significant runoff because  the sandy soils readily
absorb  precipitation.   Major  storms,  though,   could  cause  considerable
erosion in  some  drainageways that have large drainage areas.  The alterna-
tives that  involve considerable  lengths of  sewers and  force  mains  (Alter-
natives 2-7)  can be expected  to  result in  the   greatest  erosion and  sub-
sequent sedimentation.  Adverse consequences due  to  increased sedimentation
include excessive phosphorus  inputs  to lakes and streams, clogging of  road
culverts,  localized  flooding where  drainageways  are filled with sediment,
and filling of lakes  so that a substrate for macrophyte growth is provided.
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4.1.1.3.  Surface Vvater

     Wastewater collection  system  and treatment plant construction activi-
ties  (Alternatives  2-7)  could  produce discharge  of turbid  waters pumped
from  excavations  and  trenches  and  turbid  surface runoff  from disturbed
areas  resulting  in  increased turbidity and  sedimentation  in adjacent wet-
lands,  lakes,  or  waterways.   This sediment transport could result  in water
quality degradation and the potential for adverse impacts to aquatic biota.
Upgrading on-site systems (Alternatives 8A, 8B, 9, and 10) and construction
of collection systems for cluster drainfields  (Alternatives 8A,  8B, and 10)
would  contribute  turbid  runoff  to  lakes  or waterways,  but to  a lesser
extent  compared  to  the  construction  of the  centralized  collection  and
treatment alternatives.

4.1.1.4.  Groundwater

     Groundwater  may  be  impacted  by construction  activities  in localized
areas under all build alternatives.  Construction dewatering may cause some
shallow  wells  to  fail,  especially  where  pump  stations are  to  be  con-
structed.  A  potential change  in water  quality  would  likely  occur where
organic soils are disturbed either directly or by altering the water table.
Organics may  leach out  of  these  areas  and  affect  the  taste  of  water in
nearby  wells.   Spilled  fuel and other construction materials could quickly
pass through the sandy soils to contaminate the groundwater.

4.1.1.5.  Terrestrial Biota

     Construction activities associated with  various components  of  the pro-
posed  alternatives  would result  in  impacts  to wildlife and vegetation to
various degrees.  Collection sewers  (Alternatives 2-7),  some cluster drain-
fields  (Alternatives  8A,  8B,  and  10), and upgraded systems  (Alternatives 9
and  10) would  be  placed  on residential  lots;  temporary loss  of grassed
areas  and  the  removal of  trees  would result from construction  of these
facilities.   Disruption  of  backyard vegetation  and  the presence  of con-
struction  equipment and noises  would cause  temporary  displacement of most
vertebrate species  and  mortality  of a few (probably small mammal)  species,
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but  replacement  of  vegetation  and  cessation  of  construction activities
would allow  re-establishment  of the animals to the areas.  More likely the
animals commonly associated with human habitation  (e.g., eastern cottontail
rabbits, house sparrows, European starlings) that would be displaced, would
move  to suitable  neighboring habitat and  induce  no density-related stress
upon neighboring habitats.

     Proposed  conveyance lines  for Alternatives  2—7  generally  parallel
and are contiguous  to existing road  rights-of-way.   Approximately 20 feet
of roadside  vegetation  would  be destroyed during construction along county
road right-of-ways and  approximately 50 feet would be disrupted for place-
ment of force mains along M-62.

     The  placement   of   WWTPs  and  some  cluster  drainfields  proposed  for
Alternatives  2-7,  8A,  8B,  and  10  would  adversely affect  vegetation  and
wildlife  to  varying degrees  during construction,  depending  upon  the pro-
posed site.

     A  aew WWTP in Section 11 would require 80 (Alternative 2) to 100 acres
(Alternative  4).   Construction activities  would  disrupt a  larger area of
agricultural  cropland  and possibly  adjacent  wetlands.   Any  wetlands con-
struction  involving  fill would require  a  Section  404  permit  issued by the
US Army COE  or  MDNR permits issued  by  the Division of Land Resources Pro-
gram.

     Construction of  the proposed  WWTPs  at this  site would  result  in  the
permanent  displacement or mortality of  various animals commonly associated
with  cultivated  fields.   This  habitat  does not  support a  highly diverse
vertebrate population, however, so losses would not be significant.

     Construction activities  associated  with the  proposed WWTP  on agri-
cultural land in  Sections  8  (Alternative  3) and  29 and 32 (Alternatives 2
and 5)  probably would  not  destroy  any  native  vegetation.   A larger area
(100 acres) would be required for Alternatives 3 and 5 than would be needed
for Alternative  2 (25  acres).   Outfall sewers  for the  proposed  WWTPs in
Sections 29 and 32 may disrupt a wetland area occurring along the receiving
                                    4-4

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stream.   Disruption  of existing  wildlife communities  would  be similar to
that expected in Section 11.

     Conversion  of  orchard to agricultural  cropland  would be necessitated
to accommodate  the  land  application site proposed for  Section 8.  The area
required  would  depend upon  exact placement  of  the  site.   This change in
vegetation would  represent a  permanent decrease  in  habitat  diversity and
result  in a corresponding  change in  diversity  of vertebrate populations.

     Placement  of  cluster drainfields  surrounding the lakes  (Alternatives
8A,  8B,  and  10) would  primarily  be   adjacent  to residential  areas, and
little  disruption of  vegetation  or wildlife would be expected by construc-
tion  activities.   Temporary  displacement of  wildlife in  the  vicinity of
construction is  likely  to occur,  but no permanent adverse effects would be
expected.

     The  impacts on  terrestrial  biota  that would  result from upgrading the
existing  systems  (Alternative 8A,  8B,  9, and 10) would  be  insignificant
because a relatively  small amount of construction on developed land  would
be required to complete the project.

4.1.1.6.  Land Use

     Construction activities  associated with  the  implementation of any of
the "build"  alternatives  would require some  conversion of land use in the
study  area.   Under  Alternatives  2-5   residential,  agricultural,  orchard,
forests,  and wetland  areas  would  be  affected  to  varying  degrees.   The
construction of  WWTPs under these alternatives  would require the greatest
conversion of  primarily  agricultural land.   Under Alternative 3 255  acres
of cultivated  crop  land  and orchards,  located in  Section  8 of Silver  Creek
Township, would  be  used  as part of a regional land treatment system.  Less
than 1% of  the agricultural land within  the study area would be converted
to lagoons for wastewater treatment purposes.  Under Alternatives 2, 4, 5A,
and 5B  less than 2%  of  the agricultural land within the  study area  (less
than  1% of the  agricultural  land within the  four township area)  would be
used  for  the construction  and operation of  WWTPs.   The  existing Dowagiac
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WWTF would be used under Alternatives 6 and 7, eliminating the need for any
significant changes in land use within the study area.

     The construction  of  a sewer system under Alternatives 2-7 would occur
primarily in  residential  areas,  however, certain environmentally sensitive
areas would  be  affected.   Agricultural, wetland, orchard, and forest areas
will be  traversed  by  collector sewers under  these  alternatives.   The mag-
nitude of these  impacts  is not anticipated  to  be significant because most
of the sewer system would follow existing right-of-ways.

     Wetlands may  be   subject  to  sedimentation  during construction of the
sewer collection system.   Water  circulation patterns within these wetlands
may  be  permanently  modified.   Excavation,   clearing,  grading,   and  back-
filling  may  temporarily  affect  the  productivity  and aesthetic  value  of
wetlands.

     The construction of on-site and cluster systems under Alternatives 8A,
8B, 9, and 10 would occur primarily on lots which are already developed for
residential use.   Some  cluster systems may be  built  on land designated as
being agricultural  or open  space  which is  adjacent  to residential areas.
An insignificant amount of these areas would be necessary for the construc-
tion of  cluster systems.   No significant overall  land use  impacts  would
occur under Alternatives 8A, 8B,  9, and 10.

Prime Agricultural Land

     The irreversible  loss of agricultural  land to  other land  uses is a
growing  national  concern.    The  Council  on  Environmental  Quality  (CEQ)
issued a memorandum in 1976 to all Federal agencies requesting that efforts
be made  to  insure that  prime and  unique farmlands  (as designated by SCS)
are not  irreversibly  converted to  other uses unless  other  national inter-
ests  override  the  importance or benefits  derived  from  their  protection.
                                    4-6

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     The USEPA has a policy of not allowing the construction of a treatment
plant or the  placement  of interceptor sewers, funded through the Construc-
tion Grants Program,  in prime agricultural lands unless it is necessary to
eliminate  existing  point  discharges and  accommodate flows  from existing
habitation that  violates the  requirements of  the  Clean Water  Act  (USEPA
1981).   The  policy  of  USEPA  is  to  protect  prime agricultural  land  from
being adversely  affected  by primary and secondary  impacts.   It  is consid-
ered to  be a  significant impact if  40  or  more acres of prime agricultural
land are diverted from production.

     The amount  ot  prime  agricultural farmland, as  classified  by the  SCS,
affected by construction  activities is dependent upon  the  actual location
of the  wastewater  treatment facilities.  No information on prime agricult-
ural farmland  is available  for Section 11 (Cass County) of the study area,
therefore  it  is impossible  at this time  to  assess  impacts under Alterna-
tives 4 and  6.  Under Alternatives  2,  3,  5A, and 5B, the  affects of  con-
struction  activities  associated  with  wastewater  treatment  are dependent
upon  the exact  location  of those  facilities in  Sections  8, 29, and 32.
These sections contain prime agricultural farmland.

     Less  than 40  acres  of prime  agricultural  land are likely  to  be af-
fected  under Alternatives 2-6.  These lands would  be taken out of produc-
tion for use   as lagoons, treatment  facilities,  buffer zones,  and  access
roads.   The actual  acreage  of prime agricultural land taken out of produc-
tion for these treatment  alternatives is dependent  upon the  precise loca-
tion and placement of the treatment sites and interceptor routes.

     Less  than 40  acres  of  prime  agricultural land  are  likely  to be  con-
verted  for use as  cluster system sites under  Alternatives  8A,  8B, and 10.
Therefore,  no significant impacts are expected to occur.

4.1.1.7.  Demography

     Temporary  jobs  created by  the construction  of  wastewater collection
and treatment  facilities  under the "build" alternatives are  not likely to
attract  any  new permanent  residents to  the  study area.   These positions
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would be filled by workers from the study area and surrounding  three-county
area.   Some  seasonal residents  may reduce time  spent  In their study area
home  while  construction  of  on-site or sewer  systems  occurs on their pro-
perty.   No  significant demographic impacts  will  occur during  construction
of wastewater facilities.

4.1.1.8.  Economics

     The construction  of  wastewater treatment facilities under the "build"
alternatives would create a limited number of short-term construction jobs.
Masons,  pipefitters,  heavy equipment  operators,  electricians, truck dri-
vers,  plumbers,  roofers, painters,  and  carpenters  would  be  among  the
tradesmen necessary  to complete  construction of  the  proposed facilities.
Most jobs would be filled by persons living within the study area or within
a reasonable commuting distance of the study area.

     The purchase of construction materials from study area merchants would
benefit  the  local  economy.   However,  few firms offering materials required
for  the  construction of  wastewater facilities are  established within the
study  area.   Thus, most  materials  would  be  imported  from  outside  of the
study area.   Purchases  made  by construction  workers within  the study area
also would benefit the local economy.  These purchases would likely be for
fuel, food,  and clothing.  Patronage may be reduced for some business along
sewer  lines  when road   closings  and  disruptions  occur.   No  significant
economic impacts are anticipated to occur during the construction of waste-
water facilities under any of the alternatives.

4.1.1.9.  Recreation and  Tourism

     Any increase or decrease of tourism and the use of recreational facil-
ities, within the  study  area,   attributable  to the  construction  of  waste-
water  facilities  is dependent  upon construction activities which detract
from  study  area recreational  amenities.   Most recreational activities in
the  study  occur on  or  along  the  perimeter  of  the  lakes.   No major air,
water, noise, or traffic  impacts are expected to occur near the lakes which
would  interrupt tourism  and  recreation  activities.   Access to recreation
                                    4-8

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facilities  interrupted  by construction activities may  curtail some recre-
ation and  tourist  activities.   However, these  impacts  are not anticipated
to be significant.

4.1.1.10.  Transportation

     Increased truck  and  grading  equipment traffic during the construction
of  wastewater treatment  facilities under  the "build"  alternatives would
increase street  congestion.   Vehicular traffic would be inconvenienced by
excavating, grading,  backfilling,  and  temporary  road closures during con-
struction  of  conveyance  lines  along roadways  under  Alternatives 2-7, 8A,
8B,  and  10.   The   inconvenience  experienced  during  these periods  is not
anticipated to be significant.

4.1.1.11.  Energy Resources

     Residential,  commercial,  and  industrial  energy requirements  are not
likely  to  be  affected  during  the  construction  of  wastewater  facilities
under any  of  the   alternatives.   Active  competition  for  specific energy
sources would  become  apparent  if  a national fuel crisis reoccurred  such as
the  one  precipitated  by the  oil embargo of  1977.  Trucks and construction
equipment used during the construction of wastewater treatment  facilities
would increase demand for local supplies of gasoline and diesel fuel.  The
highest  demand created by trucks  and  construction equipment  would occur
under Alternatives 6 and 7.  The lowest energy demand created by trucks and
construction  equipment  would occur  under  Alternatives  8A, 8B,  9,  and 10.
No significant demands on  local energy  supplies are anticipated during con-
struction of wastewater facilities under any of the alternatives.

4.1.1.12.  Cultural Resources

     Archaeological data  for the study  area are unprocessed and not  readily
available  (Section  3.2.8.).  Three structures in the study area are listed
on  the Michigan  Register  of  Historic Sites.   Fourteen  additional sites of
architectural  significance  were   identified  by  WAPORA personnel  in 1979
(Section 3.2.8.).  Because no research  has been completed, it  is impossible
                                    4-9

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to assess adverse impacts attributable to construction activities which may
affect  historic,  archaeological,  and  architectural  sites    (By  letter,
Martha  M.  Bigelow,  Director, Michigan History  Division and State Historic
Preservation Officer, to WAPORA, Inc., 8 January 1979).  Final routings and
WWTP sites  should  be presented to the SHPO for assessment before construc-
tion activities  begin.   Construction excavations could uncover significant
cultural resources which otherwise might not be found.  To provide adequate
consideration of impacts affecting these resources an archaeological survey
of specific  sites  should be conducted following the selection of an alter-
native .

4.1.2.  Operation Impacts

     Each of the alternatives, including the No Action Alternative, involve
operations that  will  continue through the project period.  Included in the
definition of operations are constructing new  septic  tank  systems  for new
structures  and   upgrading  on-site systems  that  fail  under the  No  Action
Alternative and  Alternatives 8A,  8B, 9, and 10.  The impacts are addressed
for each of  the  major categories of the natural and man-made environments.

4.1.2.1.  Atmosphere

     The potential  emissions from the operation  of  the wastewater manage-
ment alternatives include  aerosols,  hazardous gases, and odors.  The emis-
sions pose the potential of a public health risk or nuisance.

     Aerosols are  defined as  solid  or  liquid  particles, ranging  in  size
from 0.01 to 50 micrometers that are suspended in the air.  These particles
are produced  at  wastewater  treatment  facilities during  various treatment
processes.    Some of  the  constituents  of aerosols could  be  pathogenic and
could cause respiratory and gastrointestinal infections.  Concentrations of
bacteria  or  viruses  in aerosols,  however,  are generally  insignificant
(Hickey and  Reist  1975).  The vast majority of the microorganisms in aero-
sols ire destroyed by solar radiation, desiccation, and other environmental
phenomena.   There are no records of disease outbreaks resulting from path-
ogens present in aerosols.  Therefore, no adverse impacts are expected from
aerosol emissions for any of the alternatives.
                                    4-10

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     Discharges  of  hazardous  gases  could have  adverse affects  on public
health and the environment.  Explosive, toxic, noxious, lachrymose  (causing
tears),   and  asphyxiating  gases can  be  produced  at  wastewater  treatment
facilities.   These  gases  include  chlorine,  methane,  ammonia,  hydrogen
sulfide,  carbon monoxide,  nitrogen  oxides,  sulfur, and  phosphorus.   The
knowledge of the possibility that such gases can escape from the facilities
or into work areas in dangerous or nuisance concentrations might affect the
operation of the facilities and the adjacent land uses.  Caseous emissions,
however,  can be  controlled by  proper  design,  operation,  and maintenance
procedures.

     Odor  is a property  of a  substance  that affects  the  sense  of smell.
Organic material that contains sulfur or nitrogen may be partially oxidized
anaerobically and  result  in  the emission of byproducts  that  may be malo-
dorous.   Common  emissions,  such as hydrogen sulfide and ammonia, are often
referred to  as  sewer  gases and have odors  of rotten eggs and concentrated
urine,  respectively.  Some  organic acids,  aldehydes, mercaptans,  skatoles,
indoles, and  amines  also may be odorous,  either  individually  or in combi-
nation with other compounds.  Sources of wastewater  treatment related odors
include:

     •    Fresh, septic, or incompletely treated wastewater
     •    Screenings, grit, and skimmings containing septic or putres-
          cible matter
     •    Oil, grease, fats, and soaps from food handling enterprises,
          homes, and surface runoff
     •    Gaseous  emissions from  treatment  processes,  manholes, wet
          wells, pumping  stations,  leaking containers, turbulent flow
          areas, and outfall areas
     •    Raw or incompletely stabilized sludge or septage.

Wastewater stabilization lagoons typically emit considerable odors when the
ice cover  goes  out  in the  spring.  These odors are  likely to be noticeable
for at  least one-half mile in  the wind  direction.   Odors from septic tank
effluent sewers  may  escape from lift stations where turbulent flow occurs
unless  proper  design  steps are taken to minimize odors.  Sewage may become
septic  and odorous  in the  lengthy force mains that  are part of some alter-
natives, especially during  the  low-flow winter season.
                                    4-11

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     The  occasional  failure  of  an on-site  system  may release some  odors.
Septage  haulers using  inadequate  or improperly maintained  equipment may
create odor nuisances.

4.1.2.2.  Soils

     The  operation of  the  land application  site  and cluster  drainfield
sites  for wastewater treatment  would alter the  soils of these  sites over
the life  of the project.  The potential changes depend on  the existing soil
chemical  and  hydraulic  properties and on  the  chemical characteristics and
application rate  of the  effluent.    The cropping and tillage practices on
the land  application  sites  will, to  some extent, effect  the changes  in the
soil.

     The  chemical  and  physical  properties of typical  soils of  the area are
given  in  Appendix G  of the  Draft  EIS and a report by Ellis and Erickson
(1969).   The  pR,  cation exchange capacity,  and  phosphorus retention capa-
city are  adequate  to  insure that most constituents  in the effluent will be
removed effectively at  the proposed irrigation rates.

     Organic constituents in the applied water would be oxidized  by natural
biological  processes  within  the  top few inches  of  soil  (USEPA  and  others
1977).  At  Muskegon,  Michigan  the  BOD of renovated water from  the  under-
drainage  system ranged from  1.2 mg/1 to 2.2 tng/1   (Demirjian 1975).  Sus-
pended  solids  in   the applied water  also  are removed by the soil through
filtration.   The  volatile solids  are biologically  oxidized  and inorganic
solids become part of the soil matrix (USEPA and others 1977).

     Phosphorus would  be  present  either in a storage pond  or septic tank
                                                                    _2
effluent  in an  inorganic form  as  orthophosphate  (primarily  HPO   ),  as
polyphosphates  (or condensed  phosphates),   and  as  organic  phosphate com-
pounds.   Because  the pH  of  wastewater  is  alkaline,  the  predominant form
usually is orthophosphate (USEPA 1976).  Polyphosphate is  converted quickly
to  orthophosphate  in  conventional  wastewater  treatment,  in  soil,  or  in
water.   Dissolved  organic   phosphorus is  converted  more  slowly  (day  to
weeks) to orthophosphate.
                                    4-12

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     When  effluent  is  applied  to soils,  dissolved  inorganic  phosphorus
(orthophosphate) may be adsorbed by the iron, aluminum, and/or calcium com-
pounds,  or  may be  precipitated through  with  soluble  iron,  aluminum,  and
calcium.   Because  it  is  difficult to  distinguish between  adsorption  and
precipitation  reactions,  the term  "sorption"  is utilized  to refer to  the
removal  of  phosphorus  by  both processes  (USEPA  and  others  1977).   The
degree  to which  wastewater phosphorus  is sorbed  in soil depends  on  its
concentration,  soil  pH,  temperature,  time, total  loading,  and the concen-
tration  of  other  wastewater constituents  that  directly  react  with phos-
phorus, or that affect soil pH and oxidation-reduction reactions (USEPA and
others 1977).

     The  phosphorus  in the  adsorbed  phase  in  soil  exists  in equilibrium
with  the  concentration   of  dissolved  soil phosphorus  (USEPA and  others
1977).   As  an  increasing  amount of existing adsorptive  capacity  is used,
such as  when  wastewater  enriched with phosphorus is applied, the dissolved
phosphorus concentration  similarly will be increased.   This  may  result in
an increased  concentration  of  phosphorus in the percolate, and thus in the
groundwatec or  in the recovered underdrainage water.

     Eventually, adsorbed phosphorus  is  transformed into  a crystal!ine-
mineral  state,  re-establishing  the adsorptive  capacity  of  the  soil.  This
transformation  occurs slowly,  requiring  from  months  to years.   Work by
various  researchers  indicates  that as much as 100% of the original adsorp-
tive capacity  may  be recovered in as Little as 3 months.  However, in some
instances  it  may take  years for the adsorptive capacity to fully recover
because the active cations may become increasingly bound in the crystalline
form.   The  possible  amount of phosphorus  that  could precipitate  to  the
crystalline form,  based on  a   2%  to  4% iron and 5%  to 7.5% aluminum soil
content,  is estimated to  be 250,000 pounds  of  phosphorus per acre-foot of
soil (Ellis and Erickson 1969).

     Dissolved  organic  phosphorus  in  applied  wastewater  can move quickly
through  the   soil  and enter the  groundwater.   Adequate  retention  of  the
wastewater in the  unsaturated  soil zone  is  necessary to allow enough time
for the organic phosphorus to be hydrolized by microorganisms to the ortho-
phosphate  form.  In  the  orthophosphate   form,  it  then  can  be  adsorbed.
                                    4-13

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     A limited phosphorus sorption test was conducted following the method-
ology utilized  by Enfield  and Bledsoe  (1975).   The data  from this 5-day
test for samples from the study area indicate a range of phosphorus adsorp-
tion values  of  from  62 rag/kg to 371 mg/kg.  The adsorptive capacity of the
soils apparently decreases  with depth.   This  reflects the  lower organic
matter content and reduced soil development with increasing depth.

     The surface soil of  the loamy  sands sampled  (up  to  approximately 5
feet) has  an average  phosphorus adsorptive capacity  of approximately 165
mg/kg.  The  underlying  material  below 5  feet was  not  extensively sampled,
and no  samples  were  taken from  below  a  depth  of 68 inches.  Assuming that
soil forming  processes  are  less and the  grain-size  is  larger at depths in
excess  of  5  feet, a conservative estimate  of 50  mg/kg for  a  5-day test
equivalent value appears reasonable.  Enfield and Bledsoe (1975) determined
that phosphorus  sorption after  a  4-month test period was  from  1.5 to 3.0
times the  5-day  sorption value,  reflecting  a more  steady-state approxi-
mation.   An  approximation  for long-term  sorption would be greater, a value
of 3.5 was used  in this study.

     Based on similar analyses  (Ellis and Erickson  1969),  the  study area
soils should have adequate  sorption  capacity  for phosphorus  where  drain
beds of current design are constructed.   The water quality sampling results
appear  to  verify it.   Because dry wells  result in  a  considerably smaller
soil mass  being  contacted by the percolating effluent as compared to drain
beds and drainfields, the soil material would become saturated more quickly
with phosphorus.  Also,  the  dry well introduces effluent lower in the soil
profile where the sorption capacity of soils is generally lower.  Ellis and
others  (1978)  recommended   that dry  wells  be  discontinued  from further
application for that reason.  Increases in phosphorus levels in groundwater
over time  can be expected,  although the  specific increases would be highly
variable,  and minimal where the residence  is occupied seasonally.

     The alternative  that  incorporates land application of lagoon effluent
for treatment would  result  in increased  levels of phosphorus in the soils.
Irrigation onto  the  soil  surface utilizes the surface soil for sorption of
phosphorus.   These  surface soils  have considerably greater  sorption cap-
abilities than the underlying soil (Appendix G of the Draft EIS).
                                    4-14

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     Nitrogen loadings in the wastewater are of greatest concern.  Nitrogen
would be  present  in applied wastewater principally in the form of ammonium
(NH ), nitrates (NO ), and organic nitrogen.  When wastewater is applied to
soils, the natural supply of soil nitrogen is increased.  As in the natural
processes,  most  added  organic  nitrogen  slowly  is  converted  to  ionized
ammonia by  microbial  action  in  the  soil.   This  form  of  nitrogen,  and any
ionized ammonia in the effluent, is adsorbed by soil particles.

     Plants  and soil  microbes  both  utilize ammonium  directly.   Microbes
oxidize ammonium  to  nitrite (NO )  that is quickly converted to the nitrate
(NO ) form  through nitrification.  Nitrate is highly  soluble  and  is uti-
lized  by  plants,  or  leached  from the  soil  into the  groundwater.   Under
anaerobic conditions   (in the  absence of oxygen), soil nitrate  can  be re-
duced by  soil  microbes to gaseous nitrogen forms  (denitrification).  These
gaseous forms  move upward  through the soil atmosphere  and are dissipated
into  the  air.   Denitrification depends  on organic  carbon for  an  energy
source;  thus,  the  interface between natural soil  and  the gravel fill in a
drain bed has both requisite characteristics for denitrification.

     Unlike phosphorus,  nitrogen is  not stored in soils  except in organic
matter.   Organic  matter  increases  within  the soils would  result from in-
creased  microbial  action  and   from  decreased  oxidation.   The  increased
organic matter  improves  the soil tilth (workability), water holding capac-
ity, and capability of retaining plant nutrients.

4.1.2.3.  Surface Waters

Nutrient Loads to Lakes and Rivers of the Study Area

     A major water quality concern in the study area is the acceleration of
eutrophication  in  the  lakes.  Two important nutrients in the eutrophication
process are nitrogen  and phosphorus  (Zevenboom and others 1982) with phos-
phorus usually  recognized as the most  important  (Smith and Shapiro 1981).
To  evaluate  the  impact  of  the  alternatives,  nutrient loading  levels for
phosphorus were calculated.  Changes in phosphorus  loadings  due to waste-
water management  alternatives are  presented in  Table 4-1.   These changes
                                    4-15

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reflect the  percent  increase or decrease of phosphorus  loading  compared  to
the current loading rates estimated in Section 3.1.3.1.

     If the  No Action  Alternative were implemented  in  the study area the
phosphorus loading to  all lakes would increase  compared to present condi-
tions  (Table  4-1).   The  increase is based  on  future population estimates
around  Indian  Lake  and  Sister Lakes.   An  increased  population would use
additional on-site  systems,  resulting  in  greater  phosphorus  loads to the
lakes.  Alternatives  2-7 offer the largest  percent decrease in phosphorus
lo'ids to  the  lakes.   There would  be  a  14%  reduction  of phosphorus loading
to  Indian Lake under these alternatives.  A centralized collection system
effectively  eliminates phosphorus loads associated  with  on-site systems.
Crooked Lake  would  experience the largest  percent  decrease.  Alternatives
8A, 8B, 9, and 10 would  produce  results similar to  the reduced phosphorus
loads associated  with  the alternaives using centralized collection systems
for  several  reasons.   Jones  and  Lee  (1977)  demonstrated  that  a properly
designed  and   installed  septic tank  drainfield  could  remove  nearly  100%
Table 4-1.  Comparison of phosphorus loading rates associated with the vari-
            ous alternatives to the current loading rates.

Lake
Cable
Crooked
Dewey
Indian
Magician
Pipestone
Round
No
Alternatives
Action
5%
8%
2%
2%
4%
1%
5%
increase
increase
increase
increase
increase
increase
increase
2-7
29%
45%
11%
14%
25%
5%
27%
decrease
decrease
decrease
decrease
decrease
decrease
decrease
Alternatives
8A-10
26%
39%
10%
13%
22%
4%
24%
decrease
decrease
decrease
decrease
decrease
decrease
decrease
                                    4-16

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of the phosphorus load from the septic effluent.  It was assumed for Alter-
natives 8A, 8B, 9, and 10 that upgrading existing on-site systems and plac-
ing critical areas on a cluster collection system or on holding tanks would
result in  a  90% decrease in the  phosphorus  load from on-site systems com-
pared to present conditions.

     The changes in phosphorus loading imposed by various wastewater alter-
natives could  affect the  trophic status  and  management considerations of
some  of  the lakes in the  study  area.  Current  trophic  status  is based on
secchi disc  readings,  chlorophyll  a, and phosphorus  concentrations (when
available; Section 3.1.3.1.).  Future trophic conditions will be influenced
by in-lake phosphorus  concentrations,  which are a  function of  the phos-
phorus load and other physical-chemical characteristics of each lake basin.
It appears the  "build"  alternatives  (Alternatives  2-7) would  reduce  the
phosphorus  load  so that  water quality would be  enhanced  for three lakes;
Cable, Crooked,  and  Round.   Some improvement in Magician  Lake may occur.
However,   Indian  Lake,  Dewey  Lake,  and Pipestone Lake  would likely remain
eutrophic  (Figure 4-1).   Implementation of Alternatives 8A,  8B, 9, or 10 is
predicted  to  have effects  similar  to Alternatives  2-7  (Figure 4-1) .  The
information  plotted  on   Figure  4-1  should  be  interpreted  with  caution.
Phosphorus loads and lake response is based on information currently avail-
able.  In  addition,  the  management  schemes  (Figure  4-1)  have assumed that
lake basins and the biological lake components respond in similar fashions.
This is not always the case.  Phosphorus dynamics and biological production
will  be  greatly  affected  by  unique  factors  occurring  within  each lake
basin, which are unquantified at this time.

     Some  rivers  of  the  study area would be directly impacted by discharge
of wastewater  effluents  to a receiving stream under Alternatives 2, 4, 5A,
5B,  6,  and 7  which  include  collection  sewers  and  centralized treatment.
Release of the treated  wastewater effluent  from the stabilization  lagoons
would occur between  1  March and  15 May  annually.  The release rate during
this period is designed to cause minimum impacts.
                                    4-17

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CO
o
X
0.
Ill
>
o
<
>
-J
o
i
01
r
o
o




















High Phos.
Loading
0.55 _
0.45 _
0.35 _
0.25 _



C
-2-»
0.20 _
0.19 _
0.18 _
0.17 _
0.16 _
IE 0.15 _
0» 0.14 _
0.13
0.10
0.07

0.06 _
0.05 _
0.04 _
0.03 _
0.02 _
0.01 _


Low Phos.
Loading
s^





Cable A
1
\



A



Legend
• present conditions
O Alternatives 8-10
^Alternatives 2-7

I I I I
Pipestone


DDewey.
*




i,^^
Indian.


Magician i \



Crooked i •
•Round
i
< ^
_ — jp — ________
B








i
{T




















8.0 7.0 6.0 5.0 4.0 3.0 2.0 1.0 0
(Oligotrophic) Secchi (Eutrophic)
(meters)
A. No nutrient abatement steps necessary.
B. Strong renewal potential; long term benefits may be possible without
extensive nutrient abatement.
C. Prompt action needed; degradation may be imminent if nutrient abatement
steps are not taken.
D. Problem lakes; renovation desirable but lasting improvement may require
extensive nutrient abatement.
Figure 4-1.  Future phosphorus loading conditions for the centralized waste-
             water management alternatives (Vollenweider 1979; Uttormark and
             Wall 1975).
                                  4-18

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     The  nutrient  loads discharged  to Indian Lake  outlet  or Silver Creek
coincide  with  high stream  flows  of  this time of  year;  thus, the nutrient
loads  would be  assimilated  by  the  streams.   Slightly  elevated nutrient
levels should  not  be  detrimental to the  ecology  of  the receiving streams.
Increased discharges  to Dowagiac Creek from the  Dowagiac  WWTP would occur
under  Alternatives  6  and  7.   The  increased  continuous  discharge  would
affect Dowagiac Creek to some extent, although the assimilative capacity of
the Creek was  calculated when the effluent  limits were set.  The Dowagiac
River, a  cold  water stream, would be affected to  some extent by any of the
wastewater  treatment  alternatives that have discharges  to surface waters.

Coliform Bacteria Levels in Lakes and Rivers

     Data regarding bacterial  contamination  of the lakes in  the study area
are  somewhat  inconclusive.   Bacterial  sampling  efforts usually  have  in-
volved one sample at each station for a single date.   Federal Water Quality
Regulations  require  that violations  of standards  be based on the geometric
mean of a minimum of five samples.

     Continued  reliance on existing  systems   (No Action  Alternative)  in
areas  of  high water  tables (e.g.,  Pipestone Lake)  has  potential for bac-
terial contamination.   For the  "build" alternatives,  the  wastewater man-
agement  alternatives  should  effectively  prevent   these  problems,  although
bacteria  contamination  problems  are  still a  possibility  with centralized
alternatives  in  case  of   pumping  station malfunctions  or  with  upgraded
on-site systems in case  of  surface ponding of the  effluent.

     Land application of wastewater  (to be considered under  Alternative 3)
is an  effective  way of  eliminating or immobilizing sewage-borne pathogens.
In fine-textured  soil,   bacteria  can be  filtered  out by  1  to  2 meters of
soil.   Soils  containing clay remove  most  organisms  through  adsorption.
Sandy soil removes them  through filtration (Lance  1978).

Suspended Solids and Organic Carbon Levels in Lakes and Rivers

     Alternatives implementing on-site systems (Alternatives  8A, 8B, 9, and
10)  should   effectively remove  suspended solids  from  the  wastewater  ef-
                                    4-19

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fluent.   Dissolved  organic  substances  may move  with the groundwater  into
the  lakes.   In the  study area  lakes  the  septic  leachate survey detected
groundwater  plumes  in  each  of the  lakes.   The groundwater plumes  contain
dissolved organics and  salts as components.  Dissolved organics will exert
a  BOD resulting  in  the  consumption  of  dissolved  oxygen within  a lake.
Within a  properly maintained  on-site  system,  BCD  movement to lake waters
should be insignificant.

