oEPA
United States
Environmental Protection
Agency
Region 5
230 South Dearborn Street
-Chicago, Illinois 60604
,',ne, ' 382
Water Division
Environmental Final
Impact Statement
Alternate Waste
Treatment Systems
For Rural Lake Projects
Case Study Number 6
Williams County Commissioners
Nettle Lake Area
Williams County, Ohio
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ADDENDUM
This addendum sheet serves to provide greater detail on elements con-
tained in the Final Environmental Impact Statement on Alternative Wastewater
Treatment Systems for Rural Lake Projects, Case Study No. 6 Nettle Lake Area,
Williams County, Ohio.
The EIS Recommended Action P. II-4
As this section indicates, EIS alternative 8 is selected as an approach
to upgrade or replace existing on-site waste treatment systems with different
forms of on-site technology. It is not site specific but would necessitate a
cooperative decision between a small waste flows management district (see P.
11-10) and each homeowner to select the appropriate technology for each site.
The EIS assumed replacement of approximately 30 flood prone privies with
forest service type vault toilets as one form of on-site technology. In order
to minimise mixing of flood water with these toilet wastes, and thus minimise
public health problems, the alternative proposes that these vaults be emptied
at the end of each season and back filled with fresh water. This will prevent
them from floating out of the ground during flood events. If the systems are
inundated, a vault filled with water would minimize turbulent mixing and would
thus limit the exchange of nutrients and pathogens between privy waters and
flood waters. Prior to the vacation season these vaults would again be pumped
out in preparation for summer use.
In estimating the total present worth of this alternative, the costs of
having a private septage hauler pump and backfill vault toilets were cal-
culated. The cost also reflect charges incurred to treat these wastes at the
Montpelier treatment plant(See P.V-7). Thus the $110 estimated annual average
homeowner cost takes all of these considerations into account. (See P.II-12)
Chapter III Affected Environment P. III-l
Chapter III of this document provides a generalized description of the
environmental resources found in the Study Area and the environmental impact
that would result from taking no action. For a more detailed description of
resources found locally, please consult the Draft EIS Chapter II, Environ-
mental Setting on Pages 21 through 80.
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AUG121982
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION V
23O SOUTH DEARBORN ST
CHICAGO. ILLINOIS 60604
REPLY TO ATTENTION OF:
SWF I
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed is a copy of the Final Environmental Impact Statement (EIS) for Alter-
nate Waste Treatment Systems for the Nettle Lake Area, Williams County, Ohio.
Pursuant to the National Environmental Policy Act and regulations (40 CFR Part
6, November 6, 1979) promulgated by this Agency, action or approval will not
occur until thirty days after the availability of this document is published in
the Federal Register.
After this date, we will issue a Record of Decision explaining what the final
action taken by EPA will be and mitigative measures developed through the EIS
process. Copies will be sent to all persons who received the Final EIS or who
reqtjest a copy... For additional copies of this Final EIS please contact the
Environmental Impact Section of the Water Division at the above address.
Valdasv. Ada
Regional Admi
Enclosure
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FINAL ENVIRONMENTAL IMPACT STATEMENT
ALTERNATIVE WASTEWATER TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
WILLIAMS COUNTY COMMISSIONERS
CASE STUDY NO. 6
NETTLE LAKE AREA, WILLIAMS COUNTY, OHIO
Prepared by the
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION V
CHICAGO, ILLINOIS
With the assistance of
WAPORA, Inc.
CHEVY CHASE, MARYLAND
Approved By:
Valdas V. Adamki
Regional Admini/trator
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PREPARERS
This Final Environmental Impact Statement was prepared
with the assistance of WAPORA, Inc., under the guidance
of Catherine G. Garra, EPA Region V Project Officer.
Mr. J. Ross Pilling, II was WAPORA's Project Manager.
Much of the material in the Draft Enviromental Impact
Statement was provided by WAPORA employees and sub-
contractors; they are listed in that doucment.
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EXECUTIVE SUMMARY
This Final Environmental Impact Statement (EIS) addresses water quality
and wastewater management alternatives for the Nettle Lake area, Williams
County, Ohio. (See Figure 1 for a map of the Study Area.) The EIS is based
on issues identified during a U.S. Environmental Protection Agency (EPA)
review of the Facilities Plan proposed for funding under EPA's Construction
Grants Program by the Applicant, the Commissioners of Williams County, Ohio.
The Applicant's Facilities Plan proposed the construction of a centralized
gravity/force main collection system, with an aerated waste stabilization
lagoon east of Nettle Lake, and a discharge downstream to Nettle Creek (see
Appendix E, page E-3 for a description of the Facilities Plan Proposed Ac-
tion) . The issues that made necessary the preparation of this EIS were the
following:
• Sizing of the proposed facility based on optimistic population projec-
tions could result in unneeded facilities and a high cost burden on
local residents.
• The high cost of centralized collection and treatment facilities could
result in hardship and displacement of homeowners with modest incomes
who could not afford to pay such costs.
• The amount and rate of population growth and residential development
that would occur if the facility were constructed, would increase
demand for local community services; and could adversely affect the
water quality of the lake by resulting in additional pollutant runoff
into the lake.
• The amount of growth projected could result in degradation of the
floodplain and wetland areas surrounding the lake, and could also
adversely affect the habitats of state-listed endangered species.
To document the need for the proposed project, EPA devoted a substantial
effort to defining existing water quality problems and potential public health
hazards associated with malfunctioning on-site wastewater treatment systems
surrounding Nettle Lake. This effort included an aerial photographic survey
and field investigation of surface malfunctions; a door-to-door sanitary
survey of 11 percent of the housing units, representing the most continuously
occupied homes; a septic leachate survey of the lakeshore; and water quality
modeling based upon available data. Several of these documentation techniques
had not yet been developed at the time of the original facilities plan, and
were therefore not utilized in its preparation.
EPA concluded that the principal reason why wastewater treatment improve-
ments are needed is to protect Nettle Lake and the health of the area's resi-
dents from sewage contamination during flood events. At these times, back-ups
of sewage into houses occur, effluent is found on the ground outside homes,
and privies are inundated.
The results of the technical studies and limited sanitary survey referred
to above indicate that most of the on-site wastewater treatment facilities in
the Study Area are operating satisfactorily, except during flood events.
On-site systems do not appear to contribute a significant amount of nutrients
ii
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LEGEND
LAZY ACRES SOUTH
LAKEVIEW/EUREKA BEACH
SHADY SHORE
LAZY ACRES NORTH
ROANZA BEACH
CRESTWOOD
CAMP DI CLAIRE
SHADY SHORE CAMP
FEET
2000
FIGURE I NETTLE LAKE: SEGMENTED SUBDIVISIONS IN THE PROPOSED
SERVICE AREA
ill
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to Nettle Lake. Of the total load of phosphorus entering the lake, an esti-
mated 13 percent or less comes from on-site systems. During non-flood condi-
tions, the remaining load comes from non-point sources, such as agricultural
runoff.
EIS Alternatives
The conclusions reached in the needs documentation effort described above
were integral to the development and evaluation of nine alternatives to the
Facilities Plan Proposed Action. These alternatives were presented in detail
in the Draft EIS. The alternatives, some of which were developed based on
designs evaluated in the Facilities Plan, ranged from centralized facilities
(EIS Alternative 1) to decentralized facilities (EIS Alternatives 7 and 8).
These alternatives considered water conservation, alternative collection
systems (low-pressure sewers), treatment techniques (land application), multi-
family septic systems (cluster systems), and alternative on-site technologies
(waterless toilets, holding tanks, improved privies). (See Table 1 for a
summary of the major components of the eight alternatives.) Present worth
costs ranged from $1,842,500 for the Facilities Plan Proposed Action to
$796,500 for EIS Alternative 8. The Draft EIS recommended implementation of
Alternative 8 as the most cost-effective and environmentally sound wastewater
management plan.
Public Participation
A public hearing on the Draft EIS (July 1981) was conducted on 2 October
1981, in Williams County, Ohio, to gather additional input from all interested
parties. Many comments were voiced at the hearing or were submitted to EPA in
writing before the end of the month. The majority of public comments and
questions addressed the following topics:
• The validity of EPA's analysis of field data and determination of need
for the project;
• The problems caused by frequent flooding, which inundates privies
along the lake shore;
• The potential solutions for correcting the flooding problem;
• The feasibility of continued use of on-site treatment systems;
• Project costs and affordability; and
• The implementability of decentralized wastewater management appro-
aches.
Final EIS
The primary emphasis of this Final EIS is to respond to all substantive
public and agency comments on the Draft EIS and to clarify or modify informa-
tion that was presented in the Draft EIS. The only new alternative developed
for this Final EIS is a suggested voluntary action alternative, if Federal
funding is unavailable.
IV
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Table 1
ALTERNATIVES — SUMMARY OF MAJOR COMPONENTS
Alternative
Centralized Treatment
Treatment Plant
Siting
Facilities Aerated lagoon serving Northwest Township
Plan Pro- entire Proposed Service Section 24
posed Action Area
Effluent Disposal
Discharge to Nettle
Creek
•On-lot and Cluster Systems
No
Alternative Collection Method
No
HIS Aerated lagoon serving Northwest Township
Alternative 1 Segments 1,3,4,5,7 and 8 Section 24
EIS Aerated lagoon serving Northwest Township
Alternative 2 Segments 1,3,4,5,7 and 8 Section 24
EIS Aerated lagoon serving Northwest Township
Alternative 3 Segments 1,3,4,5,7 and 8 Section 24
EIS Aerated lagoon serving
Alternative 4 Segments 1,3,4,5,7 and
EIS Stabilization Pond/land
/Iternative 5 application system
serving Segments
1,3,4,5,7 and 8
Northwest Township
Section 24
Northwest Township
Discharge to Nettle
Creek
Discharge to wetlands
(aquaculture)
Discharge to Nettle
Creek
Discharge to wetlands
(aquaculture)
Segment 2: Cluster systems
Segment 6: ST/SASs
Segment 2: Cluster systems
Segment 6: ST/SASs
Segment 2: Cluster systems
Segment 6: ST/SASs
Segment 2: Cluster systems
Segment 6: ST/SASs
Land application by Segment 2: Cluster sy.stems
rapid infiltration with 6.
recovery or renovated
wastewater and discharge
to Nettle Creek
No
No
Use of pressure sewers/septic tank
effluent pumping (STEP) system in
suitable sections of the central
collection system
Use of pressure sewers/STEF system in
suitable sections of the central col-
lection system
No
EIS
Alternative 6
EIS
Alternative 7
No
No
No
No
No
No
Segments 1,3,4,5: Holding tanks (maximum flow
reduction) and septic tanks with mounds and
"super systems"
Segment 2: Cluster systems
Segments 6 to 8: ST/SAS
Repair, replacement and hydrogen pe'roxlde
treatment of existing systems as necessary
Segments 1 to 5: Holding tanks (maximum flow
reduction) and septic tanks with mound and
"super system" absorption fields.
Segments 6 to 8: ST/SASs
Repair, replacement and hydrogen peroxide
treatment of existing systems as necessary
No
No
EIS Alternative 8
No
Segment 1 to 5: Replace privies with alternative
technologies and septic tnnk with mound or "super
system" absorption fields
Segment 6 to 8: ST/SAS
Repair, replacement, and hydrogen peroxide treatment
of existing systems as necessary
Note: See Appendix E for more detailed information
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In general, the Final EIS confirms the conclusions of the Draft EIS.
These conclusions are listed below.
• The No-Action Alternative is not an acceptable course of action.
• The Facilities Plan Proposed Action is not the most appropriate waste-
water management alternative.
• Continued use of on-site wastewater treatment systems, including new
and upgraded systems, as proposed by EIS Alternative 8, is the appro-
priate, cost-effective solution to the area's wastewater treatment
needs.
* Elimination of on-site wastewater systems from the shores of Nettle
Lake would not markedly change the nutrient loading to the lake.
Recommendations
The recommendations of the Final EIS remain the same as those proposed in
the Draft EIS:
• Design and implement EIS Alternative 8, to include the establishment
of a Small Waste Flows Management District.
• Conduct a site-specific environmental and engineering analysis of all
existing on-site systems in the Study Area.
• Repair and replace on-site systems as required.
• Upgrade existing privies or replace them with alternative forms of
toilet and on-site technology as needed.
The recommended action will reduce the potential public health hazard
during flood periods to a markedly decreased risk. It would also result in a
modest improvement in overall lake water quality. Eligible portions of the
project may receive 85% Federal funding for design and construction. With
this funding level, annual homeowner costs should amount to approximately $110
a year.
If the Applicant wished to pursue EPA Construction Grants funding, the
Facilities Plan would need to be revised to reflect the conclusions of this
EIS. The precise regulatory requirements for such funding are not known at
this time, since the Federal regulations concerning these activities are in a
state of flux. The following recommendations reflect the best understanding
of the regulations as they now stand.
A Small Waste Flows Management District would need to be established for
the operation and management of the proposed on-site and alternative systems.
To complete the Facilities Planning process, the Applicant would need to do
the following:
• Certify that the project will be constructed and that an operation and
maintenance program will be established to meet local, State, and
Federal requirements.
VI
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• Certify that privately owned individual on-site treatment systems will
be properly operated and maintained.
• Obtain assurance (such as an easement or County Ordinance) of un-
limited access to each individual system at all reasonable times.
• Establish a comprehensive program for regulation and inspection of
individual systems.
In the eventuality that Federal funding of EIS Alternative 8 is not
feasible, the alternative local management recommendation in Section I-D of
this EIS can be used. Taking no action to correct the public health problems
at Nettle Lake would result in continued contamination of the Lake during
periods of flooding. Problems with on-site systems should be addressed
through monitoring, improved maintenance, and renovation or replacement of
existing systems. A voluntary action alternative could be implemented which
makes maximal use of existing technical capability and local initiative. Such
a program would significantly reduce the public health and water pollution
problems in the area.
VII
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CONTENTS
Page
Preparers i
Executive Summary ii
List of Tables xi
List of Figures xi
I - PURPOSE OF AND NEED FOR ACTION
A. The Applicant' s Facilities Plan 1-1
1. Population 1-1
2. Secondary Impacts and Induced Growth 1-1
3. Cost-Effectiveness and Socioeconomic Impact 1-1
4. Wildlife Habitat and Wetlands Impact 1-4
B. The Need for Improved Management 1-4
C. Conclusions 1-6
II - ALTERNATIVES
A. The Facilities Plan Proposed Action II-l
B. The No-Action Alternative II-4
C. The EIS Recommendation Alternative 8 II-4
1. Technology Selection H-6
2. Community Management II-9
a. Minimum Management Requirement Option 11-10
b. Comprehensive Wastewater Management Option 11-10
c. Watershed Management Option 11-11
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Page
3. Cost Estimate 11-12
4. Implementation 11-12
a. Completion of Facilities Planning Requirements
for the Small Waste Flows District 11-12
b. Scope of Design for the Small Waste Flows District .. 11-13
c. Compliance with State and Local Standards in the
Formation of Small Waste Flows District 11-13
d. Ownership of On-Site Systems Serving Seasonal
Residences 11-14
D. The Voluntary Action Alternative 11-14
E. Other Alternatives 11-17
III - AFFECTED ENVIRONMENT AND IMPACTS OF NO ACTION
A. Soils III-l
B. Surface Water Resources III-l
C. Groundwater Resources III-3
D. Population and Land Use III-3
E. Environmentally Sensitive Areas III-4
F. Economics III-4
IV - ENVIRONMENTAL CONSEQUENCES OF THE ACTION ALTERNATIVES
A. Surface Water Resources IV-1
B. Groundwater IV-2
C. Population and Land Use IV-2
D. Economic Impacts IV-2
Comments and Responses
List of Commentors
Bibliography
Index
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APPENDICES:
Appendix A Draft EIS by Reference A-l
Appendix B Region V Guidance - Site Specific Needs
Determination and Alternative Planning for
Unsewered Areas B-l
Appendix C Community Management and Recovery of Local Costs C-l
Appendix D Sample Easement Form D-l
Appendix E EIS Alternatives E-l
Appendix F Comment Letters F-l
LIST OF TABLES
Table 1 Summary of Major Components v
Table II-l Decision Matrix II-2
Table III-l Species Sightings in and Along the Shores
of Nettle Lake III-5
LIST OF FIGURES
Page
Figure 1 Nettle Lake Study Area iii
Figure 1-1 Location of Nettle Lake Study Area 1-2
Figure 1-2 Nettle Lake Study Area 1-3
Figure II-l Facilities Plan Proposed Action II-3
Figure II-2 EIS Alternatives 8 II-5
Figure III-l Flood-prone Area III-2
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Chapter I
Purpose of and Need for Action
A. THE APPLICANT'S FACILITIES PLAN
In 1977, Floyd G. Brown. Associates submitted the "Facilities Plan -
Nettle Lake Area, Williams County, Ohio," with Addenda, on behalf of the
Williams County Commissioners, to the U.S. Environmental Protection Agency
(EPA) for Federal funding under Section 201 of the Clean Water Act of 1977.
The Facilities Plan evaluated wastewater collection and treatment alternatives
for the Nettle Lake area and developed a construction plan for a gravity/force
main collection system, treatment in an aerated lagoon east of Nettle Lake,
and discharge downstream in Nettle Creek. (See Appendix E for a description
of the Facilities Plan Proposed Action.) Figure 1-1 shows the location of
Nettle Lake in Williams County, and Figure 1-2 shows the Study Area addressed
in this EIS. A preliminary environmental review of the Facilities Plan and
Addenda by EPA indicated the possibility of significant environmental impacts
and led to the Agency's decision that an EIS was warranted.
The major issues defined in the Notice of Intent to prepare an EIS were
as follows:
1. Population. An estimated 110 permanent and 550 seasonal residents
live in the Study Area. The applicant's year 2000 population projec-
tions foresaw 250 permanent and 1,000 seasonal residents. U.S. Census
Bureau figures and P-25 population estimates showed an essentially
static permanent population in Northwest Township: 924 in 1960, 914
in 1970, and 934 in 1973. Commercial atlases for 1968 and 1977 showed
no summer population increases for the unincorporated area around
Nettle Lake: 250 summer residents in both years, with an increase in
the permanent population from 60 to 100.
2. Secondary Impacts and Induced Growth. The Facilities Plan and public
hearing transcript stated that the population projections assumed
increased growth rates caused by the availability of sewer service for
new housing development. This increased population would place addi-
tional demands on local community services. Increased development may
impact the quality of the lake and surrounding natural areas as well.
3. Cost-Effectiveness and Socioeconomic Impact. Capital costs were
estimated at $1.6 million, a $1,818 cost per capita for the 1977
summer population and $960 per capita for the year 2000 summer popula-
tion. Grant-eligible capital costs would have been covered by 75
percent Federal funding. Each resident would be charged about $192.00
per year for sewer service. The user would also be responsible for
any tap-in fee or sewer assessment, the costs of a house lateral line,
septic tank disconnection, and (in the case of some privy-equipped
homes) installation of indoor plumbing and a water supply. Even if
spread out over an extended period of time, these costs may be a
significant burden for retired persons or those owning a modest summer
home. This may result in displacement of existing residents, many of
whom live in mobile homes. Low-cost system alternatives need to be
thoroughly examined.
1-1
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NETTLE LAKE STUDY AREA
• Montptlier
WILLIAMS
COUNTY
• Bryan
FIGURE 1-1 LOCATION OF THE NETTLE LAKE STUDY AREA
1-2
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NORTHWEST
TOWNSHIP
FEET
2000
FIGURE 1-2 NETTLE LAKE: STUDY AREA
1-3
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4. Wildlife Habitat and Wetlands Impact. The Facilities Plan states that
the Nettle Lake area provides habitat for five State-listed endangered
species, according to the Ohio Department of Natural Resources. These
include two birds (King Rail and Upland Sandpiper), one snake
(Northern Copperbelly), and two fishes (Iowa Darter and Lake
Chubsucker). The Facilities Plan contains no specific discussion of
the location of these habitats. Such a grouping of species that are
considered rare within the State constitutes an area of special
scientific interest.
Several wetland areas surround the lake. Increased development may
alter the character of the wetlands, and additional groundwater
pumping by an expanded population may lower wetland levels and affect
Nettle Lake itself, one of the few natural lakes in Ohio. The
project's biological and hydrologic impacts appear environmentally
significant.
B. THE NEED FOR IMPROVED MANAGEMENT
The Facilities Plan cites the following as demonstrating a need for
action:
• Reports from the Williams County Health Department of malfunctioning
on-lot wastewater treatment facilities;
• Complaints by residents of untreated sanitary wastes entering the
lake.
The Facilities Plan also states:
"Many filter and leaching beds in the area have become filled; the
effluent often ponds on top of the ground and then drains directly to the
lake or to drainage ditches which lead to the lake. During late winter
and spring when the lake surface is at a higher elevation than normal,
this ponded effluent mixes directly with lake water. Because of the soil
limitations, the platted lots are not large enough for proper on-lot
septic tank treatment facilities."
Consequently, on 26 September 1978, the Ohio Environmental Protection
Agency (OEPA) issued NPDES Permit No. G746*AD to the Williams County
Commissioners, who agreed to prepare a wastewater management plan in
compliance with the permit.
When the EIS was under way, EPA conducted a series of studies to evaluate
in greater detail the water quality and public health problems related to the
use of on-site systems around Nettle Lake. These studies utilized newly
developed techniques that were not previously available to the Facilities
Planners. The studies were reported in the Draft EIS, in Section II.F.I. and
Appendix D. Their major conclusions are as follows:
• Eutrophication Modeling - On-site sewage treatment systems con-
tribute an estimated 13% of the phosphorus load to Nettle Lake.
Elimination of this source would result in a negligible change in
the lake's current moderately eutrophic status.
1-4
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• Aerial Photographic Survey - EPA's Environmental Monitoring and
Support Laboratory (EMSL) conducted an aerial photographic survey
in May and June 1978 to determine the location of surface mal-
functions in the Study Area. Two suspected malfunctioning
systems identified by this remote sensing technique were later
inspected on the ground, and neither were found to be malfunc-
tioning at that time.
• On-Site Sanitary Survey - EPA conducted an on-site sanitary
survey of the Nettle Lake Area between 29 November and 6 December
1978. The survey provided information on the types of on-site
systems in the area, the nature and extent of their non-
compliance with the Sanitary Code, and the nature and extent of
problems with these systems. The survey, conducted at a time
when only permanent residents were present, does not reflect peak
in-summer use conditions, but does give a representative sample
of the most intensively used systems. Of the residents surveyed,
14 percent indicated having problems with their systems. Survey
results suggested that problems with in-house backups, surface
ponding of effluent, and privy flooding are common during spring
flooding.
• Investigation of Septic Leachate Discharges - Septic leachate
discharges into Nettle Lake were investigated in December 1978 to
determine whether groundwater plumes were emerging along the
lakeshore. No distinct groundwater plumes of wastewater origin
were detected along the shoreline of Nettle Lake, at a time of
year in which such plumes would be evident if they existed.
In addition to these special studies, data have been gathered on the
recurrence and elevation of flooding in Nettle Lake, local groundwater and
well water quality, and the extent of bacterial contamination of the lake.
This effort relied upon existing data collected from local, state, county and
Federal agencies.
Fecal coliform and fecal streptococci bacteria were analyzed from water
samples taken from Nettle Lake by OEPA on 12 July and 2 August 1976. No
conclusive violation of water quality standards is apparent, and the low ratio
of fecal coliform to fecal streptococci bacteria suggest limited contamination
from farm animals, not human sources. One exception was a sample, taken in a
drainage ditch off the south shore, which suggests contamination by human
sewage. Information from the Williams County Board of Health indicates low-
level bacterial counts from surface water samples taken and no reports of
disease or illness from the area (by letter from Estel Cottrell, Williams
County Sanitarian, 15 December 1977).
Information on groundwater quality and possible sources of contamination
was solicited from the Williams County Board of Health, OEPA, Ohio DNR
Division of Water, and the U.S. Geologic Survey. Well logs and available
geologic information indicate a confining surface clay layer 30 to 180 feet
thick, overlying an artesian aquifer used for domestic water supply. None of
the sources consulted had records of groundwater contamination from on-site
wastewater management systems.
1-5
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The principal basis on which a need has been defined for improved waste-
water management in the Nettle Lake Area is the suspected water pollution and
public health problems associated with the inundation of on-site systems
during flood events. Several first-hand sources have indicated that the lake
level rises an average of 5 feet during spring runoff (see Figure III-l).
This could result in an inundation of the lots of 122 units, or 26% of the
total, including 90% of the privy systems. Floodwater intrusion into privy
systems results in the mixing of these waters and allows for transfer of
bacteria and nutrients to the lake water column. The release of bacteria and
viral disease vectors presents the possibility of contaminating surface water,
which may enter poorly sealed wells. Flooding of septic tank soil absorption
systems results in saturation of the absorption field. This can result in
backups into houses or in ponding of effluent on the ground surface, with
attendant potential for public health problems.
C. CONCLUSIONS
Flooding of on-site treatment systems in the Nettle Lake area presents a
public health and water pollution problem that needs to be addressed. The
risk of health hazard from contamination by unmanaged on-site systems is
currently substantial. Field work conducted for this EIS shows recurrent
problems associated with spring flood events. The septic leachate detector
found no effluent plumes entering the lake. The aerial photo survey located
only two suspected malfunctions that were not confirmed by ground inspection.
The sanitary survey results indicated that, of the residents surveyed, only
14% have recurrent problems with their on-site systems.
Four out of 29 residents interviewed reported backups of effluent into
their houses. All four of these houses were located in floodplain areas with
a seasonal high water table. Recent health department records show one sur-
face malfunction where effluent is ponded on the ground surface. There are no
reports of groundwater or well water contamination. Bacterial surveys of
beach areas show no violation of water quality standards. While the lake is
characterized as eutrophic, the major input of nutrients is from non-point
sources, emanating from the watershed above the lake. On-site systems may
contribute to eutrophication during mixing due to flooding; however, clayey
soils and intermittent use of the systems probably prevent leaching into the
lake for most of the year.
Many topics discussed in this EIS respond to problems and opportunities
addressed during preparation of seven individual EIS's for rural lake pro-
jects. This series, "Alternative Waste Treatment Systems for Rural Lake
Projects," began in 1977. These Seven Rural Lake EIS's were specifically
intended to evaluate the feasibility, cost-effectiveness, and environmental
impacts of alternative wastewater collection and treatment systems. The
alternative systems were compared to centralized systems that had been
proposed in Step 1 Facilities Plans. Varying modular combinations of the two
were also considered. To date, Final EIS's have been published for the first
five case studies. Each recommended that grantees optimize the operation of
existing on-site systems, and replace or upgrade failing on-site systems with
1-6
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conventional or alternative on-site systems. The major finding of the Seven
Rural Lakes EIS's is that wastewater management based on existing systems
allows substantial capital, operation, and maintenance savings compared to new
centralized facilities wherever continued use of a substantial percentage of
existing systems is feasible. Water quality objectives can still be met while
realizing this cost savings.
1-7
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Chapter II
Alternatives
Solutions to the wastewater management problems in the Nettle Lake Study
Area, as proposed by the Facilities Plan and the Draft EIS, are described in
this chapter. The discussion of these recommendations focuses on rehabili-
tation and maintenance of existing on-site wastewater treatment systems,
installation of alternative technologies, and implementation of a decentra-
lized Small Waste Flows Management District. The development of these alter-
natives was described in Chapter III of the Draft EIS. Table 1 of the Exec-
utive Summary summarizes the major components of each alternative. Table II-l
presents the major factors considered in selecting the most appropriate waste-
water management plan for the Nettle Lake Area. Appendix D describes these
alternatives in detail.
A. THE FACILITIES PLAN PROPOSED ACTION
The Facilities Plan proposed the construction of a centralized gravity/
force main collection system, together with an aerated waste stabilization
lagoon located east of the lake. Effluent would discharge to Nettle Creek
downstream of Nettle Lake, as shown in Figure II-l. Design capacity would
handle 0.14 million gallons per day (mgd) in peak summer use.
Costs developed in the Draft EIS for the Facilities Plan Proposed Action
are as follows:
1980 Construction Costs $1,750,396
(including engineering, legal,
and contingency costs)
Future Construction Costs 8,711
Annual Operation and Maintenance Expenses 4,620
1980 Local Cost 936,483
1980 Average Annual Homeowner Cost 335*
* These costs may vary due to changes in Federal regulations
enforcing the Clean Water Act as amended in December 1981
(P.L. 97-117).
The 1980 Average Annual Homeowner Cost includes all operation and main-
tenance costs for the year, plus annual payment on the debt of privately and
publicly financed construction costs at an interest rate of 6-5/8% and a
payback period of 30 years. Calculation of costs using this interest rate is
mandated by Federal regulations (40 CFR Part 35, Appendix A). This charge
would be strongly influenced by the grant eligibility of new sewers. Imple-
mentation of the Facilities Plan Proposed Action would include conventional1
construction and management procedures that are described in the Facilities
Plan.
II-l
-------
Table
Decision Matrix.
H
I
Alternatives
EIS Alternative 8
EIS Alternative 7
EIS Alternative 6
Facilities Plan
Proposed Action
EIS Alternative 2
EIS Alternative 1
MS Alternative '»
f,£S Alternative 5
tIS Altern.itlvo 1
Present
Worth
(x 1,000)
796.5
1,394.3
1.59?. 7
1,342.5
1,896.3
1.90A.9
2,331.3
2.331).')