     Centralized  collection  and treatment  alternatives that use receiving
streams for  discharge of treated  wastewater  effluents (Alternatives 2,  4,
5A,  5B,  6,  and 7) have the  discharge timed  for  release  during the spring
runoff period.  The  waste stabilization  lagoons are designed to meet State
and  Federal  discharge  standards.   Suspended  solids  and dissolved organics
are  expected to  exert  a BOD  in  the  receiving stream that  could   depress
dissolved oxygen  levels.   But most  of the  residual  BOD and ammonia should
be  oxidized  in the  respective  streams.   Increased  effluent discharge  from
the Dowagiac WWTP to Dowagiac Creek  in Alternatives 6  and  7 would result  in
increased suspended solids and dissolved  organic loadings.  These should  be
within the discharge  standards for  the stream  if the  plant is designed and
operated  properly.   Chlorination  of the effluent  from the Dowagiac plant
may  result  in chlorinated organics  (e.g.,  trihalomethanes)  that are known
to be carcinogenic.

     Lake water levels may decline slightly with the centralized collection
alternatives  because  water  would  be exported  from  the basin.   Only Pipe-
stone  Lake  has a continuous surface  water discharge  and Indian Lake and
Magician  Lakes  have  intermittent  discharges.  The  groundwater  inflow and
outflow of the  lakes,  which  cannot  be quantified with present information,
does  not  appear to  be  large  for  any  of the  lakes;  thus,  export  of  lake
water  could  potentially lower lake  levels  slightly.   Assuming no change  in
inflows and  outflows,  a  volume of  water equivalent  to  2 inches of water
would  be  exported from the  Sister  Lakes  during  the  summer.   The signifi-
cance  of  this export volume depends  on  the inflow-outflow relationships,
the  configuration  of the  shorelines,  and  the  total  volume  of the lakes.
Because the  requisite  information  is  not  available,  the  impact  of these
potential water level declines cannot be  assessed.
                                    4-20

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4.1.2.4.  Groundwater

     Long-term  impacts  that could be encountered  in  the operational phase
of  any of  the  alternatives  concern  the following  types  of  pollutants:
bacteria, dissolved organics and suspended solids; phosphorus; and nitrate-
nitrogen.  Movement  to  groundwater of other  wastewater  constituents or of
soil  chemicals  would occur,  but are not  expected to significantly affect
any of the uses of the groundwater.

     Bacteria and  dissolved organics are readily  removed by filtration and
adsorption onto  soil particles.   Two feet of  soil material  is  generally
adequate  for  bacterial  removal,  except  in  very coarse-grained,  highly
permeable soil  material.   Contamination  of drinking water wells or  surface
water  with  bacteria and  dissolved organics  in the study  area is unlikely
under any of the alternatives.

     Phosphorus  is  significant  in groundwater because it can contribute to
the  excessive  eutrophication of  lakes.   Section  4.1.2.2.  contains a dis-
cussion of phosphorus  sorption  in soils  and  supports the  conclusion that,
except  for  dry well  soil absorption  systems,  phosphorus  contributions to
the groundwater from any oi. the alternatives would be minimal.

     The  ability  to predict phosphorus  concentrations  in  percolate waters
from  soil treatment  systems has not  yet  been demonstrated  (Enfield 1978).
Models  that  have been  developed for this purpose have  not  yet been eval-
uated  under  field conditions.   Field studies have shown  that most soils,
even  medium  sands,  typically  remove in  excess   of  95% of phosphates in
relatively  short distances from  effluent sources  (Jones  and  Lee 1977) .

     One potential  source  of  phosphorus inputs to groundwater are the soil
absorption systems  included in  the  No Action Alternative  and Alternatives
8A,  8B,  9, and 10.  The groundwater  quality analyses performed in conjunc-
tion with the "Septic Snooper" survey (Appendix B  of  the Draft EIS)  confirm
that  some phosphorus  is reaching the lakes by way of the groundwater.  The
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majority  of  groundwater plumes  sampled,  though,  had phosphorus concentra-
tions  less  than  0.02 mg/1  (25 out  of  33 effluent-related  plumes).  The
contribution of phosphorus  to the lakes  from  on-site systems has not been
quantified from  the sampling  data,  but  from  theoretical data.   Thus, on-
site systems are  likely stimulating algal growth  in localized areas where
effluent  plumes  emerge, but  their contribution  to  lake eutrophication is
not quantifiable.   The greatest  quantity of phosphorus would be contributed
to groundwater under  the No Action Alternative.   A  slight amount of phos-
phorus would be contributed to  the groundwater under the alternatives that
continue to rely on on-site systems.

     Alternative 3, which  incorporates land application  of lagoon effluent
is not  expected  to significantly  increase the  phosphorus concentration in
the groundwater.   Irrigation  onto the soil surface  results in utilization
of the  complete  soil  profile for sorption in  contrast  to on-site systems
which utilize  oaly the  subsoil.  Phosphorus  in  groundwatec  under  a land
application  site   is  of concern only  when  surface  waters  are  affected.
Groundwater  from   the  site would  likely flow  primarily to  the  west,  but
partially to the Sister Lakes.

     The  wastewater  stabilization lagoons which  are  components  of  all of
the centralized  alternatives, except  Alternative 7,  may contribute phos-
phorus to the  groundwater  if  seepage  from the  lagoons is considerable.  A
study of  Minnesota wastewater stabilization  lagoons  (EA Hickok and Associ-
ates 1978) concluded  that  none of the ponds  (all  had natural soil liners)
were capable of meeting the designed and specified seepage rates.  Most of
the ponds studied  removed phosphorus effectively,  although some had seepage
rates considerably higher than the maximum allowable.

     Nitrates in groundwater  are of concern at concentrations greater than
10 mg/1  as  nitrogen  because  they cause  methemoglobineraia in  infants  who
ingest  liquids  prepared with  such waters.   This  limit  was set  in the Na-
tional Interim Primary  Drinking  Water Regulations (40 CFR 141) of the Safe
Drinking Water Act  (PL 93-523).   A general discussion of nitrogen in soils
is presented  in Section 4.1.2.2.
                                    4-22

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     The density  of  soil absorption systems is  said  to be the most impor-
tant  parameter influencing  pollution  levels  of  nitrates in  groundwater
(Scalf and  others 1977).  That source also  notes,  however,  that currently
available  "information  has not been  sufficiently  definitive  nor quantita-
tive  to  provide  a basis  for  density  criteria."   The potential  for  high
nitrate concentrations  in  groundwater is greater in areas of multi-tier or
grid  types  of residential  developments than  in single tier developments.
Depending on  the  groundwater  flow direction  and  pumping rates  of wells,
nitrate contributions from soil absorption systems may become cumulative in
multi-tier  developments.   Thus,  separation  distances  are  critical for new
construction  and  maximum density  codes are crucial  for  new subdivisions.

     The groundwater  sampling  results  (Section  3.1.3.2.) from wells  show
that elevated  nitrates  (greater  than 4 mg/1 as nitrogen)  occurred  in 11 of
the  60 wells  that were sampled.   Some of these  wells  appeared  to  have
sources of  nitrates other  than  soil  absorption systems,  particularly the
wells  on  Keeler  Lake.   Other  values  (two  were  greater  than 20 mg/1)  may
indicate direct   pollution  from   the  surface  or anomalous  sampling error
because the wells are 45 and  46  feet deep.   None  of  the  wells which were
sampled under the auspices  of the Van  Buren  County  Health  Department had
nitrates present  that  exceed  the limit  (By interview, Linda  Surlow,  Van
Buren County Health Department, to WAPORA, Inc.  15 July 1981).

     These  high   levels  of  nitrate  would perpetuate  under   the  No Action
Alternative and increased violations of  the  drinking water quality  standard
would occur.   The alternatives that include continued  use of on-site  sys-
tems and cluster  systems may not necessarily result in declines in concen-
trations of nitrates  in the groundwater.  Wells that continue  to have high
nitrate concentrations   may  need  to  be  deepened  so  that a  hydraulically
limiting layer is penetrated.

     Cluster  drainfields are  designed  similarly to individual drainfields
to ensure an  adequate areal distribution of the effluent for  satisfactory
removals  of  phosphorus.   Nitrate concentrations  within the  groundwater
below a cluster drainfield are anticipated  to be equivalent  to those below
an  individual soil  absorption  system.   Insufficient  experimentation has
been conducted to enable designing for  nitrogen removals  from septic tank
                                    4-23

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effluent.   One  precaution  would  be  to  locate the  drainfield as far  from
wells  as feasible.   Once  nitrates enter  the  groundwater,  dilution is  the
only practical means  of reducing the  concentration.

     Lagoon effluent  typically contains nitrogen  levels of approximately 12
mg/1  (Urie  1979;  Urie and  others  1978).   Nitrates  in  the groundwater below
the land application  sites  probably would  average considerably less  than 10
mg/1, the drinking water quality standard.  Volatilization, crop uptake  and
removal,  soil storage,  and denitrification  would  account for removal  of
nitrogen from the applied effluent.   Some  increase  in  nitrate  concentration
above background  levels  is anticipated, but no significant adverse  impacts
on the environment or proposed use is anticipated.

     Seepage from the wastewater stabilization lagoons could result  in  ele-
vated nitrate levels  in the groundwater below  the lagoons.  Clay liners  are
not impermeable and  plastic liners can be punctured or experience deterio-
ration.   Field  studies  (EA hickok and Associates  1978)  have  shown that a
seepage  rate  of  500 gallons per acre per  day is very difficult to  achieve
even  on  in-place,   fine-textured  soils.   On  medium-  to  coarse-textured
soils,  the  quality  of  the liner  is  of utmost  concern  for  protection  of
groundwater  quality.  Monitoring  wells are   to  be  installed as  part  of
lagoon  construction  and these are to be  sampled on  a regular basis.   The
sampling  program  would identify problems  before  neighboring   residents  are
affected.

     Changes  in groundwater levels would  occur with the centralized alter-
natives.  Export  of  water  from  the  lakeshore areas  where  it  is typically
recharged to  the  wastewater treatment  system  would change  the groundwater
levels  slightly.   The greatest  change in  groundwater  levels would occur  in
the vicinity  of  the  land  application  site.   Inadequate  data have  been
assembled to accurately predict the water  table rise.  The water table rise
would affect  not  only the  land application site,  but also the surrounding
area and  the  normal  outflow areas.   Either draintile  or recovery wells  on
the land  application area  would  prevent the water  table from  rising to  the
surface, if it is shown to be necessary through further studies.
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4.1.2.5.  Terrestrial Biota

     The  land  treatment  site proposed  in  Section  8 under  Alternative 3
would  affect  the  terrestrial biota  during  plant  operation,  however,  no
significant adverse long-term effects would be expected during normal plant
operating conditions.   Wildlife  may  avoid  the area  during waste applica-
tion.   Periodic  monitoring should  be performed to detect  the presence of
potentially harmful concentrations of heavy metals,  other toxic substances,
or inicronutrients in the soil, crops, or other vegetation.

4.1.2.6.  Land Use Impacts

     The  land use  conversions discussed in  Section 3.2.2.  would remain in
effect  for  the  operation  of  the proposed  wastewater treatment facilities
under  the "build"  alternatives.    Land  use  under  the easement  of sewage
conveyance  lines  would be   intermittently  affected  when maintenance  or
repairs were performed  on  sections  of the  lines.   Periodic excavating and
filling  would  disturb  vegetation  and  soil  along  conveyance  lines.   The
release of  low  level  odors and aerosols  from WWTPs  and the knowledge that
hazardous gases could  potentially be released from those plants may affect
land  use adjacent  to  the  plants.    Improper maintenance  of  cluster  and
on-site  systems may  create  malodorous  conditions  which  would  adversely
affect adjacent land uses.

4.1.2.7.  Demographics

     The  operation  and  maintenance  of wastewater facilities proposed under
the  "build"  alternatives will not  have a significant  impact  on the demo-
graphy  of the  study  area.   A limited number  of  long-term  jobs created by
the operation and  maintenance of these facilities likely will be filled by
persons  living within  the  study  area or within commuting distance.  No new
residents  are  expected  to  be attracted  to  the  study  area to  fill these
positions.
                                    4-25

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4.1.2.8.  Economics

     The operation of wastewater facilities under Alternatives 2,  3, 4, 5A,
5B, and 6 would create a few long-term jobs.  These jobs could be  filled by
persons residing  in  the  study area.   No  new jobs  would  be created under
Alternative  7.   The  existing staff  at the  Dowagiac  WWTP  is  expected to
assume  any  additional responsibilities as  a  result  of implementing Alter-
native 7.

     No new  jobs  are anticipated to  be  created  under  Alternatives 8A, 8B,
9, or  10.    Existing  contractors are expected to  satisfy  local demand for
construction and maintenance  services of on-site systems.   Contractors and
tradesmen involved  in the construction and maintenance  of on-site systems
will suffer a loss of work opportunities within the study area under Alter-
natives 2,  3,  4,  5A, 5B,  6,  and 7.   These  contractors  and tradesmen are
likely to compete for work opportunities in neighboring areas.  No signifi-
cant economic  impacts will occur during the operation of wastewater treat-
ment facilities under any of the alternatives.

4.1.2.9.  Recreation and Tourism

     The operation of wastewater facilities under any of the "build" alter-
natives could affect  tourist  and recreational activities in the study area
if a  malfunction of  those facilities  occurred.   A failure in the system
components of the  WWTPs  under Alternatives 2, 4, 5A, 5B, and 6 could cause
untreated or partially  treated  waste  to  be discharged  into  study  area
surface waters.  This phenomenon would result in  short-term water quality
degradation and a  reduction in the recreational use of that body of water.
Odors  emanating  from  malfunctioning on-site  systems  may  curtail outdoor
recreational activities in the near vicinity.

4.1.2.10.   Transportation

     Impacts arising  during the construction of  conveyance lines (Section
4.1.1.) would reoccur  when maintenance  or repairs are made on those lines.
Occasionally some  roads  may  be  closed temporarily.   Truck traffic  to and
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from  the  proposed  treatment  facilities  under Alternatives  2-7  will  be
associated with  supply deliveries.  Truck  traffic  associated  with repairs
and septage  hauling  will occur periodically under  Alternatives  8A, 8B,  9,
and 10.

4.1.2.11.  Energy

     The  operation of  wastewater  treatment  facilities and  pump  stations
under  the  "build" alternatives  require the use of  electricity  and fossil
fuels.   Alternatives  6 and  7  would require  the greatest  amount of these
energy sources, Alternatives 8A, 8B, 9, and 10 would require the least.  No
significant  demands would  be placed on local  energy supplies  under any of
the alternatives.

4.1.3.  Public Finance

     The total project  costs will be apportioned between the USEPA and the
local residents.   The  apportionment is made on the basis of what costs are
eligible  to  be  funded  by USEPA.   These   costs  for each  alternative are
presented  in Appendix N  of  the  Draft  EIS or Appendix  D.   The  local con-
struction  costs  and the  entire cost  of  system operation  and maintenance
will be  borne  entirely by the system users.  As discussed in Section 1.2.,
Federal  funding  through the National  Municipal  Wastewater Treatment Works
Construction Grants Program will provide funds to cover  75% of the  eligible
planning design,  and construction  costs of conventional wastewater treat-
ment  facilities.   "Innovative/alternative"  components  of  the   proposed
treatment  systems,  such as  pressure sewers,  septic tank effluent sewers,
septic  tanks,  and  soil absorption systems are  eligible  for  85% Federal
funding.   The  annual  residential user costs for each alternative are pre-
sented in  the  Table 4-2.  The detailed annual residential user cost analy-
ses with and without Federal Grant monies  are presented in Tables  N-ll and
N-12,   respectively in  Appendix  N of  the  Draft EIS and  in Table D-l  in
Appendix D.

     The annual  estimated  user cost for Indian  Lake alone has been calcu-
lated  and  is  shown  in  Table  4-3.  Costs  were  calculated only  for those
                                    4-27

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alternatives for  which  Indian Lake can be independent of the Sister Lakes.
Per  residence  costs for  Indian Lake  alone  are roughly  comparable to the
costs for the total project area.

     Wastewater  treatment  facilities  can  create  significant  financial
impacts  for communities  and  users  who  will  pay the  capital,  operation,
maintenance, and  debt costs  associated with  sewage  treatment facilities.
Two guidelines for determining the magnitude of these impacts are the State
of Michigan 10% of SEV general obligation bonding authority limit for local
governments and  the  USEPA  average  annual  user charge  to median family
income ratio (USEPA 1981).
Table 4-2.    Annual residential user costs for the entire project area
               and for Indian Lake alone.
                             Annual Cost per Residence

Alternative
2
3
4
5A
5B
6
7
8A
8B
9
10
With
Federal Grant
Project Area Indian Lake
$264.77
258.95
265.69
254.18
599.66
271.62
329.30
167.29
161.34
126.21
134.28
$281.27




313.67

182.21
162.92
120.97
125.62
Without Federal Grant
Project Area
$1,044.93
1,043.29
1,059.58
1,020.00
1,266.02
1,033.69
1,061.16
488.83
481.56
233.32
313.80
Indian Lake
$1,023.41




969.66

544.76
497.38
299.78
322.45
     Cass County would  assume  the local share of additional debt under any
of the "build" alternatives.  Berrien County and Van Buren County residents
would be billed user charges by Cass County under any of the "build" alter-
nat ive s.

     The debt  to state  equalized assessed valuation  ratio for  four  debt
scenarios,  which  include the  high-  and low-cost capital  shares  for sewer
and  on-site  systems are  presented in Table 4-3.   Under  the highest local
capital  cost scenario,   Alternative 5B,   Cass  County's debt would  rise
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Table 4-3.  Cass County debt as a percentage of state equalized assessed
            valuation under four local share capital cost scenarios.
                      High capital  Low capital  High capital  Low capital
                       cost sewer   cost sewer   cost on-site  cost on-site
                        scenario      scenario     scenario      scenario
                        (Alt. 5B)     (Alt. 7)     (Alt. 8A)     (Alt. 9)
                      $ 1,335,000
                       12,541,000
                       13,876,000
$ 1,335,000  $ 1,335,000
  3,722,900    1,452,600
  5,057,900    2,057,900
      $ 1,335,000
          968,400
        2,303,400
Existing debt 1980
Local capital share
Total debt
Total state equalized
 assessed valuation3  420,747,938   420,747,938  420,747,938   420,747,938
Ratio of debt to state
 equalized assessed
 valuation
State of Michigan
 general obligation
 bonding authority
 limit for local
 governments
                              3.3
        1.2
0.7
0.5
                              10%
        10%
10%
10%
 By telephone, Ms. Candy Copper, Cass County Treasurer's office, to WAPORA,
 Inc., 28 December 1981.
$12,541,000 over  its  1980  debt of $1,335,000 for  a total of $13,876,000.
Cass County's  debt to  state equalized assessed  valuation ratio under Al-
ternative 5B would reach 33% of the state of Michigan's general obligation
bonding authority  limit for  local governments.


     Under  the lowest  local  capital  cost  scenario,  Alternative  9, Cass

County's  debt   would   rise   $968,400  over  its  1980  debt   for  a  total  of

$2,303,400.  Cass  County's debt to state equalized assessed valuation ratio
under  Alternative  9  would  reach  5%  of  the  State  of Michigan's general

obligation bonding authority for  local governments.  Cass  County would not
approach  its   state  mandated  debt  limit  under   any  of the  alternatives.


     The USLPA considers projects  to be expensive and  as  having an adverse

impact  on  the finances  of  users  when average  annual user  charges are:
                                    4-29

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     •    1.0% of median household incomes  less than $10,000
     •    1.5% of median household incomes  between  $10,000 and  $17,000
     •    1.75% of median household incomes greater than  $17,000.

Median family incomes for Berrien, Cass and Van Buren Counties  are $19,200,
$18,600, and  $20,500,  respectively.   (By telephone, Mr.  John Maloney, Eco-
nomic Market  Analysis  Division, US Department of  Housing and Urban Devel-
opment, Detroit MI to WAPORA, Inc. 4 March  1982).

     Incomes  of  system  users residing in Van  Buren County may be somewhat
lower  than  $20,500 because  Van Buren County  is  included in the Kalamazoo
Standard  Metropolitan  Statistical  Area  (SMSA).   Wages  are  likely  to be
higher in the Kalamazoo metropolitan  area than  in Van Buren  County.  The
high wages paid in Kalamazoo tend to raise  the median family  income for the
SMSA as a whole.

     Average annual user charges expressed  as a percentage of median family
income for a household of four are presented in Table 4-4.  User fees under
Alternative 5B  surpass  suggested upper limit user  fees for system users in
all three counties.  Under Alternative 7, user fees surpass suggested upper
limit user  fees  for system users in  Cass  County.   Thus, some  system users
under  these  alternatives would  be financially adversely affected.   Alter-
native 9  offers the lowest  user fees for  system users  in  all three coun-
ties.  None  of the other  alternatives surpass  suggested upper limit user
fees as a percentage of median family income, indicating  that none of these
alternatives  would  be a  "high  cost" system that would  pose a significant
financial burden on system users.

     The  financial  stress on  low income  families  and the  local  share of
capital  cost  for  the  proposed  wastewater  facilities,   under  any of  the
"build" alternatives, may  be overstated in Tables  4-3  and   4-4 because of
the uncertainty of  how  Farmers  Home Administration (FmHA) grants and loans
might be applied.  Cass County may be eligible for a $1,200,000 grant and a
$1,000,000  loan  for 40  years at 5%  interest  from  the  FmHA (By telephone,
Mr.  Roy  Obreiter,  FmHA District  Office,  Hastings MI  to WAPORA,  Inc.  2
                                    4-30

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County
Berrien
1.38%
1.35%
1.38%
1.32%
3.12%
1.41%
1.71%
0.87%
0.84%
0.66%
0.70%
Cass
1.42%
1.39%
1.43%
1.37%fe
3.22%
1.46%,
n
1.77%
0.90%
0.87%
0.68%
0.72%
Van Buren
1 . 29%
1.26%
1 . 30%
1.24%b
2.93%
1.32%
1.61%
0.82%
0.79%
0.62%
0.66%
Table 4-4.  Average annual user charges for the "build" alternatives ex-
            pressed as a percentage of median household income for Berrien,
            Cass and Van Buren Counties.
Alternative

     2
     3
     4
     5A
     5B
     6
     /
     8A
     8B
     9
    10

a
 The USEPA considers a project expensive when average annual user charges
 exceed 1.75% of median household incomes greater than $17,000.

 The costs residents would pay under these alternatives would be considered
 expensive according to USEPA guidelines.
February 1982).   The  grant  and loan were  set  aside for wastewater facili-

ties around  Indian Lake.   Current  FmHA policy  does not  allow funding of
individual  systems ("private"  in  their  policy)  even  though  they  may be
publicly owned  (By telephone,  Paul Miller, FmHA,  to  Charles Quinlan, III,

USEPA,  11 April  1983).   Also,  the  policy  is  interpreted such  that cluster
systems, unless  they  served the entire area, are not eligible  for funding.

If  FmHA  grants  and  loans could be incorporated  into  the public financing

scheme   for  implementing  any  of  the  "build"  alternatives,  the financial

stress  on  study  area  low  income  families and  the  local share of capital

cost for the proposed wastewater facilities would be reduced.


4.2.  Secondary  Impacts


     Each of  the  alternatives,  including  the No Action Alternative, will

have effects that extend beyond primary or direct impacts.  These impacts,
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secondary impacts, would  occur because growth may occur as a direct result
of new wastewater treatment capacity or because changes in lake water qual-
ity may  occur.  The  categories that  may  experience significant secondary
impacts are described in the following sections.

4.2.1.  Demographics

     Wastewater management facilities historically have been a major factor
in determining the capacity  of an  area  to support  population growth and
development.   On-site  wastewater treatment  facilities,  although generally
available to any  potential user, limit development  to  areas  with suitable
soil  and  site  characteristics.  Sewer systems, while  not  always available
at a  specific  location or with  adequate capacity,  allow development to be
more  site  independent, since  soil,  slope,  and  drainage become  less  con-
straining design  parameters.   Consequently, the  construction  of sewers in
an area usually increases the inventory of developable land and the density
of development,  often  unleashing pent-up demand  for  or  encouraging growth
and development.

     This phenonmenon  is not  evident  in  the study area nor  is it antici-
pated to occur during  the planning  period.  Economic  factors  discussed in
Section 3.2.3.  which  follow  national,  state, and regional trends, outweigh
the incentive for growth which wastewater facilities provide.

     Population growth  in  the study area as discussed in Section 3.2.1. is
not  likely  to  be  significantly affected  by the selection  of any  of  the
alternatives.   The first  tier of sewers away from the lakes proposed under
Alternatives  2-7  would  provide service  to a  corridor  which  is  already
developed  and  where   few  lots  available   for  development exist.   Little
population increase is likely to occur in this corridor.  The cost to users
under Alternatives 2-7  may create  a financial burden for families with low
incomes.   This could  result   in displacement of these families  from  the
service area because they cannot afford user charges.

     The  selection of  Alternative  8A,  8B, or 10 would allow for the devel-
opment of  a  limited  number  of lots  which are  not suitable  for on-site
systems.   No signficant population increase is anticipated to occur.
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     Under Alternative  1  and  9,  population growth would occur as discussed
in Section 3.2.1.   The  projected conversion of seasonal  dwellings  to per-
manent homes would  continue.   Population increases would be dependent upon
the carrying capacity of  the  land available for  development.   No signifi-
cant population impacts would occur.

4.2.2.  Land Use

     Economic  factors  (Section 3.2.3.)  will have  a  greater influence than
the provision  of  wastewater facilities  (Section  4.2.)  in determining land
use for  the  study area during the planning period.  The location of waste-
water treatment  facilities and  sewer  systems under  Alternatives 2-7 will
affect patterns  of future  development.   Residential development would be
likely to occur along  sewer lines.  Because little  induced growth is pre-
dicted to occur, no significant land use impacts will occur.

     Under Alternatives 8A, 8B, 9, and 10 future development would be limi-
ted to  the carrying  capacity of  the  land.  Continued  and increased nui-
sances attributable to  failing on-site  systems in residential  areas would
make infill development of those areas less desirable.

Prime Agricultural Land

     Little prime agricultural  farmland  is likely to be  taken  out of pro-
duction  to  accommodate wastewater treatment facilities.   This  will result
in a  minimal net loss  of food and fibre which was  previously  produced on
this land.  The  lack  of induced growth  created by implementing any of the
alternatives  removes  the threat  to  prime  agricultural  farmland  usually
associated with the construction of wastewater facilities.

4.2.3.  Surface Water

     Increased housing  development along lake shores may increase nutrient
and sediment loads into the lakes as a result of the following:

     •    increased runoff from  construction of  impervious surfaces
          such as rooftops, parking areas, and paved roads
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     •    increased  housing density  normally  accelerates stonnwater
          runoff thereby increasing not only the amount of runoff, but
          also its ability  to erode soil and to transport  contaminants
     •    lawn  and garden  fertilization  may create  unnaturally high
          nutrient levels in runoff.
     Accompanying  housing  development  is  the  increase  in the  use  of the
lake for  recreational  and  fishing purposes.  An  increase  in  fishing pres-
sure  may  ultimately  result  in  detrimental  water quality  effects.  When
larger piscivores  are  removed  by angling, fewer planktivores are consumed,
resulting in  greater numbers  of planktivores.   The  planktivore community
then exerts  high  predation pressure  on the zooplankton  community.   A de-
crease in the  zooplankton  community will reduce grazing pressure on phyto-
plankton  resulting in an  increase  in  the  phytoplankton,  and greater tur-
bidity.

     The  installation of  a centralized  collection  system  probably would
induce a  more  rapid  development  rate compared  to  alternatives  calling for
upgraded on-site systems.

4.2.4.   Recreation and Tourism

     Any increase or decrease of tourism ani recreational activities within
the study area attributable to the long-term operation of wastewater facil-
ities under the  "build"  alternatives would occur  when  a  quantum change in
water quality of area lakes occurs.   A significant decline in water quality
would cause fewer tourists  to visit the study area.   Permanent and seasonal
residents of  the  study  area  would  likely decrease  some of  their  recre-
ational activities around area lakes under these conditions.

     A significant increase in water quality may contribute to an increase
of  recreational  activities among  local residents  and  tourists  within the
study area.   Other factors discussed in Section 3.2.4. would have a greater
affect upon  use  of  the study area by tourists and recreationists.   In-
creased and continuing nuisances created by failing  on-site  systems under
the No Action  Alternative  would  detract from the study areas reputation as
a  desirable  recreational  area.   Recreation  and tourist  activities would
                                    4-34

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likely decline.  No  significant  recreational or tourist impacts are likely
to occur under any of the alternatives.

4.2.5.  Economics

     It  is  unlikely  that  the  additional  wastewater  treatment  capacity
created under Alteratives  2-7 would create any population, development, or
economic  growth  (Section 3.2.3.).   Economic development  would  proceed as
discussed  in Section  3.2.3.  under  Alternatives 8A,  8B,  9,  and  10.   In-
creased and  continuing nuisances created by  failing on-site  systems under
the No Action  Alternative  would  detract from the study areas reputation as
a  desirable  recreational  area.   Recreation  and tourist  activities would
likely decline resulting  in a loss of  revenues  for study area businesses.

4.2.6.  Threatened and Endangered Species

     No threatened or  endangered species have been  identified  at  the pro-
posed plant  sites  or sewer lines.  The habitats present, however, could be
suitable  for a number  of endangered and threatened  species in the State of
Michigan  (Tables 3-14,  3-15, and 3-16 of the Draft EIS).

     The  MDNR should be  consulted to determine  whether any listed species
are actually  found  in  the vicinities of the proposed sites.  If so, appro-
priate measures must be  developed through consultation with Berrien, Cass,
and Van Buren  Counties,  MDNR, and US  Fish  and Wildlife Service, if appro-
priate, and  other  agencies  that  may be  interested  in the proposed action.

4.3.  Mitigation of Adverse Impacts

     As previously  discussed, various  adverse  impacts would  be associated
with  the  proposed alternatives.  Many of  these  adverse  impacts  could be
reduced  significantly  by  the application  of mitigative  measures.   These
mitigative measures  consist of  a variety  of  legal requirements,  planning
measures,  and  design  practices.   The  extent  to  which  these  measures are
applied will determine the  ultimate impact of the selected action.  Poten-
tial  measures  for alleviating  construction,  operation,  and  secondary ef-
                                    4-35

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fects  presented  in Sections  4.1.  and 4.2. are  discussed  in the following
sections.

4.3.1.  Mitigation of Construction Impacts

     The construction oriented  impacts presented in Section 4.1. primarily
are short-term effects resulting from construction activities at WWTP sites
or along the  route of proposed sewer  systems.   Proper design should mini-
mize  the potential impacts and the plans  and  specifications should incor-
porate mitigative measures consistent with the following discussion.

     Fugitive dust from the excavation and backfilling operations  for the
force mains and  treatment plants could be minimized by various techniques.
Frequent street  sweeping  of dirt from construction activities would reduce
the major  source  of  dust.  Prompt repaving of roads disturbed by construc-
tion also  could  reduce  dust effectively.  Construction sites, spoil piles,
and unpaved  access roads  should  be wetted periodically  to minimize dust.
Soil  stockpiles  and  backfilled trenches should  be  seeded  with a temporary
or permanent seeding or covered with mulch to reduce susceptibility to wind
erosion.

     Street cleaning  at  sites  where  trucks and equipment  gain  access to
construction  sites and of  roads along  which  a  force main would  be  con-
structed would reduce loose dirt that otherwise would  generate dust, create
unsafe  driving  conditions,  or be  washed  into  roadside ditches or storm
drains.

     Exhaust emissions and noise from construction equipment could be mini-
mized by proper  equipment maintenance.  The resident  engineer should have,
and should exercise the  authority,  to ban from  the  site  all  poorly main-
tained equipment.  Soil borings along the proposed force main rights-of-way
conducted  during  system design,  would identify organic soils that have the
potential  to  release  odors when excavated.  These  areas  could be bypassed
by rerouting  the  force main  if,  depending on  the  location, a significant
impact might be  expected.
                                    4-36

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     Spoil disposal  sites should  be  identified during  the project design
stage to  ensure that  adequate  sites  are available and  that  disposal site
impacts are minimized.  Landscaping and restoration of vegetation should be
conducted  immediately  after  disposal  is completed to  prevent  impacts from
dust generation and unsightly conditions.

     Lands disturbed by trenching for force main construction should be re-
graded and compacted  as necessary to prevent  future  subsidence.  However,
too much  compaction will  result  in conditions  unsuitable  for vegetation.

     Areas disturbed  by trenching and  grading at  the  plant site should be
revegetated as  soon as  possible  to prevent  erosion  and dust generation.
Native plants  and grasses  should be  used.  This  also will facilitate the
re-establishment of wildlife habitat.

     Construction-related  disruption   in  the  community  can  be minimized
through considerate contractor  scheduling  and appropriate public announce-
ments.   The  State  and  County  highway  departments  have regulations con-
cerning roadway disruptions, which should be rigorously applied.  Special
care should be  taken to minimize disruption of access to frequently visited
establishments.  Announcements  should  be published in local newspapers and
broadcast  from  local  radio stations to  alert  drivers  of temporary traffic
disruptions on primary  routes.   Street  closings should  be  announced  by
fliers delivered to each affected household.

     Planning  of routes  for heavy  construction  equipment and materials
should ensure  that  surface load restrictions are considered.  In this way,
damage to  streets and  roadways would be  minimized.   Trucks  hauling exca-
vation spoil to disposal sites or fill material to the WWTP sites should be
routed along primary  arteries  to minimize  the threat  to public safety and
to reduce disturbance in residential environments.

     Erosion and sedimentation must be minimized at all construction sites.
USEPA  Program   Requirements  Memorandum  78-1  establishes requirements for
control of erosion  and runoff  from construction  activities.   Adherence to
these requirements would serve  to mitigate potential problems:
                                    4-37

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     •    Construction site selection should consider potential occur-
          rence of erosion and sediment losses

     •    The  project  plan and  layout should be  designed to fit the
          local topography and soil conditions

     •    When appropriate, land grading and excavating should be kept
          at a minimum to  reduce  the  possibility of creating runoff
          and  erosion  problems  which  require extensive  control mea-
          sures

     •    Whenever possible,  topsoil  should be removed and stockpiled
          before grading begins

     •    Land exposure  should  be  minimized in terms of area and time

     •    Exposed areas subject to erosion should be covered as quick-
          ly as possible by means of mulching or vegetation

     •    Natural  vegetation  should  be   retained whenever  feasible

     •    Appropriate  structural  or agronomic  practices  to control
          runoff and sedimentation should be provided during and after
          construction

     •    Early  completion of  stabilized drainage  system (temporary
          and  permanent  systems)  will  substantially  reduce erosion
          potential

     •    Access  roadways  should be paved  or  otherwise stabilized as
          soon as feasible

     •    Clearing and grading should not be started until a  firm con-
          struction  schedule  is known and  can  be  effectively coordi-
          nated with the grading and clearing activities.