Annual
User
Charges
110
255
376
335
325
270
3fl
!^0
nutrient leading of
Che lake
• Non-point sources con-
tinue to be the most
significant sources of
bacterial contamination
* No significant impcats
growth.
tive 9.
Same as EIS Alterna-
tives 7 and 8.
• 127. reduction in
nutrient loading of
the lake
• Non-point sources con-
tinue to be the most
significant sources of
nutrient to* the lake
the potential for b,ic-
• No significant impacts
on shoreline algal
grouth .
Similar to Facilities
Plan Proposed Action
except for 9% reduction
in nutrient loading of
the lake.
Same -is Alternative 3.
Same act Alternative 3.
Ground water
Quality
impact on
bacteriologi-
cal quality.
Alternative 8.
Same an EIS
Alternatives
1 and 8.
Same as EIS
Alternatives
7 and 8.
Same as EIS
7 and 8.
Same as EIS
7 and 8.
Sam*1 as
7 and S.
Alt^rnatlvps
T jml V
7 .iiu) 8.
Environmentally
Sensitive Areas
plains, steep slopes,
wetlands, prime
agrlcultur 1 lands,
or histori al sites
term Irapac s expected
in any of he above
categories; all
facilities must com-
ply vlth the flood-
plain zoning
ordinance
• So secondary impacts
expected.
tive 8.
Same as EIS Alterna-
tives 7 and 8.
*
during dry weather
significant impacts on
forested wetland with
little wnderstory
vegetation.
Same 39 Facilities
but in addition, agri-
culture system en-
hances effluent
quality and wildlife
habitat.
Pome as Facilities
Same as AJt.rnotl
3.
Same -»s Facilities
Population
and Land Use
growth or land
Alternative 6.
Same as EIS
Alternatives
impacts — in-
induced growth
would result
in no land use
Similar to
Facilities
Plan Proposed
Action.
Facilities
Plan Proposed
Action.
Facilities
Plan Proposed
Action.
Similar to
Facilities
Plan Proposfd
Action.
Plan Proposed
Act lor.
Financial
Burden
10-15',
40-45X
30-35;
15-70?
35-407,
35-40°,
-KJ-25:,
Displacement
Pressuic
20-251
20-2 y/.
20-252
20-252
20-2 5£
15-2 OS
Flexibility
ighest for future plati-
ng; lowest for luture
;rowth.
rive 8.
Similar to EIS Alter-
natives 7 and 8 for
uture planning;
;reater for future
;rowth-
'or future growth.
Higher than El? Alter-
native 6 and the
Facilities Plan Pro-
posed Action for
future planning; gocd
But lower than both
tive 3.
Saine as ETS Alterna-
tive' 3.
Focil Hies Plan Pro-
posed Action tor
future planning;
second to Ii for
future growth.
tivp 3.
Reliability
n-Kite systems implies
oximum oppor tuni ty for
ystem failure.
tive 8.
Somewhat higher then EIS
Alternatives 7 and 8;
t«ns eliminate several
potential system fail-
ures.
»ecause of maintpnance
requirements.
Slightly less than EIS
Alternative 2; discharge
to wetlands introduces
the possibility of
"loodlnR and freezing
>r obi ems.
Facilities Plan Proposed
vided for Segment? 1 and
6.
SliBhelv less thin tip
Alternative 4; discharge
the possibility o[
flooding and freezing
problems.
3.
Alternative 2 because
extensive use of grinder
pvimps introduces an
-------
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
2000
FIGURE
NETTLE LAKE: FACILITIES PLAN PROPOSED ACTION
u-1
-------
B. THE NO-ACTION ALTERNATIVE
The No-Action Alternative implies that EPA would not provide funds to
support new construction, upgrading, or expansion of wastewater treatment
systems. If this course of action were followed, all existing on-site systems
in the Study Area would presumably continue to be used in their present condi-
tion. The No-Action Alternative is not recommended, for the following
reasons:
• There are some problems with on-site systems in the Proposed EIS Study
Area that should be addressed through monitoring, improved maintenance
of existing and future systems, residential water conservation, and
renovation or replacement of existing systems.
• There is a continuing public health hazard due to bacterial contami-
nation from those unmanaged on-site systems which are subject to
flooding.
* Improved surveillance and regulation of on-site systems in the Study
Area are justified to protect public health and to maintain the area's
recreational values.
Under the No-Action Alternative, the County Board of Health would
continue to have inadequate information with which to design appropriate
on-site system repairs. The result could be further reliance upon holding
tanks to the exclusion of other innovative methods for solving problems.
Chapter III of this document further describes the affected environment and
impacts of no-action.
C. THE EIS RECOMMENDATION, ALTERNATIVE 8
EIS Alternative 8 recommends upgraded on-site wastewater treatment for
all residences. This EIS estimates that 132 privies exist in the Study Area,
and about 90% of them are inundated by flood waters every year or two. In
order to address this problem. EIS Alternative 8 proposes replacement of
privies with any one of four different forms of technology, to be selected by
a small waste flows management district in cooperation with the homeowner.
The replacement technologies would consist of outdoor vault toilets, air-
assisted low-flush toilets and a holding tank, chemical toilets, and elec-
trical composting toilets. Other on-site systems would be upgraded as
necessary by replacing substandard systems. Approximately 35% of these
replacements would take the form of new septic tanks and 20% would take the
form of new drainfields, dual drainfields, or elevated sand mounds. Figure
II-2 illustrates this alternative.
A Small Waste Flows Management District would work with the homeowner to
select, install, operate, and maintain the technology appropriate to a parti-
cular site. The Small Waste Flows Management District would also contract for
a septage hauler or would apply for eligible 85% funding for purchase of a
"honey wagon." A post-summer pumpout program would need to be initiated for
holding tanks and vault toilets. Pumpings would continue to be land-spread on
agricultural areas, or arrangements might be made to treat the wastes at a
local wastewater treatment plant.
II-4
-------
LEGEND
SEGMENTS 1-5: Privy
replacement and septic
tanks with mounds or
dual drainfields
SEGMENTS 6: Septic tanks
with soil absorption
systems (ST/SAS)
SEGMENTS 7,8: Existing
ST/SAS
FEET
200O
FIGURE H-2 NETTLE LAKE: EIS ALTERNATIVE 8
II-5
-------
Many elements of this approach, including likely maximum costs, can be
projected, but final details will not be known until: 1) a house-by-house
analysis allows selection of a treatment method suitable for each property,
and 2) the applicant and the community decide on the method and degree of
management to be provided. These two considerations are discussed below,
followed by a presentation of costs and discussion of project implementation.
1. Technology Selection
Identification of on-site system problems and their causes is the first
step to be taken to specify technologies for individual residences. Site-
specific analysis is necessary to accomplish this. The analysis should
include the following sequential steps: Consultation with experts in the
County Health Department, and examination of their records; interviews with
residents on the use and maintenance of their systems; inspection of the site
for obvious malfunctions; and inspection of the location and condition of any
on-site wells or springs. On the basis of information gathered, additional
investigations may be warranted to identify causes and possible remedies for
recognized problems. Examples of additional investigations, keyed to
problems, are as follows:
Problem
Recurrent Backup into House or
Evident Ground Surface Malfunction
Inadequate Separation Distance
from Septic Tank or Soil Absorp-
tion System to Well
Investigations in Sequential Order
Monitor and reduce water use
Uncover, pump out, and inspect
septic tank for obstruction and
determine groundwater inflow
Rod house sewer and effluent line
Excavate and inspect drainfield
distribution lines, if present
Determine soil absorption system
size and degree of clogging by
probing and sample pit excavation.
Note soil texture and depth to
groundwater
Inspect well for proper seal, vent,
drainage, and grouting
Sample well and analyze for fecal
coliform bacteria, nitrates, and
fluorescence
Monitor groundwater flow if drink-
ing water aquifer is shallow or
unconfined
II-6
-------
Problem
Inadequate Separation Distance
from Septic Tank/Soil Absorption
System to Lakeshore, or Inadequate
Separation Distance from Soil
Absorption System to Groundwater
or Evidence of Increased Plant
Growth
Septic Tank or Soil Absorption
System Size or Design Suspected
of Being Less than Code Requires
Septic Tank or Soil Absorption
System Size or Design Known to
be Grossly Less than Code Requires
Investigations in Sequential Order
Monitor groundwater flow direction
and rate
Locate effluent plume in vicinity
of lakeshore using groundwater probe
and fluorescent analysis (septic
leachate detector)
Sample groundwater in leachate
plume at lakeshore. Analyze for
total phosphorus, total Kjeldahl
nitrogen, nitrate nitrogen, and
fecal coliform bacteria
Inspect property to assess feasi-
bility of replacement or upgrading
If feasible, document system
inadequacies by probing and
sample pit excavation
Inspect property to assess feasi-
bility of replacement or upgrading
In the selection of technologies for individual sites, this EIS strongly
recommends as follows:
• Alternatives other than those covered by existing codes should be
considered.
• The process should involve local and state officials legally respon-
sible for permitting of on-site systems, drawing fully on local exper-
tise.
* The availability and cost of skilled manpower for maintaining and
monitoring innovative or sub-code systems should be weighted against
the feasibility and cost of requiring conventional on-site systems or
off-site systems
• There should be a multidisciplinary team, consisting of a sanitarian-
administrator and available specialists in a number of fields (see
Management Section), to advise a locally appointed Sanitary Review
Board on a case by case basis
• A range of appropriate technologies should be pre-selected by local
sanitary experts.
• The individual homeowner should be informed of the different options
being considered (and their costs) when technology selections are
being made, and the owners' opinion and advice should be solicited.
II-7
-------
Using information gained from the site-by-site analysis, a technical
expert should discuss with the owners the feasible approaches to solving any
problems. Primary criteria for identifying appropriate technology should be
costs, benefits, and risk of failure. The analysis should also consider
eligibility for Construction Grants funding. Detailed determination of grant
eligibility would be performed prior to the award of a Federal grant and would
depend upon regulations in effect at that time. General guidelines for
eligibility of on-site technologies are presented below:
• Replacement of inadequately designed facilities will be eligible if
feasible. Cesspools and privies in flood-prone areas are examples of
obviously inadequate facilities. Septic tanks in very poor repair or
substantially smaller than required by state codes are another
example. Small drainfields, dry wells, or unusually designed systems
are not of obviously inadequate design, and thus their replacement is
ineligible unless they are subject to the other guidelines.
• Parts of systems that cause recurrent surface failures, backups, or
contamination of potential drinking water aquifers are eligible for
repair or replacement. This does not apply to water-using fixtures.
Systems that fail because they are abused will not be eligible unless
the abuse is terminated and the usage of the system is documented by
water meter readings and/or reinspection of the system.
• Facilities not currently causing public health or water quality pro-
blems may be eligible for repair or replacement if similar systems in
the area are failing. "Similarity of systems" includes design and
site characteristics that can be shown to be contributing to failures.
• Design of repairs and replacements, where feasible and effective,
should aspire to comply with state and local on-site design regula-
tions. Compliance is not a condition of eligibility if sub-code design
or alternative processes can reasonably be expected to eliminate or
substantially mitigate public health and water resources problems.
Innovative designs will similarly be eligible, with the added condi-
tion of assured inspection and monitoring commensurate with the degree
of risk. For sub-code, alternative or innovative systems, it is
expected that the owner or Applicant will install water conservation
devices commensurate with the degree of risk for hydraulic over-
loading.
• On-site systems built after December 1977 are not eligible for repair
or replacement but will be eligible for site analysis. Accommodation
of new water-using devices, added since December 1977, will not be a
basis for determining eligibility. Systems adequately designed for
the building they serve but malfunctioning because of hydraulic or
organic overloading or other abuse will not be eligible, except as
explained above.
In EIS Alternative 8, many technologies were considered for replacement
of existing pit privies. The criteria considered for evaluation included
capital cost, operation and maintenance cost, reliability, and applicability
to seasonal use. Other forms of technology are also available and may be
preferable to local homeowners, depending on the nature of particular problem
situations. Some of the technologies considered are listed below.
II-8
-------
Detailed determination of grant eligibility would be performed priot to
the award of a Federal grant, and would depend upon regulations in effect at
that time.
* Vault toilets
• Holding tanks - Low-flush toilets
• Chemical toilets - Oil flush toilets - Incinerating toilets - Compost
toilets
• Electrical composting toilets
• Air-assisted toilets
It is recognized that some developed lots may ultimately require service
by off-site technologies such as cluster systems. Off-site treatment and
disposal systems will be eligible for Federal funding if:
• A public health or water resource contamination problem is documented
which no combination of on-site conventional, innovative, sub-code,
flow reduction or waste restriction methods can abate, or
• The life cycle costs of off-site treatment and disposal for an indi-
vidual building or group of buildings is less than costs of appro-
priate on-site technologies for the same buildings.
These recommendations apply only to existing systems. EPA recommends and
may fund EIS Alternative 8 to help the community and system owners minimize
the failure risk, thereby protecting water quality and the public health. For
systems at new houses, EPA makes no recommendations on the permitting process,
because the Agency does not presently expect to fund remedies for their
failures. The responsibility for approving new systems in compliance with the
Ohio Sanitary Code rests with the District Board of Health of Williams County.
2. Community Management
A wide range of community management options are available, as discussed
in Appendix C, Community Management and Recovery of Local Costs. Three addi-
tional topics and their interrelationships are discussed here. They are:
risk, liability, and scope of the applicant's responsibilities.
"Risk" as used here refers to the probability that wastewater facilities
will not operate as intended, thereby causing water quality or public health
problems or inconvenience for the user. Whether centralized, small-scale, or
on-site, all wastewater facilities have inherent risks, depending on the
degree of skill employed in design, construction, operation, and maintenance.
"Liability" as used here refers to the responsibility of various parties
to minimize risk and to accept the consequences of facility failure. In the
past, the state and county have accepted liability for facilities around
Nettle Lake only insofar as permitting and inspection activities minimized
II-9
-------
risk. The consequences of facility failure rested with system owners. In
building a sewer around Nettle Lake, the Williams County Commissioners
essentially would have accepted liability for all failures except for plumbing
and house sewer blockages.
With EIS Alternative 8, the community may limit its liability only to the
improvement of those systems upgraded, and consequently would see at least a
partial abatement of some existing risks, such as the probability of system
failure due to lack of management or poorly designed and constructed on-site
treatment components. With EIS Alternative 8 the community still has the
opportunity to assume increased liability in whatever manner it sees fit, the
only limitation being that the applicant will be responsible for actively
identifying failures of interest to the community (inconvenience for the user
not included) and attempting to remedy the failures. Strictly speaking, the
Applicant's responsibility applies only to those individual systems funded by
EPA.
Many of the statements made in describing and costing EIS Alternative 8
were based on the assumption that the Applicant would play a very active role
in improving, monitoring, and maintaining all wastewater facilities around
Nettle Lake. EPA encourages this but does not require it. The scope of the
Applicant's responsibilities depends on how much liability for wastewater
facilities it wants and is legally capable of assuming. EPA will, by funding
facility planning, design, and construction, assist the Applicant in meeting
those liabilities.
To illustrate the range of approaches the applicant might take, three
possible management options are described below.
a. Minimum Management Requirement Option
The Williams County Commissioners would act as the recipient and distri-
butor of Construction Grant funds. Homeowners who wished to improve their
on-site facilities could apply to the Commissioners for assistance. After
documenting that minimum requirements for on-site system eligibility are met,
the Applicant would receive the funding and distribute it to homeowners who
show proof of satisfactory installation. These homeowners would be assessed a
fee each year to cover the cost of a site inspection, perhaps every three to
five years, and would be required to show proof of appropriate maintenance
activities as part of the site inspection. A groundwater monitoring program
would take well water samples during the site inspection.
With this approach, Williams County would not incur any long-term debt.
the County would not necessarily have any responsibility for, or interest in,
permitting of future on-site systems. Without a comprehensive site inspection
and evaluation program, it is unlikely that all water quality and public
health problems would be identified and abated. Liability for facility mal-
functions would remain wholly with the owners.
b. Comprehensive Wastewater Management Option
This is the approach recommended in this EIS for adoption by the Appli-
cant. It involves instituting the Small Waste Flows Management District
concept discussed in the Draft EIS (See particularly pages 105 through 109
and Appendix H). All buildings within the Study Area boundaries would be
11-10
-------
included. At a minimum, each building's wastewater system would be covered in
the site-specific analysis and would be inspected at regular intervals.
Owners or residents of each building would be responsible for a user charge to
repay their share of necessary operating costs. The local debt for construc-
tion of each system could be directly assessed to individual homeowners, as in
the Minimum Management option, or could be funded as long-term debt. In the
cost figures of the Draft EIS (Appendix 1-2) all these costs are funded as
long-term debt.
This approach should identify all wastewater generation, treatment, and
disposal problems in the Study Area and should ensure that future problems are
minor or short-lived. In contrast to the Minimum Management scenario, the
higher level of responsibility resulting from this approach would allow the
authority greater discretion in sharing liability for facility operation with
the resident or building owner.
Technical expertise would be provided in several different ways. The
Commissioners could hire a part-time sanitarian-administrator to conduct the
necessary studies. The Williams County District Board of Health, in coopera-
tion with the County Engineers, could also expand their staff responsibility
to accommodate this type of operation for Nettle Lake as a demonstration
project, with additional projects possible in other parts of the district.
c. Watershed Management Option
The Applicant's concern with prevention and control of water pollution
need not be restricted to wastewater facilities. It is obvious from comments
on the Draft EIS that citizens of the Study Area are greatly interested in
maintaining the water quality of Nettle Lake. If that interest is expressed
in the form of willingness to pay for additional governmental services, the
Comprehensive Wastewater Management scenario could be augmented by the fol-
lowing functions:
• Sampling of surface waters during flood events for privy contamination
• Monitoring non-point source pollution
• Controlling non-point source pollution
• Educating residents and visitors about individual pollution control,
practices, costs, and benefits
• Inventorying the biological resources of the lake and their tribu-
taries
• Researching the chemical, hydrological, and biological dynamics of the
lake
• Coordinating with other local, state, and Federal agencies on pollu-
tion control activities and funding.
11-11
-------
3. Cost Estimate
The costs associated with EPA's recommended wastewater management
approaches are construction costs, operation and maintenance costs, and esti-
mated annual costs to homeowners. The cost parameters for EIS Alternative o
are:
Service Area
1980 Construction Cost $878,400
(including engineering, legal,
and contingency costs)
Future Construction Costs $59,483
Annual Operation and Maintenance
Expense $34,181
1980 Local Cost $84,880
1980 Average Annual Homeowners Cost $110*
* These costs may vary due to changes in Federal regulations enforcing
the Clean Water Act as amended in December 1981 (P.L. 97-117).
4. Implementation
As concluded in the Draft EIS, the Recommended Action is for Williams
County to form a Small Waste Flows Management District and implement EIS
Alternative 8. The formation of this District is in compliance with the
adopted Williams County Land Use Plan (1980) which recommends "county-operated
on-site management districts to reduce (or eliminate) stream pollution." The
technologies selected for this alternative may vary from the design outlined
in Chapter IV of the Draft EIS, because the detailed site-by-site design work
needed to decide the level of on-site upgrading for each house may indicate
that particular dwellings have problems requiring different technologies from
those discussed. When upgrading of existing conventional septic tank soil
absorption systems is found to be impractical, alternative on-site measures,
such as alternative toilets, flow reduction, and holding tanks, should be
employed.
Specific aspects of implementing the Nettle Lake project were discussed
in Section VI.D. of the Draft EIS. Those discussions are summarized as
follows:
a. Completion of Facilities Planning Requirements for the Small Waste
Flows District
As part of the facilities planning process, and to expedite the release
of available design and construction funds, the applicant would need to:
• Certify that the project will be constructed and an operation and
maintenance program established to meet local, state, and Federal
requirements.
11-12
-------
• Obtain assurance (such as an easement or County Ordinance) of un-
limited access to each individual system at all reasonable times for
such purposes as inspections, monitoring, construction, maintenance,
operations, rehabilitation, and replacement. Appendix D contains a
sample easement form.
• Establish a comprehensive program for regulation and inspection of
individual systems before EPA approves the plan and specifications.
• Plan for this comprehensive program as part of the facilities plan.
b. Scope of Design for the Small Waste Flows District
A five-step program for wastewater management in Small Waste Flows
Districts was suggested in Section III.E. of the Draft EIS. The first three
steps would appropriately be completed during the design period. These steps
are as follows:
• Develop a site-specific environmental and engineering data base in a
house by house survey;
• Design the management organization; and
• Agency start-up.
U.S. EPA will assist the applicant in defining specific objectives and
tasks for design and construction work.
c. Compliance with State and Local Standards in the Small Waste Flows
District
As discussed in Section II.F of the Draft EIS, many existing on-site
systems do not conform to current standards for size, design, or distance from
wells or surface waters. For some systems, such as those with undersized
septic tanks, non-conformance can be remedied relatively easily and inexpen-
sively. In other cases, the remedy may be disruptive and expensive and should
be undertaken only where the need is clearly identified. Data on the effects
of existing systems indicate that many existing non-conforming systems, in-
cluding some that will be repaired and still not conform to design standards,
may operate satisfactorily. Where compliance with design standards is infea-
sible or too expensive, and where site monitoring of groundwater and surface
waters shows that acceptable impacts are attainable, then a variance procedure
to allow renovation and continued use of non-conforming systems is recom-
mended. Decisions to grant variances should be based on site-specific data or
on a substantial history of similar sites in the area.
Local and State decisions on variance procedures are likely to be in-
fluenced by the degree of authority vested in the small waste flows district.
If the district has the authority and sufficient financial means to correct
errors, and has the trained personnel to minimize errors in granting vari-
ances, variance procedures may be more liberal than where financial and pro-
fessional resources are limited. Higher local costs, caused by unnecessary
repairs or abandonment of systems, would be expected to result from very
conservative or no variance guidelines. Conversely, ill-conceived or impro-
perly implemented variance procedures would cause frequent water quality
11-13
-------
problems and demands for more expensive off-site technologies.
d. Ownership of On-Site Systems Serving Seasonal Residences
Construction Grants regulations allow Federal funding for 1) renovation
and replacement of publicly owned on-site systems serving permanent or sea-
sonally occupied residences, and 2) privately owned on-site systems serving
permanent residences. Privately owned systems serving seasonally occupied
residences are not eligible for Federally funded renovation and replacement.
Depending upon the extent and costs of renovation and replacement neces-
sary for seasonal residences, the County or a Small Waste Flows Management
District may elect to accept ownership of the on-site systems. Rehabilitation
of these systems would then be eligible for Federal assistance, and local
costs for seasonal residents would be dramatically reduced.
In other states, existing public health and regulatory powers have
allowed counties to pass laws or ordinances giving sanitarians or small waste
flows districts access to all on-site systems and authority to require repair
and upgrading. To a considerable extent, these powers are already exercised
by local sanitarians in Ohio. EPA Headquarters has indicated that such a law
would be a binding commitment tantamount to public ownership, and that if this
were done, no easements at all might be required. Preliminary discussion with
the Ohio Attorney General's staff suggests that existing police and public
health powers are sufficient to allow passage of such a county law.
D. THE VOLUNTARY ACTION ALTERNATIVE
Because of the project's low position on the draft Ohio Priority List,
questions have arisen recently as to the availability of EPA Construction
Grants funding for its implementation. The ability of the project to be
funded will depend upon the U.S. Congressional budgetary allocation for
Construction Grants projects. Projects higher on the Ohio Priority List may
use all available funds. If these funds do not become available, it is
strongly recommended that the County, through its planning, engineering, and
health offices, pursue alternative means of solving these local problems.
An alternative approach would be voluntary participation by property
owners in a local program analyzing, constructing, and managing on-site waste-
water treatment improvements. This would require the County to designate
Nettle Lake as a priority wastewater service area and to provide decentralized
wastewater management services to the area.
This approach has a number of advantages, as follows:
• Rapid identification of sites to be evaluated. Instead of community-
wide sanitary surveys, the applicant would publicize data on soil
conditions and past failure rates, then designate a place for owners
to sign up for assistance.
• Access considerations would be simplified, requiring only contractual
permission to enter property as needed for inspection and repairs.
• Field data collection could be limited to detailed site analysis in
the planning phase. Individual sites would be analyzed and techno-
logies could be selected for each site.
11-14
-------
• Because of the above factors, design work for this approach would be
relatively uncomplicated.
This approach, however, while appropriate for the Nettle Lake area, could
encounter the following disadvantages:
• Serious public health and water quality problems may be missed.
Individuals who know they have difficult problems that require solu-
tions with high operational costs may be reluctant to undertake cor-
rective action.
• Unless most occupants in segments with high density or high failure
rates volunteer, feasible off-site solutions may not be affordable by
those who do seek relief.
Community understanding of public management of private wastewater faci-
lities must be cultivated in the Nettle Lake area. Where community management
is desirable, the public needs to be educated about its benefits if the
program is to be successful. The public should be directly involved in agency
design and operation when individual homeowners are to be affected by manage-
ment agency policy and decisions. Homeowners may be required to perform
necessary maintenance; to repair, replace, and upgrade failed systems; and to
pay user fees to the management agency. These requirements may meet with
considerable opposition unless an effective public education program is
initiated to inform homeowners about their role in the community management
programs. Homeowners should be notified and kept informed of their responsi-
bilities and obligations to the management agency.
To involve the public more directly in agency design and operation, a
Sanitary Review Board of community residents could be established. The board
would ensure that the management agency's technical and economic decisions are
consistent with citizen interests. The powers and duties of the board could
be structured to reflect citizen interest. The board might maintain autono-
mous control over management agency decisions and personnel, or it could serve
as an advisory body to the agency. Where the board is given autonomous
authority, it may be desirable for the administrator of the management agency
to be a member of the board to ensure that technical matters are properly
understood and considered. The board could also act as an appeals body to
hear and decide on objections to agency decisions.
Planning for on-site wastewater management approaches that complement
decentralized technologies can be a complex process. Although most of the
decisions that will be needed are based on common sense, many types of infor-
mation will be required to make good decisions. The County can facilitate its
information-gathering process for these new management approaches by taking
the following steps:
• Inventory skills of existing personnel that might be available from
local, state, and Federal agencies, and from consultants and contrac-
tors .
• Assess the impacts of existing regulatory authorities on the local
management agency's design.
11-15
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• Familiarize local decision makers and the interested public with the
technology and management functions that may be required and options
for providing those functions.
An advantage of small waste flows management by Williams County would be
the flexibility that the County would retain in determining management system
operation, maintenance responsibilities, system expansion, and local economic
and environmental impacts. The major options available to communities in
designing a small waste flows management agency can be identified in terms of
the following questions:
• Who should assume ownership for the wastewater facilities?
• Should liability for wastewater facilities be borne by the homeowners,
a private organization, or the management agency?
• Should responsibility for routine operation and maintenance rest with
the homeowners, a private organization, or the management agency?
• Which functions should be incorporated into a management agency?
• Which of the functions should be performed by the homeowners, a
private organization, or the management agency?
• What type of regulatory authority should be used?
• What type of homeowner fee system should be instituted?
The County would make decisions concerning agency design on the basis of
two groups of factors. The first group are factors that must be identified
and considered before design decisions are made. They represent existing or
projected Study Area characteristics, and include the following:
• Types of wastewater facilities required or used,
• Expertise available for use by residents of the Study Area,
• Regulatory authority available to the County,
• Existing organizational structure, such as engineering, health, and
planning offices,
» Size of the management district and number of systems in use,
• County jurisdictional setting,
• Study Area residents' attitudes toward growth, and
• Residents' attitudes toward public management of decentralized waste-
water facilities.
The second group of factors to be considered are those which constitute
potential consequences of option selection decisions. These include:
11-16
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• Anticipated costs,
* Anticipated environmental impacts, and
• Anticipated levels of risk assumed by various parties.
In order to address these issues, a sequential demonstration and planning
process is advisable. A pilot study of on-site systems renovation and waste
flow reduction technologies is recommended as the first step in this process.
Technology selection will take into account the performance record of various
technologies evaluated to date. A number of potentially useful technologies
have not been well demonstrated, however, and alternative technologies have
not been tried locally. Technology selection will be improved if some of the
most promising techniques are installed and monitored locally for a period of
time.
Specifications and layouts for various decentralized technologies will be
similar for many individual sites and could lend themselves to the establish-
ment of standard design packages for non-site-dependent technologies. Time
and effort may be saved by the development and description of standard speci-
fications and layouts. Designers should be allowed flexibility within the
standard design packages to accommodate individual site characteristics.
A significant amount of guidance exists for this modified facility plan-
ning process. "Region V Guidance - Site-Specific Needs Determination and
Alternatives Planning for Unsewered Areas" (Appendix A) defines an approach to
rural wastewater planning that is applicable to the situation in the Nettle
Lake area. A Generic Environmental Impact Statement on Wastewater Management
in Rural Lake Areas has been published (EPA, 1982) which provides useful
guidance on surface water and groundwater monitoring, use of soils informa-
tion, alternative technologies, and management options.
E. OTHER ALTERNATIVES
Many other alternatives were considered in the Applicant's Facilities
Plan and in the Draft EIS. The alternatives considered, and the reasons for
their rejection or other status, are summarized below:
Facilities Plan Alternative
Optimum operation of existing on-site Rejected because of small lot
systems sizes and severe soils limitations
Centralized collection and treatment Accepted in the Facilities Plan
in an aerated lagoon east of the lake as the Proposed Action
Low-pressure sewers with grinder pumps Rejected as not cost-effective
Vacuum sewer collection Rejected as not cost-effective
Land application Rejected due to poor soil condi-
tions
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Facilities Plan Alternative
Extended aeration treatment
Controlled-discharge photosynthetie
pond
No action
Rejected due to high cost
Rejected due to odor impacts and
possible impacts on Nettle Creek
Rejected in Facilities Plan on
basis of failure to address pol-
lution problems.