     The Natural  Historic  Preservation Act of  1966,  Executive Order 11593
(1971), The  Archaeological  and  Historic Preservation Act  of  1974,  and the
1973  Procedures  of  the  Advisory Council  on  Historic Preservation require

that care must be taken early in the planning process to  identify cultural

resources and  minimize adverse  effects on them.   USEPA final regulations

for the preparation of EISs (40 CFR 1500) also specify that compliance with

these  regulations  is required  when  a Federally funded,  licensed,  or per-

mitted project is undertaken.  The State Historic Preservation Officer must
have an opportunity to determine that the requirements have been satisfied.
     Once an  alternative is  selected and  design  work begins,  a thorough

pedestrian  archaeological  survey may be  required  for those areas affected
                                    4-38

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by the proposed facility.  In addition to the information already collected
through a  literature  review (WAPORA,  Inc. 1979) and  consultation with the
State  Historic  Preservation Officer and  other  knowledgeable informants,  a
controlled  surface collection  of  discovered  sites  and minor  subsurface
testing should  be conducted.   A similar survey would  be  required of his-
toric  structures,  sites, properties,  and objects  in  and adjacent  to the
construction areas, if they might be affected by the construction or opera-
tion of the project.

     In consultation with the State Historic Preservation Officer, it would
be determined if  any  of the resources  identified  by  the surveys appear to
be eligible for the National Register of Historic Places.  Subsequently, an
evaluation would  be made of the probable effects  of  the  project on these
resources and what mitigation  procedures may be required.   Prior to initi-
ation  of  the proposed  Federally funded  project,  the  Advisory  Council on
Historic Preservation  in Washington DC should be  notified  of the intended
undertaking  and  be  provided an opportunity  to comment  on  the  proposed
project.

4.3.2.  Mitigation of Operation Impacts

     The majority  of  potentially  adverse operational  impacts of the WWTP
alternatives are  related to the discharge of effluent to  surface waters.
For the land  treatment alternative, the most significant potential adverse
effects are  impacts  on  groundwater  and  possible health  risks.   Adverse
impacts associated with  the operation of cluster  and on-site systems are
primarily related to malodorous conditions which may affect  outdoor recrea-
tional  activities.   Measures to  minimize these and  other  operation phase
impacts from all the alternatives are discussed below.

     Adverse impacts related to the operation of the proposed  sewer systems
and treatment facilities would  be minimal if  the  facilities are designed,
operated,  and maintained properly.   Aerosols,  gaseous  emissions, and odors
from the various treatment processes could be controlled to  a  large extent.
Above-ground pumps would be enclosed  and installed  to minimize sound im-
pacts.  Concentrations  of  the  effluent  constituents  discharged  from the
                                    4-39

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WWTPs  would be  regulated  by  the  conditions o£  the NPDES  permits.   The
effluent  quality  is specified by  the State of Michigan  and  must be moni-
tored.  Proper  and  regular maintenance of cluster and on-site systems also
would maximize  the  efficiency  of these systems and minimize odors released
from trial functioning systems.

     Special care  to control  chlorination and effluent  concentrations of
chlorine  residuals  should  be  taken  to  minimize  adverse  impacts  to  the
aquatic biota of  study  area  surface waters.  Tsai  (1973)  documented that
depressed numbers of fish and macroinvertebrates were found downstream from
outfalls  discharging chlorinated  effluent.   No fish were found  in water
with chlorine residuals  greater  than 0.37 mg/1, and  the  species diversity
index  reached   zero  at  0.25 mg/1.   A  50% reduction in  species diversity
index occurred  at  0.10  mg/1.   Arthur and  others  (1975)  reported that con-
centrations o£  chlorine  residuals  lethal  to various  species  of  warm water
fish range  from 0.09  to 0.30 mg/1.   Many  wastewater  treatment plants have
effluents with  chlorine  residual concentrations  of 0.5 to  2.0 mg/1.  Fur-
thermore, chlorination of  wastewater  can result in the  formation of halo-
genated organic compounds that  are potentially carcinogenic  (USEPA 1976).
Rapid mixing  of chlorine  and  design of  contact  chambers  to  provide long
contact times,  however,  can achieve the desired disinfection and the mini-
mum chlorine residual discharge  (USEPA and others 1977).  Chlorination will
require  especially  careful  application and  routine monitoring  to  insure
that chlorine residual concentrations are kept to  a minimum.

     In  the  document  Federal Guidelines for Design, Operation, and Main-
tenance of Wastewater Treatment Facilities  (Federal Water Quality Adminis-
tration 1970),  it is required that:
     All water pollution  control  facilities should be planned and de-
     signed so as to  provide  for maximum  reliability at  all  times.
     The  facilities   should  be  capable  of operating  satisfactorily
     during power  failures,  flooding, peak  loads,  equipment failure,
     and maintenance shutdowns.
                                    4-40

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4.3.3.  Mitigation of Secondary Impacts


     As discussed  in Section  4.2.,  few secondary  impacts  are expected to
occur during  the operation  of  any of the  ten  "build"  alternatives.  Ade-
quate zoning,  health,  and  water  quality  regulation  and enforcement would
minimize these  impacts.   Local growth management planning  would assist in
the regulation  of  general location,  density, and type of growth that might
occur.


4.4.  Unavoidable Adverse Impacts


     Some impacts  associated  with the implementation of any of  the "build"

alternatives cannot  be  avoided.  The centralized collection and treatment
alternatives would have the following adverse impacts:
     •    Considerable short-term  construction  dust,  noise, and traf-
          fic nuisance

     •    Alteration  of   vegetation and  wildlife  habitat  along  the
          sewer and force main corridors and at the WWTP sites

     •    Considerable  erosion  and   siltation  during  construction

     •    Discharge of BOD, SS, and phosphorus at greater than ambient
          levels  to  Silver Creek  and/or  the  Indian  Lake  outlet with
          the waste stabilization lagoon alternatives

     •    Discharge  of increased  BOD, SS,  phosphorus, ammonia,  and
          chlorine to Dowagiac Creek, from the Dowagiac WWTP  for Alter-
          natives 6 and 7

     •    Significant  odors  during spring  turnover  of waste stabili-
          zation lagoons

     •    Significant  user  fees  for wastewater treatment services for
          the residents within the proposed sewer service areas

     •    Conversion  of  agricultural  land  and, for  Section 29 (near
          Indian  Lake),  prime farmland to  waste  stabilization lagoon
          use.

     The decentralized alternatives that include primarily continued use of

existing and  upgraded on-site systems and either cluster systems or black-

watetr holding tanks  for  critical  areas would  have  the  following adverse

impacts:
                                    4-41

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     •    Some short-term  construction dust,  noise, and traffic nuis-
          ance
     •    Some erosion and siltation during construction
     •    Alteration and destruction  of wildlife habitat at the clus-
          ter dralnfield sites
     •    Discharge of percolate  with elevated levels of nitrates and
          chlorides  from soil  absorption  systems  to  the  groundwater
     •    Occasional  ephemeral odors  associated with  pumping septic
          tanks and  holding tanks  and trucking  it to disposal sites
     •    User fees  for  management  and operation of wastewater treat-
          ment services  for  the residents within the proposed service
          areas.
4.5.  Irretrievable and Irreversible Resource Commitments
     The  major  types  and  amounts  of  resources  that  would  be  committed
through  the implementation  of  any  of  the  ten "build"  alternatives are
presented in Sections 4.1. and 4.2.  Each of  the alternatives would include
some or all of the following resource commitments:

     •    Fossil fuel,  electrical  energy,  and human labor for facili-
          ties construction and operation
     •    Chemicals, especially  chlorine,  for Dowagiac WWTP operation
     •    Tax dollars for construction and operation
     •    Some utisalvageable construction materials.

     For each alternative involving a WWTP, there  is a significant consump-
tion of  these resources with no feasible means  of recovery.  Thus, non-re-
coverable resources  would be  foregone  for  the  provision of  the proposed
wastewater control system.

     Accidents  which could  occur from  system  construction  and  operation
could  cause irreversible  bodily damage  or  death,  and damage or destroy
equipment and  other resources.   Unmitigated Dowagiac WWTP  failure poten-
tially could kill aquatic life in the immediate  mixing zone.
                                    4-42

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     The  potential  accidental  destruction of  undiscovered  archaeological
sites through  excavation  activities  is not reversible.  This  would  repre-
sent permanent loss of the site.
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5.0.  PUBLIC AND AGENCY COMMENTS
     Substantive public and agency comments were received on the Draft EIS.

They have been  compiled  and summarized in  this  section.   Comments offered

through written correspondence, and through testimony at the public hearing

on  the  Draft EIS  (28 September  1982),  and that are essential  to the EIS

decision-making process,  are  addressed herein.  The comments and appropri-

ate responses are organized by subject areas of the EIS including:
          Needs Documentation
          Water Quality
          Development of Alternatives
          Environmental Impacts
          Land Use
          Economic Impacts
          Public Participation
          The EIS Process
All written comments on the Draft EIS are included in Appendix E.


     Individuals offering substantive written comments on the Draft EIS are

listed below:
Name

Doug las Benton

Daniel J.  Dyman

Kathryn B. Eckert


Peter D. Elliott

Jim and Jean Haley

Homer R. Hilner


Dale Hippensteel


Sheila M.  Huff


C. M.  Hoover
Agency

Resident, Indian Lake

Resident, Crooked Lake

Michigan Department of State
Historic Preservation Office

Southwestern Michigan Commission

Residents, Indian Lake

US Department of Agriculture
Soil Conservation Service

Cass County
Health Department

Department of Interior


Resident, Indian Lake
Comment Number

8

7


25

1, 28, 29

15

23
4, 12, 13, 14,
19

21, 22, 23, 23,
26

15
                                   5-1

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Rosemary Johnstone       Resident Magician Lake             27

Charles F. Miller        Resident, Indian Lake              16

Donald Oderkirk          Berrien County                     4, 5, 9, 10, 11
                         Health Department

Fred and Jan Polmanteer  Residents, Round Lake              6

Johnie Rodebush and      Southwestern Michigan Regional     30
Robert J. Smith          Planning Commission, Environ-
                         mental Quality Committee

Mrs. Frank Seban         Resident, Indian Lake              15

Dr. John Fredrick Smith  Cass County Health Department and  4, 8, 12
                         Resident, Magician Lake

Richard Williams         Resident, Indian Lake              4

Robert J. Smith and      Southwestern Michigan Commission   1, 19,  28,  29
Francis Sage             Planning and Resources Committee

     Citizens  offering  substantive  comments on the Draft EIS at  the public
hearing are listed below:


jlame                     Agency                             Comment Number

Douglas Benton           Resident, Indian Lake              29

Peter Elliott            Southwestern Michigan              1, 19,  28,  29
                         Commission

Marie Huft"               Resident, Indian Lake              8, 16

Lee Maager               Cass County                        4, 12,  13,  14,
                         Health Department                  19

Johnie Rodebush          Cass County Department of          1, 4, 29
                         Public Works

Robert Scherer           Tri-County Realty                  3, 7, 18

Douglas Smith            Indian Lake                        2, 8, 15,  17
                         Improvement Association

Dr. John Smith           Cass County                        8, 20,  29
                         Water Council

John Steiding            Cass County                        29
                         Planning Commission
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     Several  other  people commented informally on  the EIS or participated
in  the  public  hearing.   This  participation  and interest  is appreciated.

Comments  not addressed  in  this  chapter  either  involved  support  for one

alternative  or  another,  or  reflected  differences  of  opinion between corn-

mentors.  While  interesting,  such comments are not substantive.  Copies of

the public hearing transcript can be reviewed at USEPA's office in Chicago,

Illinois.


     The  comments  (C.) and  responses  to  the  comments  (R.)  are  presented
below.  The cominentors are identified for each comment.


NEEDS DOCUMENTATION

C.   Field work to document needs  was  done at the wrong  time  of the year
1    and as a result under-estimates the need for sewage improvements.  The
     septic  leachate  survey  was conducted  in October  1979, after the peak
     of seasonal  occupancy.   The aerial  photographic  survey was  conducted
     in May  1979 after  the  leaves  had  come out on  the trees  and shrubs.
     [Elliott, Rodebush]

R.   The  documentation of the  adequacy and  condition of existing on-site
1    systems, and  the need for improved  wastewater management  systems in-
     volves  analysis  of data  from  a number of  sources  including data ob-
     tained  from  field work, questionnaires, sanitary surveys,  soils, and
     official records  on existing  systems.  The quality  of data from any
     one  of   these  sources  varies  depending  on the  local circumstances.
     Therefore,  the identification of problem areas is a result of analysis
     of all data sources recognizing that some may be of lower quality than
     others.

     The Draft EIS recognized that the value of the aerial  survey is limit-
     ed because  of the  leaf cover  at  that time  of year,  and  that fewer
     erupting plumes may have been found in the septic leachate survey than
     might have  been  found  on  a  sampling date earlier  in  the  year.   How-
     ever, when reviewed  with  data from other  sources,  the existing needs
     can be assessed with some degree of accuracy.

C.   The  Draft  EIS states  that 10 percent of  the  on-site systems serving
2    Indian  Lake residences  were  replaced between 1970 and 1980.   However,
     the  residents have  been aware for five  years  that  planning  of waste-
     water management  improvements  has been in  progress,  and have delayed
     upgrading  their  systems,  which in turn has  led  to  an underestimation
     of the problems.  [D. Smith]

R.   The identification of existing onsite systems with problems was accom-
2    plished  by  utilization  of a number  of  information sources.   One  of
     these  sources  was   the  number  of on-site  system  replacements  from
     health  department  records.    Other   sources  of  information  included
                                   5-3

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     mailed  questionnaires and  sanitary  surveys which  identified systems
     with problems that  had  not been replaced.   Therefore,  the  process of
     needs documentation  takes  into account the fact that official records
     may underestimate problems.

C.   Ten years  ago dye  tests were  performed on  on-site  systems  in several
3    places and the dye showed up in the lake almost immediately.  [Scherer]

R.   The only dye testing performed on a systematic basis that has been re-
3    ported  was  conducted around  Pipestone  Lake  in  1972  (Ferris  State
     College lb>72).  The report stated that no direct pipes from toilets to
     the lake were found.   Other water using  fixtures were not  tested and
     subsequent investigations have identified washers and kitchen sinks as
     having  direct discharges.   However,  upgrade of  systems with problems
     identified by the dye testing  is relatively easy.  Costs for upgrading
     these systems have  been  included in the on-site upgrade alternatives.

WATER QUALITY

C.   A number of  comments expressed concern over Michigan  state policy of
4    non-degradation  of  groundwater.   This would appear  to require "zero-
     discharge" to groundwater in cluster systems.  [Oderkirk, Hippensteel,
     Dr. J. F. Smith, Williams,  Maager, Rodebush]

R.   It is not  clear how MDNR will implement the Michigan policy of nonde-
4    gradation  of  groundwater with respect to  cluster  systems.   A recent
     telephone  call  to MDNR  (Tom Kampinnen,  Construction  Grants Section,
     MDNR,  to WAPORA,  Inc.  4 May 1982) indicated that  the  policy is still
     being developed.   MDNR has  indicated  that  the non-degradation policy
     may be  interpreted  to require a very  conservatively designed cluster
     drainfield  design to  ensure  that  this  treatment   is  absolutely ef-
     fective.  If the  distance  between the trenches is  increased  over the
     distance used in  the EIS project alternatives,  the  initial construc-
     tion  costs would  be greater,  primarily because  the  pipe manifolds
     serving individual trenches would be longer.

C.   Pipestone Creek  is a designated trout stream.  [Oderkirk]
5

R.   Comment  noted.   The  fact   has been  added  to  the   discussion  of the
5    existing conditions of Pipestone Creek in Section 3.1.3.1 of the Final
     EIS.  None  of the project  alternatives will have either a  beneficial
     or adverse impact on water quality in the stream.

C.   Sewers  should be  supported  over other wastewater  management systems
6    because  of  their  long-term  benefit  on water  quality in Round Lake.
     [Polmanteer]

R.   The major water  quality concern in the lakes is eutrophication and its
6    attendant nuisance  algal blooms.  Eutrophication is accelerated when
     nutrient loadings increase, especially phosphorus,  normally the limit-
     ing nutrient  for  algal  growth.   The  phosphorus  may be  derived from
     nonpoint sources  (surface  runoff),  direct precipitation, groundwater,
     and  inadequately  treated  septic  tank effluent.  Groundwater sources
                                   5-4

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     are roost difficult to assess because flow rates and concentrations are
     generally  unknown.   The  other  sources of  phosphorus  and potential
     reductions  in loading  were estimated  for  each  of  the alternatives.

     The estimated percentages  from  each source  were surface runoff 59%,
     on-site systems 27%, and direct precipitation 13%  (Table 3-10).  Thus,
     with complete sewering, a maximum reduction (excluding groundwater)  in
     loading of 27% may be possible (Table 4-1).  With  partial sewering and
     cluster drainfields  and some blackwater holding  tanks,  the estimated
     reduction in  loading would be 24% (Table 4-1).  USEPA does not support
     projects for which the anticipated benefits appear to be this limited.
     The commitment  of funds  for complete  sewering are  not justified for
     the unquantifiable water quality benefits.

C.   It  has  been  observed  that particulate  suspensions  in lakes increase
7    with increased boating activity. [Dyman]

R.   Comment noted.  Other  researchers,  as Dr. Dyman has previously noted,
7    have concluded that  power boating does indeed dramatically affect the
     turbidity of  nearshore waters.   Phosphorus is  then  released from the
     sediments to  the  water column.   Power  boating  is restricted on Cable
     Lake which may, in part, account for the high Secchi disk measurements
     even though it is a productive lake.

DEVELOPMENT OF ALTERNATIVES

C.   A  number  of  commentors  suggested  that  Indian  Lake  be separated from
8    the plan and  sewers  proposed for this area only.  Farmers Home Admin-
     istration  (FmHA)   funding  has  been  pursued  for  sewering  Indian Lake
     since 1976. [Benton, Dr. J. F.  Smith, Marie Huff,  Dr. J. Smith]

R.   In  May  1976  the  Cass County Department of Public Works received ap-
8    proval  from  FmHA  for funds to  construct a  sewer system  for Indian
     Lake.  FmHA has set aside the funds; however, it is FmHA policy to fund
     projects approved  by state  agencies and USEPA if the  project is in-
     cluded in the construction grants process.

     MDNR  has   specified   that  an approved   Facilities Plan  be completed
     before discharge and construction  permits   could  be   issued.    The
     facilities  planning  area was designated to  include  the Sister Lakes
     area and Pipestone Lake  so that regional treatment  could be investi-
     gated.  When  the  Final EIS is issued, the grantee may pursue facility
     planning for  Indian  Lake  because regional treatment is not the recom-
     mended  alternative.    The  project  costs  for  Indian  Lake  alone  are
     presented in  Section 2.5.1.1.  and  Alternative  10 is the recommended
     action.

C.   There has been no mention of composting toilets as an alternative sys-
9    tern. [Oderkirk]

R.   Composting  toilets (as well as incineration  type toilets)  are viable
9    alternative forms of wastewater treatment.   However, it is likely that
     installation  would require significant  modification  to the residence
     and to wastewater  piping  within the residence, both of which would be
                                   5-5

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     expensive, and  most likely  not  grant eligible.  In  addition,  an on-
     site disposal system would  still be required for the other wastewater
     from the house (sinks,  showers, etc.). and the homeowner would have to
     maintain and dispose of residuals from both systems.

     In  some  cases,  where  the  installation costs  are reasonable and the
     owner understands  the  operation  and  maintenance requirements  of the
     system,  a composting toilet  may  be appropriate.  For  evaluation  of a
     general alternative to  serve the study area, holding tanks for  toilet
     wastes were considered  more appropriate.

C.   Cost should be  provided  for  the  "no action" alternative.   [Oderkirk]
10

R.   Costs for  the Ko  Action Alternative were  not developed  because the
10   future actions  of  homeowners were too difficult  to  predict.   Corres-
     ponding  costs  for  upgrading  and operating  and maintaining  on-site
     systems were not developed for that reason.  The county health depart-
     ments are  not authorized  to specify that  systems  be  upgraded  unless
     specific  public  health  threats  are obvious.   Therefore,  enforcement
     actions  against numerous  homeowners  are  not  anticipated.    The  No
     Action Alternative  is likely the  least costly, depending on continued,
     effective water  conservation efforts,  but it  also  provides the least
     protection to the water quality of the lakes.

C.   The Berrien County  Health  Department Sanitary Code does not authorize
11   permits for replacement of on-site systems.    [Oderkirk]

R.   This fact was known during preparation of  the EIS.   Around Pipestone
11   Lake, the  township supervisor has  performed  numerous  inspections and
     has verified  that  upgrades  have  been made.  The particular section of
     the Draft EIS to which  the comment was directed (3.2.2.5.2.) is  in the
     context of constraints  to new residential development.

C.   Presently there  are no waste  treatment  facilities  for  disposal  of
12   holding  tank and   septic  tank  wastes.   These  wastes  are presently
     disposed of by land application on sites with  limited capacity.   These
     wastes can cause public health problems if  not  disposed of properly.
     Disposal of these  wastes in  the  winter is  extremely  difficult  if not
     impractical because of  difficulties in getting access to the tanks on
     the homeowner's  property, and because the soils are frozen at the land
     application sites.   [Hippensteel,  Maager]

     What are  the  public health consequences of collection and disposal of
     holding tank wastes? [Dr. J.  F. Smith]

R.   Current septage disposal  practices  include land disposal on sites and
12   with methods approved by CCHD sanitarians and disposal at the Dowagiac
     WWTP for  some septage,  as  described in  Section 2.1.5.  of the Draft
     EIS.  Septage and  holding  tank wastes can be disposed of on land in a
     manner that will not have an adverse impact on public health.  Current
     winter disposal practices  are also discussed  in Section 2.1.5.  of the
     Draft EIS.
                                   5-6

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     The advantages  and disadvantages  of disposal  of  septage and holding
     tank wastes  by land  application,  including  the  public health conse-
     quences are  discussed in Section 2.2.2.8 of  the  Draft EIS.  The die-
     off of  pathogens  in  septage which  is  surface-spread  is quicker than
     that of pathogens  in  septage  injected  into  the  soil.   In  septage
     incorporated into the top 3 inches  of  the  soil,  generally 99% of all
     pathogens will die off within one month (Brown and White  1977).

     Land application of  septage and blackwater holding tank wastes in the
     winter can pose problems as discussed in Section 2.2.2.8. of the Draft
     EIS.  However,  the operation and  maintenance  of  the  on-site systems
     can be  managed to minimize the number of  systems  that would require
     winter  pumping.    The  only systems  that  absolutely  require  winter
     pumping  are the  blackwater holding tanks  for permanent  residents,
     which require  pumping about once a  month  (see  response to comment 13
     for discussion of blackwater holding tank waste volume).   Alternative
     9  includes  an  estimated  73  holding  tanks  for  permanent  residents.
     Alternative  10  includes an  estimated  42 holding  tanks for permanent
     residences.   These wastes could be  treated at  the Dowagiac treatment
     plant when land access is not feasible.

C.   The 3000 gallon holding tanks proposed for seasonal residents would be
13   inadequate if the residence became permanent.   A permanent family of 4
     (not including visitors)  would  have to pump  their  holding  tank every
     10 days  (3000  gal  tank/300 gal/day  =  10  days)  at a total annual cost
     of $7,655 ($70/1000 gal).   [Hippensteel, Maager]

R.   The holding  tanks  proposed  under  the  decentralized  alternatives are
13   for blackwater  (toilet wastes)  only.   Included  in these alternatives
     are costs for low-flow toilets (2.5 gal flush in Alternative 9 and 0.8
     gal flush in Alternative 10).   The estimated average daily flow is 30
     gpd for Alternative 9 and 10 gpd for Alternative 10.  The holding tank
     would require  pumping approximately once  each month under Alternative
     9 and once every 3 months under Alternative 10.

     Experience in Westboro,  Wisconsin  indicates that considerable savings
     (less than  $20 per  pumping)  are possible  when a  central  management
     agency  arranges for a series of  tanks to be pumped at once.  The costs
     utilized  in  the  cost  effectiveness analysis  were $40  per  pumping.
     Thus,  a  reasonable  cost  of pumping the  blackwater  holding tanks per
     year would be:

                                Seasonal Occupancy    Permanent Occupancy

          Alternative 9               $120                  $360
          Alternative 10               40                   120

     Research that  USEPA  has sponsored concluded  that  the  existing  septic
     tank and soil  absorption system has a  reasonable  chance of operating
     satisfactorily  when the  toilet  waste load and volume are removed from
     the primary  system.    In  addition,  the contribution  of phosphorus to
     the lake is  likely to be reduced by a greater than proportional extent
     because the  opportunity for adsorption and precipitation reactions are
     significantly  increased.   Severe water conservation efforts are  re-
     quired  with these systems for them to operate satisfactorily.

                                   5-7

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     The number of blackwater holding tanks estimated for Alternative 9 are
     73 and for  Alternative  10 are 42.  The  total  annual cost for pumping
     and disposing of holding tank wastes under each of the alternatives is
     reasonable.  The cost to  an individual homeowner might be high if the
     household size  were  large and he were  to  bear the entire cost alone.

C.   There are  few,  if any,  400  sf  drain beds  that  can  function  for 20
14   years.  CCHD experience indicates that 1000 sf drain beds are required
     to achieve  a 20 year  life under optimum  site  conditions.   This fact
     could double the construction cost of drain beds for upgrading on-site
     systems.   [Hippensteel,  Maager]

R.   Residences that do not implement water conservation practices and have
14   the full complement  of  water using appliances  would  likely  require a
     drain bed  larger than  400 sf.  New  systems should  be designed using
     the Sanitary Code.   For  most replacement systems the parcel sizes are
     inadequate for full-size systems.  Therefore, water conservation would
     be required  for  systems  to operate properly.  Based on reported fail-
     ures, these  smaller  sized drain beds (400 sf) with water conservation
     would continue  to  function satisfactorily through the project period.
     Because the  majority  of  on-site systems would be replacement systems,
     the 400 sf drain bed costs were utilized as typical.

     Research  elsewhere  (Hill  and  Frink  1980;  Saxton and  Zeneski 1979)
     indicates  that  on-site   systems  experience  failure  according  to  a
     typical "half-life"  pattern,  if the systems survive the initial five-
     year  period.   Initial failures  are not particularly  numerous within
     the project area.  The research indicates that a half-life of at least
     30 years  (one-half would  fail within 30  years)  is  typical  for those
     systems that survive  the  initial five-year period.  Thus, where water
     conservation is  practiced and  regular  maintenance  is performed, ap-
     proximately two-thirds of systems constructed now would be expected to
     function for 20 years.

     The final  design  for any on-site upgrade  or  new system would include
     evaluation of the site conditions and waste flow generation projection
     and the system would be designed accordingly.

C.   A number  of comments were made concerning  frustration  with the pre-
15   sent  limitations  on  water use necessitated  by problems  with existing
     on-site systems.   Water  use limitations include limited toilet flush-
     ing,  shower use, and bath use; and  the  inability to install washing
     machines for clothes or dishes.  [Hoover, Haley, D. Smith]

R.   An  alternative that  calls for  upgrades of existing  on-site systems
15   could be designed to correct deficiencies that result  in backups, slow
     drainage, and  ponding.   However,  in any design for on-site wastewater
     treatment,  flow  reduction is desirable especially in areas of limited
     hydraulic  treatment  capacity.   If  the small  waste  flows management
     district  were  implemented  as is  recommended in  this  EIS,  on-site
     systems would be designed on  the basis of  the assimilative capacity of
     hydrogeologic  conditions  on  a  lot  by  lot basis.   This  EIS contends
     that,  if  these systems  are  properly  operated  and  maintained,  the
     system  will not  present  water  pollution  or  public  health problems.
                                   5-1

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     Homeowners may  have  to make concessions to local environmental condi-
     tions however.   Residents may  have to  forgo  some  water-using appli-
     ances such as  top-loading clothes washers or garbage grinders and use
     water conserving low flush toilets and front loading washing machines.
     These limitations  should  not preclude a fairly  normal  water use pat-
     tern in the study area residences.

C.   Several comments were directed at the inadequacies of the existing on-
16   site systems installed  many years ago on very small lots and that up-
     grading systems will not meet code requirements.  [Miller, Marie Huff]

R.   Many of the  existing on-site systems were  installed  prior  to the en-
16   actment of  sanitary codes  which require  that  adequate  lot  size and
     technology  be   adhered  to.   However,  significant  numbers  of  these
     systems are  still  operative and  causing no  apparent  problems.  Where
     problems  have  been  identified,  the  EIS  has recommended  2 different
     methods  of  resolution.   Where  the  number of  problems and  housing
     density indicate a  cost-effective approach, wastewater collection and
     treatment at a  cluster  drainfield is the proposed alternative.  Where
     housing density  is  low or  the  incidence  of problems  are  scattered,
     residences with severe site limitations can be accommodated by employ-
     ing holding  tanks  for  blackwater waste flows  and  a  modified septic
     tank soil absorption system for a reduced graywater flow.

     While  severe site  limitations  may render  compliance  with  sanitary
     codes infeasible in  nearly  all cases, there is sufficient information
     on  the  condition  and effects  of the existing  systems and  the  per-
     formance of graywater/blackwater separation to predict that the use of
     on-site technology will be  practicable  for many  years  to come.   This
     EIS  does  not   propose  sub-code  technology for  new dwelling units.
     State and  local health authorities may  exercise whatever constraints
     are  legal  in   order to  minimize the  somewhat  unpredictable  public
     health problems resulting from on—site systems failure in new systems.
     This  EIS  contends  that  the  risk  of  employing  alternative  forms  of
     technology when weighed against  the cost of building sewers is within
     acceptable limits  and  presents a cost-effective environmentally sound
     alternative.

C.   Presently, some systems around Indian Lake cannot be used on an annual
17   basis because  they  overflow,  even  if  they are  pumped three  times
     annually.    The pumping  requirement  also  means  that  operation  and
     maintenance costs  for  septic  tank systems are higher  than  those  used
     in  development  of  the  decentralized alternatives  in the  Draft  EIS.
     The actual  cost  for these  residences  is about  $200 per  year.  [D.
     Smith]

R.   The alternatives  proposed in  the EIS would  improve  existing on-site
17   systems or  collect wastewater for off-site  treatment.   No  residences
     are expected to have septic tanks that would require frequent pumping.
     An  extensive range  of technologies  are  available  for  a  management
     agency to employ in upgrading on-site systems.

     Out of  125 sanitary  surveys,  one resident  reported  that  the septic
     tank  is  pumped seasonally  and the average  was  3 years,  typical for
                                   5-9

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     permanent residences.  Experience elsewhere (Personal interview, Rich-
     ard J. Otis, Univ. of Wisconsin to WAPORA, 20 November 1980) indicates
     that a management  agency  can contract septic tank pumping services at
     much below the standard rates when a number are pumped at once.

C.   Why  do  we  need to  build a  treatment  plant for  Dowagiac?  [Scherer]
18

R.   No  additional  treatment  capacity  is  proposed for Dowagiac  in any of
18   the alternatives presented  in the EIS.   Two of the alternatives would
     utilize existing excess capacity at the Dowagiac WWTP.  The costs pre-
     sented for  treatment  for  these alternatives are based on user charges
     and other  fees  specified  by the City of Dowagiac in a letter dated 19
     January 1982 (Appendix 0 of the Draft EIS).

C.   There are obvious, logical, and cost-effective solutions to wastewater
19   management  problems  in  the study area not reflected in the Draft EIS.
     [Hippensteel,  Maager]

     Based on  our  knowledge,  Pipestone Lake is  well  suited  to Alternative
     8A  or  8B, Indian Lake  to Alternative 6 and the  Sister  Lakes  to com-
     binations of 8A,  8B,  and  9 (with no holding tanks).  [Smith and Sage,
     Elliott]

R.   In  the  Final  EIS  another alternative  (Alternative  10)  was developed
19   based on  the  field  work completed since  the  Draft EIS  was published.
     This  alternative  includes upgraded  on-site systems  in  most areas,
     blackwater  holding  tanks  for some systems  with  critical site limita-
     tions, and  cluster  systems for some critical areas.  This alternative
     is a combination of Alternatives 8A, 8B, and 9.  The areas where clus-
     ter systems are proposed are shown in Figure 2-18.

     The costs  of  the alternatives that include  Indian Lake  by itself are
     presented  in Table  2-11.   The ranking of  the  alternatives for Indian
     Lake  alone is  similar to  the ranking for  the alternatives  for  the
     entire study area.

C.   Many  of   the  procedures  suggested  for wastewater management  in  the
20   Draft EIS are  against the  environmental laws of the State of Michigan.
     [Dr. J. Smith]

R.   The design approach and regulations utilized in preparing this EIS are
20   those of USEPA and may not be in strict compliance with local codes or
     laws of  the State of Michigan.  For  new  systems,  compliance with all
     codes and laws is recommended.  Comment 4 contains a discussion of the
     non-degradation  of  groundwater policy of  the Michigan Water Resources
     Commission.  The implementation of decentralized alternatives  (includ-
     ing  cluster  systems  and on-site  upgrades)  under  Michigan  Law  are
     discussed  in  Section  2.5.1.3.  of  the Draft  EIS:  Michigan  Statutes
     Section  123.241  et jseq.  and 232.73 et seq. have  been  interpreted as
     providing  counties,  townships,  villages,  and cities with sufficient
     powers  to  manage  decentralized  facilities  (Otis and  Stewart 1976).
                                   5-10

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ENVIRONMENTAL IMPACTS

C.   The Draft  E1S  does not provide a  clear  understanding of the environ-
21   mental  impacts of  each  specific  alternative  so the  least damaging
     alternative can be identified.  [S. M. Huff]

R.   The project  alternatives are each composed  of different combinations
21   of several components including centralized collection, WWTPs, cluster
     drainfields, and onsite system upgrades.  The environmental  impacts of
     each component  are similar for each project alternative.  To simplify
     the discussion, the environmental impacts are discussed on a component
     basis in Chapter  4.   In the Draft EIS, environmental impacts are pre-
     sented  on  a project  alternative  basis in  Table  4-1.  Project alter-
     natives  are grouped  together  for discussion  where  the  differences
     between  them are  not significant on  an environmental  impact basis.