EIS Alternatives Not Considered in the Facilities Plan
Residential flow reduction by
various devices
Pressure Sewers
Alternative toilets, various designs
On-site treatment and disposal,
various designs
Off-site treatment and disposal,
various designs (cluster systems)
Expected to be effective in main-
taining the operability and
minimizing impacts of on-site
systems in the EIS Recommended
Action
Extensive use of pressure sewers
rejected because of lack of need.
Incorporated in EIS Recommended
Action; useful where control of
nutrients is sought
Incorporated in EIS Recommended
Action for Nettle Lake area
Recommended only where shown to
be worth the expense
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Chapter III
Affected Environment and Impacts of No Action
A. SOILS
The soils in the Nettle Lake Study Area have been formed predominantly of
clay loam material underlain with limy loam glacial till (see also the Draft
EIS, Section II.B.3). Two major associations have been identified in the
Study Area (Stone and Powell, 1975):
• Blount, Loam Substratum Phase-Glynwood, Loam Substratum Phase soils,
found in the southeastern half of the area, are poorly drained and
occupy level or gently sloping land. Wetness resulting from seasonal
high water table and clayey subsoils is a severe limitation of this
soil for many engineering purposes.
• Glynwood, Loam Substratum Phase-Spinks-Haney soils are found in the
northwestern half of the area. These soils are moderately well
drained and occur in gently sloping to moderately steep areas. The
well-drained Spinks soils are underlain by sand and gravel; the Haney
soils are formed in deep sandy and loamy deposits.
Suitable soils for wastewater treatment by soil absorption systems are
located in the northern and western sections of the Study Area. With the main
exception of the northeastern lakeshore, all existing development within the
Study Area is located on soils rated as unsuitable for standard on-site waste-
water treatment systems. Further development on these unsuitable soils will
be limited by the Ohio Sanitary Code and the Williams County Floodplain
Ordinance. Building of new dwellings and on-site systems will continue out-
side of these soils under the No-Action Alternative. Some erosion and sedi-
mentation will probably occur because of this activity.
B. SURFACE WATER RESOURCES
Nettle Lake's tributary, Nettle Creek, originates in Hillsdale County,
Michigan, and its drainage basin comprises 20 square miles. Discharge from
Nettle Lake flows southeasterly to join the St. Joseph River near Montpelier,
Ohio. The lake itself covers 94 surface acres and has a mean depth of 20
feet.
Nettle Lake's water quality is classified as moderately eutrophic, which
means that there is a relative abundance of nutrients available for aquatic
plant growth. While periods of oxygen depletion may place stress on aquatic
animal life, sufficient oxygen exists to support and sustain them.
There is evidence that existing on-site systems are contributing
bacterial loads to the lake, especially during flood events. This contamina-
tion by human waste presents a potential for substantial public health risk.
The bacterial data discussed in Section I-B of this EIS were collected at a
time of year that would not reflect the severity of these conditions. This
situation, while requiring further documentation, constitutes a distinctly
negative impact of the No-Action Alternative.
III-l
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HUD 100 YEAR
FLOODPLAIN
5 FOOT FLOOD
ELEVATION
FEET
Source:
2000
Ganett, et.al., HUD 1977;
By telephone, L. Opdyche
11 January 1982.
FIGURE III-l. FLOOD PRONE AREAS
III-2
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Local flood studies and interviews with residents have indicated that the
floodplain of Nettle Lake (approximately 60% of the Study Area) is inundated
at least once in every two-year period—a more frequent incidence of flooding
then was presented in the Draft EIS. On the average the lake level will rise
5 feet (from 945 to 950 feet msl) during spring flood events. This flood-
prone area (delineated in Figure III-l) largely coincides with the 100-year
floodplain as mapped by the U.S. Department of Housing and Urban Development.
In 1978, Williams County investigated the feasibility of dredging Nettle
Creek from the lake downstream to the St. Joseph River to alleviate the
problem of flooding. Public meetings were held to discuss the issue, and a
decision was reached that the project was not cost-effective. The Ohio DNR
Geologic Survey has indicated that since the lakeshore is privately owned,
initiative for any type of improvement would have to come from the local level
(by telephone, Mr. Finke, 2 March 1982).
Under the No-Action Alternative, Nettle Lake would remain moderately
eutrophic. Nutrients would continue to enter the lake. This is largely due
to non-point loading contributed from up-stream sources. Most of the nutrient
load from on-site systems stems from floodwater inundation, which would
continue under the No-Action Alternative.
C. GROUNDWATER RESOURCES
Glacial deposits of sand and gravel underlying the Study Area constitute
the area's major aquifer and source of drinking water. Wells in the area are
30 to 180 feet deep and are overlain by a layer of impermeable clay. This
clay layer prohibits wastewater from entering the drinking water supply. No
significant primary or secondary impacts on groundwater quality or quantity
are anticipated as a result of the No-Action Alternative.
D. POPULATION AND LAND USE
Of the existing total in-summer population of 1,873 estimated in the
Draft EIS, approximately 93 percent are seasonal residents. Land use in the
immediate lakeshore area (148 acres, predominantly in the southern portion) is
devoted to residences and campgrounds. The population of the area is pro-
jected to be 1,904 by the year 2000, largely as a result of the conversion of
seasonal units to permanent use. This represents a change from 93% seasonal
population in 1975 to 88% in the year 2000. The limited projected growth in
new housing is due to floodplain limitations and lack of buildable lakeshore
lots, as well as competition from other lakeshore developments in surrounding
areas.
The 1980 Census has produced new population figures for Northwest
Township, showing an 11.5 percent increase between 1970 and 1980. This is a
marked departure from previous trends which showed a 1 percent loss between
1960 and 1970 and a 2 percent gain between 1970 and 1973. These figures do
not change the population estimates for Nettle Lake, as the dynamics of the
Nettle Lake Study Area are substantially different from the Township as a
whole. The No-Action Alternative will not impact these population or land use
patterns.
III-3
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E. ENVIRONMENTALLY SENSITIVE AREAS
Environmentally sensitive areas in the Study Area include floodplains,
wetlands, habitat for rare and endangered species, and historic and archaeo-
logical resources (see Draft EIS Sections II.C, D, and E). Adoption of the
No-Action Alternative would not result in adverse impacts on any of these
areas.
Information gained from comments on the Draft EIS indicates that addi-
tional species listed by the State as threatened or endangered have been
sighted at Nettle Lake (see Table III-l). Of particular note is the Blackchin
Shiner (Notropis heterodon), which was believed to have disappeared from Ohio
waters since 1957. The pugnose minnow (Notropis emiliae) population in Nettle
Lake is believed to be the highest in the State (by letter, Richard D.
Habbell, ODNR, 15 October 1981). Also of note from the standpoint of en-
dangered species protection is the recent acquisition by ODNR of 600 acres on
the east side of the lake, including a substantial portion of the wetlands in
that area.
F. ECONOMICS
The mean family income of permanent residents in Northwest Township was
estimated as $8,870 by the 1970 census. No new estimates have yet been
produced from the 1980 census. The $8,870 figure is substantially lower than
the 1970 National and State mean figures of $10,999 and $11,488 respectively.
In 1970, Northwest Township showed a higher incidence of families living under
poverty levels (16.9%) than either the County (7.4%) or the State (7.6%). The
No-Action Alternative would have no short or long-term impact on the local
economy.
III-4
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Table III-l. Species Sightings In and Along the Shores of Nettle Lake
Species
Scientific Name
Status*
Blackchin Shiner
Pugnose minnow
Iowa darter
Slender Naiad
Clearweed
White-stem Pondweed
Small Burr-reed
Tiger Salamander
Small Purple-Fringed Orchid
Large-leaved Pondweed
Notropis heterodon OBSX
Notropis emiliae OWE, OBSE
Etheostoma exile OWE, OBSE
Najas flexilis OFF
Pilea fontana OPP
Potamogeton praelongus OPE
Sparganium chlorocarpum OPE
Ambystoma tigrinum OBST
Platanthera psycodes OPT
Potamogeton amplifolius OPP
* OSBX - Extirpated (Ohio Biological Survey)
OWE - Endangered Wildlife
OBST - Threatened Wildlife (Ohio Biological Survey)
OPE - Endangered Plant
OPT - Threatened Plant
OPP - Potentially Threatened Plant
III-5
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Chapter IV
Environmental Consequences of the Action Alternatives
This chapter presents the environmental impacts of the alternatives
embodied in the Facilities Plan Proposed Action and in EIS Alternative 8 as
described in detail in the Draft EIS, Section V. Please note that EIS
Alternative 8 is not presently a set of explicit proposals for each site—it
is an approach to the formulation of such proposals, based on local condi-
tions, the environmental sensitivity of this area's natural resources, and the
ability of these resources to assimilate wastewater from on-site systems. The
recommended approach relies on environmental management in the form of con-
tinuing attention to the use and effects of small-scale systems, and on the
community's capacity to make balanced decisions in the best interests of the
natural and human environment. The environmental consequences of the action
alternatives considered in this EIS were determined by means of four primary
criteria: Costs, impacts, reliability, and flexibility. In the evaluation
and selection of a recommended alternative, impacts on the following environ-
mental aspects were considered to be decisive: Surface water, groundwater,
population, land use, and economics.
A. SURFACE WATER RESOURCES
Neither the Facilities Plan Proposed Action nor EIS Alternative 8 is
anticipated to have a significant impact on the overall water quality or
trophic status of Nettle take. The difference between the two alternatives in
terms of total phosphorus reduction to Nettle Lake is 10 percent (Facility
Plan Proposed Action, -13 percent; EIS Alternative 8, -3 percent). This would
not change the moderately eutrophic status of the lake because of the large
load of nutrients from upstream sources of agricultural runoff.
The Facility Plan Proposed Action would eliminate the mixing of human
wastes with lake waters during flood events. This would have the effect of
mitigating the potential public health threat caused by the release of
bacterially and virally contaminated waters to the lake. A decreased risk of
health hazard would be attained, but at a substantially higher dollar cost
than EIS Alternative 8.
EIS Alternative 8 would not totally eliminate overland or groundwater
transport of bacteria and viruses into the lake. However, selection of
appropriate technology, together with scrupulous management, can reduce the
risk of health hazard by controlling the amount of waste material available
for transport. Seasonal export of vault toilet and holding tank effluent
beyond the reach of floodwaters is a feasible means of reducing this risk.
Installation of in-cabin chemical toilets or electrical composting toilets
above flood levels would also achieve these ends. The analysis called for in
the next step of planning would require homeowners to work with County and
State agencies in selecting technology suitable to specific site conditions
that would reduce or eliminate water pollution and public health problems.
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B. GROUNDWATER
No significant primary or secondary impacts on groundwater quality or
quantity would result from the implementation of either the Facility Plan
Proposed Action or EIS Alternative 8. This is due to the thick impermeable
clays that overlie the artesian aquifer which supplies local domestic wells.
Projected water withdrawal rates are small, especially compared to existing
supply. The thick impermeable clays also confine the aquifer and prevent
vertical recharge and thus contamination from on-site wastewater treatment
systems in the Study Area. The Facility Plan Proposed Action would eliminate
the discharge of all wastewater effluent to the shallow groundwater table that
recharges part of Nettle Lake.
In EIS Alternative 8, potential contaminants in groundwater would be
detected by means of site-by-site environmental and engineering analysis, and
would be reduced through application of appropriate on-site technology.
Requisite actions in this alternative include: 1) inspection of existing
wells and all on-site systems; 2) sampling of wells that are down-gradient
from, or within 50 feet of, on-site systems; and 3) selection of on-site or,
where necessary, off-site measures to eliminate sources of contamination.
C. POPULATION AND LAND USE
Population figures used for the design of EIS Alternative 8 were based on
recent growth trends and data from a variety of sources. Because of the
limited development potential for both seasonal and permanent residences in
the Nettle Lake area, it is anticipated that the Facility Plan Proposed Action
would result in only a 5 percent increase over the 1.7 percent population
growth anticipated for the area for the year 2000. EIS Alternative 8 would
permit the present growth rate to continue toward the 1.7 percent growth
anticipated. This modest growth rate reflects the lack of proximity to major
centers of employment, retail trade, and service amenities. There is also a
lack of available development sites with direct access to this relatively
small lake. In addition, the Williams County Flood Plain Ordinance restricts
further development in flood plain areas. As a result of these factors,
development pressures in the Study Area are extremely limited.
New residential development, in accordance with the level of population
growth anticipated, will be relatively small during the planning period. Even
with the maximum growth potential of the Facilities Plan Proposed Action,
residential land use is expected to increase by only a maximum of ten acres
(30 new dwelling units at 3 to 4 dwelling units per acre) over the baseline
projections. All of this land would probably be converted from currently
platted but vacant residential lots. No conversion of agricultural, recrea-
tional, or other undeveloped land would be expected. EIS Alternative 8 would
induce no significant land use conversion above projected levels. No major
non-residential land use conversions are anticipated to occur, and no change
in residential densities is projected to take place under either of the
alternatives.
D. ECONOMIC IMPACTS
The major economic impact of either alternative would be in the form of
direct costs to system users. The most significant difference between the two
alternatives is their estimated direct cost. With the Facility Plan Proposed
IV-2
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Action, the 1980 average annual homeowner's cost1 around Nettle Lake would be
$335. In contrast, the 1980 average annual homeowner's cost around Nettle
Lake for EIS Alternative 8 is $110 (see Appendix 2 for more discussion on
annual costs).
The human impacts of these costs are defined in terms of the percentage
of the population facing a significant financial burden. EPA considers a
project to be excessively expensive when total annual homeowner costs for
wastewater facilities exceed the following percentages of annual household
median income:
• 1% when median income is under $10,000
• 1.5% when median income is between $10,000 and $17,000
• 1.75% when median income exceeds $17,000
Using the 1980 census mean of $5,055 per-capita income for Williams
County, and an average of 2.79 persons per household, a mean family income of
$14,100 can be calculated (by telephone, 7 April 1982, Doug Cavanaugh, Ohio
Data Center). Applying the above threshold of 1.5% to this income results in
a figure of $212; or $102 more than the average annual homeowner cost of $110
for EIS Alternative 8, and $123 less than the Facilities Plan Proposed Action
of $335—thus showing the greater cost-effectiveness of EIS Alternative 8.
"Average annual homeowner's cost" includes one residence's equal share of
its community 1980 debt retirement cost, plus 1980 operating expenses,
plus a reserve fund contribution of 20 percent of this debt retirement
share. To this is added an equivalent annual payment for private costs
(such as house sewers) as if they were paid at 6-5/8 percent for 30
years. These costs may vary due to changes in Federal regulations en-
forcing the Clean Water Act as amended in December 1981 (P.L. 97-117)
IV-3
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CHAPTER V COMMENTS AND RESPONSES
There were many substantial comments on the Draft EIS submitted by letter
and at the public hearing held on 2 October 1981. Copies of the comment
letters and the hearing transcript index are attached to this document as
Appendix F. This chapter contains a compilation of paraphrased comments
received and the response to the comments. A list of commentors is included
on page V-12.
V
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Nettle Lake Comments and Responses (C and R)
Surface Water
C.I What are the water quality modeling techniques used to develop the
nutrient budget analyses in the Draft EIS and did they rely on
locally collected field data. (Cole, Hollinger)
R.I As discussed in the Draft EIS, Section Il.C.l.b. on Surface Water
Quality, only very limited field data were available from Nettle
Lake for analysis. Consequently, in evaluating the lake water
quality, it become necessary to employ "theoretical estimates" based
on analyses of physical and chemical parameters of the lake and its
watershed along with actual data. Non-point source nutrient loads
were derived using a simple mathematical model developed by Omernik
(1976). Using the data from this model and other sources, predic-
tions of the phosphorus input and trophic status of the lake were
developed from an empirical model developed by Dillion (1975).
C.2 What is the status of the pollution problem in Nettle Lake; is it
dangerous to local residents? (Kachenmeister, Miller)
R.2 The water quality of the lake is rated as moderately eutrophic which
is to say that a substantial amount of nutrients are found in the
water of Nettle Lake. Approximately 87 percent of these nutrients
stem from runoff from residential and agricultural uses upstream of
the lake. There may be periods of oxygen
depletion stress, but there is still an abundance of oxygen for
aquatic life to thrive.
There is a problem associated with the inundation of privies during
flood events which presents a potential public health threat.
This threat exists during flood events and for short periods there-
after, but bacterial die-off reduces the impact with time (See
Final EIS Section III.B.).
C.3 Given that 87 percent of the nutrient load is coming from non-point
sources above the lake, what can be done to stem these sources of
pollution. (Maneval)
R.3 Non-point, largely agricultural sources of phosphorus are the larg-
est sources of "pollution" in Nettle Lake, and these sources are not
directly related to the proposed project. Thus this project would
only have a limited effect on reducing phosphorus loads under the
alternatives. Under the mandate of Section 208 of the Clean Water
Act of 1972, Ohio EPA has been directed to address non-point source
water quality problems. The initial Water Quality Management Plan,
Maumee/Portage River Basins (Ohio EPA, 1979) states that the Maumee
River basin is a priority for agricultural pollution abatement.
Programs will be ongoing to implement voluntary approaches to agri-
cultural pollution abatement. Coordination may be made with the
USDA Soil Conservation Service District in Bryan.
-------
C.4 What are the groundwater quality impacts of the alternatives and do
the existing on-site systems affect well water supplies? (Schutz)
R-4 As noted in Section I of the Final EIS, contact was made with var-
ious local, State, and Federal agencies to gather well water data.
No evidence currently exists that wastewaters are penetrating the
thick impermeable clays to enter domestic water supply wells.
The decentralized wastewater management approach under EIS Alter-
native 8 will address the problems of nutrient and bacterial levels
in private water supplies around the lake. During the design and
construction phase of this project, the Applicant will conduct a
survey of 100 percent of the dwellings around Nettle Lake. The
survey will include an interview with homeowners to determine the
suitability of individual wells, and an inspection of each well for
proper seal, vent, drainage, and grouting to determine the extent to
which groundwater quality is protected by proper well construction.
Flood Hazard
C.5 One of the most central issues of this EIS in the recurrence and
elevation of flooding in Nettle Lake and the question of how to
resolve the flooding problem. (Schutz, Mclrath, Eubank, Miller,
Lindley, Salvo, Williams County Commissioners)
R.5 As noted in Section III.B. of this Final EIS, flood waters raise the
elevation of the lake approximately 5 feet every year or so. This
elevation covers a broad expanse of land surrounding Nettle Lake.
The Williams County Commissioners were petitioned to initiate a
dredge project from Nettle Lake, down Nettle Creek, to the St.
Joseph's river, a distance of over 10 miles. This proposal was
ultimately rejected as not being cost-effective. Subsequent inquir-
ies with Ohio DNR Geologic Survey indicate that the lakeshore is
privately owned, thus the State does not have jurisdiction to reg-
ulate the water level and improvement actions would have to be
initiated and paid for at the local level. Such a project does not
appear to be implementable and may carry its own adverse impacts.
Biota
C.6 In addition to the fish, wildlife and plant species listed in the
Draft EIS, the Natural Heritage Program data base records the occur-
ence of 10 additional species along the shores of Nettle Lake that
were not previously noted (Hubbel).
R.6 EPA appreciates the transmittal of this information and has included
it in Section 1.4. of this Final EIS.
Needs Documentation
C.7 November was a poor time to conduct a sanitary survey in a seasonal
resort where a vast majority of the residents are not available.
(Rupp, Kachenmeister, Schutz)
V-2
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R.7 November is admittedly not the optimal time for such a survey. Tor
lake areas with high seasonal populations, the best time would be in
late spring and early summer. However, those residents who were
surveyed were year round residents who use their on-site systems
most intensively. These systems thus would have the highest probab-
ility of failure. At the time EPA made the decision to do the
survey, it was considered more important to get data quickly than to
wait eight to ten months.
Besides the Nettle Lake survey, EPA has conducted four other sanit-
ary surveys in rural lake communities. In all cases, the informa-
tion collected regarding system performance comes almost entirely
from the residents. In general, most residents are concerned with
good sanitation and are willing to offer whatever knowledge they
have. It matters little what time of year this most valuable source
of information is sought. A reticent resident will be as unhelpful
in November as in July.
With the exceptions of intermittent direct discharges and seasonal
surface ponding, information collection during site inspections is
not hampered by the time of year. Lot size, elevation above a lake,
locations of wells and septic systems, proximity of neighbors, and
surface drainage patterns all contribute to the surveyor's interpre-
tations. This type of information is available upon inspection year
round. The survey did cover 11 percent of the residences in the
Study Area. All were lakeside properties, and many were in
flood-prone areas. Thus, while the survey is heavily biased toward
residences that are most likely to have problems, a reasonable
sample was represented.
C.8 The septic leachate survey was conducted at the wrong time of the
year. Again the highest number of problems would normally appear in
peak summer usage. (Rupp, Schutz)
R.8 As with the sanitary survey, the decision to proceed with the septic
leachate survey put more emphasis on trying to get the field work
done and acquire information than to wait for what was believed to
be the optimum time of year. The winter and summer septic leachate
surveys at this and in the six other rural lake communities where
EIS's are being done have given new insights on the validity of
field data collection at various times of the year. One of the
principal findings of these subsequent surveys is that late fall is
perhaps the best time of year for detecting the existence and break-
through of effluent plumes. In areas such as Nettle Lake, plumes
take time to force their way through the soil and into the lake so
that it is not until long after the summer is over that plumes reach
there.
C.9 It is the opinion of Ohio EPA that in a lake where primary body
contact is being made, the most important environmental concern
should be with bacterial and viral contamination of the water. OEPA
feels that pathogenic contamination of the near shore areas does
exist and the potential for spread of waterborne disease is great.
(Rupp)
V-3
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R.9 This Final EIS agrees that the principal need for action in the
Nettle Lake area stems from the inundation of on-site and privy
systems and the attendant health hazard. By focusing on this issue,
the EIS should give strong indication that there is a public health
problem in the area that needs to be addressed. The EIS does main-
tain, however, that EIS Alternative 8, with appropriate on-site
management, would achieve a significantly reduced risk of health
hazard in a cost-effective manner.
C.10 The actions proposed seem to be way out of proportion to the need
defined in this EIS. Estimating from the data presented, there are
perhaps a dozen redidences which need alteration of their wastewater
handling. Perhaps such simple ideas as pumping septic tanks before
spring floods or temporarily relocating people during them could be
considered. (Salvo)
R.10 The EIS acknowledges that the overall lake water quality would not
change markedly under any of the wastewater management alternatives.
However, the EIS does document a need based on recurrent problems in
approximately 120 systems. These malfunctions represent a public
health and water quality problem that should be addressed through
monitoring, surveillance, and upgrading on-site treatment systems as
proposed under EIS Alternative 8.
C.ll As the Draft EIS states on p. 42, the bacterial sampling program was
inadequate to conclusively define a problem and thus justify any
action for the area. Is an appropriate sampling program going to be
utilized? (Schutz)
R.ll EIS Alternative 8 proposed a community wastewater management ap-
proach that specifies the development of a site-by-site environ-
mental and engineering data base. As part of the development of
this data base, this final EIS recommends that the Small Waste Flows
Management District perform a comprehensive bacterial sampling
program to quantify what the extent of bacterial contamination is.
The data collection effort calls for a comprehensive surface water
and well water sampling program on a site-by-site basis. Surface
water sampling should also be conducted before, during, and after
spring flood events to gain a better understanding of the pathways
of disease vectors into areas of direct human contact.
C.12 The aerial photograph, septic leachate, and sanitary surveys base
their analysis on "failing" systems. What constitutes a "failing"
system in these three studies? (Schutz)
R.12 A failing system is one which presents a public health or water
pollution problem in a local area. These system failures include:
backups of sewage into homes, septic tank effluent ponded on the
ground, contamination of on-site water supply wells in excess of
drinking water standards by on site treatment systems, and discharge
of untreated septic tank effluent to surface waters in excess of
water quality standards.
V-4
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C.13 Wouldn't it be wise to sample for nitrates before ruling out aquifer
contamination? (Schutz)
R.13 The EIS has relied to the greatest extent possible on available
data. Data that has been gathered from county, state and Federal
sources give no indication of groundwater contamination from on-site
systems (See section I.E. of this Final EIS). As part of the
site-by-site analysis in the next phase of facilities planning for
the Nettle Lake Area, a comprehensive well sampling program is
recommended.
Alternatives
C.14 The reliability of alternative on-site systems and toilet tech-
nologies are seriously questioned for application at Nettle Lake.
(Rupp, Schutz)
R.14 EIS Alternative 8 does not include specific design of alternative
on-site treatment and toilet technologies for specific homes in the
Study Area. Under this Alternative, local sanitarians in coopera-
tion with State agencies would become versed in such technology and
would be able to advise owne.rs on the selection of such systems.
Information on alternative toilet design and reliability is avail-
able from EPA Region V, Municipal Facilities Branch. A workshop on
alternative technologies available to implement EIS Alternative 8
can be held so that individuals have the information necessary to
make decisions. Local sanitarians would then be able to use their
knowledge of local soils and geohydrology in selecting the approp-
riate technology for each site around the lake.
The reliability of alternative toilets has increased recently as
more units are installed. Problems with earlier installations have
led to corrections in subsequent designs. Since some technologies
such as low-flow toilets do not change the method of waste disposal
from standard flush toilets, they have become more readily accept-
able and have subsequently been refined further than systems like
composting toilets.
As a result of this higher level of refinement, low-flow toilets are
required for new construction and replacement by plumbing codes in
many parts of the United States. Such codes are indications of the
reliability of these types of toilets. Although composting toilets
are not yet mentioned in plumbing codes, their reliability has
gained wide acceptance in many parts of the country. Because of the
change in disposal method associated with composting toilets, more
low-flow toilets have been installed than composting toilets. Most
of those installed, however, have proven to be very reliable, with
very few operational tasks required for initial start-up.
There have been problems with certain types of enzyme, incinerating,
small scale composting, and recirculating toilets that have demon-
strated excessive operation and maintenance problems. These types
of systems may present more problems than homeowners are willing to
V-5
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bear. However, local sanitarians, versed in this type of tech-
nology, would be available to advise owners on the selection of such
systems under EIS Alternative 8. The key requirements for maximiz-
ing the reliability of on-site technology under EIS Alternative 8
are:
o Selection of appropriate technologies for each house based upon
well-planned and executed site analysis;
o Provision of adequate community supervision of all on-site
wastewater treatment systems; and
o Measurement of and design with the natural assimilative capac-
ity of local soil/groundwater/surface water resources.
C.15 Holding tanks are not a recognized on-site treatment method under
the Ohio Sanitary Code and thus are not a viable alternative under
this project. (Schutz)
R.15 The use of holding tanks for full residential flows in areas without
any form of management district is a management practice many states
hold in disfavor. Shortcomings include continuing costs, difficulty
finding disposal areas for sewage, lack of management mechanisms to
assure the continuation of pumping contracts, and potential for
illicit connections to drains, ditches, or surface waters. The
Great Lakes - Upper Mississippi River Board of State Sanitary Engi-
neers policy statement on pump and haul procedures generally disap-
proves of this method if unsupervised but states, "this policy
statement does not preclude the possibility of establishing a manage-
ment or service program under the control of a government... accept-
able to the administrative authority."
If the small waste flows management district were implemented, this
type of technology would be considered only after evaluation of
other alternatives. The small waste flows district may contract
for long-term treatment at the Montpelier or Bryan Plant. The
District will monitor the performance of the system and will provide
long-term maintenance.
C.16 An analysis of septage and holding tank disposal options was not
presented in the Draft EIS. (Rupp)
R.16 The EIS's level of detail in design and costing was not intended to
satisfy all facilities planning requirements.The need for proper
disposal of septage and two disposal options appropriate for differ-
ent EIS alternatives were discussed on page 97 of the Draft EIS. In
alternatives which involve use of septic holding tanks, pumping once
every three to five years at a cost of $65 per pump was included in
the cost-effectiveness analyses. Selection of this cost was based
upon contacts with local contractors experienced in the proper
disposal methods appropriate to local
V-6
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codes and conditions. The same cost was assumed for pumping holding
tank wastes.
C.17 Questions were raised on the costing methods used for comparison
purposes, given the conceptual design details of the alternatives.
(Johnson, Rupp)
R.17 EPA recognizes that the level of detail in design and costing used
in preparing the EIS in not as refined as may be expected by the
State, especially for a selected alternative. However, the costing
methods used were consistent from one alternative to the other.
Because of the substantial differences between alternatives, it is
not likely that any amount of increased design and costing effort is
going to change the basic conclusion that continued use of on-site
systems in the Nettle Lake area is cost-effective compared with
centralized systems.