C.   The EIS should include more information relating to mitigation of wet-
22   land impacts.   Detailed  information  should be provided describing lo-
     cation and size of wetlands possibly affected by various alternatives,
     and on  how Executive  Orders  11990 and  11988 will  be complied with.
     [S.M.  Huff]

R.   Wetlands in  the  Indian Lake-Sister Lakes study area  are described in
22   Section 3.1.6.  based on interpretation of 1979 aerial photography.  In
     the absence  of data  from either  the  Michigan Department  of Natural
     Resources or the US Fish and Wildlife Service National Wetlands Inven-
     tory,  this is  the best information available.   Primary and secondary
     impacts are discussed  in  Sections 4.1 and 4.2.  Primary impacts could
     occur as a result  of implementation of a  centralized wastewater man-
     agement alternative.   Detrimental impacts would  result from pipeline
     construction activities  in or  bordering  on wetlands and concomitant
     filling activities.   The preferred approach under  EIS Alternative 10
     would have minimal impacts  on areas in proximity  to wetlands as on-
     site technology for new dwelling units would not be permitted in areas
     with a  very  high  water table.  Thus,  the EIS would severely limit any
     Federal action resulting in adverse impacts on wetland areas.

C.   The discussion of  mitigative measures for  erosion  presented  in the
23   Draft  EIS should be considered as general guidelines  from which speci-
     fic requirements  could be  derived.   If these  are,   in  fact require-
     ments,  it is recommended that the word must replace the word should in
     the discus son.  It is also recommended that some  mechanism such as a
     performance bond be added to assure compliance. [S. M. Huff]

     The necessary  steps  to revegetate areas of  potential erosion hazards
     exposed during  construction should be  taken  as  soon as  possible  to
     control erosion and maintain water quality. [Hilner]

R.   The EIS presents general mitigative measures to prevent erosion during
23   construction of  any of  the project alternatives.   The potential for
     erosion is greatest for the  project  alternatives  including primarily
     centralized collection  and treatment because  the  total excavation is
     the greatest for  these alternatives.   However, site,  soil  and design
     considerations do  not  warrant special mitigative measures for any one
                                   5-11

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     alternative.   Therefore,  the  soil  erosion  regulations  required  by
     USEPA  for  construction  grants  projects, and  the regulations  of the
     State of Michigan  as adopted and implemented  by  the counties will be
     sufficient  to mitigate  potential  adverse  impacts  from  any  project
     alternative.  The  responsibility  for implementation of the mitigative
     measures lies with the designer and the regulatory agencies.

C.   The  common  name  of  the  mollusk jipioblasma sulcata  delicata has been
24   mistakenly referred to as white cat's eye.  The correct common name is
     white cat's paw.    [S. M.  Huff]

R.   Comment noted.  Reference to the mollusk is deleted  from the Final EIS
24   because it has not been identified within the study area.

C.   More  information  should  be  included on  the  14 historical structures
25   noted in the EIS.  [Eckert]

R.   None of  the  14 historical structures would be affected by implementa-
25   tion  of the  alternatives;  therefore,  no  additional  information  is
     deemed necessary to evaluate mitigative measures.

LAND USE

C.   Sand and gravel deposits and associated mining are important resources
26   of  the  study area.   This  EIS should delineate areas  where  known de-
     posits occur and describe what effects, if any, project implementation
     will have on mineral resources.  [S. M. Huff]

R.   Comment noted.   The  discussion of sand and gravel resources presented
26   in  Section  3.1.2.1.2.  of the Draft EIS has  been  revised in the Final
     EIS.

ECONOMIC IMPACTS

C.   Will  user  fees  be charged on  the  basis of  a percentage  of income?
27   User fees can have a greater economic  impact  on  retired persons on a
     pension than on an employed person.  [Johnstone]

R.   User fees will be  charged based on the costs to construct and operate
27   the wastewater management  system,  and will not be based on the income
     of  the  residents  (unless special provisions are made by local author-
     ities) .  One  of  the  impacts  evaluated  in  the  EIS was  the economic
     impact  on  the residents.   The  impact was evaluated based on Federal
     guidelines concerning the acceptable range of user costs as a percent-
     age of household income.

PUBLIC PARTICIPATION

C.   Several comments discussed  dissatisfaction  with the public participa-
28   tion activity  prior to  the publication of the Draft  EIS.   The Citi-
     zen's Advisory Committee was organized rather late  in the process and
     no USEPA staff was available to meet with the group  to discuss various
     aspects of the study.  [Eliott, Smith and Sage]
                                   5-12

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R.   Several meetings with  local planning officials were conducted by both
28   USEPA and the  EIS  consultant.   These were  conducted  early in the EIS
     process and considerable  input from local  officials  was  used in pre-
     paring the EIS.  Preliminary copies of portions of the documents were
     also  sent  to  the  local  officials  for  their review  and  comments and
     those comments  were  included in subsequent  drafts.   While the inten-
     tion from the beginning was to assemble a Citizens Advisory Committee,
     schedule  and   budget   considerations  hindered  regular attendance  by
     UStPA staff.

THE EIS PROCESS

C.   A number  of  commentors  expressed  concern  that  the  cost  of  prepara-
29   tion of the EIS was too high and that the facilities planning process,
     including preparation  of  the EIS,  took too  long.  [Elliott, Smith and
     Sage, Benton,  Rodebush, Dr. J.  Smith, Steiding]

R.   An  EIS  is,  by  regulation,  more detailed than a  Facilities Plan and,
29   for  that reason, is  more costly and more time consuming.   The process
     was complicated by coordination between the  Facilities Planner, USEPA,
     and  the EIS contractor.   Reference to the project schedule milestones
     are  in Chapter 1.

     The  EIS process  is dependent on obtaining  as  much documented data as
     it is feasible to obtain.  Therefore, data-gathering efforts dominated
     the  EIS  process.  Planning, preparing  for,  conducting,  and analyzing
     field work was time-consuming  and results  from  some  field work were
     inconclusive  so  that more were required, for  example,  for lake water
     quality analyses.   One of  the objectives of the  EIS  was to  assemble
     sufficient information so  that the data and conclusions  would have
     application beyond  the  facilities planning area.
                                   5-13

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6.0.  LITERATURE CITED

Arthur,  J.W.,  and  others.   1975.   Comparative toxicity  of  sewage  -
     effluent disinfection to  freshwater aquatic life.  Water Pollution
     Control Research Service, USEPA, Washington DC.

Ayensu,  E.S.,  and  R.A.  De  Filipps.   1978.  Endangered  and threatened
     plants  of  the  United States.   Smithsonian Institution, Washington
     DC, 403 p.

Banks,  John  C.  1977.   A limnological study  of Pipestone Lake, Berrien
     County, Michigan.  Presented in partial fulfillment of the require-
     ments  for  the  course Biology 466,  Limnology,  Andrews University,
     Berrien Springs MI, 19 p.

Berrien  County  Health Department.   1971.  Pipestone  Lake  report.  St.
     Joseph MI, unpaginated.

Braun,  E.L.  1950.   Deciduous forests of  eastern North America.  Hafner
     Press, New York NY, 596 p.

Brown,  D.V.,  and  R.K.  White.   1977.   Septage  disposal alternatives in
     rural areas.   Research  bulletin  1096.   Ohio Agricultural Research
     and Development Center,  Wooster OH,  11 p.

Cass  County  Health Department.   1970.   Indian  Lake survey.  Cassopolis
     MI, 7 p.

Claspy,  E.  1966.    The  Pottowatomi  Indians  of  southwestern Michigan.
     Dowagiac MI.

Cooley,  M.F.  1979.  Selected animal  distribution maps.  Wildlife Divi-
     sion, MDNR, Lansing MI,  40 p. mimeo.

Cowardin,  L.M.,  V. Carter,  F.C.  Golet, and E.T. LaRoe. 1979.  Classifi-
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                                  6-1

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Federal  Water  Quality  Administration.   1970.   Federal  guidelines  for
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Ferris  State  College.   1972.   Pipestone  Lake  survey as  evaluated by
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                                 6-2

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Jones, R.A.,  and  G.F.  Lee. 1977.  Septic tank disposal systems as phos-
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K-V Associates, Inc.  1980.   Septic leachate survey Indian Lake - Sister
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     septic  systems.    ASAE  Paper No.  82-2558.   American  Society of
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     water  quality standards.   Water Resources Commission, Grand Rapids
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Michigan  Department of Natural Resources. 1975b.  Inland lake  self-help
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Michigan  Department  of  Natural  Resources.   1976a. Coldwater  lakes of
     Michigan.  Fisheries Division, Lansing MI. 36 p.

Michigan  Department of Natural Resources. 1976b.  Inland lake  self-help
     program  annual report, 1975.  Inland Lake Management Unit, Land Re-
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Michigan  Department  oE Natural  Resources. 1977a.  Air  quality report.
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Michigan  Department of Natural Resources. 1977b.  Inland lake  self-help
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     Resource  Programs Division, Lansing MI, 31 p.

                                 6-3

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Michigan Department  of  Natural Resources. 1978a.  Inland lake self-help
     program  annual  report,  1977.   Inland  Lake Management  Unit,  Land
     Resource Programs Division, Lansing MI, 34 p.

Michigan Department  of Natural  Resources.   1978b.   STORE! polygon re-
     trieval  data  -  Pipestone  Creek  at  River Rd. ,  Berrien County, and
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     threatened species.   Fisheries and Wildlife Divisions, Lansing MI,
     8 p.

Michigan Department  of  Natural Resources. 1981.  Proposed water quality
     standards, to amend  Act  245, Part  4  of Michigan  Water Resources
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Saxton,  G.B.,  and  J.M.   Zeneski.   1979.   Prediction of  septic  system
     failures.   Journal   of  the  Environmental  Engineering  Division,
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Scalf, M.R.,  W.J.  Dunlap,  and J.   F.  Kriessl.  1977.  Environmental ef-
     fects  of septic  tank systems.  EPA  600/3-77-096.   Robert  S.  Kerr
     Environmental Research Laboratory, Ada OK. 35 p.

Shipman,  W.L.  1977.   Letter,  Wayne  L.  Shipman, Berrien  County  Health
     Department to James R. Squire, Gove Associates, Inc., 22 June 1977.

Smith, V.H.,  and  J.  Shapiro.  1981.   Chlorophyll  -  phosphorus relations
     in individual lakes.   Their importance to lake restoration strate-
     gies.   Environmental  Science and Technology  15: 444-451.

Snow,  G.E.   1976.   A  limnological study  of Dewey  Lake,  Cass  County,
     Michigan.   Prepared  for:   Dewey  Lake  Owners'   Association,  Inc.,
     Dowagiac MI,  22 p.

Soil Conservation Service. 1980a.  Prime farmland map units in Michigan.
     Prepared by State Soil Survey Staff and cooperating agencies, 15 p.

Soil  Conservation  Service. 1980b.   Soil  survey  of  Berrien County Mich-
     igan.    Prepared  in  cooperation  with   the  Michigan  Agricultural
     Experiment Station.   US Department of Agriculture.

                                 6-4

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Southwestern  Michigan Regional Planning  Commission.  1978.   208 area-
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     Associates.   St.  Joseph  MI, variously  paged plus  attachments.

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     of three  watersheds located  in  Cass,  Van  Buren  and  Berrien Coun-
     ties. Prepared  for  Southwestern  Michigan  Regional Planning Commis-
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     sewage  effluents  and   sludge  in  Michigan.  In;  Sopper,  William E.
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     State University Press, University Park PA,  537 p. (p.7-17).

Urie, Dean  H.,  John H. Cooley, and Alfred Ray Harris. 1978.  Irrigation
     of  forest plantations  with  sewage  lagoon  effluents.   _In_:  McKim,
     Harlan  L.  (Coordinator), State  of  knowledge  in  land treatment of
     wastewater, vol.  2. US  Army COE Cold Regions Research and  Engi-
     neering Laboratory,  Hanover NH, 423 p.  (p.207-213).

US Bureau  of the  Census.   1952.   US  census  of population: 1950, volume
     II,  part 22,  Michigan.  US  Government Printing Office, Washington
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     characteristics  of  population,  part 24,  Michigan.  US Government
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     characteristics of the population, part 24,  Michigan. US Government
     Printing Office, Washington DC, 1,399 p.

US Bureau of  the  Census.  1979.  1976 population estimates and 1975 and
     revised 1974 per capita income estimates for counties, incorporated
     places,  and selected  minor  civil  divisions  in  Michigan.   Series
     P-25, No.  761.  US Government Printing Office, Washington DC, 39 p.

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     tics  of  the  population:  number of inhabitants  (final report), part
     24,  Michigan.  US Government  Printing Office,  Washington DC, 74 p.
                                 6-5

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USEPA.   1974.   National  Lutrophication  Survey,  working  paper no.  1.
     Corvallis OR, variously paged.

USEPA.  1976. Quality  criteria for water.  Office of Water and Hazardous
     Materials. Washington DC, 255 p.

USEPA.  1977.   Alternatives  for  small  wastewater  treatment  systems,
     on-site disposal/septage  treatment  and  disposal.  EPA 625/4-77-011.
     Technology Transfer, Washington  DC, 90 p.

USEPA,  US  Army Corps  of  Engineers, and US  Department  of  Agriculture.
     1977.  Process design manual for land treatment of municipal waste-
     water.  EPA 625/1-77-008.  Washington DC, variously paged.

USEPA.  1979.   Aerial  survey  Indian-Sisters  Lake  Region,  Michigan.
     Office of Research and Development, Las Vegas NV,  95 p.

USEPA.  1980a.   Design manual.   On-site wastewater treatment  and dis-
     posal systems.  Office of Research and Development, Municipal Envi-
     ronmental Research Laboratory, Cincinnati OH, 391 p.

USEPA.  1980b.   Modeling  phosphorus  loading  and  lake response  under
     uncertainty:  a manual  and compilation of export coefficients.  EPA
     440/5-80-011.  Clean Lakes Section, Washington DC.

USEPA.   1980c.   Planning wastewater  management  facilities  for  small
     communities.   Prepared  for USEPA  Municipal  Environmental Research
     Laboratory,  by  Urban Systems Research  Engineering,  Inc.,  EPA 600/
     8-80-030,  Cincinnati OH, 141 p.

USEPA.  1981.  Facilities planning 1981.  Municipal wastewater treatment.
     EPA 430/9-81-002.   Office of Water Program  Operations, Washington
     DC, 116 p.

USEPA. 1982a. Construction Grants 82 (CG-82).  EPA 430/9-81-020.  Office
     of Water  Program Operations,  Washington DC, 127  p.  +  appendicies.

USEPA.  1982b.   Management  of on-site  and  small  community wastewater
     systems.   Prepared  for USEPA  Environmental Research  Information
     Center by Roy F. Weston, Inc.  EPA 600/8-82-009 Cincinnati, OH, 223
     P-

USEPA. 1983. Final-generic environmental impact statement for wastewater
     management in rural lake  areas.   USEPA Region V,  Water Division,
     Chicago, IL,  variously paged,.

US  Geological  Survey.   1980.  Water resources data  for Michigan:  water
     year  1979.  Report MI-79-1, Lansing MI,  525 p.

Uttormark,  P.D.,  and  J.P.  Wall.  1975.   Lake classification  for  water
     quality management.   University of  Wisconsin Water  Resources Cen-
     ter.
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Vollenweider,  R.A.  1979.   Input - output  models  with special reference
     to the phosphorus loading concept in  limnology.  Schweiz. Z. Hydrol
     37:53-83.

WAPORA,  Inc.  1979.  Affected  environment  preliminary  draft  chapter of
     the Indian  Lake  - Sister Lakes environmental statement.  Submitted
     to USEPA, Region V, Chicago IL, variously paged.

WAPORA, Inc.  1981.   Memorandum to Mr. Charles Quinlan, USEPA, Region V.
     Revised population projections.  Chicago IL.

Zevenboom, W., A.B.  deVaate,  and L.R. Mur. 1982.  Assessment of factors
     limiting  growth  rate  of  j)scillatoria agardhii in hypertrophic Lake
     Wolderwizd,   1978,  by  use  of physiological  indicators.   Limnology
     and Oceanography 27:39-52.
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7.0.  LIST OF PREPARERS

     The Draft  and Final Environmental Statements  (DBS and FES) were pre-
pared by  the Chicago  Regional Office  of  WAPORA,  Inc.,  under contract  to
USEPA Region  V.   US EPA approved the DES and published  it as  the Draft EIS,
and  hereby publish  the  FES as  the Final  EIS.   USEPA, and WAPORA staff
involed  in the preparation  of the  DES/DEIS and  FES/FEIS  during the past
five years include:
USEPA
Charles Quinlan III
Kathleen Schaub
WAPORA. Inc.
Robert France
Larry Olinger
John Johnson
E. Clark Boli
Gerard Kelly
J. P. Singh

Kenneth Dobbs

Gerald Lenssen

Ellen Renzas
Kathleen Brennan
Richard C. McKean
Rosetta Arrigo
Wlliam McClain
Anita C. Locke
Project Officer
Project Officer (former)


Project Administrator
Project Administrator
Project Administrator
Project Administrator
Project Administrator
Project Manager, Environmental
Engineer and Principal Author
Assistant Project Manager and
Principal Author
Project Engineer and Principal
Author
Socioeconomist and Editor
Biologist
Biologist
Biologist
Biologist
Botanist
                                     7-1

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Gregg Larson                            Demographer

Andrew Freeman                          Demographer

Mirza Meghji                            Sr. Water Quality Scientist

Steve McComas                           Water Quality Scientist

Valerie Krejcie                         Graphics Specialist

Peter Woods                             Graphics Specialist

Phil Pekron                             Environmental Scientist

Kent Peterson                           Geologist

John Rist                               Engineer

Jan Saper                               Editor

Wendy Mouche1                           Editor

Mary Bryant                             Production Specialist

Delores Jackson-Hope                    Production Specialist

Shirley Zingery                         Production Specialist

Ross Sweeny, Jr.                        Engineer

Ross Pilling, II                        Editor



     In addition,  several  subcontractors and others assisted  in  the  prepa-
ration  of  this document.   These along with  their  areas of expertise,  are

listed below:


     •    Aerial Survey
               Office of Research and Development
               US EPA
               Las Vegas NV

     •    Septic Leachate Analysis
               K-V Associates, Inc.
               Falmouth MA

     •    Richard Larson
               Soil Scientist
               Traverse City MI
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8.0.  GLOSSARY OF TECHNICAL TERMS

Activated  sludge  process.  A  method of  secondary wastewater treatment  in
     which  a  suspended  microbiological  culture  is  maintained  inside  an
     aerated  treatment basin.   The microbial organisms oxidize the complex
     organic matter in the wastewater to carbon dioxide, water, and energy.

Advanced  secondary treatment.   Wastewater  treatment more  stringent  than
     secondary treatment but not to advanced waste treatment  levels.

Advanced  waste treatment.  Wastewater  treatment  to  treatment levels  that
     provide  for  maximum monthly  average BOD   and  SS concentrations  less
     than  10 ing/1  and/or  total nitrogen removal of greater than 50%  (total
     nitrogen removal = TKN + nitrite and nitrate).

Aerated  lagoon.    In  wastewater  treatment,  a  pond,   usually man-made,  to
     which  oxygen  is  added mechanically  for  the purpose  of decomposing
     organic wastes to elemental forms.

Aeration.  To circulate oxygen through a substance, as in wastewater  treat-
     ment, where it aids in purification.

Aerobic.   Refers  to life or  processes  that occur only  in  the presence  of
     oxygen.

Aerosol.  A suspension of liquid or solid particles in a gas.

Algae.   Simple  rootless  plants  that grow  in  bodies  of  water in relative
     proportion to  the amounts  of nutrients  available.   Algal blooms,  or
     sudden growth spurts, can affect water quality adversely.

Algal bloom.   A proliferation  of algae on the surface of lakes, streams  or
     ponds.  Algal blooms are stimulated by phosphate enrichment.

Alluvial.  Pertaining to material that has been carried by a  stream.

Ambient air.  Any unconfined portion of the atmosphere:  open air.

Ammonia-nitrogen.   Nitrogen in the form of ammonia  (NH  )  that is produced
     in  nature when nitrogen-containing  organic  material  is biologically
     decomposed.

Anaerobic.  Refers  to life  or  processes that occur in  the  absence of  ele-
     mental or free oxygen.

Aquifer.  A geologic  stratum  or unit that contains water and will allow  it
     to  pass  through.   The water  is stored in  and  travels through  spaces
     between  rock  grains in  a sand or gravel  aquifer,  small or cavernous
     openings  formed   by  solution  in  a  limestone  aquifer,   or  fissures,
     cracks, and rubble in harder rocks such as shale.

Artesian (adj.).   Refers to groundwater in a confined aquifer that is under
     sufficient pressure to have a piezometric level above the elevation  of
     the aquifer.
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Artesian well.  A  well that has a static water level higher than the water
     table or free  water  surface.   A well  in  which the static water level
     is higher  than the  land  surface  is  called a  flowing artesian well.

Assessed valuation.   The  value  of  all taxable  general  property  as deter-
     mined by the  municipal assessor of the Wisconsin  Department of Reve-
     nue .

Average annual equivalent  cost.   The expression of a non-uniform series of
     expenditures  as  a  uniform annual amount  to  simply  calculation  of
     present worth.

Bar  screen.   In wastewater  treatment,  a screen that  removes  large float-
     ing and suspended solids.

Base  flow.   The  water in  a stream  channel  that  occurs  typically during
     rainless periods, when stream flow is maintained  largely or entirely
     by discharges of groundwater.

Bedrock.  The solid rock beneath the soil.

Biochemical  oxygen  demand  (BOD).   A bioassay-type  procedure  in  which the
     weight  of oxygen  utilized  by microorganisms to oxidize and assimilate
     the organic  matter  present  per liter of water is  determined. It is
     common to note the number of days during which a test was conducted as
     a subscript to the abbreviated name.  For example, BOD  indicates that
     the results  are based  on  a five-day  long  (120-hour)  test.   The BOD
     value  is  a relative measure  of the amount (load)  of  living and dead
     oxidizable organic  matter   in  water.   A  high  demand may  deplete the
     supply of oxygen in the water, temporarily or for a prolonged time, to
     the degree  that many  or  all  kinds  of aquatic  organisms are killed.
     Determinations  of  BOD  are  useful  in  the evaluation  of the  impact of
     wastewater on receiving waters.

Biota.  The plants and animals of an area.

Chlorination.  The  application   of  chlorine to  drinking water,  sewage or
     industrial  waste  for  disinfection or  oxidation of  undesirable com-
     pounds .

Clarifier.   A settling  tank where solids are  mechanically  removed from
     waste water.

Coliform bacteria.   Members of  a large group  of bacteria that flourish in
     the feces  and/or  intestines  of warm-blooded  animals,  including man.
     Fecal  coliform bacteria,   particularly   Escherichia  coli  (E.  coli),
     enter water mostly  in  fecal matter, such as sewage or  feedlot runoff.
     Coliforms apparently  do not  cause serious human  diseases,  but these
     organisms are  abundant in  polluted waters and they are fairly easy to
     detect.  The abundance  of coliforms in water,  therefore, is used as an
     index  to  the  probability of the occurrence of such disease-producing
     organisms  (pathogens)   as  Salmonella,  Shigella, and  enteric viruses.
     These pathogens are relatively difficult  to detect.
                                    3-2

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Collector sewer.   A  sewer designed and  installed  to  collect sewage from a
     limited  number  of  individual properties  and conduct  it  to  a trunk
     sewe r.

Community.  The  plants  and animals  in a particular  area that are closely
     related through food chains and other interactions.

Cultural resources.  Fragile  and nonrenewable sites,  districts, buildings,
     structures,  or  objects  representative  of   our heritage.   Cultural
     resources  are divided  into three  categories:   historical, architec-
     tural, or  archaeological.   Cultural resources of special significance
     may  be  eligible  for  listing  on  the  National  Register  of  Historic
     Places.

Detention  time.   The average  time  required  for a volume  of water to flow
     through a basin.

Digestion.  In wastewater treatment a closed tank, sometimes heated to 95°F
     where sludge is subjected to intensified bacterial action.

Disinfection.   Effective  killing by chemical or  physical processes of all
     organisms capable of  causing  infectious disease.  Chlorination is the
     disinfection  method  commonly  employed  in  sewage treatment processes.

Dissolved oxygen  (DO).   Oxygen gas (0 ) in water.  It  is utilized in res-
     piration by  fish and other aquatic organisms, and those organisms may
     be  injured or  killed when the  concentration  is  low.   Because  much
     oxygen diffuses  into water from  the air, the concentration  of DO is
     greater, other  conditions  being   equal,  at  sea level  than  at  high
     elevations,  during  periods of high atmospheric  pressure  than during
     periods  of  low  pressure,  and  when the  water  is  turbulent  (during
     rainfall,  in  rapids, and  waterfalls)  rather than when it is placid.
     Because cool  water  can  absorb  more oxygen than warm water,  the  con-
     centration tends to  be  greater at  low  temperatures  than at high tem-
     peratures.    Dissolved  oxygen  is  depleted by  the oxidation of organic
     matter  and of  various  inorganic  chemicals.  Should   depletion  be  ex-
     treme, the water may become anaerobic.

Effluent.  Wastewater or  other liquid, partially or completely treated, or
     in  its  natural  state,  flowing  out of  a  reservoir,   basin,  treatment
     plant, or industrial treatment plant, or part thereof.

Endangered species.  Any  species of animal or plant that is in known danger
     of  extinction throughout  all or  a significant part  of  its  range.

Epilimnion.   Surface waters  of  a  lake  usually  separated from  the  bottom
     layers by oxygen levels or temperature  stratification.

Eutrophic.   Waters  with  an abundant  supply  of nutrients  and  hence  a  pro-
     lific production of  organic matter.

Eutrophication.   The process  of  enrichment  of a water body with nutrients.
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Eutrophic Lakes.   Lakes that  contain an abundant  supply  of nutrients and
     plant life typically of nuisance levels.

Fauna.  The  total  animal life of a  particular  geographic  area or habitat.

Fecal coliform bacteria.  See colifonn bacteria.

Flora.  The  total  plant  life of a  particular  geographic  area or habitat.

Flowmeter.  A  gauge  that indicates  the quantity  of  water  moving through a
     conveyance conduit.

Force  main.    A  pipe designed  to carry wastewater  under pressure  from a
     lift station.

Full equalized value.   The  value of all taxable general property as deter-
     mined by the Michigan Department of Revenue.  This value is determined
     independently of  the assessed  value and reflects actual market value.

Glacial drift.  Rock  and  soil  material picked up  and  transported  by a
     glacier and deposited elsewhere.

Gravity sewer.   A  sewer in which wastewater  flows  naturally down-gradient
     by gravity.

Gravity sewer  system.  A layout of  below grade pipes  in  which the liquid
     flows by gravity to collection point(s) within the system.

Grinder pump (GP).   Pump designed to transfer raw household wastewater to a
     higher elevation and distant location through a pressure pipe.

Groundwater.   All  interstitial water within  soils  and bedrock, especially
     that part in the zone of saturation.

Groundwater  runoff.   Groundwater that is discharged  into  a  stream channel
     as spring or seepage water.

Holding tank.   Enclosed tank, usually constructed  of  fiberglass,  steel or
     concrete, for the  storage  of wastewater prior  to  removal or disposal
     at another location.

Hypolimnion.  Relatively undisturbed waters of a lake bottom separated from
     the  surface  layer by  oxygen   levels  or  temperature stratification.

Infiltration.  The  water entering  a sewer  system  and service connections
     from the  ground  through such means as,  but not limited to, defective
     pipes, pipe joints, improper connections, or manhole walls.  Infiltra-
     tion does not include,  and is distinguished from, inflow.

Inflow.   The  water   discharged  into  a  wastewater  collection  system and
     service connections  from such  sources as,  but  not  limited  to,  roof
     drains,  cellars,  yard and  area drains,  foundation drains,  cooling
     water  discharges,  drains from  springs and  swampy  areas, manhole co-
     vers,  cross-connections  from storm sewers  and  combined sewers,  catch
                                   8-4

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     basins,  surface  runoff,  street wash waters  or  drainage.   Inflow does
     not include, and is distinguished from, infiltration.

Influent.   Water,  wastewater,  or other  liquid  flowing  into  a reservoir,
     basin, or treatment facility, or any unit thereof.

Interceptor sewer.  A sewer designed and installed to collect sewage from a
     series of  collection sewers  and  to convey  it to  a sewage treatment
     plant.

Innovative  technology.   A technology whose use has  not  been widely tested
     by  experience  and  is not  a  variant  of  conventional biological  or
     physical/chemical treatment.

Land treatment.  A method of treatment in which the soil, air, vegetation,
     bacteria, and fungi are employed to remove pollutants from wastewater.
     In  its most simple  form,  the method  includes  three steps:   (1)  pre-
     treatment  to  screen  out  large solids;  (2)  secondary  treatment;   (3)
     application  to   cropland,   pasture,  or  natural  vegetation  to  allow
     plants  and  soil  microorganisms  to  remove  additional  pollutants.
     Little  of  the   applied  water  evaporates,  and  the  remainder  either
     percolates  to  the  water table,  or  runs off  and  is  collected.    The
     water  table  may be  artificially  lowered by  drain  tiles  or  recovery
     wells.

Leachate.   Solution formed when water percolates through  solid wastes, soil
     or other materials and extracts soluble or suspendable substances from
     the material.

Lift  station.  A  facility in  a collector sewer  system, consisting  of a
     receiving chamber, pumping equipment, and associated drive and control
     devices,   that  collects wastewater  from  a low-lying district at some
     convenient point,  from which  it  is lifted to  another  portion  of  the
     collector system or to an interceptor sewer.

Limiting  factor.   A factor  whose  absence,   or  excessive  concentration,
     exerts some restraining influence upon a population.

Loam.  The  textural  class name  for soil having a moderate amount of sand,
     silt,  and  clay.   Loam  soils contain  7  to  27% of  clay,  28 to  50% of
     silt, and less than 52% of sand.

Loess.  Soil of wind-blown origin, predominantly silt and fine sand.

Macroinvertebrates.    Invertebrates that  are  visible  to  the  unaided   eye
     (those retained  by a  standard  No.  30 sieve, which  has  28  meshes  per
     inch or 0.595 mm openings); generally connotes bottom-dwelling aquatic
     animals  (benthos).

Macrophyte.   A large (not  microscopic)  plant, usually  in an  aquatic   ha-
     bitat.  They can be rooted, floating, or submerged plants.

Meltwater.  Water that  originates from the melting of snow or ice, usually
     in association with prehistoric glaciation.
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Mesotrophic.  Waters with a moderate supply of nutrients and no significant
     production of organic matter.

Mesotrophic lake.   Lakes  of  intermediate characteristics between oligotro-
     phic and eutrophic.   They  contain a moderate  supply  of  nutrients and
     plant life.

Methemo&lobinemia.  The presence  of  oxidized hemoglobin in the blood after
     poisoning  by  chlorates,  nitrates,  ferricyanides,  or various  other
     substances.

Milligram per liter (mg/1).   A concentration of 1/1000 gram of a substance
     in  1  liter  of water.   Because  1  liter  of  pure water  weighs  1,000
     grams,  the  concentration also  can  be  stated as  1 ppm (part per mil-
     lion,  by  weight).   Used  to  measure and report  the  concentrations of
     most substances  that commonly  occur  in natural  and  polluted waters.

Moraine.  A mound,  ridge,  or other  distinctive accumulation  of sediment
     deposited by a glacier.

National Register  of Historic  Places.  Official  listing  of  the cultural
     resources of.  the Nation  that are worthy of  preservation.   Listing on
     the National  Register makes  property  owners eligible  to be considered
     for  Federal  grants-in-aid   for  historic  preservation through  state
     programs.   Listing  also  provides  protection  through comment  by the
     Advisory Council on  Historic Preservation on  the  effect  of Federally
     financed,  assisted,  or  licensed undertakings  on historic properties.

Nitrate-nitrogen.   Nitrogen in  the  form of nitrate  (NO ).   It  is the most
     oxidized phase in  the  nitrogen  cycle  in  nature  and occurs  in high
     concentrations  in  the final  stages of biological oxidation.   It can
     serve as a  nutrient  for  the growth of algae and other aquatic plants.

Nitrite-nitrogen.   Nitrogen  in the  form of nitrite  (NO  ).  It  is  an in-
     termediate stage in the nitrogen cycle in nature.  Nitrite normally is
     found  in  low  concentrations  and  represents a  transient  stage  in the
     biological oxidation of organic materials.

Nonpoint source.   Any area,  in contrast to a pipe or other structure, from
     which pollutants  flow into  a body of  water.   Common pollutants from
     nonpoint sources are sediments from construction sites and fertilizers
     and sediments  from agricultural soils.

Nutrients.   Elements or compounds essential as raw materials for the growth
     and development  of  an organism;  e.g., carbon,  oxygen,  nitrogen, and
     phosphorus.

Oligotrophic.   Waters with a  small supply of nutrients and hence an insig-
     nificant production of organic matter.

Oligotrophic lakes.  Lakes  that  have a low supply of nutrients and contain
     little organic matter.   Such lakes are  characterized by  high water
     transparency and high dissolved oxygen.
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Ordinance.  A municipal or county regulation.

Outwash.  Soil  material  carried by melt water from a glacier and deposited
     beyond the marginal moraine.

Outwash plain.  A  plain  formed by material  deposited  by melt water from a
     glacier  flowing  over a  more  or  less  flat surface  of  large  area.
     Deposits  of   this  origin  are usually  distinguishable  from ordinary
     river deposits  by the  fact that  they  often grade  into moraines and
     their  constituents   bear  evidence of  glacial  origin.   Also  called
     frontal apron.

Percolation.  The  downward movement  of water through pore spaces or larger
     voids in soil or rock to the water table.

pH.  A measure of the acidity or alkalinity of a material, liquid or solid.
     pH is represented on a scale of 0 to 14 with 7 being a neutral state;
     0, most acid;  and 14, most alkaline.

Phosphorus.   An essential food element that can contribute to the eutrophi-
     cation of water bodies.

Photochemical  oxidants.    Secondary   pollutants   formed  by  the  action  of
     sunlight on nitric  oxides  and  hydrocarbons in the  air;  they  are the
     primary components of photochemical smog.

Piezometric level.   An imaginary point that represents  the  static  head of
     groundwater and is  defined by  the  level  to  which water  will  rise.

Plankton.   Minute  plants  (phytoplankton)  and  animals  (zooplankton)  that
     float  or  swim  weakly  in  rivers, ponds,  lakes,  estuaries, or  seas.

Point  source.   In  regard  to  water,  any  pipe,  ditch,   channel,  conduit,
     tunnel, well,  discrete operation,  vessel or other  floating craft,  or
     other confined  and  discrete  conveyance from  which a  substance  con-
     sidered to be a  pollutant is,   or may be, discharged  into a  body of
     water.

Present Worth.  May  be thought of as the  sum,  which if  invested now  at a
     given rate,  would  provide exactly  the  funds  required  to make  all
     necessary expenditures during the life of the project.

Pressure  sewer  system.   A wastewater collection  system  in which household
     wastes are collected in the building drain and conveyed therein to the
     pretreatment  and/or  pressurization facility.  The  system consists  of
     two  major  elements,   the  on-site or pressurization  facility,  and the
     pressurized sewer main.

Primary  treatment.    The   first  stage  in  wastewater  treatment, in  which
     substantially   all  floating  or  settleable solids  are  mechanically
     removed by screening and sedimentation.

Prime farmland.   Agricultural lands,  designated Class I or II (occasionally
     some  Class  III), having  little  or no  limitations  to profitable  crop
     production.
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Pumping station.   A facility  within  a  sewer  system that  pumps  sewage or
     effluent  against  the  force  of gravity  through an  enclosed  conduit.

Runoff.   Water from  rain,  snow  melt,  or  irrigation  that flows  over  the
     ground surface and returns to streams.  It can collect pollutants from
     air or land and carry them to the receiving waters.

Sanitary  sewer.   Buried  pipelines  that  carry only  domestic  or commercial
     wastewater, not stormwater.

Screening.  Use of  screens  to remove coarse floating  and suspended solids
     from sewage.

Secondary  treatment.   The second  stage  in the  treatment of  wastewater in
     which bacteria are utilized to decompose the organic matter in sewage.
     Effective secondary  treatment  processes  remove virtually all floating
     solids and settleable  solids,  as  well as 90% of the BOD and suspended
     solids.  USEPA regulations define  secondary treatment as 30 mg/1 BOD,
     30 mg/1 SS, or 85% removal of these substances.

Seepage cells.  Unlined  wastewater  lagoons designed so that all or part of
     wastewater percolates into the underlying soil.

Septic  Snooper.   Trademark  for the ENDECO (Environmental Devices Corpora-
     tion) Type 2100 Septic  Leachate Detector.   This instrument consists of
     an underwater  probe, a water intake  system, an analyzer control unit
     and  a  graphic recorder.   Water  drawn through  the  instrument is con-
     tinuously analyzed  for specific fluorescence  and  conductivity.   When
     calibrated against  typical effluents,  the  instrument can  detect  and
     profile  effluent—like  substances  and  thereby  locate septic  tank lea-
     chate  or other  sources  of  organic  decomposition  products  entering
     lakes and streams.

Septic  tank.   A buried  tank  used  for  the collection  of domestic wastes.
     Bacteria  in  the  wastes  decompose  the organic  matter, and  the sludge
     settles  to  the bottom.   The effluent flows out  to another treatment
     and  disposal  facility.   Sludge  is  pumped  out at  regular  intervals.

Septic  tank  effluent  pump  (STEP).   Pump  designed  to  transfer settled  ef-
     fluent  from  a septic  tank to a  higher elevation  through  a pressure
     pipe.

Septic  tank-soil  absorption  system.   A  system  of  wastewater  disposal in
     which large solids are  retained in a  tank; fine solids and liquids are
     dispersed into the surrounding soil by a system of pipes.

Settling tank.  A holding area for wastewater, where heavier particles sink
     to the bottom and the liquid decanted.

Shoaling.   The  bottom effect  that  influences the  height  of  waves moving
     from deep to shallow water.

Slope.  The incline of the surface of the  land.  It  is usually expressed as
     a  percent  (%)  of  slope that is the elevation  difference per  100 feet
     of horizontal distance.
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Sludge.  The  accumulated  solids that have been separated  from  liquids such
     as wastewater.

Soil association.   A group of  soils geographically associated  in a charac-
     teristic repeating pattern and defined and delineated as a single map-
     ping unit.

Soil textural  class.   The classification of soil material according to the
     proportions  of sand, silt, and clay.   The  principal textural classes
     in  soil,  in increasing  order  of  the amount of  silt  and clay, are as
     follows:   sand,  loamy sand,  sandy loam, loam,  silt  loam, sandy clay
     loam,  clay loam, silty  clay loam, sandy clay,  silty clay,  and clay.
     These  class  names are modified to indicate the  size of the sand frac-
     tion or the presence of  gravel, sandy loam, gravelly  loam, stony clay,
     and  cobbly  loam,  and are  used on  detailed  soil maps.   These  terms
     apply  only to  individual  soil  horizons or to the  surface layer of a
     so il type.

Storm  sewer.   A  conduit  that  collects and  transports storm water runoff.
     In many  sewerage systems,  storm sewers are separate  from  those carry-
     ing sanitary or  industrial wastewater.

Stratification.   The  condition of  a lake,  ocean,  or other  body  of water
     when the water column is divided  into  a  relatively cold bottom layer
     and a relatively warm surface layer, with a thin  boundary  layer (ther-
     mocline)  between them.   Stratification  generally  occurs  during the
     summer and during periods  of ice  cover  in  the winter.  Overturns, or
     periods of mixing,  occur in the spring and autumn.  This  condition is
     most common  in middle latitudes and is related  to weather conditions,
     basin morphology, and altitude.

Supernatant.  The  liquid  that remains  on the surface  after the solids have
     settled out in a wastewater treatment process.

Surface water.  All waters on the earth's  surface  such as streams, lakes,
     and oceans.

Suspended solids  (SS).  Small solid particles that contribute to turbidity.
     The examination  of   suspended  solids and the  BOD test constitute the
     two main determinations  for water  quality that are performed at waste-
     water treatment facilities.

Threatened  species.  Any  species  of   animal  or  plant  that is  likely  to
     become endangered  within  the  foreseeable future  throughout  all  or a
     significant part of  its  range.

Till,,   Unsorted  and unstratified  drift,  consisting  of  a  heterogeneous
     mixture of clay,  sand,  gravel,  and boulders, that is deposited by and
     underneath a glacier.

Trickling filter  process.  A method of  secondary  wastewater treatment  in
     which  the  biological growth  is attached to a fixed medium, over which
     wastewater is  sprayed.   The filter organisms biochemically oxidize the
     complex organic matter in the wastewater to carbon dioxide, water, and
     energy.
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Topography.  The configuration  of  a surface area  including  its  relief,  or
     relative  elevations,   and  the  position  of   its  natural and  manraade
     features.

Trophic status.  A measure of the productivity of a body of water typically
     expressed as  oligotrophic  (least),  mesotrophic,  and eutrophic (great-
     .-st) .

Trunk  sewer.   A  sewer  designed  and  installed  to  collect  sewage  from a
     number of collector sewers and conduct it to an interceptor sewer or,
     in some cases, to a sewage treatment plant.

Unique  farmland.   Land,  other  than prime  farmland,  that is  used  for the
     production of specific high  value  food and  fiber  crops and that has
     the  special  combination of soil  quality, location,  growing seasons,
     and  moisture  supply  needed  to economically  produce  sustained  high
     quality and/or high yields of  a specific crop under modern management.

Wastewater.   Water  carrying dissolved  or  suspended  solids from  homes,
     farms, businesses, and industries.

Wastewater stabilization lagoon.   In wastewater  treatment, a shallow pond,
     usually man-made,  in which sunlight,  algal  and  bacterial  action and
     oxygen  interact  to decompose  the organics.    Oxygen  is added  to the
     water by natural air to water  interchange.

Water  quality.   The relative  condition  of  a  body of  water,  as judged by
     a  comparison  between  contemporary  values  and  certain more  or  less
     objective  standard  values for  biological,  chemical,  and/or physical
     parameters.   The  standard values  usually  are  based  on  a specific
     series  of intended uses,  and  may  vary  as  the  intended  uses vary.

Water  table.   The upper level  of   groundwater  that is  not  confined by an
     upper impermeable  layer  and  is under atmospheric pressure.   The upper
     surface of  the substrate  that is wholly saturated with groundwater.

Wetlands.  Those areas that are inundated by surface or ground water with a
     frequency sufficient to support and under normal circumstances does or
     would support a prevalence of vegetative or aquatic life that requires
     saturated  or  seasonally  saturated  soil  conditions  for  growth and
     reproduction.
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9.0.  INDEX

Aerial photographic survey, 2-4, 2-6, 2-14, 5-3

Agricultural lands:
     conversion of, 2-65
     impacts on, 4-4 - 4-5
     See also Land uses

Air quality.  See Atmosphere

Aquatic biota.  _Se_e Wildlife, aquatic; Vegetation, aquatic

Archaeology.  See Cultural resources

Architecture.  See Cultural resources

Atmosphere:
     impacts, 3-1, 4-2, 4-10 - 4-11
     odors, 3-2, 4-11 - 4-12

Bainbridge Township, 1-1, 1-3

Berrien County, 1-1
     Health Department, 1-3

Cable Lake:
     Sanitary questionnaire, 2-7
     impacts on, 4-17, 5-5

Cass County, ii, 1-1

Centralized alternatives:
     costs, 2-40, 2-43 - 2-44, 2-45, 5-9
     impacts of, 2-65 - 2-66, 4-15 - 4-20, 4-22, 4-24, 4-41
     in Draft EIS, iii, 1-4 - 1-5
     management of, 2-67
     recommended action, x - xi, 2-71 - 2-72
     summary of, iv - vi, 2-47 - 2-56, 2-57

Chlorination, 4-40
Cluster systems, 2-38 - 2-39
Construction Grants Program.  See Funding, federal

Costs, 2-28
     cost effectiveness analysis, 1-5
     residential user, 4-28 - 4-31
     summary for alternatives, vii, 2-50, 2-62 - 2-64

Crooked Lake:
     characteristics, 3-11 - 3-12
     groundwater near 2-4, 2-12, 3-20
                                  9-1

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     land use near, 3-45
     sanitary questionnaire, 2-7
     impacts on, 4-17

Cultural Resources:
     archaeological surveys, 3-56 - 3-58
     historic sites, 3-57 - 3-58, 4-9, 5-11
     impacts on, 4-9, 4-39 - 4-40
     Indian tribes, 3-55 - 3-56

Decentralized alternatives:
     impacts of, 2-65, 4-15 - 4-20, 4-21
     in Draft EIS, iii, 1-5
     management of, 2-69 - 2-71
     recommended action, x, 2-73, 5-10
     summary, vi - vii, 2-56, 2-58 - 2-61

Dewey Lake :
     characteristics, 3-11
     groundwater plumes, 2-4
     impacts on, 4-17
     land use, 2-33, 3-42
     limnological study, 1-3 - 1-4, 2-17, 3-13 - 3-15
     sanitary questionnaire, 2-7
         ic leachate, 2-19
Dowagiac Creek, 3-2, 3-11, 4-19

Dowagiac treatment plant, v, vi, 2-21, 3-11, 4-43, 5-9

Economics :
     cost criteria, 2-29
     impacts on, 4-8, 4-26, 4-28 - 4-32, 4-35, 5-12
         also Costs
Employment, 3-49
     unemployment, 3-50 - 3-51
     impacts on, 4-7 - 4-8, 4-25 - 4-26

Energy:
     sources, 3-55, 4-42
     impacts on, 4-9, 4-27

Environmental Impact Statement:
     issues, 1-9, 1-10
     process, 5-12 - 5-L3
     required, 1-4, 1-6

Eutcophication.  jxee Water quality, trophic status

Facility Plan, 2-67
     grant application, i, 5-5
     preliminary draft, 1-4
                                  9-2

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Farmers Home Administration, i, 2-63, 4-32

Fauna.  See Wildlife

Funding:
     Federal, 1-6, 1-8, 2-66 - 2-67
     local, 1-7
     project, 4-27
     state, 1-7, 2-13, 2-66 - 2-67
     _See_ also Finances

Geology, 3-2 - 3-4, 3-5

Groundwater, 3-21 - 3-22, 3-23
     effluent plumes, 2-4 - 2-5
     impacts on, 4-3, 4-21 - 4-24
     non-degradation policy, 5-4
     surveys, 2-12 - 2-13, 2-16 - 2-17, 3-20, 3-24 - 3-26
     See also  Appendic C

Historical resources.  See Cultural resources

Impacts:
     adverse, 4-35, 4-41
     construction, vi, 2-63, 4-2 - 4-10
     operation, viii, 4-10 - 4-27
     public finance, 4-27
     secondary, 4-31 - 4-35

Income, 3-50

Indian Lake, ii, 1-1 - 1-2
     characteristics 3-7, 3-11 - 3-13
     construction grants approval, 1-4
     discharge permit, 2-32
     impacts on, 4-17
     limnological study, 3-13 - 3-15
     on-site system problems, 2-4, 2-12, 2-14, 2-19, 3-20
     sanitary surveys, 1-1, 2-7, 2-10, 2-19
     separate system for, 2-73, 5-5
     waste water loads, 2-26 - 2-27

Indian tribes.  See Cultural resources

Keeler Lake 2-4, 2-15, 2-21

Lakes, 1-1
     characteristics, 3-7, 3-12, 3-21, 3-27
     water levels, 4-20
     phosphorus loadings, 4-16
     suspended solids, 5-5
     wastewater load projections, 2-26 - 2-27
                                  9-3

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Land application, 2-33 - 2-34, 4-4, 4-12 - 4-15

Land use, 3-42 - 3-44
     development, 3-47 - 3-48, 5-10
     impacts on, 4-5 - 4-6, 4-25, 4-33 - 4-34
     Indian lands, 3-55 - 3-56
     mining 3-4, 5-12
     prime farmland, 3-45 - 3-46, 4-6 - 4-7, 4-33
     recreation, 3-51 - 3-52

Magician Lake:
     characteristics, 3-12 - 3-13
     impacts on, 4-17
     land use near, 3-45, 3-52
     limnological study, 3-13 - 3-15
     on-site system problems, 2-4, 2-7, 2-19, 3-30

Meteorology.  See Atmosphere

Michigan Department of Natural Resources, ii, 1-3, 1-4
     construction grants program, 1-7
     effluent standards, 2-33, 2-39, 3-11, 5-4
     effluent permits, 2-26, 2-28, 2-32

No Action Alternatives:
     costs, 5-6
     evaluation as recommended action, 2-71
     impacts, viii, 2-65, 4-16, 4-19, 4-21 - 4-23
     nutrient loadings, 4-15 - 4-16

Noise pollution, 3-1, 4-2

Notice of Intent, iii, 1-4

Odors.  See Atmosphere

On-site systems, 1-1, 5-5
     drainbed, 2-35, 2-37
     dry well, 2-35 - 2-26
     existing, 2-1 - 2-3
     septic tank, 2-34
     problems with, 1-1, 2-13 - 2-21, 2-61, 3-8, 3-9 - 3-10, 5-3 - 5-4, 5-9,
      5-7, 5-8
     septage disposal, 2-21, 2-26, 2-39 - 2-40, 5-6 - 5-7

Phosphorus:
     ban on detergent, 2-30
     groundwater 4-21 - 4-22
     loadings, 3-15, 3-18 - 3-21, 4-16 - 4-17, 4-18
     non-apatitic inorganic phosphorus, 3-13, 3-15 - 3-16
     Pipestone Lake, 2-10 - 2-11
     sorption, 4-13 - 4-14
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Pipestone Lake, ii
     characteristics, 3-7, 3-11, 3-12, 3-27
     impacts on, 4-17, 4-19
     land use near, 3-45
     limnological study, 2-17, 3-13 - 3-15
     on-site system problems, 2-4, 2-10, 2-16, 2-18 - 2-19,
      3-20
     service area estimates, 3-33, 3-36
     water quality, 1-3, 2-4, 2-10 - 2-11, 3-11, 3-19, 3-20

Population:
     growth, 3-31 - 3-33, 3-34, 3-40
     impacts on, 4-25, 4-32 - 4-33
     projections, 3-38 - 3-42
     service area estimates, 3-33 - 3-38

Property values, 3-52 - 3-53

Public hearings, iii, 5-12

Recommended Action, x, 2-73
     selection of, 2-62, 2-71 - 2-73

Recreation and tourism, 3-51
     impacts on, 4-8 - 4-9, 4-26, 4-34 - 4-35

Round Lake:
     groundwater near, 2-4, 2-12, 2-13
     land use near, 3-45, 3-52
     impacts on, 4-17, 5-4 - 5-5

Sanitary surveys, 2-3, 2-22 - 2-25
     aerial, 2-4 - 2-6
     mailed questionnaire, 2-6 - 2-7, 2-8
     septic leachate, 2-3, 2-16, 3-20
     tacgetted, 2-11 - 2-12
     See also  Appendices A, B and E.

Septic tanks.  See Wastewater treatment systems, on-site

Soils:
     absorption systems, 2-38, 3-8 - 3-10
     associations, 3-4 - 3-7
     impacts, 4-2, 4-12 - 4-15, 4-37 - 4-38,  5-11
     land application, 4-12

State funding.  See Funding, state

Sister Lakes.  See Lakes

Terrestrial vegetation.  See Vegetation, terrestrial
                                  9-5

-------
Tourism,  jee Recreation and tourism

Transportation, 3-56, 4-9, 4-26 - 4-27, 4-36, 4-37, 4-38

Vegetation:
     aquatic, 3-13, 3-14, 3-16
     terrestrial, 3-29 - 3-30, 4-3 - 4-4, 4-25
     threatened or endangered, 3-29 - 3-30, 4-36

Waste reduction, 2-30 - 2-31

Wastewater treatment systems.  See On-site systems, Centralized alternatives,
     Decentralized alternatives, and No Action alternative

Water quality:
     coliform bacteria, 4-19
     effluent limits, 1-8 - 1-9, 2-26 - 2-27, 2-32
     impacts on, 2-65 - 2-66, 4-3, 4-33 - 4-34
     nutrient enrichment, 2-17, 3-15-3-21, 4-15
     surface, 2-15 - 2-17, 3-11
     suspended solids, 4-19 - 4-20
     trophic status, 3-15, 3-21, 4-15, 5-4
     See also Groundwater, Phosphorus, and Lakes

Wetlands, 3-30
     development contraints, 3-49
     impacts on, 4-4 - 4-5, 4-6, 5-10 - 5-11

Wildlife:
     aquatic 3-22, 3-27, 3-28, 4-34
     terrestrial, 3-27, 3-29, 4-3 - 4-4, 4-25
     threatened or endangered, 3-27, 3-29, 4-35
                                  9-6

-------
   APPENDIX A
SANITARY SURVEY

-------
Introduction

     This  survey  was  carried out upon  request  from USEPA to better define
project needs  and develop more specific project alternatives (Contract No.
68-01-4612, DOW No.  12,  Modification No.  80).   This task became necessary
because existing  data was  inadequate to  clearly  demonstrate that Federal
involvement in a  project is justified to mitigate a public health or water
quality problem.   This  data  will  supplement  existing  data  so  that  the
project alternatives  can  be  designed  and  costed  in  greater  detail.  The
field work  commenced  28  October and was completed by 17 November 1982.  It
was  conducted  by   staff  from WAPORA Inc.  and USEPA.   Well water chemistry
analyses  were  conducted  by  WAPORA,  Inc. and fecal  coliform  tests by IHI-
Kemron, Inc.

Description of Survey Areas

     The  areas to be  covered by the sanitary survey included those identi-
fied in  the Draft EIS to  be served by  the  cluster  systems under Alterna-
tives  8A  and  8B.  Some  surveys were conducted  outside of these areas be-
cause too  few  residents could be located within these areas.  The number of
surveys was based  on a representative  15% sample of residences located
within the  service areas.   Problems with the on-site disposal systems were
anticipated, based on discussions  with the  Sanitarians,  the soil maps, and
previous  analyses of  the project area.   The needs  documentation section
(Section  2.1.  Draft   or  Final  EIS)  describes  the analysis  by  which these
areas were selected for off-site treatment by cluster systems.

Survey Form and Procedure

     The sanitary survey form used in the Indian Lake and  Sister Lakes area
is appended to this  document.   The survey form requests  information on the
folLowing:

     •    Location, description, and ownership of property
     •    Resident occupancy, household size, and duration of use
                                  A-2

-------
     •    Description  and service  history of  onsite  waste treatment
          system
     •    Description of water use  appliances and patterns
     •    Site characteristics and  sketch  of treatment system property
     •    Description and location  of the  water well.

     The  residences  were  located on property maps prepared by Gove Associ-
ates,  Inc.  and  were verified  with  the  tax  property  descriptions.   The
surveys were  conducted  between October  28 and  November  17, 1982.  Contact
was  attempted at nearly  every residence  at  least  once.   Some residences
were revisited  if  there was a reasonable  chance of  finding someone at home
at a later time.   Generally,  these  survey areas were  characterized by a
high percentage  of  seasonal  residences  so that most visits resulted in no
contacts.

     Surveyors  gave a  brief  introduction of  their  task  and  the  survey
itself.   Respondents  were   generally  helpful  in  relating  the necessary
information and  showing the  surveyors the location  of the sanitary facil-
ities.   Approximately 8 to 10 interviews were conducted per day.

     In  conjunction with the  sanitary  survey,  well water  samples  were
collected for analysis  of water quality parameters.   Samples were analyzed
for coliform bacteria content and chemical  constituents.  Well water sample
locations  were  screened  from  information on  the   sanitary  surveys.   The
target wells  were  those  with a depth  of  less than 40  feet  and protected
from surface  contamination.   Samples  were not drawn  from systems  with  a
water softener.

     The chemical analyses were conducted  according  to Methods for Chemical
Analysis of Water and  Wastes,  USEPA, 1979, Cincinnati OH.   The respective
sections  from that  manual  that detail  the analyses are chlorine (325.3),
ammonia (350.3),  total Kjeldahl   nitrogen  (351.2),  nitrites   and   ni-
trates    (353.3), and  total phosphorus  (365.3).  The  analysis  for  fecal
coliform was conducted  according to the membrane filter technique described
in Section  909C of  the Standard Methods  for the Examination  of Water and
Wastewater, APHA, 1980, Washington  DC.
                                  A-3

-------
Results and Discussion

     The information  from  the sanitary surveys is summarized in Table A-l.
The locations  of  the  surveys are shown in Figure A-l.  A great deal of in-
formation was  unavailable  or  was obscured  by  differences in terminology.
In numerous cases,  the  survey forms were not completely filled out because
the resident was not knowledgeable about the facilities.

     Occupancy was noted for each residence.  A structure was identified as
permanent if it was occupied more than 6 months of the year and seasonal if
occupied less than 6 months.  Of the residences surveyed 99 are permanently
occupied  and   20  are  seasonally  occupied   (one was  not asked).   Based on
observations of the surveyors and discussions with neighbors, approximately
75% of  the permanent  residences  in the target areas  were surveyed.  Some
areas, such as the  leased  properties on Indian Lake on the north and east
sides, residences were  not surveyed because no one  was present.  A higher
percentage of  residences  surveyed around Upper Crooked  Lake were seasonal
as compared to the other lakes.  No readily apparent reason exists for this
difference.

     The types  of  sewage  disposal systems encountered were numerous (Table
A-l).   The components  encountered were septic tanks, grease traps, privies,
dry wells, block  trenches, drain beds, raised drain beds, and tile lines.
These occurred in many combinations also.  The most common, septic tank and
dry well,  was encountered  in 50 situations.  The next  most common system
was the septic tank and drain bed, found on 24 properties.  A common system
encountered (19 systems) was the septic tank and dry well with another soil
absorption system  added to  it to  increase capacity.   Raised  drain beds,
designed to overcome  a  high water  table site  limitations were encountered
in 12 instances, 7 required lift pumps.

     Grease traps  were  common, especially  around  Pipestone  Lake.  Most of
these  discharged  to  a soil  absorption system independent  of the  one to
which  the  septic  tank discharged.  Separate  systems for laundry washwater
were common also.   It typically consisted of a tile line with or without a
grease trap.   Because of  the complexity of  the waste  disposal facilities,
                                  A-4

-------
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                                                                       43

                                                                              Sanitary Survey Conducted

                                                                        •-48  Sanitary Survey & Well
                                                                              Water Sample Conducted
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                      ^-~^j>i^V^  r~^j~^f°) r*\ /i  >V^ZJt3 \%.JI/^ \vr-"- vio.    . t/^*~^5aW! /   "--•*"-. --'

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                                                   A-6

-------
only  the  primary  system was tabulated.  Less  than  one-quarter  of  the  resi-
dents reported  the  size of the  septic  tank and an  even  smaller proportion
reported  the size of the soil absorption system  (Table  A-l).

     The  age of  the  system  (Table  A-2)  is  tabulated  by the  age  of  its
oldest  reported part.   Of the  total  of 120,  7 were less than 5 years,  15
were  5  to  10  years old, 29 were  11  to 20  years  old,  and 53  were greater
than  20 years  old.   Considering the  fact  that most  shoreline cottages were
constructed  prior to  1930,  it is  not unusual  to have  a  high proportion of
the  systems replaced.   Also,  most  of  the people  surveyed  are  permanent
residents who have begun to occupy  the residence year round only within  the
last  15 years.   Many of these people had  thoroughly remodeled  and expanded
their residence at  which time the  on-site  system was replaced  or  upgraded.

     A  total of 39  systems  have had major  repairs of  the soil absorption
system out of the 120 systems surveyed  (Table  A-2).  The  most common repair
has  been  the addition  of  a  drain bed or  drainfield  (20).   The next most
common  repair  has  been the addition of  13 dry wells  or block  trenches.
Restoning of dry wells have been  performed on 6 systems.  The septic tank
has been replaced for 8 systems and pipes have been  replaced or repaired on
16 systems.  Many  of these repairs appear  to  coincide  with the change from
seasonal  to permanent  occupancy.   Of  these  repairs,  3  are  indicated   as
occurring prior  to  1970.   Health department records indicate  only 25 such
repairs.  Thus, a number of repairs  have  been made without the benefit  of
the  design  expertise  of the sanitarians and so  may be  less than  adequate.
No area appears  to  have a greater concentration of  repairs than any other.

     The  survey  included an  attempt  to assess  how regularly   the resident
pumped the septic tank  (Table A-2).   The results of  this  question are  some-
what ambiguous because many residents reported when  it  had last been pumped
and  did not indicate  what  the  pumping  frequency  had  been.   A number  did
report whether  they pump  regularly  and for what  reason.   The number  who
pump annually or have  pumped  within  the last  year totaled 28.   The overall
average appears to  be  once every four years,  a reasonable rate considering
the numerous 500 and  750 gallon septic tanks.   The  number of residents  who
                                  A-7

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pump the  septic  tank on a  rotation  of  1 to 3 years or had the tank pumped
in the 1979 to 1981 period totalled 41.  Twenty residents reported that the
septic tank has not been pumped subsequent to 1977.

     A number  of  residents  indicated that they have  ongoing  problems with
their system  (Table  A-2).   A total of 15 indicated that they have seasonal
backups or  sluggish  drains.   The greatest concentration of these are found
around Indian  Lake.   Of 23 surveys,  9  indicated  that they experience this
problem.   Five residents  experienced seasonally wet ground over their soil
absorption system.

     The  well  water  sampling  results are presented  in Table  A-3 and the
locations are  plotted in Figure A-l.   The nitrate-nitrogen data indicated
that some groundwater had  levels above or near the 10 mgN/1 Federal drink-
ing water standard.  The majority of wells sampled (75%) had concentrations
of less than 1 mgN/1.  Thirteen wells (25%) had concentrations greater than
1 mgN/1;  and 3 out of these 13 wells had concentrations greater than the 10
mgN/1 criteria for domestic  water supply.  The  data also  indicated that
many of the higher nitrate-nitrogen concentrations are found in association
with higher concentrations  of chlorides.  Thus, the  most  likely source of
nitrates  of these  wells appeared to be related to wastewater sources.  The
total  phosphorus   concentrations  in  the  well  samples showed  no  apparent
correlation  to higher  nitrate  or high  chloride concentrations.   (Other
sources of  phosphorus  are  probably the major factors.)  The other nitrogen
species tested, ammonia-nitrogen  and total Kjeldahl nitrogen, demonstrated
little correlation with nitrate concentrations or with chloride concentra-
tions.   (A number of the values are inexplicable and are likely sampling or
laboratory error).

     A slight  correlation  between depth of well  and  nitrate concentations
appears to  exist.   Of  the  25  wells  for which the  depth  of  the  well was
known,  4  of  11 less than 50  feet  in depth had nitrate-nitrogen concentra-
tions greater  than 1 mgN/1.   Of  those  greater  than 50 feet,  4 of  14 had
concentrations greater than 1 mgN/1.
                                  A-9

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     No fecal  colitorm  could be colonized  from  any  of the well water sam-
ples.  Thus, no wells showed bacterial contamination from fecal coliform at
the present time.

     Elevated  levels  of  nitrates appear to be occurring  in certain areas.
The north  shorelands  of  Upper Crooked Lake have a greater concentration of
wells with nitrate  levels above 1 mgN/1.   Well  logs in the area show that
most of the wells  in the area have no aquiclude between the ground surface
and  the  well  screen.   This  allows  nutrients to  pass unimpeded  into the
water table and toward the wells.  Another area where a large proportion of
wells have nitrogen concentrations above 1 mgN/1  was  the southwest shore-
lands of  Indian Lake.   The  levels of ammonia and  total  Kjeldahl nitrogen
were  typically elevated  above  1 mgN/1 in  this  area while  nitrate concen-
trations and chloride concentrations  were low.  This indicates that waste-
water is  probably  not  the source for  the nutrients.  It  should be noted
that only  3 out of 49 wells actually showed nitrate  levels above the stand-
ard of 10  mgN/1 however, elevated nutrient contents are  indicators of po-
tential groundwater pollution areas.
                                  A-ll

-------
               SANITARY SURVEY. FOR CONSTRUCTION GRANTS APPLICATION
Resident:                                         Study Area:

Owner:                                            Surveyor/Date:

Address of                                        Weather:
  Property:

Lot Location:                                     Approximate Lot Dimensions:

Tax Map Designation:                              	feet by 	feet

Preliminary Resident Interview

Age of Dwelling: 	 years    Age of sewage disposal system:  	years

Type of Sewage Disposal System:
Maintenance: 	years since septic tank pumped.  Reason for pumping:_
             	years since sewage system repairs (Describe below)
             Accessibility of septic tank manholes (Describe below)
Dwelling Use:    Number of Bedrooms:	actual, 	potential, 	 Planned
                 Permanent Residents:	adults, 	children
                 Seasonal Residents:	, length of stay	
                 Typical Number of Guests:	, length of stay	

If seasonal only, plan to become permanent residents:	 In how many years?	

Water Using Fixtures (Note "w.c." if designed to conserve water):

 	Shower Heads             	Kitchen Lavoratories       	Clothes Washing Machine
    Bathtubs                 	Garbage Grinder            	Water Softener
    Bathroom Lavoratories    	Dishwasher                 	Utility Sink
    Toilets                      Other Kitchen                  Other Utilities
     Plans for Changes:

Problems Recognized by Resident:
Resident Will Allow Follow-Up Engineering Studies: 	Soil Borings 	Groundwater
                                                   	Well Water Sample
                                            A-12

-------
            SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
Water Supply

Water Supply Source (check one)
        Public Water Supply
        Community or Shared Well
        On-Lot Well
        Other (Describe)
If public water supply or
  community well:
If shared or on-lot well:
  	 Fixed Billing Rate $
  	 Metered Rate       $
  Average usage for prior year:
        Drilled Well
        Bored Well
        Dug Well
        Driven Well
Well Depth (if known):

Well Distance:
feet total

feet to house
              	 feet" to soil disposal area


Visual Inspection:  Type of Casing

                    Integrity of Casing

                    Grouting Apparent?

                    Vent Type and Condition

                    Seal Type and Condition

Water Sample Collected:

                    	 No

                    	 Yes

                    (Attach Analysis Report)
feet to water table

feet to septic tank

feet to surface water
                                     A-13

-------
               SANITARY SURVEY FOR CONSTRUCTION GRANTS APPLICATION
Surveyor's Visual Observations of Effluent Disposal Site:
Drainage Facilities and Discharge Location:




     Basement Sump




     Footing Drains




     Roof Drains




     Driveway Runoff




     Other









Property and Facility Sketch
                                        A-14

-------
     APPENDIX B
WATER QUALITY SURVEY
    OF AREA LAKES

-------
                    WATER QUALITY SURVEY OF AREA LAKES

Introduction

     This  survey  was  carried out  upon  request  from USEPA  (Contract No.
68-01-4612, DOW No.  12,  Modification No. 80) to gather additional informa-
tion  for  defining  the  trophic status  of the  lakes  of the  project area.
This  task  was undertaken  because  existing  information  was  inadequate for
drawing comparisons  among the  lakes and for clarifying whether the lakes
are experiencing  water quality problems attributable to  the existing on-
site  systems.   The  lake  sampling  took  place  during  two periods,  27-30
October and  16-20 November  1982,  and was conducted  by  staff from WAPORA,
Inc.  Laboratory  tests were  conducted by WAPORA,  Inc.  for water chemistry
and by IHI-Kemron, Inc. for fecal coliform counts.

Survey and Laboratory Methods

     Lake water samples  were collected at two  or  more stations in each of
the eight  lakes.   At each of the stations shown in Figure B-l, water qual-
ity samples were  taken at two depths:  3 feet below  the surface and 3 feet
above the  bottom.   At each station Secchi disk measurements were taken and
dissolved oxygen and temperature profiles were recorded.  During the second
sampling visit (16-20 November), surficial lake sediments were collected at
each station using a ponar grab sampler.