C.18 The average annual homeowner cost calculation is unclear; is it
based on 100 percent participation of the Study Area residences;
will houses with serviceable on-site systems be required to part-
icipate? (Cole, Eubank, Frankforther, Webb, Monahan)
R.18 The costing of EIS Alternative 8 and attendant annual homeowner cost
allocation was conducted on the assumption of 100 percent particip-
ation of all houses in the Study Area. All residences would be
responsible for retirement of the debt incurred for upgrading facil-
ities around the lake. However, establishment of the actual charge
system to be implemented at Nettle Lake will be an element in the
process of designing the small waste flows management district. The
various methods for recovering local cost incurred and establishing
a system of user charges is discussed in Appendix B of this Final
EIS. It is recommended that all residences be inspected in the
site-by-site analysis for the performance of their on-site treatment
system.
C.19 Wouldn't it be more disirable to pay for a technologically advanced
system rather than a minimal amount for a system that may function
no better than what currently exists? (Schutz)
R.19 As shown in Section IV.D. of the Final EIS, the average annual
homeowner cost is estimate at $110 a year; the Facilities Plan
Proposed Action, $335 a year. The economic impact of the Facilities
Plan Proposed Action is thus significant under current EPA defin-
itions and is likely to be an unworkable solution. EIS Alternative
8 would utilize alternative on-site technologies that have made
significant advances technologically in recent years. This tech-
nology coupled with rigorous management will decrease the risk of
health hazard in a cost-effective manner.
C.20 Considering that the (Draft) EIS did not document a severe water
quality problem and federal funding through the Environmental Pro-
tection Agency currently is not available, we do not believe that
any additional corrective action should be taken at this time.
(Williams County Commissioners)
V-7
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R.20 The Draft and Final EIS have indicated that the principal need for
the project stems from the substantial risk of public health hazard
associated with the inundation of privy systems during spring flood
events. EIS Alternative 8 was developed to specificall address the
problems defined in the EIS Study Area with Federal participation
through the Construction Grants Program. Section II.D. of the Final
EIS recommends a voluntary action alternative that can be taken to
mitigate this health hazard, making maximum use of existing tech-
nical capability at the local level.
C.21 Serious questions have been expressed over the performance of any
form of on-site systems during flood events. (Schutz)
R.21 In a resort area such as Nettle Lake where 93% of the population is
seasonal, early spring flooding will not affect system use since
most of the systems would not be in use until later in the season
when the water table has dropped to an lower level. For permanent
homes in areas subject to flooding, decisions will have to be made
between the homeowner and the Small Waste Flows Management District
on water use limitations during periods of high water. One method
might be to hold portable chemical toilets in reserve for use during
periods of high water.
Impacts
C.22 What are the impacts on retired persons and people with limited
incomes? (Eubank, Seasler)
R.22 Of the total permanent population in the Northwest Township, census
figures show that 16 percent of the population in 1970 were living
below Federally established poverty levels. However, no data area
availabel on people who live at Nettle Lake on a seasonal basis.
The Draft EIS Section V.E.3. did conclude that the more centralized
alternatives (EIS Alternatives 2 and 3, and the Facility Plan Pro-
posed Action) could be a financial burden on population living
around the lake. EIS Alternative 8 would This EIS estimates that
these statistics would affect retired persons with limited for fixed
incomes more than any other segment of the population. The applic-
ant might seek additional sources of funding (such as FHA) to allev-
iate some of the burden placed on residents with fixed incomes.
C.23 The Draft EIS does not contain an inventory of mineral or other
natural resources extracted from the local area for sale. (Huff)
/
R.23 Sand, gravel, and peat are mined in the Williams County area; how-
ever, no extraction operations of any type are found in the EIS
Study Area. The project is not anticipated to have any impact on
extractive resources in the area with the exception of construction
materials used for upgrading on-site systems as specified in Sec-
tions VII and VIII of the Draft EIS.
V-8
-------
C.24 The Facilities Plan Proposed Action appears to have met the
cost-effectiveness criteria of Program Requirements Memorandum (PRM)
78-9 and is therefore not a viable EIS issue. (Schutz)
R.24 At the time that the Notice of Intent was issued, PRM 78-9 had not
been promulgated and therefore its definitions did not apply. At
that time, public and agency comments indicated that the project
costs might be more expensive than local residents could afford and
significant adverse environmental impacts could be associated with
the development of the project.
C.25 It seems that the writers of the EIS were unable to conceal their
value bias against growth by using the adjective "induced" with it.
(Salvo)
R.25 The point that the EIS tries to make is that bringing new wastewater
facilities into an area where there previously were none can provide
a significan new influence that would stimulate growth. The liter-
ature is very conclusive on this point. It indicates that new sewer
facilities have an overwhelming influence on the rate, location, and
density of new residential development (See Real Estate Research
Corp., 1974, The Costs of Sprawl).
Implementation and Management
C.26 The legality of an on-site wastewater management has been questioned
under existing Ohio enabling legislation. (Rupp, Miller, Schutz)
R.26 At the present time, Ohio has no enabling legislation specifically
endorsing the formation of this type of destrict, although it has
been proposed. U.S.EPA believes that there is no legal language
that prohibits the formation of this type of agency. Thus the
police power of Williams County should extend to cover this type of
function.
Included in Section Section II.B.2 and Appendix of this Final EIS is
a discussion of three management approaches possible for Nettle
Lake. While EPA can recommend an approach, final selection of any
one or a combination of these is up to the applicant. EPA wishes to
encourage the approach; the benefits are well worth the cost.
C.27 Since the majority of the on-site systems around Nettle Lake do not
meet sanitary code specifications because of severe site limita-
tions, upgrading on-site systems will not solve the problem over the
20-year life span of the project. (Schutz, Rupp)
R.27 There is sufficient information on the condition and effects of the
existing systems to predict that, with modifications their use in
most areas around Nettle Lake will be acceptable for years to come.
The existing systems are old; many are undersized and poorly main-
tained. Yet the failure rate is low at present and can be reduced
even further and kept at very low levels with the procedures recom-
mended under EIS Alternative 8.
V-9
-------
The Draft and Final EIS's recognize that some individuals homes may
require new and innovative technology to provide reliable wastewater
treatment. Discussion of the proposed technologies are proceeding
as part of a Generic Environmental Impact Statement on Rural Lake
Projects and will be available soon.
C.28 OEPA recommends a meeting between US EPA, the Applicant, the Ohio
Clearinghouse, and interested Ohio reviewers to discuss the Facil-
ities Plan and the EIS in more detail and to consider the results of
local floodplain zoning, the adoption of more stringent county
subdivision regulations, and increased enforcement of Ohio sanitary
codes by the local health department. (Schutz)
R.28 The Final EIS concurs with this proposal and has incorporated it
into the recommendation for formation of the Small Waste Flows
Management District and implementation of EIS Alternative 8 (See
Final EIS Section II.C.). The adoption of this new approach would
necessitate a pilot program to clearly demonstrate the viability of
these methods. This would require the combined talents of all
parties mentioned in order to make this project work as well as any
other Facilities Plan.
C.29 Concern was expressed that insufficient coordination occurred be-
tween local residents, County, State, and Federal agencies.
(Schutz)
R.29 EPA has made considerable effort to elicit input from sources of
local information pertinent to the EIS effort. Contacts were made
early in the process to gather as much existing information as
possible. In addition there have been published notices on three
public meetings, a public hearing, publication of an EIS newsletter,
and circulation of the EIS to all interested parties. This review
period on the Draft EIS has served to solicit precisely the type of
input that EPA has received on shortcomings or omissions of the EIS.
Should the Williams County Commissioners decide to implement EIS
Alternative 8 with the formation of a small waste flows management
district, considerable opportunity for public and agency input will
be actively encouraged. US EPA will be depending upon Ohio EPA for
technical assistance and coordination efforts with the Ohio Health
Department on issues related to planning appropriate on-site waste-
water management in the Nettle Lake area. See Section II.B. of the
Final EIS for a description of the various means of involvement.
C.30 The concern has arisen that conclusions reached in this EIS will
serve as a basis for EPA policy for all rural lake projects.
(Johnson, Salvo)
R.30 This project is one of seven rural lake EIS projects that EPA has
conducted in the upper mid-west states. The findings from the seven
EIS's are forming the basis for a Generic EIS on Wastewater Manage-
ment in Rural Lake Project Handbook that will provide1guidelines to
conduct facility planning in these areas.
V-10
-------
The general conclusion resulting from this work is that rural com-
munities' wastewater systems should be selected and designed on the
basis of local data obtained for each individual community. (See
Section I.C. of this Final EIS). The specific conclusions for the
Nettle Lake Study Area are based on locally acquired information and
are not necessarily transferrable to other communities.
Miscellaneous
C.31 Is the reference to "900 feet msl" on p. 21 of the Draft EIS cor-
rect? (Schutz)
R.31 The commentor notes that the height of the lake averages 945 feet
msl and the shoreline at the edge of the lake is thus the low point
of the Study Area.
C.32 This EIS should be submitted for review by an independent third
party more familiar with the performance of environmental assess-
ments and environmental conditions in Ohio. (Schutz)
R.32 The purpose of the publication of a Draft EIS and holding public
hearings is to solicit comments from a wide variety of interests,
thus comprising a comprehensive review. EPA received 17 comment
letters and testimony at the public hearing by 20 different people.
The Final EIS, as required under the regulations enforcing the
National Environmental Policy Act, has responded to these comments.
V-ll
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LIST OF COMMENTORS
Mr. Gary Cole, Floyd G. Brown Associates
Mr. Bruce Hollinger, Floyd G. Brown Associates
Mr. Claire Kachenmeister, Area Resident
Mr. Vernon Miller, Area Resident
Mr. Russ Maneval, Area Resident
Mr. Albert Mcllrath, Area Resident
Mr. Louvere Eubank, Area Resident
Mr. Clifford Lindey, Area Reaisent
Mr. Lynn Salvo, Concerned Citizen
Williams County Commissioners
Mr. Alan L. Rupp, Ohio Environmental Protection Agency
Mr. Roger Hubbel, Ohio Department of Natural Resources
Ms. Beverly Frankforther, Area Resident
Mr. & Mrs. Eldon B. Webb, Area Residents
Rep. Larry Manahan, State Senator
Ms. Flossie Sesler, Area Resident
Ms. Sheila M. Huff, U.S. Department of Interior
Mr. Dennis Miller, Maumee Valley Resource Conservation, Development
and Planning Organization
V-12
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VI-2
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VI-5
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INDEX
Aerial photographic survey
See Field studies
Agriculture, runoff from, iv; 1-5; IV-1
Alternatives:
components and comparisons, iv, v; II-2, 17-18; IV-1
costs, iv; 1-1; 11-12
criteria for evaluation, IV-1
no-action, iv; II-4; III-3
planning of, by community 11-17
recommended, iv, vi; 11-14 - 11-14
voluntary action, iv, vii; 11-14 - 11-17
Bacterial and viral contamination, 1-5,6; III-l
Clean Water Act, 1-1; 11-1,12
Costs
Facilities Plan proposed action, II-l; II-l
present worth, iv
recommended alternative, 11-12
to homeowners, vi; 1-1; 11-1,10-11; IV-3
Draft EIS, ii,iv,vi; 1-4; 11-1,11,12,13; III-4; IV-1
Endangered species
See Wildlife, threatened or endangered
Erosion and sedimentation, III-l
Eutrophication
See Water quality, trophic level
Facilities Plan, ii; 1-1,4
proposed action, ii,vi; 1-1; II-l; IV-1
comparison with recommended alternative, IV-1
costs, iv; 1-1; II-l
impacts, ii
revisions needed for funding, vi; 11-12
Fecal coliforms
See Bacterial and viral contamination
Field studies
aerial photographic survey, ii; 1-5,6
bacterial surveys, 1-6
sanitary survey, ii; 1-5,6
septic leachate survey, ii; 1-5,6
VI I-1
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Floodplain, 11; 1-6; 111-3,4
Flood-prone areas, III-2
Floods, III-3
problems caused by, ii,iv,vii; 1-4,5,6; II-4
Funding, Federal, iv,vi,vii; II-4
eligibility for, 11-8,9,10,14
Groundwater resources, III-3; IV-2
geology, 1-5; III-3; IV-2
impacts, III-3; IV-2
monitoring, 11-10
quality, 1-5
water table, 1-6; IV-2
wells, 1-5,6
use, 1-4
Historic and archaeological resources, III-4
Land use, III-3; IV-2
Needs documentation, i, iv
Nettle Lake, 1-6; III-l
contamination, 1-4
water levels, 1-6; III-3
See also; Water quality
Non-point source runoff, iv; 1-6; III-3; IV-1
NPDES permit, 1-4
Nutrients
See; Phosphorus
Phosphorus
levels, IV-1
loading, iv,vi; 1-4
sources of, iv, 1-4
Population, II-l; III-3; IV-2
induced growth, ii; 1-1
projections, ii; 1-1
Privies
See; Wastewater treatment, on-site systems
Public health, 1-5
hazards, ii,vi,vii; 1-6; 11-4,15; IV-1
VII-2
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Wetlands, ii; 1-4; III-4
Wildlife, III-5
habitat areas, 1-4
threatened and endangered species, ii; 1-4; III-4
VII-3
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APPENDIX A
DRAFT EIS BY REFERENCE
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APPENDIX B
EPA REGION V GUIDANCE -
SITE SPECIFIC NEEDS DETERMINATION and
ALTERNATIVE PLANNING FOR UNSEWERED AREAS
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REGION V GUIDANCE
SITE SPECIFIC NEEDS
DETERMINATION AND ALTERNATIVE PLANNING
FOR UNSEWERED AREAS.
I. Objective
The objective of this guidance is to clarify fulfillment of the require-
ments regarding the demonstration of need for sewage treatment associated with
the application of Program Requirements Memorandum (PRM) 78-9, "Funding of
Sewage Collection System Projects," and PRM 79-8, "Small Wastewater Systems."
This guidance is written particularly with respect to the needs of small,
rural communities and the consideration of individual on-site and small scale
technologies. It suggests procedures which may be utilized to minimize the
time, effort, and expense necessary to demonstrate facilities needs. It is
also intended to provide guidance pertaining to the selection of decentraliza-
tion alternatives for a cost-effectiveness comparison. It is intended to
prevent indiscriminate definition of need based upon "broad brush" use of a
single criterion or on decisions unsupported by fact.
The procedure recommended herein may not be the optimum procedure for all
projects. However, compliance with this approach will be prima facie evidence
for the acceptability of the "needs" portion of a proposed plan of study. If
another method is proposed for documenting needs for wastewater facilities, it
is recommended that the grant applicant discuss the proposed approach with
reviewing authorities prior to the submission of the Plan of Study and the
Step 1 grant application.
This guidance is predicated on the premise that planning expenditures
should be commensurate with the cost and risk of implementing feasible alter-
natives for a specific planning area. The guidance further recognizes the
complexity of planning alternative technology. It presents procedures for,
and rationally limits, the amount of detailed site investigation necessary to
determine the suitability of alternative technology for specific areas within
the community, and allows for a degree of risk inherent to limited data
gathering.
II. Goal
The goal of this process is to enable communities to categorize existing
on-site treatment systems into three groups. The groups are those experi-
encing: (a) obvious sewage treatment problems, (b) no problem, and (c)
potential problems representing a planning risk that requires resolution by
the acquisition of original data.
The acquisition of original data as described will support not only
documentation of need but also development of appropriate alternatives and
their associated costs.
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III. Criteria for site-specific needs determination
A. Direct evidence that demonstrates obvious problems includes:
1. Failure by surface (breakout) ponding of filter field discharges
can be identified through direct observations, mailed question-
naires, and remote imagery.
2. Sewage backup in residences can be identified through respones
to mailed questionnaires, knowledge of local septage haulers, or
knowledge of local health or zoning officials.
3. Flowing effluent pipes detected by aerial photography, site
visits, knowledge of local officials, or results of mailed ques-
tionnnaires.
4. Contamination of water supply wells (groundwater) by sewage can
be demonstrated by well inspection and sampling and analyses for
whiteners, chlorides, nitrates, fecal coliform bacteria, or
other indicators, and a finding of their presence in concen-
trations which significantly exceed background levels in ground-
waters of the area or primary drinking water quality standards.
Improperly constructed wells or wells inadequately protected
from surface runoff cannot be used to demonstrate an obvious
need. Wells for which construction and protection are unknown
cannot be used to demonstrate an obvious need.
5. Samples taken from effluents entering surface water through soil
that analysis shows to have unacceptable quantities of nutrients
or bacteria.
B. Indirect evidence that indicates potential problems due to site
limitations or inadequate design of treatment systems includes:
1. Seasonal or year-round high water table. Seasonal or annual
water table can be determined by taking transit sightings from a
known lake level, if the dwelling in question is adjacent to a
lake or other surface waters. Elsewhere, Soil Conservation
Service maps may indicate depth to groundwater.
2. Water well isolation distances (depending on depth of well and
presence or absence of impermeable soils). Isolation distances
may be addressed in part by lot size. In cases where a commu-
nity water system is installed or is concurrently planned, this
criterion will not be considered. Lots, including consolidated
lots, which are less than 10,000 square feet in area, will be
assumed to have insufficient isolation distances. However,
before this criterion may be used as areawide evidence, a corre-
lation with results of limited representative sampling which
substantiate water well contamination must be made.
3. Documented groundwater flow from a filter field toward a water
supply well may override seemingly adequate separation
distances.
B-2
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4. Sewage effluent or tracer dye in surface water detected by site
visit or various effluent detection systems. Additional tests
that indicate unacceptable quantities of nutrients or bacteria
in the effluent reaching surface water will establish direct
evidence of need.
5. Bedrock proximity (within three feet of filter field pipe) can
be assessed by utilizing existing SCS soils maps.
6. Slowly permeable soils with greater than 60 minutes/inch perc-
olation rate.
7. Rapidly permeable soil with less than 0.1 minutes/inch percola-
tion rate. Soil permeability may be assessed by evaluating
existing SCS maps.
8. While holding tanks, in certain cases, can be a cost-effective
alternative, for purposes of site-specific needs determination,
a residence equipped with a holding tank for domestic sewage
should be considered as indirect evidence of need for sewage
treatment facilities. Location of holding tanks will be identi-
fied through records of local permitting officials, septage
haulers, or results of mailed questionnaires.
9. On-site treatment systems which do not conform to accepted prac-
tices or current sanitary codes may be documented by owners,
installers, or local permitting officials. This category would
include cesspools and grossly under-sized system components (the
proverbial "55 gallon drum" septic tank).
10. On-site systems: (a) incorporating components, (b) installed on
individual lots, or (c) of an age, that local data indicate are
characterized by excessive defect and failure rates, or non-
cost-effective maintenance requirements.
Indirect evidence may not be used alone to document the need for
either centralized or decentralized facilities. Prior to field
investigation, indirect evidence should be used to define the scope
and level of effort of the investigations. When the investigations
are finalized, indirect evidence and results of the field work can
be used together to predict the type and number of on-site and small
scale facilities needed in the community. Facilities predictions
form the basis for alternatives development in Step 1 facilities
planning.
IV. Needs determination for unsewered communities
For projects in which the scope of work is difficult to assess during the
Step 1 application, it is recommended that Step 1 be divided into two phases
to more effectively allow estimation of the planning scope and associated
costs. Phase I will consist of a review of existing or easily obtainable
data. Phase II will include on-site investigations and representative sam-
B-3
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pling necessary to adequately define water quality and public health problems,
identify causes of the problems and predict measures that remedy the problems.
Phase II will also include development of alternatives and completion of the
facilities plans. Both phases should be addressed in the Plan of Study and
grant application. The phases are discussed in greater detail below.
A. Phase I
The review of existing or easily obtainable data may include the
following as appropriate:
1. Review of local well and septic tank permit records. Repair
permits for septic tank systems can provide valuable data on
rates and causes of system failures as well as information on the
repairability of local systems.
2. Interviews with health department ,or other officials responsible
for existing systems, with septic tank installers and haulers,
and with well drillers.
3. Review of soils maps
4. Calculation of lot sizes
5. Estimate depth to water table by reference to lake levels or from
information in soil maps.
6. Aerial photography interpreted to identify suspected surface
malfunctions
7. Leachate detection surveys of ground or surface water
8. A mailed questionnaire regarding each owner's or resident's
knowledge of the on-site system and its performance. Mailed
questionnaires will generate useful data only if well prepared.
Generally, mailed questionnaires should be used only where avail-
able information indicate very low problem rates (to support No
Action alternatives) or where the data indicate very high problem
rates (to support central collection and treatment alternatives).
This preliminary data will be used to categorize developed lots
within the planning area into one of three groups:
1. Obvious-problem
2. No-problem
3. Inconclusive
The"obvious-problem" group consists of those lots where at least one
criterion of direct evidence of a need (specified on Page 2 of this
guidance) is satisfied.
The "no-problem" group consists cf those lots where there is no
direct or indirect evidence to indicate that the present system is
inadequate or malfunctioning.
B-4
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The "inconclusive" group consist of developed lots with indirect
evidence of problems. The size of this group and the types of in-
direct evidence associated with it will dictate the scope and level
of effort of field investigations conducted during Phase II.
Typically field work in Phase I will be limited to rapid, community-
wide surveys which require little or no entry onto private property.
Examples are acquisition and interpretation of aerial photography,
field checking of aerial photography interpretations, and shoreline
effluent scans. Additionally, a windshield survey of the community
in the company of health department officials, soil scientists or
other locally knowledgeable persons will help the applicants' repre-
sentative or consultant develop a strategy and cost estimate for
Phase II field investigations.
To facilitate communication of Phase I information, preparation of a
planning area base map at a scale sufficient to locate individual
buildings will normally be helpful. U.S. Geological survey 7.5
minute maps (1:24,000) Soil Conservation Service soil maps (1:15,840)
or local tax maps can be used to inexpensively prepare base maps. At
the end of Phase I, base maps can be used to show developed areas
obviously requiring centralized facilities, individual buildings with
obvious problems and developed areas with indirect evidence of
problems.
Phase I as used here applies principally to needs documentation
activi ties. Obviously, other facilities planning tasks can proceed
concurrently with Phase I.
B. Mid-Course Review
At the end of Phase I, the results of the Phase I effort should be
presented for review and concurrence before proceeding to Phase II.
The Mid-Course Meeting facilities plan review is an appropriate time
for the presentation and discussion of the Phase I results.
The following should be considered at the Mid-Course Meeting:
1. It may become apparent during Phase I that on-site, alternative
technology systems will not be cost-effective for segments of the
community that have obvious needs. In this case, a preliminary
cost estimate for conventional collection and treatment should be
compared to that for the innovative/alternative treatment solu-
tion. If cost estimates and technical analysis indicate that the
use of alternative technology is clearly not cost-effective,
needs documentation may be terminated for these segments without
proceeding to the on-site investigations of Phase II.
2. The number of lots to be investiaged during the on-site evalua-
tion should be reasonably estimated. If the original estimation
of on-site work included in the Step 1 Grant Agreement is found
to be in error at the end of the preliminary evaluation (Phase
I), a request to amend the grant amount, if necessary, may be
B-5
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submitted and a grant amendment expeditiously processed provided
there is concurrence at the Mid-Course Meeting.
C. Phase II Work
Field investigations in Phase II have two primary purposes:
o reclassification of buildings from the "inconclusive" category to
"obvious problem", "no problem" or "potential problem" categories
(defined below)
o development of information needed to predict the technologies and
their costs for responding to the community's waste water
problems.
Field investigations can also be designed to accomplish other objec-
tives such as public participation, socio-economic data collection,
etc.
During Phase II previously unrecognised but documentable water quali-
ty and public health problems may be identified, increasing the
number of "obvious problem" buildings. The remainder of buildings
investigated will be classified in the two remaining categories. In
order to do this, representative sampling of site conditions and
water quality in conjunction with partial santiary surveys may be
conducted. Both "obvious" and "inconclusive" problem buildings
should be included in the partial sanitary survey so that reasonable
correlations between site conditions, system usage and system
failures in the community can be made.
"Potential problems" are systems which do not yet exhibit direct
evidence of failure but which can reasonably be expected to fail in
the future. Justifying this expectation must rely on analysis of the
causes for failure of substantially similar systems in the community.
Similarity will be judged on informaton for system usage (number of
occupants and types of sanitary appliances), system design and age,
and verified site limitations (permeability, depth to groundwater or
bedrock, slope, surface drainage, etc.). Buildings in the "inclu-
sive" category whose systems are not similar to any documented fail-
ing system will be included in the "No Problem" category.
This work should be proposed and conducted with the knowledge that
adoption of decentralized alternatives will necessitate complete site
analysis for each building later in the Construction Grants process.
Work should, therefore, be thorough enough that augmentation of the
Phase II work by later studies can be accomplished without duplicat-
ing the Phase II work. The work should also seek the causes of
problem, not just their existence, so that typical on-site and small
scale technologies can be tentatively identified and incorporated
into community alternatives.
Representative sampling of site conditions and water quality should
be carefully coordinated with partial sanitary surveys. While the
design of this work will obviously have to be tailored to each com-
munity's unique situation, general guidance is provided here.
B-6
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1. Representative Sampling
a. Seasonal or permanent high water table. Soil surveys and
comparison with known lake levels reviewed in Phase I may not
be accurate enough to explain specific on-site system problems
or to carefully delineate groups of lots where high water
table is a serious site limitation. Soil to a depth of 5 or 6
feet on or adjacent to suspect lots can resolve such uncer-
tainties. Where seasonal high water table is suspected and
work has to be conducted during dry weather, a soil scientist
with knowledge of local soils should be involved.
b. Groundwater Flow. The safety of on-site well water supplies
and springs on small lots may depend on the rate and direction
of groundwater flow. Estimating the effects of effluents on
surface waters may also require such information. Methods
which indicate groundwater flow characteristics should be
selected and supervised by qualified professionals. Generally
this work in Phase II will be limited to evaluation of well
logs and other available data and of rapid surveys in special
areas such as lakeshores. Exceptions for more intensive work
will be considered where uncertainties about sources of well
contamination need to be resolved for specific lots or groups
of lots.
c. Well water contamination. Where lot sizes are small or soils
are especially permeable, collection and analysis of well
water samples at residences included in sanitary surveys
should be considered. Parameters that can be evaluated as
pollution indicators include, but are not limited to: chlo-
rides, nitrates, phosphates, fecal coliforms, surfactants,
whiteners and other readily detectable constituents inherent
to domestic waste water. No well samples should be collected
from wells that are improperly protected from surface runoff
or other non-wastewater sources. An inspection report should
accompany each well analysis.
d. Shallow groundwater contamination. In areas with drainfield
to groundwater separation distances less than state standards,
shallow groundwater at or near affected water bodies (lake,
stream, unconfined aquifers) should be sampled before aban-
doning on-site wastewater systems on the basis of high water
tables. Discrete samples may be collected during checks of
high water tables for analysis of conventional parameters as
listed above. Alternatively, as rapid survey techniques are
perfected, they may be more appropriate.
e. Soil permeability. If very slow or very rapid soil per-
meability is suspected of contributing to surface malfunc-
tions, backups or groundwater contamination, soil characteris-
tics can be evaluated by augering to 5 or 6 foot depth on or
adjacent to selected lots. Usually, descriptions of soil
horizons by depth, color, texture and presence of mottling,
B-7
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water or bedrock will suffice. Percolation tests for existing
systems will be necessary only in extraordinary circumstances.
2. Partial Sanitary Surveys
It is not the intent of needs documentation to finally identify
each and every wastewater problem in a community. It is not
cost-effective to select appropriate technologies for each
property in Step 1.
Therefore, Phase II sanitary surveys will include only a suf-
ficient number of existing buildings to confirm the level and type
of need present, and to predict the type and approximate number of
measures to correct the problems. Correlation of partial sanitary
survey data, representative sampling, and indirect evidence of
system problems should be sufficient to meet these objectives.
Sanitary surveys should include for each building:
o an interview with the resident to determine age of the build-
ing and sewage disposal system, design and location of the
sewage disposal system, system maintenance, occupancy of the
building, water using appliances, use of water conservation
devices, and problems with the wastewater system.
o an inspection of the property, preferably in the company of the
resident, noting location of well, septic tank, soil absorption
system, pit privies and other sanitary facilities; lot dimen-
sions; slope; roof and surface drainage; evidence of past and
present malfunctions; and other relevant information such as a
algae growth in shoreline areas.
o any representative sampling that is appropriate to the site and
that can be scheduled concurrently.
o preliminary conclusions on maintenance, repairs, applicable
water conservation methods, and types and location of replace-
ment or upgrading for existing wastewater systems.
As a rule of thumb, the number of buildings surveyed should not
exceed 30 percent. Where Phase I data is very incomplete, the
buildings may be selected on a random basis and should include a
minimum of 20 percent of existing buildings. Where buildings with
obvious problems and areas with indirect evidence of problems are
well delineated in Phase I, the surveys can be better focused,
perhaps requiring fewer buildings to be surveyed. From 10 to 50
percent of buildings having obvious problems should be surveyed.
In areas with indirect evidence of problems, 20 to 30 percent
would be sufficient. Areas with neither direct nor indirect
evidence may be surveyed where system age, unusual occupancy
patterns or especially severe consequences of system failure so
indicate.
B-8
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V. Planning of Alternatives
In unsewered, low housing density areas, PRM 78-9, "Funding of Sewage
Collection System Projects", puts the burden of proof for need and cost-
effectiveness of sewers on the applicant. The four criteria outlined in PRM
78-9 for eligibility of collector sewers are:
o need
o cost-effectiveness
o substantial human habitation in 1972
o 2/3 rule
Figure 1 portrays the relationship of these criteria in a decision flow
diagram.
Definition of need by the approach outlined above will address the first
criterion. Estimating cost-effectiveness will typically require two steps:
determining the feasibility of non-sewered technologies for remedying obvious
and potential problems, and comparing the present worth of feasible non-
sewered technologies with the present worth of sewers.