     The water samples  were  tested  according  to these  sections  in  the
Methods for Chemical Analysis of Water and Wastes, (USEPA,  1979, Cincinnati
OH): total phosphorus (356.3), total Kjeldahl nitrogen (351.2), and nitrite
and nitrate nitrogen (353.3)).  Chlorophyll 
-------
Figure B-1. Lake water quality and sediment sampling stations (October and November  1982).
                                            B-3

-------
1-11].   Chlorophyll degradation  products were tested similar to the method
of  Vallentyne,  J.R.  1954.   [Sedimentary Chlorophyll  Determination  as  a
Paleobotanical Method.   Canadian  J.  Botany.  33:304-13], and is reported as
sedimentary pigment  degradation units  (SPDU)  per  gm dry weight.   Organic
matter content of the surficial lake sediments was determined by the method
in Plumb,  R.K.,  Jr.  1981.  Procedures for Handling and Chemical Analysis of
Sediment  and  Water  Samples.   [Technical  report  EPA/CE 81-1,  USCOE, Vicks-
burg MS,   p.3-73].   Calcium carbonate  and  particle  size analysis  of the
sediment  samples  were  performed  by  the acid digestion  method (Procedure
3.2.3.) and the  hydrometer method  (Procedure  3.4.3.)  respectively,  des-
cribed by  Sobek,  A.A.,  W.A.  Schuller, J.R.  Freeman,  and R.M.  Smith.  1978.
[Field  and Laboratory  Methods  Applicable   to  Overburdens and  Minesoils.
USEPA,  Cincinnati OH].

Results

     The  water  quality  parameters  tested in  this  study  (Table   B-l) are
generally  consistent  with previous studies.   However,  the autumn sampling
time obscures some  of the lake characteristics  that  are of greater concern
to  the residents of  the area.   Specifically, at  the end of  November no
direct indication can be found of blue-green  algal bloom intensity in the
lakes.

     The  Secchi disk  data show that Indian Lake, Pipestone Lake, and  Dewey
Lake had  similar  clarity readings at these sampling  dates (approximately 8
feet).   Cable Lake,  and Magician Lake had slightly greater clarity  (9  to 15
feet),  and Round Lake,  Upper  Crooked Lake,  Lower  Crooked Lake,  and  Cable
Lake had   the  highest  clarity  (12.5  to 22  feet).   The  trend  in clarity
between the two sampling  dates  was mixed:  clarity  improved  in Round Lake
and Lower  Crooked Lake; clarity declined in  Cable  Lake and Magician  Lake;
in the others changes  were not  significant.   All of  the lakes had  rela-
tively high water clarity.
                                  B-4

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-------
     Chlorophyll a_ concentrations,  a measure of the phytoplankton present,
in Dewey Lake  were highest of all lakes and averaged 11.8 ug/1.  Pipestone
Lake had the next  highest, averaging 7.4 ug/1.   Cable  Lake concentrations
averaged 5.1 ug/1,  (largely  attributable  to high  concentrations near the
bottom  on  the  later  sampling  date).   The  other  lakes had  chlorophyll ^
levels between  2.0 and  3.7 ug/1 in descending order: Indian Lake, Magician
Lake,  Round  Lake, Upper  Crooked  Lake,  and Lower  Crooked Lake.   In some
lakes  the  chlorophyll a^ levels were greater at  the  second sampling date,
but not consistently  so.  No consistent correlation between the surface and
the near bottom samples was observed.

     The total  phosphorus concentrations in lake water samples were all low
(Table  B-l);  most  were  near or  below  the detection  limit  of 0.01 mg/1.
The  highest  average  concentration  (0.05  mg/1) was measured at  the early
sampling date  in  Pipestone  Lake.   The average  phosphorus levels  at the
early  sampling  date were above the detection limit in nearly all the  lakes
but  fell to  near  or  below  the  detection  limit  at  the later sampling date.

     The nitrate-nitrogen concentrations measured in the lakes were near or
below  the detection limit (0.05 mgN/1).  Only  in  samples  taken  from  Pipe-
stone  Lake  at  the later  date  and  in Dewey Lake and  Magician  Lake at both
sampling dates  were nitrates  measured above detection limits.  Total  Kjel-
dahl  nitrogen   (TKN)  concentrations were highest   in Magician  Lake,  Dewey
Lake, and Pipestone Lake  (1.3, 1.0, 0.9 mgN/1, respectively) and are in the
0.5  to 0.7 mgN/1  range  in the other lakes.   The  TKN  concentrations were
greater at  the second  sampling date  for  three  lakes  and lesser for five
lake s.

     The  sampling results for  average  temperature  and  dissolved  oxygen
(Table B-2)  show  that the  lakes were similar.  All the lakes, except  Pipe-
stone  Lake  at  the early  sampling date, were completely mixed on  both  samp-
ling dates.  The lake water temperatures declined approximately 6°C between
the  two  sampling dates.  Temperature  and  dissolved  oxygen  differences
between lakes  were not  conclusive.  Pipestone Lake  was  stratified at the
first  sampling date   in  terms of  low dissolved  oxygen  content measured in
the  lower portion of the  profile. By the second sampling date, the lake was
completely mixed  and  dissolved oxygen concentrations were  near saturation.
                                  B-8

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-------
     The  lake  sediment  sampling data  are shown  in  Table B-3.   The data
indicate  that  some lakes  are  highly variable  in bottom  sediment charac-
teristics from station  to station (Indian Lake)  and  others appear to have
relatively consistent characteristics (Pipestone Lake).

     The organic matter, sand,  and calcium carbonate proportions are highly
variable  within  and between lakes.  Organic matter  ranged from  4% in one
sample in Magician Lake to 22% in Cable  Lake.   The calcium carbonate con-
centrations were highly variable, both within and between lakes.   Carbonate
concentrations indicate whether macrophytes and  plankton,  especially dia-
toms, are  present  in  the lake in considerable numbers.   In  shallow areas
where macrophytes  are  present the  carbonates  precipitate out  and become
part of  the sediment.  In the deeper areas, carbon dioxide from decomposing
organic  matter  may resolubilize  the carbonate  precipitate.   This  would
account   for  the  differences noted  in  the  carbonate contents  between the
shallow and deep sediment samples.

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sample and 22% at one of the shallow carbonate samples.  Pipestone Lake and
Magician  Lake  samples  have  average  calcium carbonate  contents  of 21% and
19%  respectively.   Both of  these lakes have shorelands  that have consid-
erable  marl  (calcium  carbonate)  deposits associated with  macrophytes.
Indian Lake, Round Lake,  and Lower Crooked Lake have contents in  the 6% to
12%  range.  The  other lakes have sediment  carbonate  contents of  less than
3%.  The sand content in Pipestone Lake sediments  (after ignition) was 14%,
the  lowest of any  lake.  The sand content of most of the other lakes ranged
from 24%  to 34%, with considerable variability within  lakes.   Indian Lake
and  Dewey Lake  had sand contents of  46%  and 57%, respectively, although a
few unusually sandy samples account for these high averages.

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biologically  available  phosphorus.   It  does  not  include  the   organic-P
fraction  and,  therefore,  is not a measure of algal products.  NAI-P can be
of natural origin or may be enhanced by cultural sources such as  inorganic
fertilizer, domestic  wastewater,  or  animal wastes.  The chlorophyll degra-
dation  products  are an  indication  of  organic  deposition  from  algal pro-
                                  B-10

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duction where  the  chlorophyll degradation products and the NAI-P are high.
The  lowest  values  were  measured  in Indian Lake,  Dewey  Lake,  and Magician
Lake.   In  eutrophic lakes  the phosphorus in the  sediments  is cycled back
into the water column during the summer under certain anoxic (oxygen-deple-
ted)  conditions  (Armstrong,  D.E.   1979.   Phosphorus Transport  Across the
Sediment-water  Interface.  In;  USEPA  Lake  Restoration.  EPA 440/5-79-01).
Thus, biologically available sediment phosphorus (NAI-P) is recycled to the
water column and converted  to organic phosphorus by phytoplankton.  There-
fore, the sediment NAI-P would be low.  In mesotrophic lakes, the sediments
are a phosphorus sink  and NAI-P is  high  in  the sediments.  The concentra-
tion of NAI-P  in  the sediment, if  correlated with other lake characteris-
tics, can be used  as an indicator of algal productivity. Pipestone Lake is
inconsistent with   the  trend,  possibly  because the  lake has  a suspected
greater external phosphorus loading.

Discussion

     The lakes have similar  water  quality, although  some differences are
apparent.    The water  quality sampling results  alone are  insufficient to
determine the  trophic  status  of these lakes.  Thus, a composite picture of
the lakes is necessary in order to be able to assess lake eutrophy.

     The water quality and  sediment sampling data  were  evaluated and the
lakes were  rated for overall productivity based on  the primary indicators
(Table  B-4). Round  Lake  and Lower Crooked Lake do not display characteris-
tics  of high  productivity among  the primary  indicators.  In  Cable Lake
chlorophyll ji  data  indicated  high algae  productivity at  these sampling
dates,  although  the  other productivity  indicators displayed  low produc-
tivity.  In Cable  Lake and Upper Crooked Lake,  the chlorophyll degradation
products are  relatively high,  indicating high  productivity.   These  lakes
have  high  Secchi  disk measurements  and diverse  algal communities (Section
3.1.3.2.);  therefore, the appearance of the water is acceptable even though
the algal productivity is high.

     Indian Lake,  Pipestone Lake, Dewey Lake, and Magician Lake exhibit two
or  more indicators  of  high productivity.  Dewey  Lake  exhibits nearly all
                                  B-12

-------
Table B-4.  Primary indicators of algal and macrophyte  productivity in the  Indian
            Lake and Sister Lakes as determined by  the  October  and  November 1982
            sampling dates.
                                                           Sediment  data
    Lake
	 Water quality data	
Secchi     "               Total
 Disk    Chlorophyll a   Nitrogen
Indian

Pipestone

Round

Upper Crooked

Lower Crooked

Cable

Dewey

Magician
High

High
                      Non-Apatitic
                       Inorganic
                       Phosphorus

                         High
High
High
High
High

High
                        Chlorophyll
                        Degradation
                         Products
                High
                                                        High
                                                        High
High

High
High

High
                                    B-13

-------
the primary  indicators  of high productivity.  The chlorophyll a_ concentra-
tions were greatest,  about 50% greater than the concentration in Pipestone
Lake, the  lake  with the next greatest value.  Indian Lake has a low Secchi
disk depth,  and  low sediment NAI-P.  The  chlorophyll  a. and total nitrogen
data indicate that the algae may have dropped out of the water column prior
to  the  sampling dates.   Pipestone Lake displays  some  different character-
istics  from  the other  lakes.   The  Secchi disk depth,  chlorophyll a_, and
total nitrogen values all indicate that it is a highly productive lake.  In
addition,  the  organic matter  percentage  is high in the  sediments and the
sand  content is  low.   The  high concentrations  of NAI-P  and chlorophyll
degradation  products  in  the  sediment indicate that the productivity of the
lake has been  very high and that principal  summer  nutrient sources may be
external to  the lake  (not from the sediments).

     Magician  Lake data  is  most  difficult to  interpret.   The  open lake
Secchi disk  depths and  the chlorophyll a_ values are not indicative of high
algal productivity.   The total nitrogen concentration  is  greater in Magi-
cian Lake than in any other lake.  The concentrations of NAI-P, chlorophyll
degradation  products, and organic matter are lowest of all the lakes, which
may  indicate a great deal of nutrient  cycling from  the  sediments or low
productivity in  the  open  water.   The Landsat mapping  of  macrophytes dis-
plays large  areas of lakebottom with heavy growth  of  macrophytes.  These
macrophytes  are  likely  competing with the open water  algae for the avail-
able nutrients.   The  rooted  macrophytes also trap plankton and cause depo-
sition on  the  bottom.   Marl,  a common soil material  around  Magician Lake
and Pipestone  Lake,  forms where the  lake water is  hard  and  the  lake is
shallow and has rooted macrophytes.

     The data indicate that Dewey Lake, Pipestone Lake, and Indian Lake are
eutrophic;  Magician Lake is mesotrophic to eutrophic; and Round Lake, Upper
Crooked Lake, Lower Crooked Lake, and Cable Lake are mesotrophic.  The lake
morphometry, along  with  external phosphorus inputs, appear to be the pri-
mary  factors in trophic  status.   The lakes that have  major  inputs of nu-
trients  and  organic  matter  from swamp disturbance  and drainage,  such as
Indian  Lake, Pipestone   Lake,  and Dewey Lake,  are  eutrophic.   These lakes
also have  extensive  areas where the  depths  are  shallow and are character-
                                  B-14

-------
ized by a  volume  to surface area  ratio  that is low.  As  a result of this
morphometric characteristic, the water temperature warms up more quickly in
the  spring,  becomes warmer  in the  summer,  and rooted  aquatic plants can
readily colonize bottom sediments in these lakes.  Magician Lake is similar
to  those  lakes but  appears to  have less nutrient  input  from  marshes  or
other sources.

     The finding of  elevated chlorophyll degradation products and elevated
NAI-P,  together  in Pipestone  Lake indicate a  high  probability that phos-
phorus  is  available in  luxurient  amounts during  the growing  season.   As
stated  previously,  the data also indicate that the principal source of this
excess  phosphorus  is  external.   Thus,  Pipestone Lake is the only eutrophic
lake studied  which appears  to be  significantly  influenced  by  cultural
factors.   Further  study  would  be required to determine if those sources of
phosphorus could be abated in a cost effective manner.
                                  B-15

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         APPENDIX C

Shallow Groundwater Study of
   Soil Absorption Systems

-------
           SHALLOW GROUNDWATER  STUDY  OF  SOIL  ABSORPTION SYSTEMS
INTRODUCTION

     This  study was  carried  out upon  request  from USEPA  (Contract  No.
68-01-4612, DOW  No.  12, Modification No.  80)  to  gather  data  on  the  contri-
bution  of  septic  tank  and soil  absorption  systems to nutrient  loading  of
the  study  area lakes.   This task was  undertaken because considerable  dif-
ferences of  opinion have  been proffered  as  to  the actual impact of  these
systems  on  lake eutrophication.   The  shallow  groundwater  sampling  took
place  in the  period  of 1-20  November  1982,  and was conducted  by  WAPORA,
Inc.  Laboratory tests were conducted for  water chemistry and soil analysis
by WAPORA, Inc.  and for fecal  coliform by  IHI-Kemron,  Inc.

Sampling Locations and Installation

     Five  on-site  systems  were selected for  study  of the nutrient  removal
from the effluent  as  it passes through  the  soil to  the lake.   These  sites
(Figure  C-l)  were selected  from  the  residences whose  occupants had  been
interviewed for  the sanitary survey.  The  sites were  in  shallow  groundwater
areas where flow direction was toward the  lake.

     Site 1 was  located at the southeast side  of  Round Lake and  was  a  drain
bed  at  the Beechwood  Resort.  It  serves 4 cabins,  one of which  is occupied
year-round.   The drain bed  was   located about  100  feet  from the shoreline
and was installed in 1976.  The drain bed  was  constructed in  fill sand  over
muck over sand.

     Site  2  was located  at  the  northeast side  of Indian Lake  and was a
raised  drain  bed dosed by a  lift pump  that  was  constructed  in  1980.   The
residence  is  owned by  Thomas  McHenry  and was  occupied by 4 college  stu-
dents.   The  drain bed  was located  about  60  feet  from the  shore  and was
constructed on mucky sand soil.
                                    C-2

-------
            ROUND
            LAKE
              Site 1
       Beechwood Resort
        INDIAN
        LAKE
.Anderson
 • Site 4
xV
            /''
                                                          / /
                                                         ' /
                                           ,<"&•
                                   Site
                                           X
                                                    •^ //' .-•* .-•*"'- •'"''• >K
Figure  C-1. Locations of monitored groundwater near soil  absorption systems.
                                   C-3

-------
     Site  3  was located at  the  northeast side of  Indian  Lake  near Site 2.
It  was described as  a dry  well and  tile line  that  was constructed  many
years  ago.  The  residence was  owned  and  occupied by Mr.  and Mrs.  James
Black.  The  soil  material was mucky sand and the  system  was about 50 feet
from the shoreline.

     Site  4  was located on  the  south  side of  Indian Lake  and was  owned and
occupied by  Mr. and Mrs.  Anderson.   The  system  had a septic tank and  dry
well with  tile  lines running radially from it.   The system  was  constructed
in  mucky  sand  and  fill sand approximately 60  years  ago and was  approxi-
mately 100 feet from the shoreline.

     Site 5 was located on the south side of  Indian Lake  two houses west of
the  Anderson residence and  was  owned  and occupied by Mrs.  McFadden.   The
system had  a septic  tank,  lift  pump, and  raised drain  bed  and  was  con-
structed in 1976.  The system was constructed  over  mucky sand and  sand  fill
and was approximately 80 feet from the shoreline.

     Wellpoints  were driven  into  the soil  after a  hole  had  first  been
augered to the  water table.  The  first was placed at the end  of  the  soil
absorption system,  the  second at three feet,  and  third at 30 feet, and  the
fourth in  the  shallow water.  At each of the  test  sites a background  well-
point  also was  installed.   A silver-plated copper  rod was inserted in  each
wellpoint as an indicator of anaerobic water  conditions  by tarnish on the
rod.

     Seepage meters, constructed of a  part of  a 55-gal drum  with a  flexible
sample bag,  were driven  into the lake bottom to measure groundwater  flow
rates into the  lakes.  These were placed  in water  about 10 feet offshore in
water less than 3 feet deep.

Sampling and Laboratory Methods

     The groundwater  levels  in  the wellpoints  were   measured  with a  sur-
veyor's level and  a tape.   Lake level was the datum  for  the measurements.
                                  C-4

-------
     The wells  were  pumped when the points were installed then left uncap-
ped  overnight.    The  water  samples  were collected  with a  hand-operated
vacuum pump and a sample chamber.  The sample chamber was purged with argon
gas before  sampling.   The  sample was  filtered  under  argon gas with a 0.45
micron,  14  cm  diameter  millipore  filter.  At  2 sites  (10 total samples),
duplicate groudwater samples were collected without argon and field filter-
ing.  Filtered and unfiltered samples were acidified  (10% H SO ) and stored
at 4°C until analysis.

     The groundwater samples were tested according to these sections in the
Methods  of  Chemical Analysis  of Water and Wastes,  [USEPA 1979 Cincinnati
OH]: total phosphorus  (356.3), total Kjeldahl nitrogen  (351.2), nitrite and
nitrate  nitrogen  (353.3),  ammonia nitrogen  (350.3),  and dissolved calcium
(215.1).  Fecal coliform was analyzed by the membrane  filter technique as
described in Section 909C of Standard Methods.

     Soil samples were collected by the soil auger from a depth of 1.5 feet
at  each  soil absorption system, at  4 background  locations,  and from the
lake bottom from the  northeast side  of  Indian Lake.   In the soils, non-
apatitic inorganic phosphorus  (NAI-P)  was tested similar  to  the method of
Williams, J.D.H., H.  Shear,  and R. L. Thomas 1980. [Availability to Scene-
desmus  quadricauda  of Different  Forms of  Phosphorus in Sedimentary Mate-
rials  from  the  Great Lakes.   Limnol.   Oceanogr.  25(1): 1-11].   Organic
matter content  of the soils was determined by the method in Plumb, R.H.,
Jr.  1981.   Procedures for  Handling and  Chemical Analysis of Sediment and
Water  Samples.    [Technical  report  EPA/CE  81-1,  USCOE,   Vicksburg  MS,  p.
3-73].    Calcium carbonate  and  particle  size analysis  of the soil samples
were performed  by  the  acid digestion method  (Procedure 3.2.3.)  and the
hydrometer  method  (Procedure  3.4.3.)  respectively,  described  by  Sobek,
A.A., W.A. Schuller, J.R. Freeman, and R.M. Smith.  1978.  [Field and Labora-
tory Methods  Applicable  to  Overburdens  and Minesoils.   USEPA, Cincinnati
OH].

Results and Discussion

     The  hydraulic   gradient was  toward  the  lake  at  all but  one  of the
sampling sites, as  indicated by the water level and  seepage meter measure-

                                    C-5

-------
ments.   The wells  at  the  Round Lake  site did  not  recharge  sufficiently
after pumping  and  the water levels measured in  them were  below lake  level.
During sampling  of  Sites 2 and  3 (McHenry  and Black) and  prior to  sampling
of Sites  4  and 5 (Anderson and  McFadden)  approximately 1.5  inches of  pre-
cipitation  fell.  The groundwater levels in the McHenry wells  between  the
raised drain  bed  and  the  lake  rose  1.0  feet  overnight.   The hydraulic
profiles  for  each  of  the  sampling  sites are  shown  in  Figure C-2.   The
dramatic rise  in the water table can be observed  in the  water levels  of  the
McHenry site wells.   Because a  conservative tracer, for example, chlorine,
was not analyzed,  the effect of the  precipitation on the sampling results
is unknown.  The groundwater flow velocities were  measured with the seepage
meters embedded in the shallow littoral zone of  the lake at the sites.   The
results of  the seepage  meter  measurements are  presented  in the following
table (no measurements were possible at the Anderson site) :

                      Beechwood   McHenry   Black   McFadden
No. of measurements       5422
Ave.  velocity  (ft/day)    3.6       3.3       5.3     14.9

Possibly, a  lense  of coarse soil material  was  encountered at  the McFadden
site  in an area where the shore and lake bottom  soils are  generally of  less
permeable  organic  sediments.  This  could  account  for   the relatively  high
rate  of groundwater  discharge  at the McFadden  site.   Wave action may  also
account for the high velocity measured.

     Total  dissolved phosphorus  concentrations  were  below  the detection
limit  of  0.01  mg/L  (except  for one  sample)  for the  shallow  groundwater
samples.   The  sample  from the wellpoint  located 3 feet downgrade from  the
drain bed at the  Anderson site  had a  phosphorus concentration  of 8.2 mg/L
(Table C-l).   This  elevated  phosphorus  concentration  was  likely  due  to
sample contamination by  sediment as  indicated  by  laboratory  filtration.

     The  primary  forms of  nitrogen  measured were total Kjeldahl nitrogen
and ammonia  (Table  C-l).   Concentrations of nitrates  were generally below
detection (0.05 tngN/L).  Total Kjeldahl nitrogen  (TKN) values were typical-
ly higher near the  soil absorption system  than  in the lake groundwater  and
background samples.   Ammonia concentrations also were typically high  in  the
                                    C-6

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                                                                      LAKE
                                                                100
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                                                                     LAKE
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                                                                  LAKE
                            03         30                   86
       Distance from lakeside edge of soil absorption system, ft.

 Figure C-2. Hydraulic  and ground surface profiles for each site measured
             with an engineering level and tape.
                                  C-8

-------
same  samples.   The highest  ammonia nitrogen  concentrations  were found in
samples  from  the  Beechwood Resort  and  Anderson  sites.   The concentrations
found in  the  Black site samples were also elevated above background levels
hut not  as high  as those reported for  the  Beechwood  Resort and Anderson
sites.  The Black and  Anderson systems were  "dry well  and tile  line" sys-
tems and the Beechwood Resort had a standard drain bed  (for 1 permanent and
3 seasonal dwellings).   The  sites  with the  lowest  TKN  and ammonia concen-
trations  at  the  soil  absorption  systems were both  raised  drain beds that
were dosed by a small lift pump.

     Dissolved calcium concentration (Table C-l)  in the shallow groundwater
samples  ranged  from  24 mgCa/L to  196  mgCa/L.   Calcium  tests  were made
because  this  ion  may be responsible  for  precipitating  dissolved phosphate
under  oxic conditions.   The concentrations  of  dissolved  calcium  did not
appear to be correlated with any other parameter.

     The silver-plated rods inserted in each well point were ambiguous with
respect to whether the groundwater was aerobic or anaerobic.  The rods may
indicate  that the well points  30 feet  from  the soil absorption  systems at
the Beechwood Resort  and the McFadden sites and  the well point 3 feet from
the soil  absorption system  at the  Anderson  site had  anaerobic waters in
them.  However, the sulfate  tarnishing reaction may have been slowed under
the groundwater  and temperature  conditions  that  resulted  from the rains.

     A comparison was  made between immediate  field  filtration and labora-
tory filtration for a number of samples.  The results show  that ammonia and
TKN values are  nearly  identical  (Figure  C-3).   The  field  filtered samples
tested for  phosphorus  had concentrations below  detection  (0.01 mgP/L) but
the  laboratory  filtered  samples  had  concentrations between  0.18  and 4.4
mgP/L.  The groundwater samples contained considerable  particulate that was
immediately  filtered  out  in  the  field-filtered  samples.  The laboratory-
filtered  samples  were agitated considerably and  subje'cted to temperature
and pH variations.  Under those conditions, phosphorus was likely released
from the particulate matter to  solution.
                                    C-9

-------
100.0_
 0.01
       0.1
     1.0                   10.0
LABORATORY FILTERED (mg/l)
       Figure C-3. Comparison of the results of samples filtered in
                   the field under argon or in the  laboratory.
                                 C-10

-------
     The soil samples were taken from near the soil absorption system for 5
sites, from the lake bottom for 2 sites, and from the background well for 4
sites.  The  particle  size analysis showed that  the  samples were predomin-
antly sand.  The  least  sand in the samples was 45% in the lake sample from
the  Black  site.  Sand  typically  accounted  for  about 90%  of particulate.
The organic matter contents ranged from 0.2 to 26%.  The higher percentages
were  found  in  the soil  near the drain  bed at the Beechwood Resort, in the
lake  at  the Black  site,  and  at  the background  location at  the McFadden
site.

     The NAI-P concentrations of the soil were variable, ranging  from 45 to
793 mgP/kg.  No  pattern was discernable with  respect  to organic matter or
particle size.   The calcium carbonate content also did not appear to corre-
late with other  parameters.   Generally, the higher  CaCO  values were mea-
sured in  conjunction with  the finer soil  particles but  not with organic
matter.   The higher  values  were associated with lake bottom and background
samples.

CONCLUSIONS

     On-site systems  appeared  to  contribute a minimal amount of phosphorus
to the  lakes under  late autumn weather  conditions.   This statement should
be interpreted  with  caution,  however,  because several factors lessened the
probability of measuring high phosphorus concentrations.  The lakes were at
their lowest levels  in  many years and  the  autumn had been relatively dry.
Thus, the  soil absorption  systems had  been operating  with  aerated soils
under them,  the  condition  under  which  phosphorus  is  readily removed from
the dissolved form in groundwater.   Another factor was the heavy precipita-
tion  during the  sampling  period  that  may have  diluted  the  groundwater
samples and  increased oxygen levels.  However,  the  high dissolved calcium
measured in the groundwater indicates that the calcium and phosphates would
likely form  relatively  insoluble  compounds  (Lee, G.F.  1976  [Review of the
potential water quality  benefits  from  a phosphate  built detergent ban in
the  State  of Michigan.   Presented to  Michigan  Department of  Natural Re-
sources Hearing  on  a  Detergent  Phosphate  Ban,  Lansing MI,  December 8];
Stumm, W.  and J.J.  Morgan  1970 [Aquatic  chemistry.  Wiley - Interscience,
                                    C-ll

-------
New York.  583 p.]).  Because the  water  table had been  low,  the adsorption
and precipitation  reactions were  likely  preventing  phosphorus from moving
through the groundwater to the lake.

     The  movement   of  nitrogen  compounds  to  the  lake also  appears  to be
rather minimal  during  the time of sampling.   The conditions  were  favorable
for  denitrification  (conversion  to  nitrogen gas)   to  occur  within  the
groundwater.  The  nitrogen  must  be  in the nitrate form and a carbon source
must be present in an anaerobic environment  (Reddy,  K.R., P.S.C. Rao,  and
R.E. Jessup  1982  [The  effect  of  carbon  mineralization on denitrification
kinetics  in  mineral and  organic soils.   Soil Science  Society  of America
Journal,  vol.  46 no.  1 pg. 62-68]).   The nitrate  concentrations are  low
even though some high TKN and ammonia  concentrations were  measured.  There-
fore,  denitrification is the presumed  reason  for the low levels of nitrates
measured in the groundwater.

     A difference  between the  types of soil  absorption system is  apparent.
The raised drain bed systems (McHenry and McFadden sites)  had significantly
lower  groundwatec   nitrogen  concentrations  than  the  other  systems.   This
indicates that  more treatment  may be  occuring within  the  raised  drain  bed
itself rather than  in the natural ground.
                                    C-12

-------
                 APPENDIX D





PRELIMINARY COST ESTIMATES FOR ALTERNATIVE 10

-------
Table D-l.  Annual residential user costs with and without USEPA and State
            grants.


Item                  USEPA Grant   USEPA + State Grants   Without Grants

Local share of
 capital costs        $1,131,300         $863,800            $5,664,700

Annual equivalent
 of local share-7        112,000           85,500               567,000

Annual O&M cost          228,500          228,500               228,500

Annual cost to
 local residents         340,500          314,000               795,500

Monthly cost per
 residence-7               11.19            10.32                 26.15

Annual cost/per
 residence-7              134.28           123.84                313.80
a/
— Local share amortized at 7 5/8% interest at 20 years  (0.09903).

—Based on 2535 residences in 1981.
                                  D-2

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-------
Table D-5.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #1 Indian
            Lake (Alternative 10).
Item Quantity
STE sewer pipe
4" 3,640 If
Lift Station
43 gpm TDH 48 ft
Forcemain, individual trench
3" 1,500 If
Service connection
gravity 69
Septic tank
upgrade 46
replace 23
Cluster drainfield
Edgewood-Tice 70
Subtotal initial cost
Service factor (35%)
Subtotal initial capital cost
Future connections cost
Building sewer 1
Septic tank & gravity 1
Subtotal future connections
cost
Annual future connections
cost
Unit Cost Construction
$ 35.30 $128,500

30,900
14.15 21,230

1,577 108,800
143 6,580
750 17,250

1,250 87,500
400,760
140,270
541,030

55 60
2,277 2,280
2,340

117
Salvage
$ 77,100

9,270
12,730

65,300
3,960
10,350

—
178,710


30
1,370
1,400

70
O&M
$ 138

1,362
—

—
460
230

2,080
4,270
—

10
10

0.5
                                       D-6

-------
Table D-6.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #3 Indian
            Lake (Alternative 10).
Item Quantity
STE sewer pipe
4" 1,350 If
Lift Station
13 gpm TDK 68 ft
Forcemain, individual trench
3" 1,500 If
Service connection
gravity 20
Septic tank
upgrade 14
replace 6
Cluster drainfield
South Shore Annex 21
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer 1
Septic tank & gravity 1
Future connections cost
Annual future connections cost
Unit Cost

$ 35.30



14.15

1,577

143
750

1,250




55
2,277


Construction

$ 47,700

12,750

21,230

31,530

2,000
4,500

26,250
145,960
51,090
197,050

60
2,280
2,340
117
Salvage

$28,600

3,830

12,730

18,900

1,200
2,700

—
67,960



30
1,370
1,400
70
O&M

$ 52

1,333

—

—

140
60

2,080
3,665



—
10
10
0.5
                                       D-7

-------
Table D-7.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District  #2 Pipestone
            Lake (Alternative 10).
Item Quantity
STE sewer pipe
4" 2,150
Lift Station
13 gpm TDH 25 ft
Forcemain, common trench
2" 150
Forcemain, individual trench
2" 450
Service connection
gravity 2b>
STE pump I
Septic tank
upgrade 21
replace 8
Cluster drainfield
Bass Island Sub. 29
Initial cost
Service factor (35%)
Initial capital cost
Unit Cost
$ 35.30


4.60
13.00

1,577
3,428
143
750

1,250

Construction
$ 75,900

12,750
690
5,850

45,730
3,430
3,000
6,000

36,250
189,600
66,360
255,960
Salvage
$45,540

3,830
410
3,510

27,440
1,030
1,800
3,600

0
87,160
O&M
$ 82

1,322
0
0

0
63
210
80

2,080
3,837
                                       D-8

-------
Table D-8.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #3 Pipestone
            Lake (Alternative 10).
Item

STE sewer pipe
  4"

Lift Station
  16 gpm TI)h 35 ft
  25 gpm TDH 35 ft

Forcemain, common trench
  2"

Forcemain, individual trench
Service connection
  gravity
  STE pump

Septic tank
  upgrade
  replace

Cluster drainfield
  North Lake area

Initial cost
Service factor (35%)
Initial capital cost
Quantity    Unit Cost   Construction   Salvage     0&M_


 5,080      $ 35.30       $179,320     $107,590   $  193

950 4.60
1,000 13.00
36 1,577
5 3,428
31 143
10 750
41 1,250

12,750
12,750
4,370
13,000
56,770
17,140
4,430
7,500
51,250
359,290
125,750
485,040
3,830
3,830
2,620
7,800
34,060
5,140
2,660
4,500
0
172,030
1,324
1,423
0
0
0
315
310
100
2,080
5,745
                                       D-9

-------
Table D-9.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #5
            Sister Lakes (Alternative 10).
Item
STL sewer pipe
4"
Lift Station
31 gpm TDK 57 ft
Forcemain, common trench
3"
Forcemain, individual trench
3"
Service connection
gravity
pressure
Septic tank
upgrade
replace
Cluster drainfield
Sister Lake
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer
Septic tank & gravity
Future connections cost
Annual future connections
Quantity

3,000 If



1,700 If

900 If

37
5

31
11

50




3
3

cost
Unit Cost

$ 35.30



5.75

14.15

1,577
3,600

143
750

1,250




55
2,277


Construction

$105,900

30,900

9,780

12,730

58,300
18,000

4,440
8,250

62,500
310,800
108,780
419,580

170
6,830
7,000
350
Salvage^

$ 63,500

9,270

5,870

7,650

35,000
5,400

2,660
4,950

—
134,300



100
4,100
4,200
210
O&M

$ 114

1,356

—

—

—
315

310
110

2,080
4,285



—
30
30
L.5
                                       D-10

-------
Quantity
2,300 If


L

200
550
200
350

If
If
If
If
Unit
$ 35

4
5
13
14
Cost
.30

.60
.75
.00
.15
Construction
$ 81,
12,
12,
3,
2,
4,
200
750
750
920
160
600
960
Salvage
$ 48,700
3
3
1
1
2
,830
,830
550
,900
,560
,970
O&M
$ 88
1,326
1,320
—
—
Table D-10.  Quantities and costs for septic tank effluent gravity sewers and
             cluster drainfields serving limited areas for District #10
             Sister Lakes (Alternative 10).
Item

STh sewer pipe
  4"

Lift Station
  21 gpm TDH 30 ft
  10 gpm TDH 26 ft

Forcemain, common trench
  2"
  3"

Forcemain, individual trench
  2"
  3"
Service connection
  gravity                      45         1,577         70,950       42,550

Septic tank
  upgrade
  replace

Cluster drainfield
  Gilmore Beach
  Folk's Landing

Initial cost
Service factor (35%)
Initial capital cost

Future connections cost
  Building sewer
  Septic tank & gravity
  Future connections cost
  Annual future connections cost
27
18
33
15



3
3

t
143
750
1,250
1,250



55
2,277


3,860
13,500
41,300
18,750
266,700
93,350
360,050
170
6,830
7,000
350
2,320
8,100
__
	
116,310


100
4,100
4,200
210
270
180
2,080
2,080
7,344


„
30
30
1.5
                                       D-ll

-------
Table D-ll. Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #11
            Sister Lakes (Alternative 10).
Item
STL sewer pipe
4"
Lift Station
11 gpm TbH 24 ft
Forcemain, common trench
2"
Forcemain, individual trench
2"
Service connection
gravity
STE pressure
Septic tank
upgrade
replace
Cluster drainfield
Maple Island
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer
Septic tank & gravity
Future connections cost
Annual future connections
Quantity

700 If



100 If

50 If

14
2

11
5

17




1
1

cost
Unit Cost

$ 35.30



4.60

13.00

1,577
3,600

143
750

1,250




55
2,277


Construction

$ 24,700

12,750

460

650

22,060
7,200

1,570
3,750

21,250
94,360
33,030
127,390

60
2,280
2,340
117
Salvage

$ 14,820

3,830

280

390

13,250
2,160

950
2,250

—
37,390



30
1,370
1,400
70
O&M

$ 27

1,317

—

—

—
126

110
50

2,080
3,710



—
1C
10
0.5
                                       D-12

-------
Table D-12. Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #13
            Sister Lakes (Alternative 10).

Item

STE sewer pipe
  4"

Lift Station
  14 gpm TDH 30 ft

Forcemain, individual trench
  2"

Service connection
  gravity
  pressure

Septic tank
  upgrade
  replace

Cluster drainfield
  Magician Bay Park

Initial cost
Service factor (35%)
Initial capital cost
Quantity
1,700 If

I
300 If
19
3
14
8
22

Unit Cost
$ 35.30

13.00
1,577
3,600
143
750
1,250

Construction
$ 60,000
12,750
3,900
29,930
10,800
2,000
6,000
27,500
152,880
53,510
206,390
Salvage
$ 36,000
3,830
2,340
18,000
3,240
1,200
3,600
—
68,210
O&M
$ 65
1,321
—
189
140
80
2,080
3,875
                                       D-13

-------
Table D-13.  Quantities and costs for septic tank effluent gravity sewers and
            cluster drainfields serving limited areas for District #15
            Sister Lakes (Alternative 10).
Item Quantity
STE sewer pipe
4" 700 If
Lift Station
13 gpm TDK 65 ft
Forcemain, individual trench
2" 2,300 If
Service connection
gravity 20
Septic tank
upgrade 15
replace 5
Cluster drainfield
Sandy Beach Resort 21
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer 1
Septic tank & gravity 1
Future connections cost
Annual future connections cost
Unit Cost
$ 35.30


13.00

1,577
143
750

1,250



55
2,277

Construction
$ 24,700

12,750
29,900

31,540
2,150
3,750

26,250
131,040
45,860
177,900

60
2,280
2,340
117
Salvage
$ 14,820

3,830
17,940

18,820
1,290
2,250

—
58,950


30
1,370
1,400
70
O&M
$ 27

1,330
—

—
150
50

2,080
3,637


10
10
0.5
                                       D-14

-------
Table D-14.  Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #1 Indian
            Lakes (Alternative 10).
Item
Quantity    Unit Cost   Construction   Salvage
STE pressure sewer pipe
  2V                         950
  3"                        2,350
  4"                        1,300

Service connections
  STE pump                     69

Septic tank
  upgrade                      46
  replace                      23

Cluster drainfield
  Edgewood-Tice                82
  Dosing pump 43 gpm
   TDH 20 ft

Subtotal initial cost
Service factor (35%)
Subtotal, initial capital cost

Future connections cost
  Building sewer                1
  Septic tank + STE pump        1
  Future connections cost
  Annual future connections cost
            $ 17.35
              18.20
              19.50
              3,428
                143
                750
              1,250
                 55
              4,128
$ 16,470
  42,750
  25,330
 236,500
   6,580
  17,250
  87,500

  30,900

 463,280
 162,150
 625,430
      60
   4,130
   4,190
     210
  9,890
  2,570
 15,200
  3,960
 10,350
     30
  1,240
  1,270
     64
                         O&M
 18
 45
 25
 70,900    4,350
460
230
           2,080

  9,270    1,422

122,140    8,630
 73
 73
  4
                                       D-15

-------
Table D-15. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #3 Indian
            Lakes (Alternative 10).
Item

STE pressure sewer pipe
  2"
  3"
  4"

Service connections
  STE pump

Septic tank
  upgrade
  replace

Cluster drainfield
  South Shore Annex
  Dosing pump 13 gpm
   TDH 20 ft

Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
  Building sewer
  Septic tank + STE pump
  Future connections cost
  Annual future connections cost
Quantity    Unit Cost   Construction   Salvage
  350 If
1,990 If
1,500 If
   16
$ 17.00
  18.20
  19.50
  3,428
$  5,950
  18,200
  29,250
  54,900
$  3,570
  10,920
  17,550
                                       O&M
 7
19
29
  16,430    1,009
14
6
21




1
1

t
143 2,000
750 4,500
1,250 26,250
12,750
153,800
53,830
207,630
55 60
4,128 4,130
4,190
210
1,200
2,700
—
3,830
56,200


30
1,240
1,270
64
140
60
2,080
1,317
4,661



73
73
4
                                       D-16

-------
Table D-L6. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #2 Pipestone
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M

STE pressure sewer pipe
  2"                          900       $ 17.00       $ 15,300     $  9,180   $   17
  2%"                       1,800         17.35         31,230       18,740       34
  3"                          600         18.20         10,920        6,550       11

Service connections
  STE pump                     27         3,428         92,560       27,770    1,701

Septic tank
  upgrade                      21           143          3,000        1,800      210
  replace                       8           750          6,000        3,600       80

Cluster drainfield
  Bass Island Sub.             29         1,250         36,250            0    2,080
  Dosing pump 18 gpm
   TDH 20 ft                                            12,750        3,830    1,319

Subtotal initial cost                                  208,010       71,468    5,452
Service factor (35%)                                    72,800
Subtotal initial capital cost                          280,810
                                       D-17

-------
Table D-17. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #3 Pipestone
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M

STE pressure sewer pipe
  2"                          600       $ 17.00       $ 10,200     $  6,120   $   11
  2h"                       1,680         17.35         29,150       17,490       32
  3"                        2,250         18.20         40,950       24,570       43

Service connections
  STL pump                     38         3,428        130,260       78,160    2,394

Septic tank
  upgrade                      31           143          4,430        2,660      310
  replace                      10           750          7,500        4,500      100

Cluster drainfield
  North lake an>a              41         1,250         51,250            0    2,080
  Dosing pump 25 gpm
   TbH 20 ft                                            12,750        3,830    1,413

Subtotal initial cost                                  286,500      137,500    6,383
Service factor (35%)                                   100,270
Subtotal initial capital cost                          386,770
                                       D-18

-------
Table D-18. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #5 Sister
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M

STE pressure sewer pipe
  2%"                         750 If    $ 17.35       $ 13,000     $  7,800   $   14
  3"                        3,200 If      18.20         58,300       34,980       61

Service connections
  STE pump                     30         3,428        102,800       30,840    1,890

Septic tank
  upgrade                      31           143          4,440        2,660      310
  replace                      11           750          8,250        4,950      110

Cluster drainfield
  Sister Lakes                 50         1,250         62,500           —    2,080
  Dosing pump 31 gpm
   TDK 20 ft                                            30,900        9,270    1,326

Initial cost                                           280,190       90,500    5,791
Service factor (35%)                                    98,070
Initial capital cost                                   378,260

Future connections cost
  Building sewer                3            55            170          100
  Septic tank + STE pump        3         4,128         12,380        3,710      219
  Future connections cost                               12,550        3,810      219
  Annual future connections cost                           628          191       11
                                       D-19

-------
Table D-19. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #10 Sister
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M
STE pressure sewer pipe
2V
3"
Service connections
STE pump
Septic tank
upgrade
replace
Cluster drainfield
Gilmore Beach
Dosing pump 21 gpm
TDH 20 ft
Folk's Landing
Dosing pump 10 gpm TDH
20 ft
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer
Septic tank + STE pump
Future connections cost
Annual future connections

350 If
2,700 If

35

27
18

33


15






3
3

cost

$ 17.35
18.20

3,428

143
750

1,250


1,250






55
4,128



$ 6,070
49,200

120,000

3,860
13,500

41,300

12,750
18,750

12,750
278,180
97,360
375,540

170
12,380
12,550
628

$ 3,640
29,500

36,000

2,320
8,100

—

3,830
—

3,830
87,220



100
3,710
3,810
191

$ 7
52

2,205

270
180

2,080

1,321
2,080

1,315
9,510



—
219
219
11
                                       D-20

-------
Table D-20. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #11 Sister
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     0£M
STE pressure sewer pipe
2 100 If $ 17.00
2h" 600 If 17.35
Service connections
STE pump 12 3,428
Septic tank
upgrade 11 143
replace 5 750
Cluster drainfield
Maple Island 17 1,250
Dosing pump 11 gpm
TDH 20 ft
Initial cost
Service factor (35%)
Initial capital cost
Future connections cost
Building sewer 1 55
Septic tank + STL pump 1 4,128
Future connections cost
Annual future connections cost

$ 1,700
10,400

41,200

1,570
3,750

21,250

12,750
92,620
32,420
125,040

60
4,130
4,190
210

$ 1,020
6,250

12,330

950
2,250

—

3,830
26,630



30
1,240
1,270
64

$ 2
11

756

110
50

2,080

1,316
4,325



—
73
73
4
                                       D-21

-------
Table D-21. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #13 Sister
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M

STE pressure sewer pipe
  2h"                       1,700 If    $ 17.35     $   29,500     $ 17,700   $   32
  3                           300         18.20          5,460        3,280        6

Service connections
  STE pump                     18         3,428         61,700       18,500    1,133

Septic tank
  upgrade                      14           143          2,000        1,200      140
  replace                       8           750          6,000        3,600       80

Cluster drainfield
  Magician Bay Park            22         1,250         27,500           —    2,080
  Dosing pump 14 gpm
   TDH 20 ft                                            12,750        3,830    1,317

Initial cost                                           144,910       48,110    4,788
Service factor (35%)                                    50,720
Initial capital cost                                   195,630
                                       D-22

-------
Table D-22. Quantities and costs for septic tank effluent pressure sewers and
            cluster drainfields serving limited areas for District #15 Sister
            Lakes (Alternative 10).

Item                        Quantity    Unit Cost   Construction   Salvage     O&M

STE pressure sewer pipe
  2"                          100 If    $ 17.00        $ 1,700     $  1,020   $    2
  3"                        3,050 If      18.20         55,500       33,300       58

Service connections
  STE pump                     15         3,428         51,400       15,400      945

Septic tank
  upgrade                      15           143          2,150        1,290      150
  replace                       5           750          3,750        2,250       50

Cluster drainfield
  Sandy Beach Resort           21         1,250         26,250           —    2,080
  Dosing pump 13 gpm
   TDH 20 ft                                            12,750        3,830    1,317

Initial cost                                           153,500       57,090    4,602
Service factor (35%)                                    53,730
Initial capital cost                                   207,230

Future connections cost
  Building sewer                1            55             60           30
  Septic tank + STE pump        1         4,128          4,130        1,240       73
  Future connections cost                                4,190        1,270       73
  Annual future connections cost                           210           64        4
                                       D-23

-------
Table D-23. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #1 Indian Lake
            (Alternative 10).
Item

Septic tank
  upgrade
  replace
Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  Lift pump + raised drain
   bed
  dry well
  lift pump + dry welL
Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank:
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
    154
     30
    184
     27
      7
      7

     10
      5
     12

     10
      8
      2
$  143
   750

   754
 1,620
 1,555

 2,421
   578
 1,444

 1,470
   835
   835
$22,030
 22,450

 20,330
 1L.340
 10,890

 24,210
  2,890
 17,340

 14,700
  6,680
  1,670

154,530
 54,090
208,620
$13,230
 13,500
  4,000
  1,000

 31,730
                                      O&M
$1,540
   300
 1,840

   434
              620

              744
   320
   240

 6,038
17
17
17
12
7
4
8
3
3
3
1
2


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


940
11,900

9,040
11,340
6,220
19,380
1,730
4,330
4,410
840
1,670
70,800
3,540
560
7,140

—
—
—
—
—
—
—
500
1,000
9,200
460
—
170
170
—
434
—
496
—
186
—
140
240
1,736
868
                                       D-24

-------
Table D-24. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  //2 Indian Lake
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    jJnit Cost   Construction   Salvage
    101
     21

    122
      7
     10
      5

      7
      5
     10
      6
      0
$  143
   750
   754
 1,620
 1,555

 2,421
   578
 1,444
 1,470
   835
   835
$14,430
 15,730
  5,280
 16,200
  7,780

 16,970
  2,890
 14,440
  8,820
  5,020
                         107,560
                          37,650
                         145,210
13
13
13
10
3
10
2
0
2
3
2
1


55
700

754
1,620
1,555
2,421

1,444
1,470
835
835


720
9,100

7,540
4,860
15,550
4,840

2,890
4,410
1,670
840
52,420
2,621
$,8,690
  9,450
  3,010
                           21,150
 O&M


$1,010
   210

 1,220

   620


   434

   620



   240


 4,354
                                           430
                                         5,460       130
                                                     130

                                                     186

                                                     124

                                                     124
                                         1,000        80
                                           500       120
                                         7,390       894
                                           370        45
                                       D-25

-------
Table D-25. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  #3  Indian Lake
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
     13
                                     O&M
99
38
137
4
7
9
9
2
6
$ 143
750

754
1,620
1,555
1,555
578
1,444
$14,150
28,470

3,010
11,340
14,000
21,800
1,160
8,670
$ 8,510 $ 990
17,100 380
1,370
—
434
— —
558
—
372
1,470
  835
  835
 19,110
  6,680
  4,180

128,570
 45,000
173,570
                                         4,010
                                         2,500

                                        32,110
  320
  600

5,024
18
18
18
12
7
4
8
3
3
3
1
2


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


990
12,600

9,040
11,340
6,230
19,370
1,730
4,340
4,410
840
1,670
72,560
3,628
590
7,560

—
—
—
—
—
—
—
500
1,000
9,650
483
—
180
180
—
434
—
496
—
186
__
40
240
1,756
88
                                       D-26

-------
Table D-26. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #1 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
      9
      8
      1
                                     O&M
85
20
105
20
5
5
15
3
4
$ 143
750

754
1,620
1,555
2,421
578
1,444
$12,130
15,000

15,080
8,100
7,780
36,350
1,730
5,780
$ 7,310 $ 850
9,000 200
1,050
—
310
— —
930
—
248
1,470
  835
  835
 13,230
  6,680
    840

122,700
 42,950
165,650
 4,000
   500

20,810
  320
  120

4,028
21
21
21
10
5
5
8
2
4
1
1
0


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


1,160
14,700

7,540
8,100
7,780
19,370
1,160
5,780
1,470
840
—
67,900
3,395
690
8,820

—
—
—
—
—
—
—
500
--
10,010
501
—
210
210
—
310
—
496
—
248
—
40
—
1,514
76
                                       D-27

-------
Table D-27. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  M Sister Lakes
            (Alternative 10).
Item

Sept:!", tank
  up0t ide
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift putup + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
      12
       8
       4
                                     O&M
84
27
111
10
7
7
15
5
5
$ 143
750

754
1,620
1,555
2,421
578
1,444
$12,000
20,250

7,540
11,340
10,880
36,350
2,890
7,230
$ 7,200 $ 840
12,130 270
1,110
—
434
— —
930
— —
310
L.470
  835
  835
 17,640
  6,680
  3,340

136,140
 47,650
183,790
 4,000
 2,000

25,330
  320
  480

4,694
29
29
29
20
7
6
5
2
2
3
2
1


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


1,590
20,300

15,080
11,340
9,330
12,120
1 , 160
2,890
4,410
1,670
840
80,730
4,037
960
12,170

—
—
—
—
—
—
—
1,000
500
14,630
732
—
290
290
—
434
—
310
—
124
—
80
120
1,648
83
                                       D-28

-------
Table D-28. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #5 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
           O&M
145
50
195
20
12
9
12
5
9
$ 143
750

754
1,620
1,555
2,421
578
1,444
$20,720
37,500

15,080
19,440
14,000
29,060
2,890
13,000
$12,470 $1,450
22,500 500
1,950
—
744
— —
744
—
558
18
8
10
1,470
835
835
26,460
6,680
8,350
—
4,000
5,000
—
320
1,200
                         193,140
                          67,600
                         260,740
43,970
7,466
18
18
18
15
4
4
3
2
5
6
2
4


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


990
12,600

11,300
6,480
6,230
7,270
1,160
7,230
8,820
1,670
3,340
67,090
3,355
590
7,560

—
—
—
—
—
—
—
1,000
2,000
11,150
558
—
180
180
—
248
—
186
—
310
—
80
480
1,664
83
                                       D-29

-------
Table D-29. Quantities and costs for upgrading and operating on-site  systems
            in areas not served by cluster systems for District  //6 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lii~t pump + raised drain
   bed
  dry well
  lift pump + dry well
Holding tank systems
  water conservation devices
  tank for seasonal residences
  tank for permanent residences

Initial cost
Service factor (35%)
Initial capital cost

Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  Permanent residences
  Future costs
  Annual future cost
Unit Cost   Construction
O&M
172
44
216
12
1L
14
15
7
15
21.
18
3



30
30
30
25
5
5
5
4
8
5
3
2


$ 143
750

754
1,620
1,555
2,421
578
1,444
L,470
835
835



55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


$24,600
33,000

9,050
17,820
21,800
36,300
4,050
21,680
30,870
15,020
2,510
216,700
75,850
292,550
1,650
21,000

18,850
8,100
7,780
12,100
2,310
11,560
7,350
2,510
1,670
94,880
4,744
$14,800
19,800

—
—
—
—
—
— —
__
9,020
1,500
45,120


990
12,600

—
—
—
—
—
—
—
1,500
1,000
16,090
805
$1,720
440
2,160
—
682
—
930
—
930
__
720
360
7,942


__
300
300
—
310
—
310
—
496
—
240
240
2,076
104
                                       D-30

-------
Table D-30. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #7 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
     75
     12
$  143
   750
$10,730
  9,000
87
5
13
5
5
5
12




754
1,620
1,555
2,421
578
1,444




3,770
21,060
7,780
12,110
2,890
17,330
84,670
29,630
114,300
$ 6,440
  5,400
                                        11,840
 O&M


$  750
   120

   870

   806


   310

   744

 3,600
10
10
10
7
3
2
2
0
7


55
700

754
1,620
1,555
2,421
578
1,444


550
7,000

5,280
4,860
3,110
4,840
—
10,110
35,750
1,788
330
4,200

—
—
—
—
—
—
4,530
267
—
100
100
—
186
—
124
—
434
944
47
                                       D-31

-------
Table D-31. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #8 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
    125
     17

    142
     17
      7
     12

      7
      5
      5
      5
      4
      1
$  143
   750
   754
 1,620
 1,555

 2,421
   578
 1,444
 1,470
   835
   835
$17,880
 12,750
 12,810
 11,340
 18,670

 17,940
  2,890
  7,230
  7,350
  3,340
    840

113,040
 39,560
152,600
$10,760
  7,650
  2,000
    500

 20,910
 O&M


$1,250
   170

 1,420

   434


   434

   310
   160
   120

 4,298
32
32
32
17
7
5
7
5
2


55
700

754
1,620
1,555
2,421
578
1,444


1,760
22,400

12,810
11,340
7,780
17,940
2,890
2,890
79,810
3,991
1,060
13,440

—
—
—
—
—
—
14,500
725
                                                     320
                                                     320

                                                     434

                                                     434
                                                     434
                                                     124
                                                   1,632
                                                      82
                                       D-32

-------
Table D-32. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District //9 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank system
  water conservation devies
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
           O&M
146
44
190
12
12
12
15
5
15
$ 143
750

754
1,620
1,555
2,421
578
1,444
$20,860
33,000

9,050
19,430
18,670
36,320
2,890
21,630
$12,560 $1,460
19,800 440
1,900
—
744
— —
930
—
930
17
12
5
1,470
835
835
24,990
10,030
4,180
—
6,000
2,500
—
480
600
                         201,050
                          10,370
                         241,720
40,860
7,684
27
27
27
15
9
4
10
5
10
4
2
2


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


1,490
18,900

11,320
14,580
6,230
24,210
2,890
14,440
5,880
1,670
1,670
103,280
5,164
890
11,330

—
—
—
—
—
—
—
1,000
1,000
14,220
711
—
270
270
—
558
—
620
—
620
— —
80
240
2,654
133
                                       D-33

-------
Table D-33. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  #10 Sister Lakes
            (Alternative 10).
Item                        Quantlt)

Septic tank
  upgrade                        72
  replace                        21

Soil absorption system           93
  drain bed                      14
  lift pump + drain bed          13
  raised drain bed                8
  lift pump + raised drain
   bed                            7
  dry well                        5
  lift pump + dry well            5
      Unit Cost   Construction   Salvage
holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost

Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank system
  water conservation devies
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
5
3
2
       $  143
          750
          754
        1,620
        1,555

        2,421
          578
        1,444
1,470
  835
  835
           $10,300
            15,730
            10,550
            21,070
            12,440

            16,950
             2,890
             7,230
  7,350
  2,510
  1,670

108,690
 38,040
146,730
              $ 6,190
                9,450
 1,500
 1,000

18,140
           O&M


          $  720
             210

             930

             806


             434

             310
  120
  240

3,770
24
24
24
12
11
7
6
3
5
1
0
1


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


1,320
16,800

9,050
17,830
10,890
14,530
1,730
7,230
1,470
—
840
81,690
4,085
790
10,070

—
—
—
—
—
— —
—
—
500
11,360
568
—
240
240
—
682
—
372
—
310
—
—
120
1,964
98
                                       D-34

-------
Table D-34. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #11 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well
Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost

Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank system
  water conservation devies
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   Salvage
     85
     29
     16
     12
      4
$  L43
   750
 1,470
   835
   835
$12,140
 21,750
114
5
15
9
13
2
12

754
1,620
1,555
2,421
578
1,444


24,300
14,000
31,480
1,150
17,340
 23,520
 10,020
  3,340

159,040
 55,660
214,700
$ 7,400
 13,050
  6,000
  2,000

 28,450
 O&M


$  850
   290

 1,140

   930


   806

   744
   480
   480

 5,720
8
8
8
5
6
3
4
0
4
2
1
1


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


440
5,600

3,770
9,730
4,670
9,690

5,780
2,940
840
840
44,300
2,215
260
3,760

—
—
—
—
—
—
—
500
500
5,020
251
—
80
80
—
372
—
248
—
248
—
40
120
1,188
59
                                       D-35

-------
Table D-35. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  #12 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Initial cost
Service factor (35%)
Initial capital cost
Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well

  Future costs
  Annual future cost
Quantity    Unit Cost   Construction   jalva
0£M
60
21
81
10
10
5
10
5
10



10
10
10
7
8
3
10
0
5


$ 143
750
__
754
1,620
1,555
2,421
578
1,444



55
700
—
754
1,620
1,555
2,421
578
1,444


$ 8,580
15,750
—
7,540
16,200
7,780
24,210
2,890
14,440
97,390
34,080
131,470
550
7,000
—
5,280
12,960
4,660
24,210
_-
7,220
61,880
3,094
$ 5,150
9,450
	 ,
—
—
—
—
—
—
14,600
—

330
4,200
—
—
—
—
—
—
—
4,530
—
$ 600
210
810
—
620
—
620
—
620
3,480
—


100
100
—
496
—
620
—
310
1,626
81
                                       D-36

-------
Table D-36. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District  #13 Sister Lakes
            (Alternative 10).
Item                        Quantit
Septic tank
  upgrade
  replace

Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost

Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well

Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

  Future costs
  Annual future cost
Unit Cost   Construction   Salvage
0£M
81
37
118
5
15
10
12
7
12
15
11
4



32
32
32
25
5
5
7
2
4
3
2
1


$ 143
750
—
754
1,620
1,555
2,421
578
1,444
1,470
835
835



55
700
—
754
1,620
1,555
2,421
578
1,444
1,470
835
835


$11,560
27,730
—
3,770
24,300
15,550
29,050
4,050
17,330
22,050
9,190
3,340
167,920
58,770
226,690
1,760
22,400
—
18,830
8,100
7,780
16,950
1,160
5,780
4,410
1,670
840
89,680
4,484
$ 6,950
16,630
—
—
—
—
—
—
—
__
5,500
2,000
31,080
—

1,060
13,440
—
—
—
—
—
—
—
^^^
1,000
500
16,000
800
$ 810
370
1,180
—
930
—
744
—
744
__
440
480
5,698
—

L T mri
320
320
—
310
—
434
—
248
„
80
120
1,832
92
                                       D-37

-------
Table D-37. Quantities and costs for upgrading and operating  on-site  systems
            in areas not served by cluster systems for District  #14 Sister  Lakes
            (Alternative 10).
Item                        ^SB^itZ    Unit Cost   Construction    Salvage     0 &M
Septic tank
  upgrade                        22      $   143      $  3,150        $  1,890     $   220
  replace                         7          750         5,250          3,150         70

Soil absorption system           29          —           --            —        290
  drain bed                       0          754
  lift pump + drain bed           5       1,620         8,100            —        310
  raised drain bed                3       1,555         4,660
  lift pump + raised drain
   bed                            2       2,421         4,840            —        124
  dry well                        1          578          580
  lift pump + dry well            1       1,444         1,440            —         62

Holding tank systems
  water conservation devices      5       1,470         7,350            —
  seasonal residences             5          835       4,, 180          2,500        200

Initial cost                                          39,550          7,540     1,476
Service factor (35%)                                  13,840
Initial capital cost                                  53,390

Future costs
  Building sewer                  3          55          160           100
  Septic tank                     3          700         2,100          1,260         30
  Soil absorption systems         3          —           —            —         30
  drain bed                       2          754         1,510
  lift pump + drain bed           2       1,620         3,240            —        124
  raised drain bed                1       1,555         1,560
  lift pump + raised drain bed    1       2,421         2,420            —         62
  lift pump + dry weLl            2       1,444         2,890            —        124
  Future costs                                        13,880          1,360        370
  Annual future cost                                     694            68         19
                                       D-38

-------
Table B-38. Quantities and costs for upgrading and operating on-site systems
            in areas not served by cluster systems for District #15 Sister Lakes
            (Alternative 10).
Item

Septic tank
  upgrade
  replace
Soil absorption system
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain
   bed
  dry well
  lift pump + dry well
Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences

Initial cost
Service factor (35%)
Initial capital cost

Future costs
  Building sewer
  Septic tank
  Soil absorption systems
  drain bed
  lift pump + drain bed
  raised drain bed
  lift pump + raised drain bed
  dry well
  lift pump + dry well
  Holding tank systems
  water conservation devices
  seasonal residences
  permanent residences
  Future costs
  Annual future cost
Quantity    IJnit Cost   Construction   Salvage
O&M
146
27
173
20
15
17
13
7
17
7
5
2



$ 143
750
—
754
1,620
1,555
2,421
578
1,444
1,470
835
835



$20,860
20,250
—
15,080
24,300
26,450
31,500
4,050
24,530
10,290
4,170
1,670
183,150
64,100
247,250
$12,550
12,140
—
—
—
—
—
—
—
—
2,500
1,000
28,180
—

$ 1,460
270
1,730
—
931
—
806
—
1,053
—
200
240
6,690
—

28
28
28
15
8
8
12
5
7
3
2
1


55
700

754
1,620
1,555
2,421
578
1,444
1,470
835
835


1,540
19,600

11,310
12,960
12,430
29,100
2,890
10,120
4,410
1,670
840
106,870
5,344
940
11,760

—
—
—
—
—
—
—
1,000
500
14,200
710
—
280
280
—
496
—
744
—
434
—
80
120
2,434
122
                                       D-39

-------
         APPENDIX E




Letters and Written Comments

-------
I  SOUTHWESTERN
     MICHIGAN
    COMMISSION
   "Serving Business
    and Government"
                       SOUTHWESTERN   MICHIGAN COMMISSION
                                  2907 Division Street, St. Joseph, Ml 49085-3498
                                     616/983-1529-Within 616, 800/442-0762
        September 28, 1982
        Mr.  Harlan D. Hirt, 5WFI-12
        Chief, Environmental  Impact  Section
        U.S.  Environmental Protection  Agency
        230  S. Dearborn Street
        Chicago, IL   60604

        Dear Mr. Hirt:

        Attached is the Southwestern Michigan Commission's  Public  Hearing
        Statement on the Draft  Environmental Impact Statement  for  the
        Indian/Sister/Pipestone Lakes  Wastewater Treatment  System.

        This  Public Hearing Statement  was approved first by the  Commission's
        Planning and Resources  Committee and then by the full  Southwestern
        Michigan Commission (previously named the Southwestern Michigan
        Regional Planning Commission).

        Please contact me if  you have  any questions regarding  this  Statement.

        Sincerely,
        PLANNING AND RESOURCES
        Peter D. Elliott
        Program Manager
        Attachment
Business Promotion Program • Miles and Twin Cities Area Transportation • Human Resources • Regional Planning •

    Tourist Council • Ridesharing • Southwestern Michigan Development Company, Inc. Ph. 616/983-7234

-------
                             THE
             SOUTHWESTERN MICHIGAN COMMISSION'S
                  PUBLIC HEARING STATEMENT
                           ON THE
            DRAFT ENVIRONMENTAL IMPACT STATEMENT
                           FOR THE
              INDIAN / SISTER / FIRESTONE LAKES
                 WASTEWATER TREATMENT SYSTEM

                     September 28, 1982

The Southwestern Michigan Commission is gravely concerned that
                       .»
the U.S. Environmental Protection Agency has not addressed
comments previously submitted by our Comniiss'ion.  Specifically,
the Commission has expressed concern that Alternative #9, the
recommended wastewater system alternative, is not viable and is
unappropriate based on existing physical conditions and costs.
We believe that a combination of several alternatives may be
appropriate.

These comments were submitted to the U.S. EPA in May of 1982 along
with an invitation to meet with us.  There has been no follow-up
on these comments, so the Commission wishes to reiterate them and
to ask that the alternatives be re-evaluated.  This re-evaluation
must consider the real local situation, both environmental and
governmental.  Based on our knowledge, Pipestone Lake is well suited
to Alternative ;;3A or S3, Indian Lake to Alternative l'-6, anc; the
Sister Lakes to combinations of #8A, 8B, and 9 (with no holding tanks)

Practically all of the data-base collected to date for this Environ-
mental  Impact Statement is unacceptable in our minds.  The Septic
Leachate Survey was conducted in October of 1979, well after the
seasonal influx of lake residents had departed.  The aerial photo-
graphy survey was likewise conducted at the wrong time of the year,
after the trees and shrubs had leafed out in May of 1979.  This makes
                           (more)

-------
  Southwestern  Michigan  Commission
  Public  Hearing  Statement
  September  28, 1982
  Page  2
  the  photography  practically  useless  for  its  intended  purpose of
  detecting  septic system failures.  The demographic  data  is  acceptable
  to us  only because  a  preliminary  review  by our  County and Regional
  staff  pointed  out gross errors  that  the  EPA  has since corrected.

  Attached for the Public Hearing Record are three letters from  our
  Commission to  the U.S.  EPA over the  past three  years  that have
  provided comments and guidance, all  of which has been largely  ignored.
  In August  of 1979,  the  Commission  requested  significant  involvement
  in the development  of this draft  EIS.  This  has not happened.  Although
  a  Citizen's Advisory  Committee  v»as organized rather late in the
  process, no EPA  staff was  available  to meet  with the  group  to  discuss
  various aspects  of  the  study.

  This EIS project, with an  expected final cost of $425,000,  has
  been so mis-managed by the U.S. EPA  that the Southwestern Michigan
  Commission cannot support  the  Draft  Environmental  Impact Statement
  and  most likely  the Final  Statement  until  such  time that a  major
  re-evaluation  of the  recommended  wastewater  system  alternative
  occurs along with extensive  involvement  of County Planning  and
  Health Department expertise  from our three counties.
  IP closing,  wa vrish to endorse th? cor'.T.?nt3  of  Lho  ^erri
  and Cass County Health Departments dated May 6,  1982  and  September
  21, 1982, respectively.
  This Public Hearing Statement was
  approved at the September 28, 1982
  meeting of the:
  SOUTHWESTERN MICHIGAN COMMISSION     PLANNING AND RESOURCES COMMITTEE
                                             ^-\
                        ^' "                  / /
                       <•'               /•//-   ^-v;   , /'
                    -   N-                //_.-^_-~i'   •-.,'/   A*i
.                    --                  ' '  '         ^-^X-—
                                              _
  Frances Sage, Chair — -;  y           Robert J.  Smith /"Chair

-------
Southwestern Michigan Commission
Public Hearing Statement
September 28, 1982
Page 3
cc:  U.S. Senator Donald Riegle, Jr.
     U.S. Senator Carl  Levin
     U.S. Representative Mark D. Siljander
     State Senator Harry Cast, Jr.
     State Senator John A.  Wei born
     State Representative Carl F. Gnodtke
     State Representative Harmon Cropsey
     State Representative Bel a E. Kennedy
     State Representative Lad S. Stacey
     John C. Hertel, Chairman, Senate Environmental  and Agricultural
        Affairs Committee
     Tom Anderson, Chairman, House  Conservation Environment and
        Recreation Committee
     Raymond Hood, Chairman, House  Public Health Committee
     James Barcia, Chairman, House  Public Works Committee
     Valdas Adamcus, U.S. EPA Regional  Administrator
     Harlan D. Hirt, Chief, Environmental Impact Section, U.S.  EPA
     Charles A. Quinlan,1 III, U.S.  EPA Project Monitor
     Howard A. Tanner,  Director, Michigan Department of Natural
        Resources
     Robert J. Courchaine,  Michigan Department of Natural Resources
     Johnie A. Rodebush, Chairman,  Cass County Department of Public
        Works
     Mr. & Mrs. Richard A.  Meisterheim, Co-Chair, Citizen's Advisory
        Committee

-------
Southwestern Michigan Regional Planning Commission
2907 Division Street • St. Joseph, Michigan 49085 • Telephone 616/983-1529

August 28, 1979
Ms. Kathleen Schaub
EIS Preparation Section
Environmental Engineering Branch
U. S. Environmental Protection Agency
230 South Dearborn Street
Chicago, IL   60604

Dear Ms. Schaub:
                     >
Re:  Indian Lake/Sister Lakes EIS

The Southwestern Michigan Regional  Planning Commission's (SMRPC's)
Environmental Quality Committee met to  discuss the Indian Lake/
Sister Lakes Study.  There was much discussion concerning the role
that local people will  play in developing  plans for this area.
I would like to pass along a few  thoughts  and request some information.:

During the development of the 208 Areawide Water Quality Plan, the
SMRPC established a TAC to advise the Commission on water quality
matters.  Many of the people that you are  organizing into a TAC were
on this former TAC which currently continues in a very much smaller
version.  The former TAC established bylaws and reported directly to
the SMRPC.  I have enclosed a copy of those bylaws for your reference.