The determination of feasibility for non-sewered technologies should not
be limited to standard septic tank/soil absorption systems. Where lot sites,
site limitations or excessive flows can be overcome by alternative techno-
logies, these must be considered. To the extent that the needs documentation
results show that existing soil absorption systems smaller than current code
requirements can operate satisfactorily sub-code replacements for obvious
problems should also be considered if lot site or other restrictions preclude
full sized systems.
The use of needs documentation results in developing alternatives should
be guided by methods selected to design the Phase II field investigations. If
sanitary surveys and representative sampling were conducted on a random basis,
then the types and numbers of technical remedies should be projected for the
entire area surveyed without bias. However, if efforts were focused on
identified problem or inconclusive segments of a community, then predictions
from the data should be made for surveyed segments only. Real but unre-
cognized problems in "no problem" areas can be accounted for by assuming
upgrading or replacement of existing systems in these areas at frequencies
reasonably lower than surveyed segments.
Infeasibility of remedying individual, obvious problems on-site will not
be sufficient justification for proposing central sewering of a community or
segment of a community. Off-site treatment can be achieved by pumping and
hauling and by small scale, neighborhood collection and treatment systems.
The choice between these approaches should be based upon a cost comparison
which includes serious flow reduction measures in conjunction with any holding
tanks.
Segment by segment cost-effectiveness comparisons will be required only
for those segments where new facilities for off-site treatment are proposed.
Community-wide cost estimates for upgrading or replacement of on-site systems
in decentralized areas will generally be adequate for description of Proposed
Actions pending detailed site analysis and cost estimates for each building in
Step 2.
B-9
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Phase 1
Needs
Documentation
studies
Inconclusive
Documented groundwater
contamination public
health hazard or point
source violation ?
No
Yes
Phase 2
Needs
Documentation
studies
Inconclusive
Alternatives to
sewers feasible?
Note I: Substantial human habitation is determined on a
small tract (city block or areas of five acres or less)
basis. The bulk (generally two-thirds) of the flow
design capacity through the sewer system is to be
for wastewater originating from the habitation
existing on October 18, 1972.
lote 2: Eligibility is also subject to other criteria not in-
corporated into this decision flow diagram such
as not affording capacity for development on en-
vironmentally sensitive lands, conformance with
approved 208 and air quality plans, and conform-
ance with Executive Orders on Wetlands and
Floodplains and Agency policy on wetlands.
No
(Document reasons)
Yes
Present worth
estimates of sewer-
ing and alternatives
Cost comparison
Sewers cheaper
Substantial human
habitation present
in 1972? (see note I)
Alternatives
cheaper
Sewers
eligible
(See note 2)
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-------
Field work necessary to thoroughly evaluate the condition of individual
on-site systems and to select technology for necessary upgrading or replace-
ment is generally to be viewed as Step 2 or Step 2 + 3 work. Typical field
work for this level of analysis includes completion of the sanitary survey
and, as appropriate to each building, installation and monitoring of water
meters, inspection of septic tanks, rodding house sewers and effluent lines,
probing or limited excavation of soil absorption systems for inspection, and
other measures listed above for representative sampling. Construction of
on-site replacements and upgrading may proceed in tandem with this site
specific analysis provided:
o state and local officials concur (their prior concurrence might
be limited to standard systems),
o contract language allows for flexibility in the facilities to
be constructed,
o property owner concurrence with the selected alterations is obtained,
and
o additional cost-effectiveness analysis to support technology selection
is not necessary.
Necessary state and local agency approval of off-site, non-standard, or
owner-protested facilities or those requiring additional cost analysis would
optimally proceed on a segment-by-segment basis to minimize the time between
technology selection and construction.
The establishment of a management district's authority to accept re-
sponsibility for the proper installation, operation and maintenance of indi-
vidual systems per 40 CFR 35.918-1(e) and (i) should be completed before award
of Step 2 or Step 2 + 3 grants. Development of a management district's pro-
gram for regulation and inspection of systems must be completed before a Step
3 grant award or before authorization to proceed with construction procurement
is granted under a Step 2+3 grant.
VI. Public participation
The following comments are intended to demonstrate how this guidance
relates to the standard requirements for public participation. It is not all
inclusive.
A. Although mailed questionnaries have limited utility for needs docu-
mentation, they can serve as useful public participation tools. A
useful "mailing list" may include all owners of residences within
unsewered areas in the planning area and other interested and
affected parties.
The requirement for consulting with the public set forth in 40 CFR
35.917-5(b)(5) will be considered satisfied if questionnaires are
submitted by individuals on the "mailing list."
B-ll
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B. The public meeting required by 40 CFR 35.917-5(b)(6) provides an
opportunity for property owners to be informed of whether or not
they have been found to need wastewater treatment facilities. During
the meeting they can respond to the consultant's determination of
their need status. A map with each lot designated as no-need,
obvious-problem, or inconclusive would be helpful for public under-
standing. This meeting could be conveniently scheduled at the end of
Phase I.
C. Partial sanitary surveys conducted during Phase 2 of needs documen-
tation offer an excellent opportunity to gain public input provided
surveyors are adequately informed about the project or can refer
difficult questions to a knowledgeable person for immediate re-
sponse.
D. The final public hearing required by 40 CFR 35.917-5 should be sche-
duled at the end of facilities planning. At this public hearing a
map showing service areas for grantee supervised decentralized
technologies will be displayed. Within service areas, tentatively
proposed methods of treatment and disposal for individual developed
lots will be available to the lot owners. It should made clear to
the public that site investigations conducted in Steps 2 or 3 may
result in adjustments to the proposed treatment and disposal methods
for individual lots.
B-12
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APPENDIX C
COMMUNITY MANAGEMENT AND RECOVERY OF LOCAL COSTS
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COMMUNITY MANAGEMENT
"Community management" refers to the management of small waste flows systems by a
centralized authority. These may include on-site systems, small cluster systems
with subsurface disposal and other small-scale technologies. They can be managed
by a wide variety of public or private entities or a combination of these entities.
Public entities may include state, regional, or local agencies and nonprofit
organizations; private entities may include private homeowner associations and
private contractors.
In this chapter, the term "management agency" refers to the authority responsible
for managing the systems. A management agency need not be an autonomous agency
with the single purpose of managing these systems. It may in fact be charged with
other duties sharing systems management responsibility through agreements with
other agencies. The term "management program" in this chapter refers to the broad
range of services needed to ensure the proper design, installation, and operation
and maintenance of the small waste flows systems.
A. THE NEED'FOR MANAGEMENT
1. PAST AND PRESENT MANAGEMENT PRACTICES
As discussed in Section I.C.I., governmental concern with the use of on-site sys-
tems has increased in response to perceived and actual inadequacies of early sys-
tems. Host governmental authorities now regulate the installation of new systems
and can require upgrading and replacement of failing on-site systems. Few authori-
ties, however, have accepted supervisory responsibility for operation and main-
tenance of on-site systems.
The value of small waste flows systems as a long-term rather than short-term alter-
native to centralized collection treatment began to be recognized in the 1970*s.
As a result, communities preparing facilities plans after September 30, 1978, were
required to provide an analysis of the use of innovative and alternative wastewater
processes and techniques that could solve a community's wastewater needs (PRM 78-9,
U.S. EPA, 1978a). Included as alternative processes are individual and other
on-site treatment systems with subsurface disposal units (drainfields).
The 1977 Clean Water Act amendments recognized the need for continuing supervision
of the operation and maintenance of on-site systems. U.S. EPA Construction Grant
Regulations (U.S. EPA, 1978a; U.S. EPA, 1979b), which implement that act, require
that before a construction grant for private wastewater systems may be made, the
applicant must meet a number of requirements, including:
o certifying that a public body will be responsible for the proper installation,
operation, and maintenance of the funded systems;
o establishing a comprehensive program for regulation and inspection of on-site
systems that will include periodic testing of existing potable water wells and,
where a substantial number of on-site systems exists, more extensive monitoring
of aquifers; and
o obtaining assurance of unlimite-l access to each individual system at all rea-
sonable times for inspection, monitoring, construction, maintenance operation,
rehabilitation, and replacement.
PRM 79-8 extends these requirements to grants for publicly owned systems.
C-l
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2. COMMUNITIY OBLIGATIONS FOR MANAGEMENT OF PRIVATE WASTEWATER SYSTEMS
Communities have obligations to protect public health and water resources from the
adverse impacts of malfunctioning private wastewater systems. Depending on the
type and frequency of malfunctions, community obligations may outweigh individuals'
rights to constant privacy and absolute possession of private property.
In the most severe cases, the community may require abandonment of privately owned
systems. The economic feasibility of most sanitary district expansion is based on
their statutory authority to require property owners to abandon existing on-site
systems and hookup to new sewers. Under existing state and local law this can
often be done even without demonstrating need.
For less severe cases, central community management is a way to minimize this
intrusion, avoiding, higher costs, landscaping damage, and abandonment of poten-
tially satisfactory facilities. The degree of central management needed is a
reflection of the problem itself, and the interference with privacy and property is
no greater than that required for public health by actual conditions.
Where the public health and water quality impacts of existing on-site systems are
acceptable under present management practices, no changes should be necessary in
management or in individuals' privacy or property. This is in stark contrast to
sewering, where all systems in a given area must connect, whether or not they are
working well.
EIS II-C-D Proper assessment of system problems (both type and severity) is the key to deter-
mining community obligations while minimizing or eliminating intrusion. Overesti-
mation of systems' adverse impacts may lead to overregulation, increased community
costs and reduced community support for management programs. Underestimation of
the problems or necessary management may perpetuate problems to the detriment of
the entire community.
EIS 1-6-1 The previous chapter discussed ways to measure the impacts of existing on-site
systems. On-site system density, failure rate, and the vulnerability of the
affected water resources can all affect the level of management needed. When
houses are far apart, the probability of a system malfunction harming other resi-
dents may be too low. for community concern. However, when houses are closer
together, the potential for public health and groundwater impacts is greater. At
high densities, even with no apparent system malfunctions, impacts on groundwater
quality by nitrates and other chemical constituents may be of concern to the com-
munity.
The significance of failures relates directly to density. Among denser popula-
tions, the potential for adverse impacts is greater. Even where the failure rate
is low, densely developed communities have an interest in aggressively preventing
future failures. Failures occurring in sparsely settled areas may pose only a
marginal threat to the common good. Some individual failures such as plumbing
backups are of interest to the general public since disease contracted by one
individual can spread to affect many.
Water resources vulnerable to on-site systems include recreational lakes, water
supply reservoirs, groundwater aquifers, and other water bodies. The vulnerability
of these water resources and their usage by the public will determine threats to
the community posed by on-site system problems. Where a eutrophic lake is re-
ceiving a small amount of nutrient input from on-site systems, the community obli-
gation to abate the input may be absent. However, when a lake is oligotrophic or
is used as a water supply, the community may have to recognize a greater obliga-
tion.
Community involvement with existing on-site systems should be limited to assessment
of water quality and public health impacts, requiring remedial action where un-
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acceptable impacts exist and implementing management programs to deal with future
impacts. Community obligations associated with future wastewater systems should be
to regulate their design, installation, and operation and maintenance, in order to
limit their potential to affect public health and the environment.
B. SIX COMMUNITY MANAGEMENT MODELS
The following six models reflect increasing levels of community obligation for the
management of private wastewater systems. When community obligation is low, com-
munity management may be limited to initial installation. Increasing community
obligations may require management of all phases of system life, including instal-
lation, operation and maintenance, failure, renovation and, ultimately^ abandon-
ment. Abandonment represents the maximum intervention that a community may take in
managing individual systems and should only be taken when community obligations for
protecting public health and water resources cannot be satisfied in any other way.
1. STATUS QUO ALTERNATIVE
Where community obligation for the regulation of private systems is low because of
a low density of systems, lack of problems with the existing systems, and/or lack
of sensitive water resources, a community management program may be minimal. Such
a program is usually limited to management agency approval of permits, inspection
of system installations, and investigation of complaints concerning failures of
on-site systems. Management programs such as this are currently in general use
throughout Region V.
Under this approach, the homeowner is completely liable for system operation and
maintenance, including necessary system repairs. The management agency does not
conduct routine inspections to monitor system performance, finance system repairs,
consider the use of off-site treatment, or permit the use of experimental on-site
designs.
This approach is normally adequate for rural land areas where scattered devel-
opment, farms, and large tract subdivisions predominate. Construction Grants
funding eligibility, however, requires both identified community need and a higher
level of community management than this alternative offers.
2. OWNER VOLUNTEER
Certain communities may have limited areas of high density, high failure rates, or
sensitive water resources, which may raise community obligations for the private
systems. In addition to the management program outlined under the status quo
model, the community management agency may survey the likely impact areas to
identify specific problems. Homeowners would be notified of necessary repairs for
their systems, and the community management agency may offer technical and possibly
financial assistance to facilitate the repairs.
If a significant enough problem area is identified, the homeowners could receive
Construction Grants funds for repair of their systems. The community management
agency could apply for and distribute the funds to homeowners whose systems qualify
for assistance.
The homeowner would retain both responsibility for system operation and maintenance
and liability-for system repair. The community management agency's role would be
limited to education and technical assistance. For Construction Grant recipients,
the community management agency must also insure proper operation and maintenance
of the systems. At a minimum this could be accomplished by homeowners, periodi-
cally providing proof that the system is being properly maintained (that is, by
providing pumping records) or by direct inspection and monitoring by the management
agency.
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3. UNIVERSAL COMMUNITY MANAGEMENT
As system density, failure rate, and sensitivity of water resources increase,
community obligations for managing private systems shift from voluntary owner
participation to universal community management. Under this approach, all
wastewater facilities ;in a community or section of a community would be in-
cluded in a management program. Wastewater facilities may include on-site
-systems, cluster systems, other small-scale facilities, or combinations of
these small waste flows technologies. Cluster systems and other off-site
facilities would only be utilized where difficulties ia the use of on-site
alternatives require the community to explore all feasible solutions to
meeting the community wastewater needs.
The community management agency would assume all of the management responsi-
bilities common to the preceding two models. The management agency would also
conduct well water sampling and appropriate monitoring of water resources
impacted by the wastewater systems. Depending on the type of wastewater
facilities utilized, the level of risk assumed by the management agency, and
other factors, the management agency could assume responsibility for per-
forming system operation and maintenance and liability for system repairs.
The community management agency could apply for and distribute Construction
Grants funds to property owners for repair of qualified private systems if the
owners retain liability. Alternatively, the agency could contract directly
with installation firms and recover the local share of the construction costs
from owners immediately or as part of periodic user charges. In any case,
owners would be assessed periodic fees to cover the costs of management ser-
vices actually provided.
4. COMBINED MANAGEMENT APPROACHES
Sections of a given community may have different wastewater and management
needs based on system density, failure rate, and sensitivity of water re-
sources. Centralized wastewater facilities may be in place or required in
certain areas, and small waste flows systems may be appropriate for other
areas. Owing to varying levels of community obligations, both voluntary and
universal management zones may also be present. A management agency should
develop specific approaches for each section of the community based on both
the projected types of wastewater facilities and community obligations for
regulating the private systems. By so doing, the agency can ensure that the
program meets each given area's needs.
A .possible objection to this approach is the diversity of skills that may be
needed. However, there may be sufficient overlap in skills so that agency
staff can be maintained at a reasonable number. For instance, sewage treat-
ment plant operators may be able to inspect and repair on-site dosing pump and
STEP units. Laboratory personnel can collect and analyze groundwater and
surface water samples as well as treatment plant effluent samples. The com-
munity may group property owners by type of wastewater system and achieve
economies of scale in providing services that would not be achieved by private
contractors providing services to owners individually.
Under a multizone management approach, homeowners would be responsible for
paying annual fees to support the management services received. Responsi-
bility for operation and maintenance and liability for system failure may vary
within each zone.
5. COMPREHENSIVE WATER QUALITY MANAGEMENT
Where the sensitivity of water resources is the paramount concern, prevention
and control of water pollution need not be restricted to wastewater facili-
ties. The management program in these communities would consist of universal
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community management of the wastewater facilities and be expanded to identify and
control other sources of water pollution. Additional management agency responsibi-
lities may include pollution control assessment and control activities such as:
o non-point source monitoring,
o non-point source control,
o education of residents and visitors about individual pollution control prac-
tices, costs, and benefits,
o inventory of the biological resources of the lake and its tributaries,
o research into the chemical, hydrological and biological dynamics of the lake,
and
o coordination with other local, state, and Federal agencies on pollution control
activities and funding.
Communities with such a high interest in the control of water pollution are also
likely to assume direct responsibility for system operation and maintenance and
liability for correcting system failures.
C. DESIGN OF SMALL WASTE FLOWS MANAGEMENT PROGRAMS
TRD VI-H The process by which a community develops a management program involves six major
steps:
1. inventorying factors affecting the design process,
2. making decisions on system ownership and liability,
3. identifying services to be provided,
4. determining how selected services will be performed,
5. determining who will be responsible for providing services, and
6. implementing the management program.
Each is discussed in the following sections.
1. INVENTORYING FACTORS AFFECTING THE DESIGN PROCESS
Communities face many choices in designing a management program. The factors
influencing the community decisions are of two types. "First-order factors" need
to be identified and considered before program design decisions are made. They are
existing or projected community characteristics. First-order factors include:
o types of wastewater facilities utilized and proposed,
o expertise available to the community,
o size of the community or management district and number of systems in use,
o available regulatory authority,
o community jurisdictional setting,
o community attitudes toward growth, and
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o community attitudes toward public management of private wastewater facilities.
"Second-order factors" are potential consequences of program design decisions.
These factors include:
o costs, including initial costs and economic impact of failures,
o environmental impacts, especially impacts on water resources, and
o level of risk assumed by various parties.
The ultimate success of a management program will be measured by these second-order
factors.
Most of these factors will directly or indirectly affect decisions for the remain-
ing program design steps.
2. MAKING DECISIONS ON SYSTEM OWNERSHIP AND LIABILITY
TRD VI-B Wastewater facilities may be owned by the individual user by a community management
agency, or by a private organization. User ownership of facilities generally is
limited to those located upon his or her property. For off-site systems that serve
more than one homeowner, community or private organization ownership is most
likely.
Liability involves acceptance of the responsibility for consequences of facility
failure. Assumption of liability may involve making necessary repairs and,
possibly, paying damages to parties injured by facility failure. Historically,
communities have accepted all liability for the failure of centralized collection
and treatment systems, with the exception of house connections and plumbing block-
ages. The liability for individual system failures has traditionally remained with
the system owner. With improved management of decentralized systems, there may be
advantages to reassignment of the liability for system failure. The assignment of
liability to either individuals or a public agency is a matter of choice for the
community and its residents.
A community may assign ownership and liability separately for the wastewater sys-
tems. For instance, a management agency may agree to replace, upgrade, or repair
privately owned small waste flows facilities that malfunction after Construction
Grants projects are completed. In return for accepting this liability, the agency
EIS III-I requires that owners pay a reserve fund charge along with other user charges. The
reserve fund charge is, in essence, comparable to an insurance premium.
A possible objection to management agencies assuming liability for future malfunc-
tions is that the economic incentive for owners to use their systems judiciously is
removed. This possibility will be weighed against the impacts of prolonged
failures should owners not be financially able to make repairs quickly. A resolu-
EIS III-E tion of this trade-off may be agency assumption of liability on condition that use
variances are issued and complied with or that user charges are based on metered
water use with rapidly increasing rates above a predetermined limit.
3. IDENTIFYING SERVICES TO BE PROVIDED
TRD VI-A The range of services that a management agency could perform in managing small
waste flows systems varies greatly within the limitation of state guidelines. For
Construction Grants grantees, Federal guidelines may also influence local discre-
tion. Services chosen should be those needed to fulfill community obligations
without superfluous regulation, authorities, manpower, or investments. Although a
few services are essential to all management programs, many are optional, and their
incorporation into a management program is left to community discretion.
Table III-C-1 lists administrative, technical and planning services that a com-
munity might select.
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TABLE III-C-1. POTENTIAL MANAGEMENT PROGRAM SERVICES
Administrative
o
o
o
o
o
o
o
o
o
o
o
o
Technical
o
o
o
o
o
o
o
o
o
Planning
o
o
Staffing-
Financial
Permits
Bonding
Certification programs
Service contract supervision
Accept for public management privately installed facilities
Interagency coordination
Training programs
Public education
Enforcement
Property/access acquisition
System design
Plan review
Soils investigations
System installation
Routine inspection and maintenance
Septage collection and disposal
Pilot studies
Flow reduction program
Water quality monitoring
Land use planning
Sewer and water planning
4. DETERMINING HOW SELECTED SERVICES WILL BE PERFORMED
It is an artificial distinction to separate selection of services from the defini-
tion of how they should be performed and the designation of parties and persons to
perform them. In practice, these three design steps will be taken in sequence, and
perhaps repeated, each step directly influencing the others.
Taken by itself, this step defines specific practices by which the services will be
provided. For instance, for water quality monitoring, the decision must be made
whether to include non-point source and surface water monitoring. Then the ground-
water monitoring plan, and other monitoring as decided, must be designed. This
EIS III-I step would also develop the user charge system acd make decisions on financing the
local share. For plan review services, specific policies oa experimental or innova-
tive systems may be established or existing standards and procedures may be con-
firmed.
5. DETERMINING WHO WILL BE RESPONSIBLE FOR PROVIDING SERVICES
Generally there are three groups who could provide the services selected and de-
tailed in the two prior steps:
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o the public management agency (includes assistance from regional and state organi-
zations) ,
o property owners or occupants, and
o private organizations such as contractors, consultants, development companies,
private utilities, and private community associations.
Some communities may control services by providing them directly, but others may
provide those services that only the designated regulatory body can provide (as
permit issuance and enforcement), supervising the services assigned to owners or
TKD VI-C private organizations. Assignment of service responsibilities should account for
the skills and regulatory authority needed to successfully provide the service as
well as the costs for different parties to provide them and the risks attendant on
poor performance.
EIS IV-A-3 The public management agency need not be a new or single-purpose organization.
Personnel with appropriate expertise may already be available in agencies with
necessary authority to provide public management services. A combination of inter-
agency agreements, supplemental training of existing personnel and new hires will
be an adequate basis for agency development in many communities. Other communities
may, for various administrative or legal reasons, find it more suitable to estab-
lish a new operating agency.
6. IMPLEMENTING THE MANAGEMENT PROGRAM
The last step in the design process is implementation of the management program.
The specifics of this step will vary widely depending on decisions made ?« *t--e
design process. Examples of'implementation procedures are:
o drafting and adopting county or municipal ordinances establishing the agency or
providing it with needed authorities,
EIS III-I o hiring new personnel,
o notifying potential contractors and consultants of performance criteria and
contract requirements for operating within the management district,
o drafting and adopting interagency agreements,
EIS III-D o creating a sanitary review board, and
IV-F o informing property owners about their responsibilities for specific services.
D. PUBLIC INVOLVEMENT IN AGENCY DESIGN AND OPERATION
Public attitudes toward community growth and public management of private waste-
water facilities must be considered in agency design decisions.
EIS IV-C-2 The use of small waste flows systems in some settings will directly impact
community growth. Unlike centralized systems, small waste flows systems do not
provide impetus for growth. While this may be desirable in many rural areas, other
areas seek the growth facilitated by centralized sewers for economic and other
reasons.
EIS VI-B On the other hand, the use of alternative small waste flows systems facilities may
permit the development of land formerly considered undevelopable. This may lead to
scattered rural development and/or the development of enviromentally sensitive
property, which may be contrary to public desires. Such development may be con-
trolled by effective land use planning if the problem is recognized.
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Community understanding of public management of private wastewater facilities will
be limited in many rural areas. Where community management is desirable, the
public must be educated about its benefits if the program is to be successful.
The public will be directly involved in agency design and operation when individual
homeowners are affected by'management agency policy and decisions. Homeowners may
be required to perform necessary maintenance, to repair, replace, and upgrade
failed systems and to pay user fees to the management agency. These requirements
may meet with considerable opposition unless an effective public education program
is initiated to inform homeowners about their role in the community management pro-
grams. Homeowners should be notified and kept informed of their responsibilities
and obligations to the management agency.
EIS IV-F To involve the public more directly in agency design and operation, a Sanitary
Review Board of community residents could be established. The board would ensure
that the management agency's technical and economic decisions are consistent with
citizen interests. The powers and duties of the board could be structured to
reflect citizen interest. The board might maintain autonomous control over manage-
ment agency decisions and personnel, or it could serve as an advisory body to the
agency. Where the board is given autonomous authority, it may be desirable for the
administrator of the management agency to be a member of the board to ensure that
technical matters are properly understood and considered. The board could also act
as an appeals body to hear and decide on objections to agency decisions. This
function is similar to that performed by zoning and other boards.
E. USE OF VARIANCES
OT) VII-A-B Variances are granted where practical or physical constraints prohibit literal
compliance with the regulations. All states in Region V currently allow construc-
tion variances for the new construction of on-site systems where conditions prevent
conformity to code. Variances may also be granted for existing systems.
In any small waste flows district with existing on-site systems, many systems may
not conform to current regulatory standards for site conditions, system design, or
distances from wells or surface waters. Some systems can be upgraded easily and
inexpensively to conform with current codes. In many situations, however, up-
grading may be unfeasible or impracticable because of site limitations and/or
costs. From an economic viewpoint, it would clearly be desirable to continue to
utilize a system for its full, useful life, as measured by absence of adverse
public health or water quality impacts rather than by conformity to code.
Many study results have indicated the viability of existing on-site systems, in-
cluding those which may not be in conformance with existing code requirements.
Data developed during the study of alternative waste treatment systems for the
Seven Rural Lake Projects indicated that many nonconforming systems operate satis-
factorily and cause no adverse impacts. In these seven studies, although up to 90%
of the systems were nonconforming, failure rates represented by system backups,
surface ponding, elevated well nitrate levels and well coliform levels, combined,
ranged from a low of 8% to a high of 27%. Many of the problems identified were the
result of poor system maintenance and could be corrected with minimal cost and
TRD II-D effort. Chemical analysis was also performed on effluent plumes entering the lakes
from groundwater. This indicated that even when drainfields or dry wells were
actually in groundwater, water quality standards were met at adjacent shorelines in
nearly all cases. Bacteriological and nutrient levels at the shorelines were
comparable to those found in the center of the lake. The studies indicated that
the natural assimilative capacity of soil/groundwater/surface water systems is
greater than had previously been expected, and that actual public health and water
quality problems caused by on-site systems were not as extensive as nonconformity
with sanitary codes might indicate.
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1. CONSTRUCTION VARIANCES
TRD XV-A Region V states currently allow variances for new construction of on-site systems
where either practical or physical constraints make literal compliance with the
regulations infeasible'. Presumably, such variances could also be granted where
upgrading is necessary;'for existing systems. This type of variance may be con-
sidered as a construction variance since it allows construction which is noncon-
.forming to the regulations.
Generally, existing nonconfonning systems are considered "grandfathered" systems
and they are permitted to operate until problems arise.. Correction is then
normally required to bring the systems into confonnance, if possible. If not,
construction variances may be required.
2. USAGE VARIANCES
In most cases, existing nonconforraing systems are not inspected. The governing
body may have little or no knowledge of system design or construction and takes no
liability for the system's performance. Difficulties arise, however, when non-
conforming systems are inspected during a sanitary survey. The governing body then
becomes cognizant of the nonconforming systems, and their liability for system
performance may change. For example, if the governing body allows continued use of
nonconforming systems with no structural changes, a court may rule, upon subsequent
system failure, that the governing body was negligent in not requiring these sys-
tems to be upgraded, since the government was cognizant of the systems' noncon-
formity. The inspection and the lack of required upgrading may be considered
tantamount to permitting the systems.
EIS III-C-2 To prevent this type of liability problem, a second type of variance, termed a
"usage variance," may be granted. Usage variances are granted to those systems
considered to have additional useful life, and which are not now causing, and
generally have a slight potential for causing; public health or water quality
problems. By issuing a usage variance, the governing body is legally recognizing
that a nonconforming system exists. At the same time, the governing body notifies
the system owner of the system's nonconformity, of his or her liability in case of
system failure, and of maintenance and flow reduction measures that may be re-
quired. This process results in a clear record between the governing body, system
owner, and other interested parties concerning the continued use of the system and
liability in case of system failure. Provided that the governing body has the
power to grant such variances and that the justification for each variance has been
documented, the governing body would be-within its discretion in deciding to grant
such variances, and not liable .for legal action in the case of system failure.
3. ISSUING VARIANCES
Construction or usage variances may be conditional, requiring periodic monitoring
of system performance and renewal of the variances based upon satisfactory system
performance. Conditions could also limit building occupancy or require the use of
flow reduction devices.
Decisions to grant variances should be made on a well-documented, case-by-case
basis. Construction variances should be restricted to those situations where
compliance with regulations is impracticable or unfeasible and where, based on data
concerning similar systems, soil conditions, and other information, the proposed
construction can be reasonably expected to perform adequately and cause no adverse
impacts. Usage variances should be limited to situations where site-specific
performance data can be obtained concerning existing system performance.
TRD VII-B The variances granted should directly relate to the financial resources and staff
expertise available to the governing body. Where financial resources allow per-
formance monitoring and employment of experienced personnel to minimize errors, the
governing body may be more liberal in the types of variances allowed. Sufficient
financial resources to correct future failures where variances have been granted
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for high risk sites would also be desirable. Where financial resources and experi-
enced staff will be limited, more conservative variance guidelines may be con-
sidered. Although costs may be incurred when corrections must be made to systems
previously granted variances, they are expected to be substantially less than the
• costs of making unnecessary system repairs for code conformance or of totally
abandoning useful systems when no variances are allowed.
The use of variance procedures may alter a community's decisions in designing its
management agency. When variances are utilized, the management agency accepts a
higher risk of system failure in order to achieve a lower overall cost to the
community by allowing continued use of existing systems. When it accepts this
higher level of risk, the management agency may also elect to assume liability for
system repairs. Assumption of liability, in turn, affects decisions on user charge
systems.
F. ACCESS CONSIDERATIONS
TRD VIII-E U.S. EPA Construction Grants regulations (U.S. EPA, 1978a) implementing the 1977
Clean Water Act require in Section 35.918-l(h) that communities seeking funds for
individual systems must "obtain assurance (such as an easement or covenant running
with the land), before Step 2 grant award, of unlimited access to each individual
system at all reasonable times for such purposes as inspection, monitoring, con-
struction, maintenance, operation, rehabilitation, and replacement." PRM 79-8 also
applies this to publicly owned on-site treatment systems, or their equivalent.
Access is also a consideration during facilities planning surveys and detailed site
analysis.
When the individual systems are on private property, the community must obtain the
legal authority to enter such property. The three ways that a community can le-
gally gain access to property for inspection of an individual wastewater system
are:
1. by gaining the permission of the property owners,
2. by the acquisition of deeded rights, and
3. by a statutory grant of authority from the state legislation.
Each of these alternatives will be individually discussed.
1. BY OWNER'S PERMISSION
The easiest way to gain access to private property for purposes of inspection is
with the owner's permission. This can be oral or written. There are several
problems with this approach if a community requires guaranteed and long-term
access. Bare permission by the owner can always be revoked. Moreover, when the
property changes hands, the permission granted by the previous owner is of no legal
standing. In some instances, the property owners may be difficult to locate, and a
minority of property owners can be expected to refuse to grant permission under any
circumstances. For these reasons, a community eventually may need more binding
legal authority to eater property. Owner's permission will usually suffice for
community surveys during facilities planning, however.
2. ACQUISITION OF DEEDED RIGHTS
The acquisition of deeded rights may involve the community in obtaining easements,
easements in gross, or outright ownership of the individual wastewater systems.
Easements confer a legal right, formally conveyed by deed or other witnessed and
notarized writing and 'filed with land records, which conveys to one property owner
the right to use the land of an adjacent property owner for a specified purpose.
As applied to individual wastewater systems with no physical connection to agency-
owned property, such a conventional easement may not be possible. The right to
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enter the property of another, unrelated to the ownership of adjoining land, is
sometimes called an easement in gross. However, easements in gross are sometimes
held to expire upon a change of land ownership.
Property law relating to easements is highly formal, technical, and specific to a
given state. Communities needing to acquire easements should consult first with
local property attorneys and state or county agencies.
3. STATUTORY GRANTS OF AUTHORITY
In general, there are three types of statutes that confer rights of entry on muni-
cipal officials in connection with wastewater treatment systems:
1. statutes to abate or prevent nuisances,
2. statutes requiring licenses or permits, and
3. statutes establishing special wastewater management districts for small waste
flows systems.
. Statutes that confer the right to enter and inspect private property are commonly
based on the community's right to prevent and abate nuisances. Since individual
wastewater systems are traditionally considered to be nuisances per se when so
constructed or maintained as to threaten or injure the health of others, communi-
ties can regulate and take actions necessary to assure compliance with their re-
quirements for the construction and maintenance of private wastewater systems.
Statutes requiring licenses or permits can be utilized to require owners to obtain
renewable permits for the continued use of their wastewater system. With such
requirements courts often imply, if they do not state expressly, that entry and
inspection are necessary prerequisites for the renewal of the permits.
Statutes granting communities the right to form on-site wastewater management
districts have also granted communities access rights once the management district
is formed. To minimize problems arising with utilization of such blanket
authority, the degree of intrusiveness of any inspection program should be mini-
mized consistent with maintaining the effectiveness of the district. Public educa-
tion should be part of any inspection program, and homeowners should be notified
prior to inspection.
Under the U.S. EPA Facility Requirements Division Memorandum of July 8, 1980,
access by statutory grants is considered equivalent to public ownership or easement
in satisfying requirements of 40 CFR 35.918-l(h). Some state statues granting this
access limit it only to certain classes of municipalities..
G- IMPLEMENTING WATER CONSERVATION PROGRAMS
TRD VIII-D Rural unsewered areas may be supplied with water by individual wells or by a com-
munity distribution system. Homeowners supplied by public systems often use more
water than those with individual systems. The chances for hydraulically over-
loading on-site wastewater systems is subsequently greater for those served by a
public water system. Methods for implementing water conservation programs in these
areas include:
i
o rate structure changes (increases in price),
o use restrictions,
o changes in plumbing codes,
o public education, and
o community subsidized distribution of flow reduction devices.
For rural areas served by individual wells, pricing schemes, use restrictions, and
legal limits on amount of water used are not. usually feasible. Water conservation
programs for unsewered areas with individual water supplies must therefore rely on
1) changes in plumbing codes, 2) public educition, 3) community subsidized water
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conservation devices, or 4) on-site system permits requiring the installation of
flow reduction devices. Combinations of these methods should be considered when
planning a water conservation program.
Plumbing codes can require that plumbing fixtures used for new construction and
retrofit applications be of the low-flow type. This method would gradually result
in most residences using water conservation devices. While gradual replacement
will achieve 20-year design goals with centralized wastewater facilities, more
rapid methods for implementing water conservation programs may be needed to achieve
water quality and public health goals with small waste flows facilities. Public
education can focus on the following economic benefits of flow reduction:
o reduced well water pumping,
o reduced water treatment (where treatment is necessary),
o reduced energy costs for heating water, and
o prolonged life of on-site wastewater treatment system.
Public education should be used in conjunction with other methods of implementing
water conservation programs to achieve the maximum benefit of each method.
Communities can subsidize the purchase and installation of flow reduction devices.
This practice provides homeowners with a readily available means to conserve water
and fosters good public relations at the same time. Distribution and installation
of water reduction devices should be followed up to determine public acceptance and
utility of the devices in saving water. Follow-up studies can determine the best
devices for future distribution. Another method includes a requirement in the
permit issued for on-site treatment systems stating that flow reduction devices
will be installed. Such restrictions could be written into permits for new systems
as well as those for upgrading or replacing failed systems.
H. MONITORING GROUNPWATER AND SURFACE WATER
TRD VIII-C The success of pollution control programs cannot be taken for granted. There are
many causes of unsatisfactory performance for any facility. Generally, the more
complex the program or the greater the number of facilities, the greater the pro-
bability of failure. Early, thorough consideration of the causes of failure may
prevent many potential failures. However, failures may still occur. Depending on
the value of impacted resources, long-term monitoring may be necessary to comple-
ment structural elements of a selected pollution control program. Croundwater and
surface water monitoring approaches are discussed below as they would be applied in
small waste flows management.
1. GROUNDWATER
Nearly all on-site and many small-scale wastewater technologies discharge effluents
to the soil. Except in rare instances, the treated effluents then enter ground-
water. Effluent impacts on receiving groundwaters and the resulting impairment of
the groundwater's potential use are not easily predicted. Consequently, both
facilities planning and long-term operational success depend on sample collection
and laboratory analysis.
EIS II-D-6 Groundwater sampling programs for facilities planning are discussed in Chapters
II.D.6 and IV.D.I. Information developed for planning will help define the need
IV-D-1 for and methods of long-term grouadwater monitoring.
Three types of groundwater monitoring strategies may be needed: potable well
sampling, aquifer sampling, and shallow groundwater sampling.
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a. Potable Well Sampling
Most dwellings served by on-site systems in Region V also have on-site well water
supplies. These wells are usually the point closest to on-site wastewater systems
at which groundwater quality is a concern. Requirements for monitoring potable
water wells are stated>in 40 CFR 35.918-l(i) and PRM 79-8. PRM 79-8 states that a
comprehensive program for regulation and inspection of Federally funded publicly
.and privately owned small waste flows systems shall also include, at a minimum,
testing of selected existing potable water wells on an annual basis.
This policy allows the selection of wells tested each year on a case-by-case basis.
The following suggestions may be useful in developing local monitoring programs.
o On-site wells within 50 feet of drain fields, within 100 feet and down gradient
from drain fields in unconfined aquifers, or penetrating unconfined fractured or
channeled aquifers could be sampled annually.
o Sand point wells and other shallow wells down gradient from drain fields could
be sampled every 2 to 5 years or when the on-site system is inspected every 3
years.
o Wells not at risk need not be monitored. Examples are properly located wells
cased and grouted down to a known, continuous confining layer; wells known to be
substantially upgradient from wastewater disposal systems; and wells that have
tested satisfactorily over extended periods of time.
o Private wells serving more than one dwelling could be sampled as suggested for
on-site wells except where water withdrawal may be sufficient to alter natural
groundwater flow patterns. These could be sampled annually unless a hydro-
geologist demonstrates why more or less frequent sampling is appropriate.
o Public water supplies should be sampled as required by state regulatory
agencies.
At a minimum, sample analysis should include nitrate-nitrogen and fecal colifona
bacteria. Where improperly protected wells (wells with inadequate seals, casing,
or grouting) must be sampled, analysis is also recommended for non-naturally
occurring constituents of domestic wastewater, such as brighteners or surfactants.
This analysis will help determine the source of contamination.
When samples are positive for bacteria or show unexpectedly high nitrate concen-
trations, provisions should be made for confirmatory sampling within a short time.
b. Aquifer Sampling
Sampling of aquifers will be necessary in addition to potable well sampling when
large numbers of on-site systems are present in a groundwater shed or when waste-
water from multiple dwellings or dwelling unit equivalents is land disposed at a
single site.
Accumulations of nitrates in an aquifer down gradient from on-site systems are
unlikely to affect public health unless a number of systems are lined up in the
direction of groundwater flow. While the boundaries of groundwater sheds and flow
vectors within them are difficult to delineate, it is safe to assume that single or
double tiers of development will not result in hazardous accumulations of nitrates.
Therefore, strip developments along roads or lakeshores should seldom be causes for
aquifer monitoring. On-site well monitoring will suffice. For more intensive
development, the need for and design of aquifer monitoring programs should be
determined on a case-by-case basis by qualified kydrogeologists.
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Monitoring programs for cluster systems, rapid infiltration, or slow rate land
TRD II-K application should be developed in concert with detailed design of the system
III-B itself. Hydrogeologic studies conducted for site evaluation and system design will
provide information required for development of the monitoring program. A minimum
system size above which aquifer monitoring should be required is not recommended
here. State regulatory agencies are encouraged to address this topic.
c. Shallow Groundwater Sampling
On-site systems along stream banks and lake shores and larger land disposal systems
located further away may contribute pathogenic organisms and phosphorus by effluent
transport in groundwater. Although unacceptable discharges of this type should
have been discovered and remedied during the Construction Grants process or similar
work, continued surveillance of suspect systems may be advisable. The need for and
design of a shallow groundwater monitoring program should be based on results of
prior sampling, uses of the impacted surface waters, possible temporal changes in
the discharges, results of septic leachate scans, and requests for this service
from property owners.
2. SURFACE WATERS
Two types of surface water monitoring may be advisable in rural communities that
rely on the optimum operation approach: effluent surveys and non-point source
monitoring.
a. Effluent Surveys
EIS II-D-l-c In lake communities, periodic septic leachate surveys would identify future ground-
water failures of on-site systems and improve understanding of factors influencing
effluent plume movement. As with septic leachate surveys conducted in Step 1, a
capability for collecting, storing, and analyzing selected samples is desirable.
Because the state of the art in leachate detection is still developing, and'because
of uncertainties regarding presently available instrumentation, shoreline septic
leachate surveys will not be required at this time in monitoring programs. Pur-
chase of currently available instrumentation will be eligible for Construction
Grants funding until superior equipment is developed. Grantees will be required to
show that comparable instruments are not available on a timely basis from other
nearby grantees. Funded instruments will be made available to other grantees.
Where leachates from cluster systems, rapid infiltration systems, or slow rate land
application systems are expected to emerge in streams or lakes, monitoring of the
leachate may be required depending on proximity of the systems to surface waters,
use of the surface waters, and results of aquifer monitoring. Appropriate moni-
toring methods should be specified during detailed design of the systems. The need
to implement some monitoring programs may be conditional on results of aquifer
monitoring.
b. Non-point Source Monitoring
Grantees will not be required to monitor non-point sources of pollution. However,
Construction Grants-funded laboratory facilities may be used for sample analysis.
In comparing the cost-effectiveness of constructing a local laboratory with joint
use of other municipal laboratories, or contracting with private laboratories, the
projected number and type of samples can include those generated by a non-point
source monitoring program that the grantee implements prior to or concurrent with
Step 3 of Construction Grants activities.
015
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I. RECOVERY OF LOCAL COSTS
1. DEFINITIONS
TRD VIII-B The local costs of a project will generally be allocated to users of the system.
The local costs consist of private capital costs, public capital costs (local share
of capital), interest on public debt, operations and maintenance, aad the reserve
fund. With the exception of private costs, communities have a great deal of flexi-
bility in determining how local costs are allocated and recovered.
Private capital costs will be borne directly by the users. That is, the users will
contract for or purchase items related to the project. Examples of private cost
items include house sewers, necessary plumbing modifications, and flow reduction
devices. The payment of these costs is agreed upon by the user and contractor or
supplier. Communities are not involved in the payment and recovery of private
capital costs.
The community is involved directly, however, in the recovery of public capital
costs, interest on debt, operation and maintenance costs, and reserve fund costs.
These costs are usually recovered through a user charge system. U.S. EPA PRM 76-3
requires that the facilities plan include the estimated monthly charge for opera-
tion and maintenance, the estimated monthly debt service charge, the estimated
connection charge, and the total monthly charge to a typical residential customer.
The stated purpose for this is to encourage the consideration of least costly
alternatives and the possible use of public and private facilities. A user charge
system must be developed by the community and approved by U.S. EPA during Step 3,
at the latest, of the Construction Grants Program.
Capital costs need not be part of an approved user charge system. Instead, users
may be required to pay capital costs at the beginning of the project. However,
most communities do include capital costs in their user charge systems. For cen-
tralized facilities and cluster systems, capital costs can be recovered from both
present and future owners. Public capital costs for on-site systems are recovered
from present users only. Future users of on-site systems will not be subsidized,
and all their capital costs will be private costs in the absence of a local govern-
ment subsidy.
Operation and maintenance costs, if the project receives grant funds, must be
allocated on the basis of each user's proportionate use of the system. For optimum
operation alternatives, proportionate use can be measured by type of user (for
example, residential), duration of use (seasonal, permanent), flow, or type of
technology. Users may also be billed directly for specific services provided by
the management agency. In the case of some on-site technologies, some operation
and maintenance costs may be paid by users directly to private contractors such as
septic tank pumpers and haulers.
A reserve fund is not required but is encouraged by U.S. EPA. The reserve fund can
provide for replacement of equipment and future expansion of centralized facili-
ties. For on-site systems, the reserve fund can replace systems that may fail ia
the future. The reserve fund reflects the liability a community is willing to
assume for each type of system used. If the community assumes no liability for
future failures of wastewater systems, a reserve fund is not necessary. Payments
into the reserve fund generally are low when the failure rate for systems is low.
Greater payments are required for a relatively high failure rate. Reserve fund
charges can be levied from different user groups at varying rates.
2. USER CHARGE STRUCTURES
The local public costs can be allocated by user charges in a variety of ways at the
discretion of the local government. Three major ways of allocating local public
costs are averaging the costs among all users in the project's service area, estab-
lishing user groups, (that is, charging on the basis of criteria such as flow,
C-16
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mediate in cost,
3. BASIS FOR SELECTION
technology used, or location), and charging each user the specific costs of faci-
lities and services provided by the community. The method of allocating costs
chosen by the community may be based on considerations such as the costs of imple-
menting the user charge system, the number and locations of residents benefitting
from the project, the extent to which a mix of technologies is used, and the consi-
deration of equity and efficiency.
The cost of implementing the user charge system may be high yet still politically
feasible if all users are charged by the community for the specific costs they
impose on the community. A sophisticated bookkeeping system would be required to
allocate specific capital, operation and maintenance, and reserve funds for each
user; such a system may exceed the administrative capacity of the local government.
Averaging all costs among all users would be the least expensive and time-consuming
method of allocating costs. A system based on user groups would probably be inter-
mi9»rf*f at*» -in <~ncit-
The beneficiaries of the project are the initial consideration in the design of a
user charge system. In addition to owners receiving direct assistance in the
improvment, replacement or operation of their on-site systems, beneficiaries may
include:
o residents and non-residents who use the water resources being protected,
o where off-site facilities are constructed, land owners who could not previously
build but are thus enabled to,
o businessmen whose revenues depend on the attractions of the water resources
being protected, and
o property owners do not require assistance at present but for whom the avail-
ability of assistance is a benefit,
o property owners who would otherwise be required to pay the price of sewers but
who can retain properly operating on-site systems under an optimum operation
alternative.
If such benefits are well distributed among users, the case for averaging all local
costs is good. However, the range of technologies that may be used, the often
localized or spotty problems for which improvements are necessary, and the possi-
bility of use restrictions can be expected to present a more complex benefit dis-
tribution. A useful exercise for grantees, once the water quality problems are
defined and appropriate technologies selected, would be to identify classes of
beneficiaries.
Allocating costs to classes of users is most reasonable when a mix of technologies
is used. Costs may vary significantly according to the type of technology used.
Users with low-cost systems might be reluctant to subsidize users with high-cost
technologies. Charging by user class requires the community to spend more time and
effort for bookkeeping than it would to average costs among all users. However,
the user group method would be less difficult and expensive than the individual
user/specific cost method.
The final consideration in choosing a way to allocate costs involves the issues of
equity and efficency. Equity in this case refers to charging users in proportion
to the costs they impose on the management system. For the optimum operation
alternative, the most equitable user charge system is the individual user/specific
cost nethod. For instance, residents with conventional septic tank/soil absorption
systems on large, well-drained lots would have very low costs. They may be charged
only for septic tank pumping and drainfield inspection once every three years.
Residents with dosed systems or residents served by cluster systems may have to pay
larger charges and more frequently. Residents using holding tanks could have
routine and quite substantial costs.
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4. CONSEQUENCES AND TRADE-OFFS
User charge systems can affect the efficiency of the wastewater management system.
Charges that encourage users to abuse their wastewater facilities are inefficient.
Charges that promote efficiency, however, may not be equitable. Consider owners of
holding tanks: if they have to pay the full cost of pumping their wastes, they may
occasionally dispose of the wastes themselves in a manner hazardous to themselves
or their neighbors. However, it is not equitable for the management agency to
provide free pumping service for them and to average the cost to all other users.
Clearly in this case, equity and efficiency in a user charge must be balanced.
Charging substantial fees for water use that will not economically threaten the
holding tank owners may encourage vigo'rous conservation and may prevent owners from
endangering ethers with unsanitary practices. A partial subsidy may otherwise
benefit the community by making holding tanks a feasible option so that everyone
does not have to contribute to buying a sewer.
J. BROADER RESPONSIBILITIES OF PUBLIC AGENCIES RELATED TO RURAL WASTEWATSR
MANAGEMENT
Public agencies managing small waste flows systems may already possess or may
assume responsibilities in addition to those related to wastewater management.
Assumption of multiple responsibilities may be particularly attractive in small
communities with few paid personnel. In such communities, the small waste flows
systems alone may not justify full-time positions, making multiple responsibilities
more efficient. Examples of broader responsibilities that may be assumed by a
wastewater management agency are discussed below.
EIS III-C-1-5
TRD VI-A
VIII-A
EIS IV-C-2
EIS III-H-1
TRD X-D
EIS IV-A-3
TRD VIII-B
TRD II-C
XII-G
EIS III-H-2-b
K. PERSONNEL
TRD VI-D
Many rural communities lack any form of land use planning, the only land use
restrictions relating to the suitability of a given site for on-site wastewater
disposal. These restrictions may be altered through approval of innovative on-site
systems or adoption of performance-based design standards by a management agency.
If this occurs, the community may desire to develop appropriate land use
designations. The management agency could be designed to provide this service.
The use of private water systems is predominant in rural communities. In addition
to ensuring adequate wastewater disposal, the management agency could ensure safe
and adequate water supply. The agency can accomplish this by routinely inspecting
and monitoring individual wells and/or community water supplies and by providing
public education related to water supply management. The periodic inspection and
monitoring of individual wells by a management agency is already mandated by
Construction Grants Regulations Section 35.918-l(i) for grants involving individual
systems.
Section 201(f) of the Clean Water Act of 1977 states that the administrator shall
encourage waste treatment management that combines open space and recreational
considerations with such management. A community management agency could coor-
dinate the use of wastewater management district properties for recreational use,
such as the use of a community drainfield for picnic or park land. The management
agency could also manage recreational facilities not part of the management
district.
In communities with particularly sensitive water resources, the management agency
could investigate and monitor sources of pollution unrelated to the wastewater
facilities. In many rural areas, the management agency may be the only public body
involved in pollution control; therefore, assumption of broader responsibilities in
this area could be of great community benefit.
A broad range of skills and expertise may be required by the management agency-
Typical job titles that may be involved in some aspect of wastewater management
include:
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o system designer, o small waste flows contractor,
0 clerk, o laboratory technician,
o administrator, o water resource scientist,
o inspector, o soil scientist,
o attorney, o laborer,
o equipment operator, o environmental planner, and
o plumber, o wastewater system operator.
Although the list of job classifications is long, one person could provide a number
of the skills. It is not necessary to employ one person to fill each position.
Customary job titles such as engineer and sanitarian are not listed as such, in
order to define more clearly the types of personnel needed and to avoid limiting
personnel to these disciplines. Sanitarians and engineers could, however, fill
many of the job classifications.
The task of defining and fulfilling management agency personnel needs requires five
steps:
1. assess skills and skill levels required by the management agency,
2. estimate the level of effort required by skill,
3. inventory available personnel and define their skill levels,
4. select personnel to meet management agency needs and acquire their services
through interagency agreements, hiring, or contracts, and
TRD VI-F 5. seek training programs to fill any remaining gaps in expertise required by the
management agency.
A community planning a management program should consider hiring key personnel
early in the process. These personnel, such as an administrator experienced with
small waste flows technologies, would be invaluable in assisting the community in
the design process, then later administering operation, maintenance and repair
services.
The search for personnel who may assist the management agency should not be limited
TRD XV-C to the local area. All sources of potential assistance should be evaluated, in-
cluding state, regional and other municipal personnel, U.S. Soil Conservation
EIS V-B-2 Service personnel, utility company workers, private contractors, and consultants.
State and regional agencies can provide many types of assistance, including:
o direct technical assistance,
o assistance to local communities in grant application and administration,
o preparation of community wastewater needs analysis,
o identifying the local feasibility of small waste flows technology and manage-
ment,
o review and upgrading of local and state regulations,
o dissemination of information on small waste flows technology and management, and
C-19
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o preparation of manpower inventories for local small waste flows programs.
In many rural communities, economies of scale in management may be realized by
sharing personnel with other communities, or by a regional agency furnishing
assistance on a shared .time basis.
The community management agency should ensure that private contractors and consul-
tants hired to perform management agency services are experienced in the utiliza-
tion and management of small waste 'flows systems. Without experienced assistance,
the community may not fully realize the benefits of the optimum operation approach.
L. REVISING THE MANAGEMENT PROGRAM
After the management program has been implemented, documentation of the performance
of the program as a whole and of each of its component parts is important to long-
term success and economy. Periodic review of this information, and evaluation and
revision of the management program, should be an ongoing process.
The initial implementation of a management program in a community cannot be ex-
pected to result in an ideal program. This is particularly true since community
management of small waste flows systems as broadly defined in this EIS will be a
totally new management approach for many communities. As the program is imple-
mented, unforeseen problems with the system are likely to develop. Certain seem-
ingly prudent management practices may appear otherwise in. actual operation.
The agency should encourage feedback on its management program by soliciting and
being receptive to community and public comments on the program. The agency should
develop minimum requirements for periodic evaluation of the successes and.problems
in the management program and of necessary revisions to the program to make it
operate more effectively.
Provisions for revision of the management program should be flexible enough to
allow constructive improvement in the program without altering the community's
original commitment to the management of the small waste flows systems. Where this
commitment is questioned, the community's original analysis of the need for a
management program may have been wrong. If Construction Grants funds have been
received for the individual systems, continuity in the management program must be
assured by the community or by state or regional agencies.
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APPENDIX D
SAMPLE EASEMENT FORM
-------
SEWER EASEMENT AMD RIGHT OF WAY
(I)(WE)
of
respectively, in consideration of the prospective benefits to be derived from
a new or upgraded sewer and/or improved water quality in Crystal Lake, do
hereby convey and release to the an ease-
ment and right of way for unlimited access to the present or future on-site
sewer system or other systems of sewage disposal, at all reasonable times for
such purposes as inspection, monitoring, construction, maintenance, operation,
rehabilitation, and replacement, over, upon and across lands owned by (me)(us)
and situated in the Township of , County of Benzie, State
of Michigan, and more particularly described as follows:
In witness, whereof, I have hereto set my hand this
day of , 19 .
WITNESSES:
STATE OF ) ss.
)
COUNTY OF )
Subscribed and sworn to before me this day of , 19 .
Notary Public
My commission expires:
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APPENDIX E
EIS ALTERNATIVES
-------
EIS ALTERNATIVES
A. APPROACH
The preceding chapter described options for the functional compon-
ents of wastewater management systems for the communities in the Study
Area. This chapter examines alternative wastewater management plans for
the Study Area, including a No Action Alternative.
The Proposed Action developed in the Facilities Plan (described
earlier) provided for centralized collection and treatment of waste-
water. In response to questions about the expense of the Proposed
Action, the development of EIS Alternatives emphasized decentralized and
alternative or innovative technologies, alternative collection systems,
decentralized treatment, and land disposal of wastewaters. The EIS
Alternatives would manage wastewaters in the same service area as the
Facilities Plan Proposed Action, but the EIS Alternatives use decentral-
ized collection and treatment to avoid some of the costs of sewers.
Because of the high cost of collection in the Proposed Action, the
cost-effectiveness of pressure sewers, vacuum sewers, and small-diameter
gravity sewers were compared. Of these, pressure sewers were the most
cost-effective. Similarly, the use of a septic tank effluent pumping
(STEP) system was analyzed as an alternative to grinder pumps. Assuming
35% of the septic tanks would be replaced, the STEP system was computed
to be more cost-effective and was used in the EIS Alternatives. This
selection should be reviewed during the preparation of detailed designs.
Analysis of decentralized treatment technologies and site condi-
tions showed feasible alternatives to sewering the entire Study Area.
It would be possible to combine multi-family filter fields (cluster
systems) with rehabilitated and new on-site treatment systems to meet
the wastewater treatment needs in parts of the Study Area. Addi-
tionally, on-site upgrading of existing treatment systems is examined,
which includes abandoning privies in flood-prone areas and replacing
them with vault toilets, composting toilets, or other technologies.
. Appendix 1-1 presents the assumptions used in design and costing of
the alternatives. Section IV.B lists the major features of the Proposed
Action and of the EIS Alternatives,
B. ALTERNATIVES
The Facilities Plan Proposed Action has been compared with the No
Action Alternative and eight new approaches developed in this EIS.
Table IV-1 summarizes these alternatives.
1. NO ACTION
The No Action Alternative implies that EPA would not provide funds
to Support new construction, upgrading, or expansion of existing waste-
E-l
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Table IV-l
ALTERNATIVES — SUMMARY OF MAJOR COMPONENTS
Alternative
Facilities
Plan Pro-
posed Art I on
Centralized Treatment
Aerated l.jgocn nerving
entire Proposed Service
Area
Treatment Plant
Siting
Northwest Township
Section 24
Effluent Disposal
Discharge to Nettle
Creek
On-lot and Cluster Systems
Ho
Alternative Collection Method
No
I'lS Aurnti'J Inj'.non serving Northwest Township
Alternative I Sot>im-itts 1,3.4,5,7 and 8 Section 24
E1S AciMLi'd lagoon serving Northwest Township
Alcerii.ttlve 2 Segments 1,],4,5;7 anil 8 Section 24
EIS Ac-raced lagoon serving Northwest Township
Alternative 3 Scp,n:encs 1,3,4,5,7 and 8 Section 24
E1S Aerated lagooft serving Northwest Township
Alternative 4 Segments 1,3,4,5,7 and 8 Section 24
K\S Stabilization Pond/land
/ItcrnntIvv 5 appl lent(on system
serving Segments
1 ,],
-------
water collection and treatment systems. Any changes or improvements of
malfunctioning systems would be at the initiative and expense of either
the property owner or local government.
2. FACILITIES PLAN PROPOSED ACTION
The facilities Plan recommended construction of a regional collec-
tion system and centralized treatment. The collection system would
comprise a combination of gravity sewers with lift stations and force
mains.
The Facilities Plan proposed treatment of 0.14 mgd of wastewater by
aerated lagoons, with discharge to Nettle Creek. Figure IV-1 is a
representation of the proposed treatment process. The proposed layout
for this alternative is illustrated in Figure IV-2.