We believe that the first step toward e successful study is for you
to clarify for us the roles that  l.be venous loc-?l aQer.oes. advisory
groups, staff, and citizens will  play in the conduct of the study.
Especially set out the structure  and roles of the TAC that you have
organized, and also the role of the SMRPC, which has received EPA
approval as the Water Quality Board for southwestern Michigan.  We
would like to know who the TAC will advise an-d will it be a decision
making group.  It is particularly important that the purpose of your
TAC be clearly detailed to the members.  Many of the members must
justify time spent at meetings and in reviewing information.  Also,
in what manner will local comments receive serious consideration,
and how will conflicts be resolved?

According to the Federal Regulations, the purpose of a Notice of
Intent  is to encourage agency and public input into a draft EIS.
We would  like, at this point, to  specifically request opportunities
for this  input, not merely in the form  of exchanging data, but with
review  and the making of recommendations during the development of
the draft EIS.  Perhaps as sections of  chapters are written, you could
send~mem"- to the SMRPC for .'distribution to the TAC.       .   .

-------
Ms. Kathleen Schauh
Page 2
August 28, 1979
The SMRPC is very interested in assisting  a  well-organized  study  that
will respond to the needs and financial  capabilities  of the residents
of our region.  The result of any study  must,  of necessity, be
politically feasible and also workable within  the existing  local
codes and ordinances.  The Environmental Quality Committee  and  staff
stand ready to coordinate any meetings and distribute any information
and papers for review at the local level that  will  be necessary.
With your timely response to these questions,  we can  be prepared  to
provide input to this important study.

I look forward to your reply.  Please respond  to the  SMRPC,
Environmental Quality Committee, Mr.  Robert  Smith,  Chairman in
care of Mr. Peter Elliott at the letterhead  address.
Sincerely,

SOUTHWESTERN MICHIGAN REGIONAL
   PLANNING COMMISSION
ENVIRONMENTAL QUALITY
COMMITTEE
mjo
Enclosure
                                              Robert  J. Smith,  Chairman
cc:  Mr. Gene Wojcik, Chief, EIS Section
     Mr. John Piccininni, 208 Project Officer *
     Mr. John McGuire, EPA Regional  Administrator,  Region V
     Boards of Commissioners; Berrienj Cass,  and  Van  Buren Counties
     Boards of Public Works
     Township Supervisors:  Bainbridge (Berrten),  Keeler  (Van  Buren),
        Silver Creek (Cass), 'Pokagcn
     David A, Stockman, f^nbe." of

-------
   Southwestern SVlichigan Regional Planning Commission
   2907 Division Street • St. Joseph, Michigan 49085 • Telephone 616/983-1529


January 25, 1980
Ms. Kathleen M.  Schaub,  Project Officer
EIS Section
Environmental Engineering  Branch
U. S. Environmental  Protection Agency
230 South Dearborn Street
Chicago, II   60604

RE:  Indian/Sister Lakes EIS
                          t
Dear Ms. Schaub:

Thank you very much for  the information that you recently sent me.
Mr. Tally Richards and  I are  prepared to call the first advisory
group meeting as soon as there are review materials available.

I feel that review materials  should be mailed out in advance of any.
meeting with the meeting notice.  This will provide time for thorough
advanced reading so that the  meeting can be used for productive
discussion.  Please let  me know how you think this sort of mailing
can best be accomplished.  I  do not believe that the SMRPC could
absorb these mailing costs.

As was requested in the  SMRPC's August 28, 1979 letter, we expect
input into the draft EIS,  not simple review of the draft before the
final EIS.  This is very important.  For the EIS to be successful in
this region, support rnust  bz  built from the beginning.  This hasn't
bean accomplished thus  for.   There is a lot of skepticism en tho part
of many local officials  and citizens.

Please send chapters or  portions  of chapters, (such as the Introduction,
Environmental Setting),  or data and field reports.(soils, groundwater,
surface water, Septic Snooper, etc.) when they are drafted so that
our local review and input may begin.  If local people are initially
provided a draft EIS, similar to  what has been done for the Rural Lake
Projects - Case Studies, I believe the reaction will be most unfavorable.

-------
Ms. Kathleen M. Scha
January 25, 1980
Page 2
Please notify Mr. Richards and myself when to expect the first set of
review materials, and a schedule for all future outputs would be
very he!pful.

We await your earliest response.  Please call me if this warrants
discussion.

Sincerely,
Peter D. Elliott
Planner

PDE/mz
re;  Mr.  Gene Wojcik, Chief, EIS Section
     Mr.  John Piccininni, 208 Project. Officer

-------
                               Administrators for:
                               HUMAN RESOURCES COMMISSION and
                               SOUTHWESTERN MICHIGAN
                               BUSINESS PROMOTION PROGRAM

       Southwestern Michigan Regional Planning Commission
       2907 Division Street • St. Joseph, Michigan 49085 • 616/983-1529 or 800/442-0762

May 18, 1982
Charles A. Quinlan III, Project Monitor
U.S. Environmental Protection Agency
Attention:  5WFI-12
230 South Dearborn
Chicago, IL  60604

Dear Mr. Quinlan:

Environmental Health and Planning  Staff  from  Berrien,  Cass and Van
Buren Counties and the SMRPC staff have  discussed Chapters I - IV
of the Preliminary Draft Environmental Statement  for Indian/Sister
Lakes, Michigan.  Based on their cursory examination of the docu-
ments, we must notify you that Chapter 2.0  -  DISCUSSIONS OF WASTE-
WATER TREATMENT ALTERNATIVES is locally  unacceptable in its present
form.  Alternative #9 is not viable and  is  unappropriate based on
existing physical conditions and costs.  A  combination of several
alternatives may be appropriate.

These comments are being submitted to you because local technical
staff in cooperation x^ith the SMRPC's Planning  and Resources Com-
mittee, the Cass County Department of Public  Works,  and the EIS
Citizens Advisory Committee feel they have  an obligation to point
out serious problems at the earliest possible time.   Specific
solutions to these problems could  be offered  locally,  however,
reimbursement for the time needed  for this  has  not been made
available.

We invite you to meet with us and  oar staff to  discuss these com-
ments in detail.

Sincerely,

PLANNING AND RESOURCES COMMITTEE
Robert  J.  Smith,  Chairman

jah

cc:  Valdas Adamcus, EPA  Regional Administrator.
     Johnie  Rodebush,  Chairman,  Cass County  Dept.  of Public Works
     Mr.  & Mrs. Meisterheim,  Co-Chair,  Citizens Advisory Committee

       E.vrrisn                Cvcr*                 v,'o.i Buran

-------
                           BERRIEN COUNTY HEALTH DEPARTMENT
769 Pipestone,  P.O. Box  706        425 West Buffalo Street            1205 North Front Street
Benton  Harbor, Michigan  49022     New Buffalo,  Michigan 49117       Niles, Michigan 49120
Telephone:  926-7121               Telephone:   469-5220              Telephone:  684-2800
                                              May 6, 1982
              Mr. Peter Elliott
              Southwestern Michigan  Regional  Planning Commission
              2907 Division Street
              St. Joseph, Michigan  49085

                                               Re:   Indian/Sister/Pipestone  Lakes
                                                    Environmental Statement

              Dear Mr.  Elliott:

              Enclosed please  find my comments to subject plan with the first
              comments  being  specific and the second set of comments  being of a
              more general nature.  Due to time limitations  this quick  review  is
              not intended to  be comprehensive and  may be only a "bandaide
              to a terminally  ill  project".

              A.    Specific Comments:

                    Page 2-18, last paragraph, fourth line - add  "and  Berrieh" between
                    Cass and  County.

                    2-35 Summary, sixth line - I object to "are not  necessary" since
                    a limited  soil absorption  capacity would  make water conservation
                    measures a valuable tool on  individual situations.

                    2-77 - There has  been no mention of  composting toilets  as an
                    alternative system.

                    2-83 - I do  net ag.'e-a with  cojt  Snores  i'o - C!LC;VV, -;(::•. a -.L.T :•:.:'•  °-
                    and an alternative number  10 ''Do Nothing" should  be added
                    with its associated cost!

                    2-83 - Alternatives 8 A and 8 B do not mention Michigan's legal
                             " against cluster  systems.    *
                    2-53 -  Land Disposal - this section contains many naive statements.

                    3-17 -  Pipestone  Creek is  a designated trout stream.

                    3-74 -  The Berrien  County Health Department Sanitary Code
                    does not authorize  permits for replacement systems.

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Mr. Peter Elliott
May 6,  1982
Page 2
      3-75 - sixth  line "rarely  limit installation  of on-site systems" is
      not accurate.

      3-76 - last paragraph is  inaccurate.

      4-24 - last paragraph -  poor comparison as Muskegon's  project
      uses very heavy dose rates.
                     »
B.    General Comments

      1.  Pipestone Lake is well suited to alternative 8 A or 8 B and
          I'm sure these alternatives  for apprimately the 60 structures
          around  Pipestone  Lake could  have  already been accomplished
          with the money spent on  12 years  of  study!

                                Sincerely,
                                 Donald Oderkirk, R.S.,  M.S.
                                 Director of Environmental Health
DO:bm

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                                                      RECEIVED SEP 2 3 198

               Cass County  Health Department
                     24010 HOSPITAL ROAO a CASSOPOUS. MICHIGAN 49031
                                                             PHONES
                                                              CASSOPOLIS 445-8654
                                                              DOWAGIAC 782-2856
September 21, 1982
Val Adamkus
Regional Administrator
Region 5
E.P.A.                    ,
230 S. Dearborn Street    '
Chicago, Illinois 60608

Re:       Draft Environmental Impact  Statement,  Indian Lake-Sister
          Lakes, Cass, Berrien and Van  Buren  Counties, Michigan


Dear Mr. Adamkus:

Recently our department  received  a draft  copy of the above-captioned
document. Because of the volume of paper  generated in the report
we could not review each page in  detail.   However, a concerted  effort
was made to review those aspects  related  to the  proposed alternative
 (attached) .  The following  comments and questions are meant to be
part of the public record and must be taken into consideration:

   Sludge Disposal  (pg.  2-46) the region  in question does not have
   facilities for sludge disposal such  as incineration, digestion or
   wet  - oxidation processes.  Presently nearly all septic sludge is
   disposed of by surface land application on sites designed to handle
   a minimal amount of effluent.  Sludge  is obviously a hazardous waste
   that if improperly handled can degrade the environment and be the
   cause of serious disease,  (pg. 2-52)    Septage is extremely difficult
   if not •'impractical to handle in the  winter because of access to
   homes and frozen disposal  sites.   Because  the plan relies heavily
   on  (pump and  haul) we question the. logic!

   The Water Resources Commission is  presently corsilering significant
   changes in their pump and  haul policy  that will certainly affect
   this alternative depending on  the  outcome.

    (Pg. 2-56)  There  is  no  guarantee  that any Waste Water Treatment
   Plant will accept  this material over an extended period of time.
   There is a real possibility that  pump  and  haul wastes will not have
   an environmentally safe  grave.

   Pg.  2-47)  There are  few if any  400  sq. ft. drain beds that function
   for  20 years.  Our experiences would indicate that 1000 sq. ft. would
   be necessary  to  reach a  20 year  life and that would be under optimum
   site  condition.  This could easily double  the cost estimate in the
   Tables  (Sec.  D) .

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Val Adarnkus                                         Page 2
September 21, 1982
    Pg. 2-51) Discusses seasonal or temporary systems.   Based on
    their estimates of having a tank pumped 3 times a year means
    that a family of 4 (no company allowed)  can only live 10 days
    at their homes. (300 gal. day x 10 days = 3000 gal).  This
    3000 gallons does not allow for infiltration of the tanks and
    cannot prevent the sale of a summer home to a year around premise.
    If this should occur a new owner would have an annual cost of
    $7,665.00 (300 gals/day x 365 days T 1000 gallon haul capacity x
    $70/load) to just maintain a minimal water usage.

    Pg. 2-52) Refers to cluster systems.  If M.D.N.R. continues to
    effectively prevent the discharge of effluent into the ground
    water at non-degradable levels (in effect 0-discharge as present-
    ly defined by W R.C.) thsre will be no use of cluster systems
    that depend on drain fields for final disposal.  There is no drain
    field that can consistently discharge "distilled" water which is
    about as close to 0-discharge as we can determine.

Obviously there are a number of serious problems with the alternative
proposed.  These problems will not be resolved by additional studies
as recommended by E.P.A.  In fact you can be assured that a serious
waste of your E.P.A. funding is the only "sure thing" of these studies.

It is unfortunate that legitimate local involvement is not solicited
for these projects.  We are problem-solving oriented and feel there
are obvious, logical, and cost effective solutions that are not re-
flected in the draft.  To assure successful studies in the future, we
would recommend you first determine what expertise is existing and
available in the community and second require that the budgets of these
studies include local reimbursement.

Thank you for your consideration and also enclosed is a copy of a past
letter concerning  the project.

Sincerely,

CASS COUNTY  HEALTH DEPARTMENT
Division of  Environmental Health
 Dale  Hippensteel, Director

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MDNR.   Water  quality  inx^he "receiving  streams^would be  altered^" but ySt
seriously degraded  during  the annual discharge period.   The la'nd application
alternative should result in minimal operating impacts because the infiltrated
water should^^e of Comparatively lUgh quality.

     S^ptage/and  holding ta^k/waste hauling wJuld  result in afinimal  adverse
imoadts. /Some ephemeralXddors  from the mimping  operation  .xfculd be  detected
and trjick traffic wou>^/be present.  Sep^age disposal would  be cond^itted  in  an
env.ironmentally coslBaxtible way with application  to agricultural/lands.
                   ^^^——.
    RECOMMENDED ACTION
     The  least cost alternative  from both  an economic  and an  environmental
pp.r8iect5.ve is Alternative 9 - on-site system upgrading and  blackwater holding
tanks  for some critical areas.  -Because insufficient data have  been--developed
                                                                   s
in  the study  thus  far  to  conclusively document  a need  for improved  sewage
treatment,  USEPA,  Region V  has decided that  additional  studies will  be  con-
ducted  during  the period between publication of  the Draft  EIS and  the  Final
EIS.

These  studies  may include:
          A  sanitary survey  of  30% of the  residences  in the study  area
          A  septic  leachate  detector scan of  drinking  water  samples
          obtained  from  each house visited  in the  sanitary survey  for
          traces of  wastewater effluent
A  near-shore  hydrology  study  to
ground -ntar  flow.
                                              determine  -he  direction  of
 ,  8ed On  the  available information and  the additional  studies,  a more  pre-
 ;,,-, " y deflnad waatewater management system  for the study area will be  recom-
  ,,...-- -,- -   .th* Final EIS-  An  alternative that includes primary reliance  otT]
 -W*"*^? ^»t««tar management systems is clearly justified for the study area-J
 IE*  mcBMBded alternative aay  include  holding tanks>  blackwater holding
 tO&JM.- ASd Clu3tar  drainfields where it is demonstrated that off-site  treat-
      of ia«tesratsr ia Deeded.

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               Cass County Health  Department
                       , 2 • H03?ITAl 90*0 » CASSOfOUS. MICHIGAN 400J1


                                   Anril 27   1979             CASSOKJUSMSJS
                                   April ^/  ,ia/y             OOWACIAC TW.M
 Mr.  Kent Peterson
 Wapora Inc.
 Suite 490
 35 E. Wacker Dr.
 Chicago, ILL. 60601

                    RE: Indian Lake and  Sisters  Lake study.

 Dear Mr. Peterson;

      This letter is to confirm our April 25, 1979 conversation
concerning your request for the following information:

      1) Replacement septic systems installed in the Sisters
         Lake area since 1978.
      2) Location of any dry-well systems in the area of Sisters
         Lakes
      3) Location of all the sewage disposal problems of the area.
      4) Listing of location and typw of all"alternative"systems
         in the  area.                           :

     As we discussed it will be impossible to obtain  this  in-
formation prior  to June, 1979 as you requested. We presently
do not have the  staff  to purge our files in detail to assimilate
this data due to numerous  reasons.

      However, we would certainly provide any assistance we could
if your  company  would  decide  to visit our office  and  use our
files  to gather  this information. We recently aided another
engineering  company  in their  research  and it took their engineer
approximately three  days  to accurately  gather this type of
information.

      We  also would presume that  if  extensive technical  assistance
 if  needed from our Division that  your  company has included that
 reimbursement is available to the  County.

      Please  feel free  to  contact  our  office  if  you have any
 further questions.                         4
                                    Sincerely,
Don Oberkeik                      s^CfcSS COUNTY HEALTH DEPARTMENT
Les Brown                        (   / )  /7  //
Pete Elliot                      v—<^JC&& tt
                                    Dale Hippenseel,RS.
                                    Environmental Director
 DH/bk

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September 23, 1982
Environmental Protection Agency
Chicago, Illinois

Subject:  Sewer Project for Indian Lake, Cass County, Michigan

As a property owner with 270 front feet on Indian Lake who has installed
new septic systems in compliance with local health requirements.  We
believe strongly that the only way to save this lake from continued pollution
is to install a central sewer system.

There are times when we are forced to  limit use of toilets.  We alleviate
these problems by pumping the tanks annually or  when needed.

We favor moving ahead with a system for Indian Lake in a cooperative
program with the city of Dowagiac, which we understand has low utilization
of their system.
C. M. Hoover
Moody Road at Brush Lake Road
Indian Lake
Rt. 2
Eau Claire, Michigan   49111

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                           -L^oaqla^. CPT•  J3e.n.ton
                         650 J>. WcitgaU <#
-------
                                    650 Jo.  A'-'^pj-'t^  t  - -
                                    Des Plaines, 111. 60016
                                        . 22, 1982
United States Environmental
Protection Agency
Region 5
230 do. Dearborn dt.
Chicago, Illinois 6060^

Attnt  Mr. Ciiarles Quinlan

Re i  Indian Lake Wastewater Treatment
     Sept. 9, 1982 Meeting

Dear Mr. Quinlans

     I appreciate and tnenk you for t:ie direct  and  informative
mode of tne meeting.
     £>ome items covered were:
(a) Increasing density and use of septic  systems  is occurina
     at Indian Lake.
( b) 50$ or so of lake frontage lots have  septic systems  located
     witnin 2 feet of lake hi«|h water  level.
(c) i'lost existing septic systems do not conform to  present
     township code.  Many lots ar£ inadequate in  size  to oerm.it
     conf ori-nance .
(d) Many septic systems are!"flusned sparingly   end  pumped annual
     ly or more often ot keep useable.
(e) Indian Lake residents took steps toward  imorov^d wastewpter
     treatment in 1975.
(f) Znese residents feel P long ranae  cost  effective solution
     to wastewater treatment improvement  is  a hiwn  oriority in-
     vestment .
(g) Indian La'^e people a^'e interested  in  resolvinc-  tn^> need as
     a separate party.
     In view of t:ie above items  an^  4~ne  19?^  r^rat't  for  a o
icant wastewater treatment for Indian  Ia'>re,  isn1^  positive
action indicated now?
     I, and my friends  from  t;iQ  Lake,  look  forward  to tne
      2otn
                                      Respectfully,
                                      Doupffass  Benton  P.2.

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                                           724 Ranch Road
                                           Wheaton, Illinois  6018?
                                           September 29, 1982
Mr. Harlan D. Hirt
Chief, Environmental Impact Section
U.S. Environmental Protection Agency
230 S. Dearborn St.
Chicago, IL  60604

       Attn:  5WFI

Dear Mr. Hirt:

We are in favor of a waste water treatment facility for the greater
Sister Lakes area.

Our summer cottage on Round Lake has been a family treasure since
1928.  The healthiness of the Lake and its long-term survival
are of vital importance to me.

We strongly support a sewer system and hope the community can over—
look the cost in the short term for the long term benefits.  The only
other choice will eventually be the destruction of our loved Round Lake.

                                           Sincerely,


                                           Fred and Jan Polmanteer
                                                              CO
                                                                   O

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                     /


     This letter is concerning a proposed sewage system for Indian Lake,
Eau Claire, Michigan.

     We have recently become greatly concerned about the pollution of
Indian Lake.  Various problems with septic tanks around Indian Lake have
made it necessary to take action in order to keep the lake both clean and
safe.  We feel that it would be very worthwhile for a sewage system to
be created for the residents of our lake.  It would eliminate the pollution
and also the problems and expense incurred yearly to maintain a septic tank»

     Problems with our septic tank include.the following:

     - septic system does not allow the toilet to be flushed regularly

     - shower can only be sued for a very limited time

     - laundry facilities cannot be installed or used

     - septic must be pumped at least twice a year for it to function
       somewhat properly.

     A sewage system would also eliminate these problems.

     However, we feel that the proposed sewage system should be kept
separate and unique from the Sisters Lake area.  The reason being that it
would hold-up the progress of installation, as necessary and timely surveys
must be performed for the Sisters Lake area which have alreday been completed
for Indian Lake.  Also, the population of Sisters Lakes is large enough
to warrant a sewage system for that area apart from Indian Lake.  Therefore,
it would seem most advantageous to hook-up andfr Indian Lake sewage system
to the nearby waterworks in Dowagic, whose facility would be able to
accomodate it.

     In closing, I would like to repeat that it is urgent that we take
immediate action to control the pollution of Indian Lake as all of its
residents are affected by it.
                                               \
                                   Sincerely,

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                                3662 W. 113th St.               L35
                                Chicago, IL   60655       2g    fN>    -Tl
                                September 17, 1982        >>    oo    "
U. S. Environmental Protection Agency                     r-\
Region V                                                  —'     §:
230 S. Dearborn St.                                       iS     __
Chicago, IL   60604                                       CC     —
                                                          o    <=;    C3
Attn:  Valdas V. Adamkus                                  ^    c*>

Dear Sir:

I received the Draft Environmental Impact Statement for the
Indian Lake - Sister Lakes Wastewater Treatment Facilities in
Berrien, Cass and Van Buren Counties in Michigan.

I briefly read through it and have a question about the
payment plan that was outlined accordingly to the proposals
that could be adopted.

It states we would be paying a percentage of income in
accordance with the plan that would be selected.  I would like
to know if a person retires would the payment be rated to
income if one is on pension?  I am working now but in a few
years plan on retiring.

Would appreciate it if you could answer this question for
me.
                                Sincerely,
                                Rosemary
                                Magician tak'e Resident

-------
FRANK
MILLER
6 O/>|UO                          Main Office & Plant:                   *f
                 13831 South Emerald Avenue • Chicago, Illinois 60627  • Area 312:466-3500
Eftablithcd 1889
                                                                            "O
                                                   October 11,  1982
           U. S. Environmental Protection Agency                      p»
           230 S. Dearborn St.
           Region 5
           Chicago, Illinois 60604

           Att: Mr. Charles Quilan

           Dear Mr. Quilan:

                     I am an owner of a summer home on Indian  Lake which is
           in the Sister Lakes area in Dowagiac, Michigan.

                     For some time, we have been trying to  get sewers placed
           in this area because of the congestion and old septic  systems that
           were put in as far back as fifty years ago and maybe longer.

                     Some of the homes were built very close to one another
           at that time, and should a replacement of a septic  system be nec-
           essary with the new codes that have been changed, it would be very
           difficult for some of these homes to meet.  Therefore, the only
           solution would be that a sewer system be put in,  and the one that
           we would like would be Alternative 6.  It is our hope  that you
           would approve of this sewer system.
                                                                            en
                     a
                     Hoping that your decision is favora
I remain
           CFM:rk

-------
                               Richard  Williams
                                             PHONE (312)96O-33OO


                        R.T. WILLIAMS & ASSOCIATES, INC.
                                          consulting engineers
                        34 WEST BURLINGTON STREET WESTMpNT, ILI$JOIS 6Q£59
                                    October  13, [£982—     •"
Mr. Charles Quinlan                             "J:"-   -^
United States Environmental Protection Agency   -    ro    • ~, ,
Region Five                                     *£.    r ,    \	
230 South Dearborn                               O    -*=   v—•'-
Chicago, IL 60604                                X    ^


Dear Mr. Quinlan:

This letter  is  in response to the upcoming  decision
that will  be  made by your department concerning  the
selection  of  a  design  concept  for the   proposed
sewer  system  serving Indian  Lake,  Michigan. I have
a  residence  on Indian  Lake  and  I  am personally in
favor   of   Alternative Six   and   do  not   see   the
feasibility of  Alternate  Nine due to the low ground
water   conditions.     Alternate  Nine  probably  is
economical   and   nominally   applicable   to  most
situations but  considering our lowlands, there will
be  problems  in the  future.  Combining this  fact  and
the  costs  of  maintaining many  independent  systems
when we are all  aware  of the excess capacity  built
into the Dowagiac system only makes  the decision to
annex  to the  Dowagiac  system logical.  I  hope your
decision is the best one  for  our  community.
                               Sincerely,
RW/mlm
3590-2

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              ->-x<*_<*-»<_^»
.V5*^^-3*-
                                           ^-^



                                              So ^^sC^S^Ca^^s^ '
•**s£4^_ v^S >I^i^:^^^Vs^^>,

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              •c*H>s^ ^_a_>v-»—-
-------
 United States
 Department of
 Agriculture
Soil
Conservation
Service
1405 South Harrison Road, Room 101
East Lansing, Michigan
48823
                                                           November 1,  1982
Mr. Harlan D. Hirt,  Chief
Environmental Impact Section
Environmental Protection Agency
230 South Dearborn Street
Chicago, Illinois   60604
Dear Mr. Hirt:
A copy of the Draft  Environmental Impact Statement  (EIS) for the Indian Lake -
Sister Lakes Wastewater Treatment Facilities  in  Berrien, Cass and Van Buren
Counties in Michigan,  dated August 1982, was  received by this office for review
and comment.

We are pleased  to  note that soils information for  the counties involved was
available and incorporated in the draft report.  It  was also noted that refer-
ence is made to potential erosion hazards on  soils  that will be exposed during
construction.   We  suggest that the necessary  steps will be taken to revegetate
the areas involved as  soon as possible to control  erosion and maintain the
water quality within the water areas affected.

We appreciate the  opportunity to review and comment  on this document.
Sincerely,
Homer R. Hilner
State Conservationist
cc:  Peter C. Myers,  Chief, SCS, Washington, D.C.   20013
HRH:cms:kp  4831B
  The Soil Conservation Service
  is an agency of the
  Department of Agriculture

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          United States Department of the Interior
                       OFFICE OF THE SECRETARY
                         NORTH CENTRAL REGION
                       175 WEST JACKSON BOULEVARD
                         CHICAGO. ILLINOIS 60604
ER-82/1526                                    28 October
Mr. Valdas V. Adamkus,  Regional Administrator
U.S. Environmental Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois  60604

Dear Mr. Adamkus:

The Department of Interior has reviewed  the Draft Environmental Impact
Statement (EIS) for Indian Lake-Sister Lakes Vastewater Treatment
System, Berrien, Cass,  and Van Buren Counties and find the document to
be seriously deficient  in not providing  a  clear understanding of the
environmental impacts of each specific alternative so the least
damaging alternative can be identified.  Due to the  lack of
information and site specific detail, we found the Draft EIS to be
premature and inadequate.

Ye believe there should be more information relating to mitigation of
wetland impacts, detailed information describing location and size of
wetlands possibly impacted by various alternatives,  and information on
how Executive Orders 11990 and 11988 will  be complied with.  Ye do not
believe that mitigation measures  to offset unavoidable losses are
adequately developed in the document in  its present  form.

Another serious deficiency with the document is the  lack of a definite
preferred alternative with subsequent discussion of  actual site
specific impacts.  Ye strongly recommend that, after additional
studies have been completed and deficiencies corrected, a revised
draft statement be issued.  Ye do not believe the Final EIS is the
proper document for a preferred alternative to finally materialize.
If a revised draft statement is not issued, we may pursue a CEQ
Referral.

Ye also have some specific comments concerning the requirements for
control of erosion and runoff from construction activities, pages 4-50
and 4-51•  Ye believe these requirements should be considered as
general guidelines from which specific  requirements  could be derived.
If these are in fact requirements, we recommend using must instead of
should for each statement.  Ye also recommend adding some mechanism
such as a performance bond to assure compliance.

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                                                                   -2-
Another specific comment concerns Section 3.1.4*2  Mollusks, page
3-45, which references the mollusk (Epioblasma sulcata delicata) as
the white cat's eye.  Please note that the correct common name is the
white cat's paw.

Sand and gravel resources and associated mining are important
characteristics of the study area and have not been included as part
of the discussion of the Affected Environment (Section 3«0).
Extensive resources of sand and gravel occur throughout the area.
Glacial karaes, in particular, are composed of valuable sand and
gravel.

For completeness, the EIS should delineate areas where known deposits
occur and should describe what effects, if any, project implementation
will have on mineral resources.

In summary we would like to state that, based on the limited
information available to us, we agree with the assumption that an
alternative that includes primary reliance on on-site wastewater
management is justified for the study area.
                                       Sincerely yours
                                        heila  M.  Huff
                                       Regional Environmental Officer

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                                        FOR:   DR.  SMITH
              1.  What is the cost of proposed new study?

              2.  Is there implementation money available?

              3.  How can further studies be stopped?

              A.  Was funding made available to local  agencies  to assist?

              5.  What are the public health consequences of  sewage purge and
                  haul procedures?

              6.  How dees the Vater Resources Commission position on non-degradation
                  of ground water affect the use of semi-public sewage systems.

              7.  Why was the Indian Lake not seperated out since F.H.A. money was
                  available sometime ago for construction of  sewers.

              8.  Who do you really expect to solve our local problems?
.
                                    sen 73.
                                                                            c?

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                                Dr. Daniel J. Dyman
                                50140 Adams Drive
                                Dowagiac, MI 49047
                            September  28,  1982
EPA
Region 5
Chicago, IL  60604

Gentlemen:

In my absence from your 9/28/82 meeting,  please  consider
my following proposal.

Having on occasion studied  the water  quality  of  some  of
the lakes reviewed in the Draft Environmental Impact
Statement Indian Lake - Sister Lakes  .  .  .,   I concur
with your findings that "nutrient  levels  were lower as  a
group than might be expected for lakes  with anticipated
water quality problems."  However,  I  have observed that
particulate suspension in various  lakes increases as
the boating season peaks.   These particulates including
plankton limit the depth of the photic  zone and  thus
limit oxygen availability in the water.    Possibily with
restricted boat size, horsepower,  and usage,  the photic
zone might be extended beyond the  themocline.  This
would increase the oxygen supply required for normal
decay processes as well as  serve as a reserve against
the possibility of summer stagnation  which may occur.

Thank you for your consideration.
                            Sincerely,
                            Daniel J. Dyman, Ed.D.

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   MICHIGAN   DEPARTMENT   OF   STATE
        RICHARD H. AUSTIN
SECRETARY OF STATE
                                                                          LANSING
     September  17,  1982
     Mr. Marian  D.  Hirt,  Chief
     Environmental  Impact Section
     United States  Environmental  Protection Agency
     Region V
     230 S. Dearborn  St.
     Chicago,  IL 60604

                                              Re:
                                                        u
                                    MICHIGAN  48918


                                    MICHIGAN HISTORY DIVISION


                                    ADMINISTRATION, PUBLICATIONS
                                    RESEARCH, AND HISTORIC SITES
                                    208 N. Capitol Avenue

                                    STATE ARCHIVES
                                    3405 N. Logan Street

                                    STATE MUSEUM
                                    208 N. Capitol Avenue
             ER-1665
             Indian Lake - Sister Lakes
             Wastewater Treatment System
             Draft Environmental Impact Statement
     Dear Mr. Hirt:
     Our staff has  reviewed this draft EIS and would like to offer the  following com-
     ments.  Before final  plans are approved, we will want an opportunity to review
     any structures 50 years old or older that will be demolished, removed or altered
     as a  result  of this  project.  To do this we will require photographs (keyed to a
     map)  along with any  historic information available on the  structures (date of
     construction,  function, etc.).  We also note that the list of 14 structures given
     on page 3-91 is basically useless as even the most minimal  locational information
     is not presented.   Information on these sites and photographs of them should
     either be included in the final EIS or, preferably, presented to us for our evalu-
     ation prior  to the preparation of the final EIS.

     We concur with recommendations in section 4.1.1.12 concerning archaeological sur-
     veys.  Any sewer lines not under or immediately adjacent to highway right-of-ways
     and all new  treatment plant construction should be subjected to archaeological
     survey.

     Any questions  in regard to this letter should be directed  to John  R. Halsey, State
     Archaeologist  and Environmental Review Coordinator or Robert 0. Christensen, Re-
     gional Preservation  Coordinator at (517) 373-0510.

     Thank you for  this opportunity to comment.

     Sincerely,

     Martha M. Bigelow
     Director, Michigan History Division
     and
     State/Historic Preservation Officer
                   B. Eckert
                  State Historic Preservation Officer
MH-69
      MMB/KBE/JRH/sl
                                                                 U.S. GOVERNMENT PRINTING OFFICE: 1983-655—992

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