3. EIS ALTERNATIVE 1
EIS Alternative 1 is similar to the Facilities Plan Proposed
Action. 'Segments 1, 3, 4, 5, 7, and 8 would be sewered as in the Faci-
lities Plan Proposed Action (see Figure IV-3). Similarly, wastewater
would be treated in an aerated lagoon and discharged to Nettle Creek.
However, Segment 2 would be served by cluster systems, while Segment 6
would remain with the existing on-site ST/SAS systems, since soils in
this segment are suitable for on-lot treatment. The design flow for the
aerated lagoon would be reduced to 0.09 mgd. This alternative is de-
picted in Figure IV-4.
4. EIS ALTERNATIVE 2
EIS Alternative 2 differs from EIS Alternative 1 only in the type
of discharge provided after centralized collection and treatment. In
this alternative, treated wastewater from the aerated lagoon would be
discharged to nearby wetlands, thus reducing the length of the outfall
line. Figure IV-5 depicts this alternative.
5. EIS ALTERNATIVE 3
EIS Alternative 3 employs pressure sewers instead of gravity sewers
wherever suitable. Septic tank effluent pumping (STEP) was selected
over grinder pumps on the basis of cost-effectiveness. This alternative
was intended to investigate whether the different methods of collection
would reduce costs; in a few parts of the Service Area, notably Segment
1, gravity sewers were retained. This was because gravity sewers could
be more cost-effective than pressure sewers in this higher density area.
As in EIS Alternative 1, 0.09 mgd of wastewater would be conveyed
to an aerated lagoon for treatment and discharge to Nettle Creek. EIS
Alternative 3 is illustrated in Figure IV-6.
-------
M
I
RAW
WASTE
WATER
PRELIMI-
NARY
TREAT-
MENT
i frb
AERATED
LAOOON
-i ., ,, ftfr-
CHLORINATION
DISCHARGE TO
NETTLE CREEK
FIGURE IV-1
FACILITIES PLAN PROPOSED ACTION
TREATMENT PROCESSES
-------
TO AERATION
LAGOON THEN
TO NETTLE
CREEK
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
FEET
200O
FIGURE IV-2 NETTLE LAKE: FACILITIES PLAN PROPOSED ACTION
E-5
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LEGEND
LAZY ACRES SOUTH
LAKEVIEW/EUREKA BEACH
SHADY SHORE
LAZY ACRES NORTH.
ROANZA BEACH
CRESTWOOD
CAMP DI CLAIRE
SHADY SHORE CAMP
FEET
2000
FIGURE IV-3 NETTLE LAKE: SEGMENTED SUBDIVISIONS IN THE PROPOSED
SERVICE AREA
E-6
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TO AERATION
LAGOON THEN
TO NETTLE
..CREEK
m
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
SAS CLUSTER
ST/SAS
FEET
20OO
FIGURE IV-4 NETTLE LAKE: EIS ALTERNATIVE 1
E-7
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TO AERATION
LAGOON THEN
TO WETLANDS
DISCHARGE.
LEGEND
B PUMP STATION
— GRAVITY SEWER
-- FORCE MAIN
• SAS CLUSTER
-W^f&l ST/SAS
FEET
200O
FIGURE IV-5 NETTLE LAKE: EIS ALTERNATIVE 2
E-8
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LTD AERATION;
AGQON THEN
TO NETTLE
CREEK
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
PRESSURE SEWER
SAS CLUSTER
ST/SAS
FEET
2000
FIGURE IV-6 METTLE LAKE: EIS ALTERNATIVE 3
E-9
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6. EIS ALTERNATIVE 4
EIS Alternative 4 would employ the STEP system of pressure collec-
tion, with on-site ST/SAS treatment in Segment 6 and two cluster systems
in Segment 2. The difference,between this and the previous alternative
is that, in this alternative treated wastewater would be discharged to
wetland^ instead of directly to Nettle Creek. This alternative would
employ pressure sewers instead of gravity sewers. Figure IV-7 depicts
this alternative.
7. EIS ALTERNATIVE 5
EIS Alternative 5 investigated land application as an alternative
method of treatment. The only soils near Nettle take suitable for land
treatment are located southwest of the lake and their characteristics
dictate the type of land application that would be appropriate. Since
the two basic soils are Spinks sand and Ottokee sand, both of which have
a permeability greater than 6 inches per hour, rapid infiltration was
selected. Pretreatment for the 0.09 ragd of flow would include prelimi-
nary treatment, a stabilization pond, and chlorination. Recovery wells
would collect renovated effluent and would discharge to Nettle Creek.
As in previous alternatives, Segment 6 would employ on-site systems
and Segment 2, cluster systems. Wastewater would be collected by a
combination of gravity sewers and lift stations with force mains. The
treatment process is illustrated in Figure IV-8 and the alternative in
Figure IV-9.
8. EIS ALTERNATIVE 6
EIS Alternative 6 would provide service to residences in Segment 2
by two cluster systems with drainfields located west of the segment.
Cluster systems are examined as a solution in Segment 2 because soils
within the residential developments are indicated as being unsuitable
for absorption systems, while suitable soils exist within short
distances to the west of the developments. All other segments would be
served by upgraded on-site ST/SAS systems. In this alternative, all
privies would be abandoned, backfilled, and indoor plumbing would be
installed. This alternative is illustrated in Figure IV-10.
9. EIS ALTERNATIVE 7
EIS Alternative 7 is based upon on-site disposal for all resi-
dences. No central collection or treatment would be provided. A small
waste flows agency would be responsible for maintaining, repairing,
and/or replacing on-site systems as appropriate.
In Segments 1-5, holding tanks would replace the existing privies.
A water supply would be installed, bathrooms constructed, and maximum
water-saving devices would be installed in these residences, reducing
consumption to 13.4 gpcd. For on-site ST/SAS systems in these segments,
it is assumed that 35% of the septic tanks and 20% of the drainfields
would require replacement. Half of these drainfields would be replaced
by sand mounds and half by dual drainfields. The latter would" consist
E-10
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I TO AERATED
LAGOON
I THEN TO
WETLANDS
DISCHARGE
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
PRESSURE SEWER
SAS CLUSTER
ST/SAS
FEET
200O
FIGURE IV-7 NETTLE LAKE: EIS ALTERNATIVE 4
E-ll
-------
RAW
WASTE ^
WATER
i
M
10
PRELIMI-
NARY
TREAT-
MENT
STABILI-
ZATION
POND
\
\
V
STORAGE
LAGOON
i
1
1.
CHLORINATION
1
RAPID
NFILT
RATIOI
BASINS
1
RECOVERY
^ fl RECEIVIN
,/ STREAM
WELLS
FIGURE IV-8 EIS ALTERNATIVE 5 TREATMENT PROCESSES
-------
FROM RAPID
INFILTRATION
SITE TO
NETTLE CREEK
TO RAPID
INFILTRATION SITE
LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
SAS CLUSTER
ST/SAS
FEET
20OO
FIGURE IV-9 NETTLE LAKE: EIS ALTERNATIVE 5
E-13
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LEGEND
PUMP STATION
GRAVITY SEWER
FORCE MAIN
SAS CLUSTER
f " | HOLDING TANKS AND
SEPTIC TANKS
WITH MOUNDS OR
SUPER SYSTEMS
ST/SAS
iHllliiHl EXISTING ST/SAS
FEET
200O
FIGURE IV-10 NF1TTLE LAKE: EIS ALTERNATIVE 6
E-1'4
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of two full-sized drainfields and a valving arrangement, permitting one
field to function while the other is inactive.
The large lot sizes and suitable soils permit the existing on-site
systems in Segment 6 to continue in use. As in Segments 1 through 5,
35% of the septic tanks and 20% of the drainfields are assumed to re-
quire replacement. Conventional drainfields would be used to replace
faulty ones in this segment.
In Segments 7 and 8 the existing on-site systems would continue in
use. It is assumed that the only costs associated with these systems
would be those for ordinary operation and maintenance.
In all segments it was assumed that 10% of the septic systems would
require hydrogen peroxide treatment at some time during the planning
period. Figure IV-11 illustrates this alternative. A small waste flows
agency would be responsible for maintaining, repairing and/or replacing
on-site systems as appropriate.
10. EIS ALTERNATIVE 8
EIS Alternative 8 also recommends on-site wastewater treatment for
all residences. In segments 1 through 5 all privies would be replaced
with different technologies. This EIS estimates that 132 privies exist
in the Study Area, and many of them are inundated and washed out
.annually. In order to address this problem, this alternative recommends
abandonment of these privies. The alternative assumes replacement of
privies equally with four different forms of technology selected by the
homeowner in cooperation with the small waste flows district. The
replacement technologies would consist of outdoor vault toilets, air
assisted low flush toilets and a holding tank, chemical toilets, and
electrical composting toilets. All other segments would upgrade on-site
systems as described in Alternative 7.
The small waste flows district would work with the homeowner to
select, install, operate, and maintain the technology appropriate to a
particular site. Figure IV-12 illustrates this alternative. The small
waste flows district would also contract for a septage hauler or would
apply for the eligible 85% funding for purchase of a "honey wagon." A
post summer purapout program would probably be initiated for holding
tanks and vault toilets. Pumpings would continue to be land-spread on
agricultural areas.
C. FLEXIBILITY OF ALTERNATIVES
This section evaluates the flexibility of the Proposed Action and
the EIS Alternatives to accommodate future Service Area growth, along
with their operational flexibility over the design period. It should be
recognized that flexibility for accommodating future growth relies upon
certain conditions that are opposed to the accommodation of planning for
the future. Specifically, flexibility for future expansion implies a
commitment to provide growth and its associated infrastructure. Retain-
ing the flexibility to provide planning for the future implies deferment
of any such commitment. Viewed in this context, the No Action Alterna-
E-15
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LEGEND
] SEGMENTS 1-5: Holding
and septic tanks
with mounds or dual
drainfields
| SEGMENTS 6: Septic tanks
with soil absorption
systems (ST/SAS)
SEGMENTS 7,8: Existing
ST/SAS
FEET
2000
FIGURE IV-11 NETTLE LAKE: EIS ALTERNATIVE 7
E-16
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LEGEND
SEGMENTS 1-5: Privy
replacement and septic
tanks with mounds or
dual drainfields
SEGMENTS 6: Septic tanks
with soil absorption
systems (ST/SAS)
SEGMENTS 7,8: Existing
ST/SAS
FEET
2000
FIGURE IV-12 NETTLE LAKE: EIS ALTERNATIVE 8
E-17
-------
tive offers the greatest flexibility for planning for the future and the
least flexibility for fu'-re growth. Conversely, the Facility Plan
Proposed Action offers the least flexibility for planning for the future
and the greatest flexibility for future growth. ,
1. NO ACTION
By maintaining the status quo, the No-Action Alternative provides
the greatest flexibility in planning for the future. Conversely, the
flexibility for accommodating future growth is minimal because no action
would be taken that would permit progress in that direction.
2. FACILITIES PLAN PROPOSED ACTION
This alternative offers good flexibility for growth; as long as
land is available, aerated lagoons can be expanded to accommodate in-
creased flows relatively easily. Flexibility for future growth is,
however, reduced somewhat because the entire Proposed Service Area is
sewered. Greater flexibility for future expansion is usually available
with alternatives that require a smaller initial commitment of re-
sources .
3. EIS ALTERNATIVE 1
Because of the similarity between Alternative 1 and the Facilities
Plan Proposed Action, this alternative similarly offers high flexibility
in accommodating future growth by employing cluster systems in Segment
2. By retaining septic systems in Segment 6, less growth is possible
than would be expected with the Facilities Plan Proposed Action. To
this extent, the flexibility in planning for the future has been in-
creased in Alternative 1 relative to the Facilities Plan Proposed
Action.
4. EIS ALTERNATIVE 2
EIS Alternatives 1 and 2 are essentially identical differing only
in the point of discharge of treated wastewater. Consequently, the
flexibilities of the two alternatives are also quite similar. The
flexibility of EIS Alternative 2 to accommodate future growth is high,
and there is somewhat limited flexibility in planning for the future,
though, like Alternative 1, it is greater than that of the Facilities
Plan Proposed Action. The changed point of discharge is not expected to
appreciably alter these flexibilities.
5. EIS ALTERNATIVE 3
Because EIS Alternative 3 is similar to Alternative 1, differing
only in the type of collection system, the flexibilities of the two
alternatives are also similar. Ability of the alternative to accom-
modate future growth depends more upon the layout of the collection
system than upon the type of collection. Since the layouts of the two
alternatives are virtually identical, the flexibilities of each are
comparable.
E-18
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6. EIS ALTERNATIVE 4
Since the only difference between Alternative 4 and Alternative 3
lies in the point of discharge of treated wastewater, there is no appre-
ciable difference in the flexibilities of the two alternatives.
7. EIS ALTERNATIVE 5
EIS Alternative 5 differs from Alternatives 1 to 4 and the Faci-
lities Plan Proposed Action in the method of wastewater treatment.
Where the previous alternatives proposed aerated lagoons for treatment,
EIS Alternative 5 would employ rapid infiltration and recovery wells.
The use of land application for treatment provides somewhat greater
flexibility to accommodate future growth than aerated lagoons. This is
because it is easier to expand the capacity of a land treatment facility
than to expand an aerated lagoon. Consequently, if pressures for addi-
tional growth develop, a land treatment facility can be more easily
expanded to meet the pressure. Conversely, this decreases the flexi-
bility to plan for the future. This alternative's flexibility for
growth, while higher than those of EIS Alternatives 1 to 4, is lower
than that of the Facilities Plan Proposed Action because of the decen-
tralized systems that would serve Segments 2 and 6 in Alternative 5.
Its flexibility for future planning is higher only than the Facilities
Plan Proposed Action.
8. EIS ALTERNATIVE 6
Because of the similarity between Alternative 6 and Alternatives 7
and 8, this alternative offers high flexibility in planning for the
future. By providing cluster systems in Segment 2, the flexibility to
accommodate future growth is somewhat greater than for Alternatives 7
and 8.
9. EIS ALTERNATIVES 7 and 8
Alternatives 7 and 8 offer the most decentralized approach of all
wastewater management plans evaluated in this EIS and thus the most
flexibility for future planning. Lacking centralized collection and
treatment facilities for present and future residents, they are the
least flexible of all alternatives in terms of accommodating future
growth.
D. COSTS OF ALTERNATIVES
*•
Project costs were grouped by capital expenses, operating and
maintenance expenses, and salvage values of the equipment for each
alternative. A contingency fund amounting to 25% of capital and 20% of
salvage value was included to provide for such expenses as engineering
and legal fees, acquisition of rights-of-way, and administration. The
assumptions used in the analyses are described in Appendix 1-1. De-
tailed costs for each alternative are presented in Appendix 1-2.
Table IV-2 summarizes present and future project costs for each of
the alternatives. The analyses of total present worth and annual equiv-
E-19
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Table IV-2
COST-EFFECTIVE ANALYSIS OF ALTERNATIVES
FACILITIES PLAN
PROPOSED ACTION EIS 1 EIS 2
bd
1
Present Project Cost
(x$l,000) 1,976.6
Future Project Constuctlon Costa
(x$l,000/yr) 2.2
Total Present Worth
(x$l.OOO) 1,842.5
Average Annu.il Equivalent Cost
(x$ 1.000) 16B.8
1,885.7 1,885.2
3.7 3.7
1,904.9 1.896.3
174.5 173.7
EIS 4
EIS 5 EIS 6 EIS 7 EIS 8
2,121.2 2,120.7 2,308.0 1,287.3 1,059.2 557.1
5.5 5.5 3.7 4.3 3.2 3.2
2.339.9 2,331.3 2,334.3 1.599.7 1.394.3 796.5
214.3 213.5 213.8 146.5 127.7. - 73.0
O
-------
alent costs of each alternative are also included. (Debt service of
financing the local share is not included.) A discussion of Federal and
state cost-sharing and remaining local costs is presented in Section
V.E. •
E. RESOURCES NEEDED TO OPERATE AND MAINTAIN WASTEWATER
FACILITIES (By Alternative)
The operation and maintenance (O&M) costs cover the costs of labor,
electricity, fuel, chemicals, and materials needed to run wastewater
facilities proposed by the alternatives. To enable direct comparison of
resources needed to run these facilities, the annual labor, energy, and
chemical/material/supply requirements of each alternative have been
estimated and are shown in Table IV-3.
The labor required to operate and maintain the sewers and the
sewage treatment plant proposed by the Facilities Plan appears to be
less than the labor required for alternative facilities. However, note
that the labor estimates for the Alternatives 7 and 8 and Alternative 6
are conservatively high because they are based in part on the assumption
that 5 hours per system will be spent to monitor septic systems and to
pump septic tanks (once per tank per 4 years). Also, note that use of
flow reduction devices lowers the labor required to operate the Facili-
ties Plan Proposed Action facilities.
The energy required to collect and to treat area wastewater is less
for Alternatives 7 and 8 and Alternatives 5 and 6 than for remaining
alternatives. The Alternatives 6, 7, and 8 rely on extensive use of
on-site wastewater systems, which generally require less energy to
operate than centralized treatment facilities. (Note, however, that the
energy requirements shown for these alternatives do not include energy
required to haul septage and holding tank wastes to a disposal site.)
Similarly, Alternative 5 proposes use of rapid infiltration treatment, a
process that requires less energy than the aerated lagoon process pro-
posed by remaining alternatives. As was the case with labor, use of
flow reduction devices lowers energy required to operate the Facilities
Plan Proposed Action facilities.
Finally, although costs of chemicals, materials, and other supplies
appear to be higher for Alternatives 5, 6, 7, and 8 than for remaining
alternatives, the costs given for Alternatives 6, 7, and 8 are almost
certainly overstated. These alternative costs are for chemicals,
materials, and supplies needed to treat holding tank wastes at a treat-
ment plant (probably the Montpelier municipal plant), yet these costs
are higher than costs shown for treatment of all area wastewater at a
treatment plant. Therefore, these costs should be considered to be
rough estimates only.
E-21
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Table IV-3. Annual Resource Requirements by Alternative
KESOURCE
LABOR
(raanhours/yr.)
ENERGY*
(fcwh/yr.)
CHEMICALS ,
MATERIALS &
SUPPLIES0
($/year)
/vfIPA
FPPA* 123456 7&S U!l2wf
1,991 2,387 2,379 4,403 4,394 2,635 3,461"*" 3,573* 1,660
202,780 141,880 141,880 177,480 177,480 70,079 60,750 69,750 122,862
2,421 1,954 1,954 1,954 1,954 3,037 5,350* 6,600+ 1,757
* Facility Plan Proposed Action
• Not including energy used for pumping and hauling of septage and holding tank wastes,
but including energy used for treatment of these wastes
o Not including materials needed for sewer or pump station maintenance
+ These figures are conservatively stated
E-22
-------
Table IV-4 Estimated Annual User Charges
Alternative
User Charges
Per Household
Facilities Plan Proposed Action
EIS Alternative 1
EIS Alternative 2 —
EIS Alternative 3
EIS Alternative 4
EIS Alternative 5
EIS Alternative 6
EIS Alternative 7
EIS Alternative 8 —
$335
$270
$325
$320
$361
$355
$376
$255
$110
Table IV-5
Alternative
Facilities Plan
Proposed Action
EIS Alternative 1
EIS Alternative 2
EIS Alternative 3
EIS Alternative 4
EIS Alternative 5
EIS Alternative 6
EIS Alternative 7
EIS Alternative 8
Total Local Share of Capital Costs
(1979 Dollars)
Local Share of
Public Costs*
396,271
126,255
344,200
325,110
289,149
270,059
392,717
90,446
83,568
Local Share of
Private Costs**
540,212
349,504
537,504
537,504
537,504
537,504
537,504
291,984
1,320
Total Local
Share
936,483
475,759
881,704
862,614
826,653
807,563
930,221
382,430
84,888
* Includes percentage of costs not covered by the Federal grant (15% - 25%),
operation and maintenance costs, debt financing and a reserve fund charge.
** Includes costs to be paid out-of-pocket by homeowner: gravity sewer house
lateral or cluster system hook-up, indoor bathroom construction and water
saving devices.
E-23
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Table fy».6 Estimated Annual User Charges
Alternative
User Charges
Facilities Plan Proposed Action
EIS Alternative 1
EIS Alternative 2
EIS Alternative 3
EIS Alternative 4
EIS Alternative 5
EIS Alternative 6
EIS Alternative 7
EIS Alternative 8
335
270
325
320
361
355
376
255
110
TABLE IV-7
Total Local Share of Capital Costs
(1979 Dollars)
Alternative
Facilities Plan
Proposed Action
EIS Alternative 1
EIS Alternative 2
EIS Alternative 3
EIS Alternative 4
EIS Alternative 5
EIS Alternative 6
EIS Alternative 7
EIS Alternative 8
(1)
Local Share of
Public Costs
396,271
126,255
344,200
325,110
289,149
270,059
392,717
90,446
83,568
(2)
Local Share of
Private Costs
540,212
349,504
537,504
537,504
537,504
537,504
537,504
291,984
1,320
(3)
Total local
Share
936,483
475,759
881,704
862,614
826,653
807,563
930,221
382,430
84,888
E-24
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APPENDIX F
COMMENT LETTERS
-------
DEL.BEHT L- LATTA
tm OIVTMICT. OHIO
COMMITTEES!
RUIXS
BUDGET
I.
*:.•* •».**»*&' r IW^UJj'fe*
o
ror:
DELBERI L. LATTA
Representative to Congress
JS/bk
-------
f^U--^..- ,-^Sf> <-A>- ^ ^ /? 7//J
^ /> //. i~> .^ft^-M&
.Ci-L.^J<^-^~ ViL.-^\ /
Jo?, AJ,.
••^ /9
-vy^LC-'j <-.c«
^
SwantOQ, Oklo
S«pt. 17, 1981
Gene Wozolk, Oklef E.I.3 Section
Water Division
Dear Sir!
On tk« matter of tke Draft £.1.3. We Hill be unable
to attend tkls meeting of Oot. 2, 1981. Is we bare a
Nepkew getting married Oot. 3, and It IB away.
I can not eee kow tkls will bauflct us. AB we kare
our own leack bed and septic tank. When we put It in
we kad It Inspected and OK and titty are still giving us
good working service.
We do not live at Hettle Lake. Hs are tkelr only In
tke summer montka, and not more then 2 to 3 days a week
and some time not tkat. It la juet my lusband and myself.
wko uses tke cottage.
We are botk retired and live on e fixed Income and tkle
would be a added expense, and a burden to us.
We kave worked kard to get tkls o ittage, and koped
to be able to en^or It, and do a llttl risking in our retire-
ment days wltk out a lot added oapenae wkiok we do not need.
Iklngs suck as tkls makes It kard for s to kave a cottage
and be able to enjoy it.
My Husband is not abl« to do tkit kind of work any more.
So wklle we ware working, and could do tkls kind of work.
we ka4 every tkiug taken care of. So c w we can set back,
and enjoy tke convenience of our cottr ;t. i. drilled well,Leack
bed, and septic tank. So tills 1:3 kow v feel about tke I.I.S
csj
I
-------
for Alternative Waste Water Treatment System for Settle
Lake. Why should we have to pay for some one else, who
realy nead this kind of service?
Slneerelv Tours,
JT.M.f. L.F.F.
Br» L.F.F.
Mr. & Hre. John Faber
>«-H-«-
1850 I'atton Terrace
McLean, Va. 22101
September 2*f, 1981
Ms. Catherine Grlssom Garra, Project Monitor
230 South Dearborn Street
Chicago, Illinois 60604
Dear Ms. Garrat
Having carefully read the impressive Draft Environmental Impact Statement
on alternate Haste treatment systems for Mettle Lake, a rural Ohio lake, X
wish to submit my comments on it.
After considerable thought, it appeared to me that the fundamental issue of
this project is the advisability of rural sewering. This Draft EIS presents an
interesting and concise description of the subject on pp. 10-12. I believe
the SIS would benefit by having this description directly at the beginning.
The reader would then immediately see the larger picture into which the
Nettle lake problem fits. The issues listed as significant issues in the EIS
are, in ray opinion, subsets of this larger issue and should be treated as such
by being discussed second. Growth is one of these offshoot issues. It seems
to mo that the writers of the EIS were unable to conceal their value bias
against growth by using the adjective "induced" with it. (By "induced",
something is less than "tiormal" or "natural".) I personally have this bias
myself but it is not the same bias as that of U. S, policy which generally
hails and encourages growth.
A second general comment concerns the need (as distinguished from want) for
this project. Is it the local people who need it? The sanitary survey re-
sults would not indicate so as only 1^ noted problems. The fact that others
"may have considered these problems too routine to mention" would suggest that
the need is not of grassroots origin. Further, if it were, some brief anec-
CO
-------
dotal material could easily have been included to document it. If it is not
for the local people, is it to preserve the lake? Sanitary snooping and
aerial photography failed to reveal seepage into the lake. Could the "need"
be instead a "want" of politicians to see Federal dollars flow into the area?
From the history beginning on p. 1, one night infer that to be the case.
In any case, the actions proposed seem to be way out of proportion to the
need. (In fact, it seems remarkable that such a huge document as this EIS has
been prepared for such a small problem in a small community.) Estimating from
the data presented, there are perhaps a dozen residences which need alteration
of their wastewater handling. Perhaps such simple ideas as pumping septic
tanks before spring floods or temporarily relocating people during them could
be considered.
This brings me to my third general comment. There seems to be almost a disdain
for the local people. Who are they? One can piece together that they are not
well off, are mostly in manufacturing and that many live in mobile hones and
use privies but that leaves plenty of blanks. How do they cope with the
situation? Do they visit relatives out-of-town when spring rains come? Bo
they want the sewer or any other form of outside intervention? Could they be
contented as they are? The only part of the project that touched base with
local people was the sanitary survey through the thorough well-written ques-
tionnaire in Appendix D. Perhaps the survey could have been educative as well
with questions such as "Do you know what a composting toilet is?", etc. In
that way people could have been thinking about their choices well in advance
of having to decide. Some very good ideas for involving local people are
tucked away nearly at the end of the document (p. 167). These should be ex-
panded.
My fourth general comment is that there is a good selection of alternative
technologies considered and discussed, Including conservation.
My next set of comments regards the document itself more than the problems
it addresses. I would like to see a human element enter more in the intro-
duction. Who are the people? How do they live? What is it like to live on
Nettle lake? My guess is that the drawing on the front cover is not repre-
sentative, or is it? How about a photo or two to set the scene?
Second, I would suggest indentation and/or different size lettering to set off
headings, subheadings, etc. These are difficult to follow when neatly lined
up in a column. I had to refer back to the table of contents constantly.
Third, the graphics are abundant, pleasant, and easy to read with a few ex- I
PM
ceptions. Two critical tables, IV-1, p. 112, and VI-1, p. 160, which summarize
pages and pages of narrative are done in fine print. They should be pullout
pages or printed over several pages. The impact matrix, pp. 153-7, could be
moved to the beginning of the chapter and be followed by a discussion of major
points. Further, I'd suggest that the column "Impact Description" be subdivided
into the 8-10 alternatives so that it would be possible to see at a glance all
the impacts of a. selected alternative. Set up as it is, the table is conducive
to one selecting an impact one is concerned about and checking to see which
alternative would affect it the way one wishes. This could leave one blind to
the other consequences of the alternative. Next, the maps which illustrate
the alternatives are redundant. The differences should be highlighted,by color
if possible. What strikes the reader is how they are the same rather than dif-
ferent.
-------
finally, there is a certain redundance in the document. Perhaps it could be
streamlined a bit.
My third set of comments regards details that could be improved. I will list
and discuss them in order by their page numbers. v
i- a. DEIS is an unnecessary acronym. Draft EIS is short enough and more
meaningful.
b. What is "Step 2"?
vi- Population numbers don't total up correctly.
xil- Impacts could be more concise and clear in a pictorial table.
xviii- "Septic" is inserted an extra time.
2- Include two or three major cities on the map of Ohio to show distance
of Nettle lake from metropolitan areas.
6- It should be spelled out explicitly and together in one place why the
conclusions of the Browne and E?A studies differ.
15- Give the case study numbers. Nettle lake has a #6 on the cover but
it's never referred to again. This detail could help put Mettle Lake
into perspective as part of a larger rural sewering question.
17-'Septic snooper"near the top of the page needs quotation marks and an
asterisk.
18- List the criteria, then discuss them.
21- Where Indian mounds are mentioned, add "See Figure 11-13".
57- The relationship between Northwest Township and the study area isn't
clarified until here, rather late for getting one's bearings.
64- "Communications" is printed extraneously once in the table.
67- Since there's only one industrial/commercial site on the map, specify
what it is.
72- Septic snooping was done in December instead of at spring flooding
when it would have been most likely to pick up something.
89- It's rather late in the document to be defining centralized vs. decen-
tralized.
116- Where is the rationale behind the eight subdivisions selected for all
the alternatives? I could only figure out that 6 was soil suitable
for soiltbsorption systems and that 7 and 8 were the camps but I
couldn't find the basis on which the rest of the study area was cut
up.
137- This graph is very technical. Also, the alternatives seem to be
listed rather than in three positions on the graph.
150- The No Action alternative should definitely be included in these tables.
It might show that even the recommended alternative, #8, is expensive.
162- a. The last item in the list doesn't seen to belong.
b. The statement about throwing conpost in the garbage reveals a lack
of understanding of the purpose of a. composting toilet. Why waste
a waste? You're turning a waste into a resource this way. You'd
pay for composted cow manure so why not use your own free manure?
165- Hear the middle of the page, a comna is needed between "Step 2" and
"the design period",
169, 171, 173- Chapters 7,8, and 9 could comprise one chapter which should
come before, not after, the conclusions. As is, they physically appear
to have no bearing on the conclusions.
Appendices- Several did not copy well.
in
I will close my comments with a short list of spelling errors.
xii- middle- "wasteswaters" for "wastewaters"
xvi- middle- "projecttions" for "projections"
xx- a. middle- "burder" for "burden"
b. near bottom- "seaslonal" for "seasonal"
95- top- "paritloned" for "partitioned"
153- near bottom of matrix in right column- "reducted" for "reduced"
I hope my comments will be useful to you and I hope that Nettle lake and its
residents will be benefitted by the great amount of work which has been ex-
pended for them in preparing this Draft EIS.
Respectively submitted,
Lynn Salvo
-------
United States
I Department of
Agriculture
Soil
Conservation
Service
200 North High Street
Room 522
Columbus, Ohio 43215
September 28, 1981
Mr. Gene Wojcik
Chief, E.I.S. Section
Water Division
Region V, U.S., EPA
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Wojcik:
The draft Environmental Impact Statement for Alternate Waste Treatment
Systems for Rural Lake Projects, Case Study Number 6, Williams County
Commissioners, Nettle Lake Area, Williams County, Ohio, was directed to
the U.S.O.A., Soil Conservation Service, Columbus, Ohio, for review and
comment .
We have reviewed this document and have no major concerns with the
document as submitted.
We appreciate the opportunity to review and comment on this project.
Sincerely ,
Robert R. Shaw
State Conservationist
&
October 14, 1981
Gene Wojcik
Chief, EIS Section
Water Division
U.S. EPA
Region V
230 South Dearborn St.
Chicago, JL 60604
RE: Comments on Nettle Lake, EIS
Mr. Wojcik:
As the director of the Maumee Valley Resource Conservation, Development and
Planning Organization, a multi-county planning organization, serving the
Counties of Defiance, Fulton, Henry, Paul ding, and Williams, I would like
to.comment on the Nettle Lake EIS. Our agency has been actively involved
in 208 planning through a subcontract with the State of Ohio. As a part
of our local 208 Planning Process an On-Lot Sewage Disposal Committee was
formed. The Committee actively studied On-Lot Sewage Disposal problems
and solutions for nearly a year and a half. A major issue of concern to
the Committee was the high cost of provision of centralized treatment system
In order to ' treat problem areas
As a result of this concern the Committee did formulate alternative re-
commednations for dealing with local problem areas. These recommendations
included: 1) The use of alternative and innovative treatment technologies
in order to address pollution control, while limiting construction costs,
and 2) The establishment of a management agency which would inspect and main-
tain individual or group treatment systems.
In conclusion, the recommendation selected for potential application to the
Nettle Lake Area is generally supportive of the recommendations established
by the On-Lot Sewage Disposal Committee. The only concern that arises from
the proposed recommendation is that the operation of an On-Lot district.
-MVRCD&PO
1012 Ralston Avenue
Defiance. Ohio 43512
Phone: (419) 782-4548-
-------
Gene Wojclk
October 14, 1981
Page 2
At the time of our study enabling legislation applying to the establishment
and operation of an On-Lot Sewage Management District did not exist. There-
fore, would you please inform me of any changes with regard to the enabling
legislation in the State of Ohio.
Sincerely,
Dennis Miller
Director
DM/gv
U.S. DEPARTMENT OF TRANSPORTATION
FEDERAL HIGHWAY ADMINISTRATION
REGION 3
I82O9 DIXIE HIGHWAY
HOHEWOOD, ILLINOIS OO43O
October 16, 1981
IN MCIM.Y ftCFKR TOi
HEP-05
Mr. Gene Wojcik, Chief
EIS Section, Water Division
Environmental Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. lilojcik:
The draft EIS for the alternate wastewater treatment system, Nettle
Lake area, Williams County, Ohio has been reviewed with regard to
effects on the adjacent roadways from the proposed alternates. The
alternatives outlined do not appear to have any effect on the
adjacent roadways. We, therefore, have no comments to offer on the
draft EIS.
Sincerely yours,
James A. Walsh
Associate Regional Administrator
for Planning and Program Development
-------
Williams County
Nettle Lake
Seweragp
Mr. Gene Wojclk, Chief October 16, 1981
EIS Section, Water Division
U.S. EPA - Bagion V
230 S. Dearborn Street
Chicago, Illinois 60601
Daar Mr. Wojcik:
In response to the draft EIS for Nettle Lake, we have the following corrments:
1. Comirents 1, 2, 3 & 4 in our letter of September 9, 1980, are still valid.
2. As noted in liable VI-1, Alternative 8 (the selected alternative) has the
lowest reliability. We cannot in good conscience support a solution
which will provide only a short term improvement, the holding tank-pump
out portion of the selected alternative could have our endorsement if:
a. there is County operation,
b. the tanks are put on all residences, and
c. provisions are made to treat the pumped out waste.
-Yours -truly,
Allen L. Rupp, P.E/
Wastewater Sectic
ALR/Jw
cc: Jack Hoogeveen, Public Wastewater Section
cc: Williams County Health Department
Slate ol Ohio Environmental Protection Agency
Northwest District Ottice
1035 Devlac Grove Drive, Bowling Green, Ohio43402 • (419) 352-8461
James A. Rhodes, Governor
Wayne S. Nichols, Director
Re: Nettle Lake
Sewerage
SF: 12
September 9, 1980
U.S. EPA
EIS Section, Environmental
Engineering Branch
230 S. Dearborn
.Chicago, Illinois 60604
Gentlemen:
Subsequent to the July 28, 1980 public meeting on the Nettle Lake EIS,
we have the following comments:
1. We believe that the consultant's surveys were totally inadequate
siiice they were made at times of low occupancy of the summer
homes. We cannot understand why the "septic snooper" was used
in December, the door-to-door survey was made in November and
December, and the aerial "signature" photography study was
flown in May. Obviously, a summer resort in northwest Ohio
would only experience heavy use from Memorial Day to Labor Day.
2. From the information we received, the consultant apparently feels
that the only environmental threat to the people using the lake
is the phosphorous input. It is our opinion that in a lake
where primary body contact is being made, the most important
environmental concern should be with bacterial and viral
contamination of the water. We feel that pathogenic contam-
ination of the near shore areas does exist and the potential
for the spread of waterborne diseases is great. We believe
the people were misled at the public meeting and should have
been more fully advised of the serious public health hazard
that exists.
3. It also appears that the consultant is leaning toward upgrading
existing individual sewage systems as the solution to all
problems. Frankly, this is a non-solution for the following
reasons:
a. Many of the lots around the lake are so small the
replacement of the existing leaching field or construction
of a new one where none existed before would be impossible.
On most lots, the water supply well is, or would be,
too close to the sewage system.
OC
State ol Ohio Environmental Protection Agency
Northwest District Ollico
1035 Dovlac Grove Drive, Bowling Greon, Ohio 43^02 -(419) 352-8461
James A, Rhodes, Governor
James F. McAvoy, Director
-------
U.S. EPA
September 9,
Page two
1980
b. Even if it would be possible to install new on-lot systems
on the small lots, the severe soils would not permit a
prolonged operating life. When second failures begin to
occur, we will probably have to order sewers in the area.
c. Mound systems are also subject to eventual failure over
a period of years and the replacement costs should be included
in the cost of the project. It appears that the mounds are
proposed in the flood plain area where their prolonged
operation is doubtful following a severe flood.
d. The continued use of privies (if they are upgraded) may
keep most of the sewage out of the lake, however, they
do provide breeding places for flys and mosquitos and
therein create additional public health hazards.
4. Inflation has increased so much in the last three years that no matter
what the solution, the local share of the cost will probably be
higher than if the project had proceeded with central sewers in
1977 when the EIS was initiated. Three years for an EIS on this
small area seems to be an exceptionally long time.
5. Alternatives 1 and 7/8 do not appear to provide a plant for treating
holding tank wastes.
In summary, from the information provided, we feel the surveys were improperly
conducted, the serious public health aspects of the problem were ignored,
and alternatives 1 and 7/8 provide only temporary solutions which will
eventually result in a return of pathogens to the lake.
Yours
•oup Chief
[/.• Rupp,
Public Wastewate
ALR:sd
cc: Williams County Health Department
cc: Williams County Commissioners
cc: Representative Larry W. Manahan
United States Department jf the .Interior
OFFICE OF TUB 8ECIIETARY
NORTH CENTRAL KIXilGN
176 WEST JACKSON UOULEVA1U)
CHICAGO. ILLINOrS 60&X
ER-81-180V
October 20, 1981
Mr. Valdas V. Adamkus, Acting Regional Administrator
U.S. Environmental Proteetion Agency
Region 5
230 South Dearborn Street
Chicago, Illinois 60604
Dear Mr. Adamkus:
The Department of Interior has reviewed the Draft Environmental Impact Statement
for Alternative Waste Treatment Systems for Rural Lake Projects, Case Study
No. 6, Nettle Lake Area, Williams County, Ohio.
We believe that adequate treatment of fish and wildlife resources in the project
area has been demonstrated in the document, and the alternative plan recommended
will result in little or no damage to valuable wetlands adjacent to Nettle Lake.
The Draft Environmental Impact Statement does not contain an inventory of min-
eral resources or mention mineral resources as a significant natural resource of
the affected environment. Sand, gravel, and peat are produced in Williams County.
The Environmental Impact Statement should include the above resource informa-
tion. If the impact on in-the-ground mineral resources is considered minimal,
the draft should contain a statement to that effect. Mention should also be made
of construction material committed to the project.
Sincerely yours,
Sheila Minor Huff
Regional Environmental Officer
-------
HOWARD W. SKILES
MAURICE L, BRETTHAUER
WILLIAMS COUNTY
COMMISSIONERS OFFICE
BRYAN, OHIO 43SQ6
October 20, 1981
Mr, Gene Wojcik
EIS Section, Water Division
United States Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, II. 60604
Dear Gene:
Subject:
Comments on Nettle Lake Environmental Impact
Statement (EIS) - SWEE
We are taking this opportunity to comment on the Draft Environmental
Impact Statement (EIS) for the Nettle Lake Area and explain our
position on any further corrective action. Considering that the EIS
did not document a severe water quality problem, that the Williams
County Board of Health presently regulates the onsite systems in the
subject area, and federal grant funding through the Environmental Pro-
tection Agency (EPA) currently is not available, we do not believe that
any additional corrective action should be taken at this time.
The EIS stated that the majority of the existing onsite treatment systems
were operating satisfactorily. It was also documented that flooding
of the leach fields and pit privies of the residences during the spring
floods was contributing to the increased nutrient input to the Lake
revealed that ,the onsite systems were only responsible for 13 percent
or less of the total nutrient load. It is therefore, our contention
that improvement of the existing onsite systems will not significantly
improve the water quality of Nettle Lake and could only impose an
undue financial burden on the existing residences.
The Williams County Board of Health is responsible for investigating
any reported sewage nuisances. Bans on installation permits may be
imposed on any area that is currently unsuitable for installation of
septic tanks with soil absorption fields. This existing management
system may be used to control any future increase in point source
pollutant loads to Nettle Lake and also can be used to correct any
reported sewage nuesances.
Mr. Gene Wojcik
Chicago, II
October 20, 1981
Page 2
An additional concern that was discussed at the public hearing was the
possibility of a myriad of different individual mechanical units being
operated and maintained by a County management system. Such a "solution"
would create management problems by requiring excessive personnel expertise
and spare parts to adequately maintain these many different types of
units.
Following the public, hearing for the EIS/ held on October 2, 1981, we
discussed the current funding status of the Nettle Lake area with Mr.
Jack Hoogeveen, Construction Grants Coordinator with the Ohio Environmental
Protection Agency (OEPA). We understand that the Nettle Lake Project
will not be receiving fiscal year 1981 funding and with a 1981 priority
list sequence number of 100 may not receive a grant in fiscal year 1981.
We do not believe that the residents in the Nettle Lake area would be able
to "handle" the financial burden of the EIS recommended plan without
grant assistance.
Again, due to the above stated reasons, it is our intention to not pursue
any additional corrective action for the existing onsite treatment systems
at Nettle Lake. Please contact us if you need any additional clarification
on our position. Based on these and other comments you have received, we
request that you inform us of the final recommendations you expect to
make in the final EIS before final publication.
Sincerely,
#.
W/tlilAMS COUNTY COMMISSIONERS
WWC/ngk
cc: Floyde Browne Associates, Limited
A. R. Rupp, NWDO/OEPA
Jack Hoogeveen, OEPA
-------
STATE CLEARINGHOUSE
30 EAST BROAD STREET • 39TH FLOOR • COLUMBUS, OHIO 43215 • 614 / 466-7461
81-10-22 P
08
Valdas V. Adamkus, Acting Reg. Administrator
U.S. Environmental Protection Agency
Region V, 230 South Dearborn Street
Chicago, Illinois 60604
RE: Review of Environmental Impact Statement/Assessment
Title: Draft Environmental Impact Statement for Alternative Wastewater
Treatment Systems for the Nettle Lake Area In Williams County, Ohio.
SAI Number: 36-552-0005
Dear Mr. Adamkus:
The State Clearinghouse coordinated the review of the above
referenced environmental impact statement/assessment.
This environmental report was reviewed by all interested State
agencies. Attached is a list of the following species in and along the
shores of Nettle Lake. It is the opinion of the Department of Natural
Resources (DNR) that implementation of the preferred alternative will
not have any significant adverse impacts on the natural resources of the
Nettle Lake area. Please contact Michael Colvin of DNR if you have any
further questions about the above or attached comments.
The Ohio Department of Health (DON), being the state agency having
primacy over domestic onsite systems in Ohio, has serious concerns regarding
various issues raised and comments made in the Nettle Lake EIS. We request
that a third-party review of this EIS be performed by a firm more familiar
with Ohio laws and the actual conditions of the study area. Under the economic
impact measures, wouldn't it be more desirable to pay &Q% more for a technologically
appropriate system rather than a minimal amount for a system that may function no
better than the system that currently exists? Secondly, a code for onsite sewage
disposal existed prior to 1974. The current code Is known as Chapter 3701-29 of
of the Ohio Administrative Code (OAC) which contains Rules 3701-29-01 through
3701-29-21, OAC. A holding tank is not a wastewater treatment system and can not
be included in the code. Also, is there a reason that enforcement of existing
Ohio laws and administrative codes and appropriate land subdivision requirements
can not mitigate environmental hazards? The U.S. EPA should consider the results
of local zoning to prohibit further development 1n the floodplains, the adoption of
more stringent county subdivision regulations and increased enforcement of Ohio
sanitary codes by the local health department. Why can't identified (1f they are)
malfunctioning on-s1te wastewater treatment systems be brought Into compliance,
thus preventing water pollution?
Valdas V. Adamkus, Acting Regional Administrator
October 22, 1981
Page 2
On-site systems improperly located in floodplains represent the same
hazards as the current privies. On page 48, the Draft EIS states: "The Planning
Director must require within flood prone areas new and replacement water supply
systems to be designated to minimize or eliminate infiltration of flood waters.
into the systems." The only acceptable way of satisfying this requirement 1s to
not locate any on-site or soil-dependent sewage treatment systems within a floodplain.
Under Groundwater Contamination on page 78, wouldn't it be wise to sample for nitrates
before ruling out aquafer contamination? Were the residents questioned about illness
and odors from their drinking water? In reviewing the various collection-systems,
was consideration given to the effects of groundwater infiltration? The last three
technologies listed on page 93 of On-lot treatment and disposal, are considered
experimental systems in Ohio and would require special reviews before permitting
their installation.
When we consider that (1) cost-effectiveness was used as a justification for
doing an EIS despite the apparent compliance of the Facilities Plan, (2) the cost
of on-site systems were arrived at without evaluating the Individual lots and (3)
no direct measurable effect has been shown as required to justify federal funding,
we wonder why the No Action alternative wasn't selected. It 1s recommended that
you contact the Ohio Department of Health to answer these and many other questions r-
you may find in the attached comments. "7
Thank you for the opportunity to review this statement/assessment.
Sincerely,
Judith Y. Brachman
Administering Officer
JYB:alf
DNR, M1ke Colvin
EPA, Beth Whitman
DOH, Bob Schutz
-------
STATE CLEAR UICHOUSS ENVIRONMENTAL
IHPACT_STATEi-!ENT COVER SHEET
Floor
te Review Started
turn No Later ThanQjfobu.
SAI Number
Draft XX.
Final
Summary, full copy to follow
ascription
. DLLn
Number of Copies Returned
Environmental Protection Agency
•Attn: Beth Wolfe
D6partment of Natural Resources
Attn: Hike Colvin
Preservation Office
Attn: Bert Drennen
rtaient of Transportation
Attn: Helen Stone
x"
Department of Economic & Coitmunity Dev.
Attn: Bob Freedman
Department of Health
Attn: Bob Schutz
Department of Energy
Attn: Chris Schlemner
Department of Agriculture
Attn: Ed Kirby
Mo comment or further interest
_ Coraents on overleaf
__. Comments attached
Sionature of Reviewer '
OCT 20 1981
iilcarlngiiiiiisa
_
Kane of Reviewer (.Print or Type)
Mf.it S A. hhlUO
Coveino;
JOHN H. ACKRMAN M.O.M.PH.
Director of he.iur>
faa tllfki' «„« 118
Columsw Oi-'o 43216
telephont(6|i!) 455-3543
October 19, 1981
Re: Williams County (Ohio)
Nettle Lake Area
Alternative Wastewater
Treatment Systems
Draft Environmental
Impact Statement
Gene Wojcik, Chief
EIS Section
Water Division
U.S. Environmental
. Protection Agency
Region V (vj
230 South Dearborn Street rH
Chicago, Illinois 60604 I
Dear Mr. Wojcik:
Per Mr. Adankus* letter dated August 28, 1981 which we received on October 5, 1981
regarding the above-referenced project we wish to make those comments which you will
find on the attached pages. These comments should be viewed of paramount importance
to this department.
We are appreciative of the current EPA Construction Grants Program requirements to re-
view all cost effective systems, including onsite systems, as alternatives to conven-
tional sewage collection and treatment systems, where such conventional facilities
may be unreallstically expensive.
Notwithstanding our support of such alternative wastewater treatment system program,
as the state agency having primacy over domestic onsite systems in Ohio, we have
serious concerns regarding various issues raised and comments made in the Nettle Lake
EIS. Perhaps these concerns could have been resolved had our department been notified
of the study and involved in its development. This lack of notification and involve-
ment ±3 a courtesy we sorely missed.
rUBLIC HEALTH COUNCIL
M«r» A. Agm, M O., Chiimoimn
William Dci'ner, Jr, MO. Viet Cltmrnun J. Bruu Wtngnr. D V M.
Hicttard V. Bruruw, Q.O.S. flfvao A. Robert, M.H.A. Rob«rt L. Turton, D.O. £n«in W. Pioniorf, H. Ph.
-------
Gene WojcMk
October 19, 1981
Page Z
Re: Williams County (Ohio)
Nettle Lake Area
Alternative Wastewater
Treatment Systems
Draft Environmental
Impact Statement
As a final thought, we request that a third-party review of this EIS be performed by
a firm more familiar with Ohio laws and the actual conditions of the study area.-:'
This seems particularly necessary due to some of the inappropriate cooments in the
draft EIS.
We trust that our comments at this late stage will receive some consideration.
Very truly yours,
Robert J. Schutz, P.E., R.S.
Chief Engineer
Bureau of Environmental Health
EJS/km
Copy Furnished!
ODH
John Frazier, Chief, Bureau of Environmental Health,
Judith Brachman, Administrator, State Clearinghouse
Greg Binder, Chief, Office of Construction Grants, Ohio EFA
Ernie Roterlng, Chief, Office of Water Pollution, Ohio EPA
John H. Cousins, Chief, Division of Water, ODNR
Glen Hackett, Head, Private Water System and Household Sewage Disposal Unit, ODH
• Enclosures
. SUBJECT: A-9S SAI 036-552-0005
Williams County
Northwest Township
Nettle Lake ARea Alternate
Waste Treatment Systems
Environmental Impact Statement
(Draft)
APPLICANT: U.S. Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
COMMENTS FOR THE STATE CLEARINGHOUSE!
We recommend that this draft environmental impact statement (EIS) not proceed to a
final EIS until additional study has been undertaken and the concerns directed to
the applicant have been satisfactorily addressed.
Further, we strongly recommend that this draft EIS be submitted to a comprehensive
review by an independent organization familiar with the performance of environmental
assessments, with Ohio's sewage disposal regulations and with the actual environmental
conditions of the study area. ^
At the very least, the U.S. EPA should conduct a meeting with the Ohio Clearinghouse I
and the Ohio review agencies to discuss the draft EIS before proceeding further. ^
COMMENTS FOR THE APPLICANT;
page iii, Legal Implementation
The first sentence is Incorrect and should be discussed Ohio EPA and Ohio Department
of Health officials at least.
page vi, Cost Effectiveness
We were of the understanding that the Facilities Plan Proposed Action was within the
cost-effectiveness criteria of PEM 78-9 and therefore not a viable EIS issue. Were
ve mistaken?
page viii, Environment-Soils,Sentence 4
If the present systems are so effective why ie any action or grant necessary?
Surface Water Resources Paragraph 2
Using the strict definition of a 100-year flood plain we concur that a 12 chance of
flooding in any year may be interpretated; however, are we supposed to believe that
flooding only occurs that frequently in actuality?
-------
• page xii, EIS Alternative 7
Is "elevated sand mound" absorption now a recommended design for floodplains?
The same question applies to "holding tanks."
EIS Alternative 8
How does seasonal pucping of vault toilets prevent flood water contamination?
Key Impacts of the Alternatives. Surface Waters
We were of the belief that exposure to disease organisms, either directly or through
insect vectors, is a question, not eutrophication.
page xlii, Floodplain Impacts Sentence 4
This is totally unrealistic. How do you define and enforce temporary limitations?
Sentence 7 (final)
We disagree with conclusion. Onsite systems improperly located in floodplains repre-
sent the same hazards as the current privies.
Economic Impacts
^Wouldn't it be more desirable to pay 80% more for a technologically appropriate system
^rather than a minimal amount for a system that may function no better than what cur-
rently exists?
Page 1-6, History of the Construction Grant Application
Hasn't it deemed appropriate for the contractors to contact the state and local health
departments?
Page 21, Physiography Sentence 2
Is the reference to "900 feet msl" correct? We note in Figure II-l that the lake
surface is 945 feet msl.
KPage 42, Bacteria Paragraph 2
As stated, the bacterial sampling was inadequate, but does not appear to Justify any
action for the area. Is an appropriate sampling program going to be utilized for the
final EIS?
Page 44, Table II-7
The results listed are not indicative of a "direct measurable effect" upon which to
Justify any action.
Page 48, final paragraph•-
The only acceptable method of satisfying this requirement is to not locate any on-site
or soil-dependent sewage treatment system within a floodglain.
Page 68, c. Future Land Use, Paragraph 2
Is there a reason that enforcement of existing Otilo laws and administrative codes and
appropriate land subdivision requirements can not mitigate environmental hazards?
Why can't identified (if they are) malfunctioning on-site wastewater treatment systems
be brought into compliance, thus preventing water pollution?
Page 70, Special Studies
What constituted "failing" in the three studies?
We assume that references to SAS are the same as DF, since the terms seem to be used
Interchangably.
Page 73, c. Nettle Lake Construction Grant Sanitary Survey, next to the last sentence.
How did the survey suggest that backup, ponding and odor problems were "common"?
Page 75, COMPLIANCE WITH THE SANITARY CODE.
A code for onsite sewage disposal existed prior to 1974. The current code is known
as Chapter 3701-29 of the Ohio Administrative Code (OAC) which contains Rules 3701-29-
01 through 3701-29-21, OAC.
A holding tank is not a wastewater treatment system and therefore is not included in
the code. r—|
Page 77, Undersized Dratnfields. &
This is an accurate statement, but other comments in the EIS seemed to forget it.
\J?age 78, Groundwater Contamination.
Wouldn't it be wise to sample for nitrates before ruling out aquafer contamination?
Were the residents questioned about illness, dierhea, or odors from their drinking
water?
Page 79, Odors.
Was the surveyor convinced that the odors were produced by the onsite systems since
it has been stated that this is a eutrophic lake?
Page 81, Paragraph 3.
Again we note that the centralized facilities including the various alternative collec-
tion systems seem to have met the economic criteria for funding.
Page 87, COLLECTION.
In reviewing the various collection-systems, was consideration given to the effects
of groundwater infiltration?
Page 93, On-lot treatment and disposal.
The last three technologies listed,under-this heading are considered experimental
systems in Ohio and would require special reviews before permitting their installa-
tion.
-------
Page 94, next to last paragraph
The major problem is the innundation of any onsite system by flood waters.
Page 99, ON-SITE SEPTIC SYSTEMS, last paragraph.
We can only ask what? to this paragraph as we can not determine what the restriction
would be.
Page 101, Grinder Pumps. Paragraph 2.
Tou might be surprised to find that water closets and bathtubs still function during
power outages depending upon the water supply's storage capacity.
Page 103, Sand Mounds.
Not in all cases. Even the Wisconsin folks who developed this design stress that it
is not recommended in floodplains.
Alternative Toilets, second sentence.
This statement is inconsistent with our experiences. Nearly all demonstrations of
alternative toilets which we have permitted, have been removed by the owners voluntarily.
Page 109, Design of the Management Organization.
We disagree with the management agency choice. Even the County Sanitary Engineers of
Ohio which is an arm of the County Commissioners Association of Ohio has expressed the
inappropriateness of such designation. This is not a criticism of the Williams County
Board of Commissioners in any way; merely a recognition of organization capabilities
as enabled in Ohio.
Agency Start-Pp.
This is unnecessary in Ohio because the structure of local health departments under
the local boards of health already exist in Ohio.
Page 143, FLOODPLAINS, Primary Impacts.
Again we stress that soil absorption even when proceeded by a "watertight" septic tank
can not function when innundated by flooding or high water table.
Page 149, Calculation of User Charges, third paragraph.
How can the user charge be evaluated if the costs vary as expressed in your first
sentence.
Do these co/sts assume public ownership of mounds and ST/SAS7
Page 152, MITIGATIVE MEASURES.
We didn't find a significant financial burden by any alternative using the U.S. EPA
criteria.
1
Tills document appears to be a Justification for federal funding rather than a state-
ment of environmental impact.
We believe that it would be appropriate for the U.S. EPA, Region V Project Officer to
do the following:
1. Have this draft EIS reviewed by an appropriate Environmental Assessment
organization such as Battelle Memorial Institute;
2. Hold a meeting with the State (Ohio) Clearinghouse and interested Ohio re-
viewers to discuss the facilities plan and EIS in more detail;
3. Consider the results of local zoning to prohibit further development in the
floodplains, the adoption of more stringent county subdivision regulations
and increased enforcement of Ohio sanitary codes by the local health depart-
ment.
When we consider that (1) cost-effectiveness was used as a justification for doing an
EIS despite the apparent compliance of the Facilities Plan, (2) the costs of on-site
systems was arrived at without evaluating the individual lots and (3) no direct
measurable effect has been shown as required to justify federal funding, we wonder
why the No Action alternative wasn't selected.
We have other review comments, but these constitute the most significant. If)
Robert J. iJclmtz, P.E., R.S.
Chief Engineer
10/15/81-km
-------
TO:
FROM:
Judith Y. Brachman, Administering Officer
State Clearinghouse
DATE: October 15, 1981
Roger D. Hubbell, Chief , ,
Office of Outdoor Recreation Services
RE: COMMENTS SAI #36-552-0005
on thP n^« Far? DePal"tment of Natural Resources comments
S" S% * E"v'ro«e<>tal Impact Statement entitled Alternate
Area wmlf ntrSySIemS l°J Rural Lake fleets, Nettle Lake
has been lost transmittal form for this project
Fm/iJln y°* iT -^ 3uestions> P1ease contact Michael Colvin,
Environmental Review Coordinator at 614-466-8387.
RDH:sjk
Enc.
ODNR
Ohio Department of Natural Resources
Fountain Square- Columbus, Ohio 43224 -(614)466-3770
October 15, 1981
COMMENTS ON DRAFT ENVIRONMENTAL IMPACT STATEMENT
ALTERNATE WASTE TREATMENT SYSTEMS FOR RURAL LAKE PROJECTS
NETTLE LAKE AREA, WILLIAMS COUNTY, OHIO
USEPA, JULY 1981
SAI 136-552-0005
The Ohio Department of Natural Resources has completed a review
of the above-referenced document and concurs with it's findings and
recommendations.
In addition to the fish, wildlife and plant species listed in
the DEIS, the Natural Heritage Program data base records the occur-
ence of the following species in and along the shores of Nettle
Lake:
Noiropis heterodon* - Blackchin Shiner OBSX: in 3-4
ft. of water at old launch ramp, SW. Corner of Nettle
Lake, 10/80.
Notropis emiliae* - Pugnose minnow OWE, OBSE: off
gravel bar, east side of Nettle Lake, 10/80
Etheostoma exile - Iowa darter OWE, OBSE: gravel bar,
east side of Nettle Lake, 10/80
Najas flexilis - Slender Naiad OPP; west shore of
Nettle Lake, 7/71
Pilea fontana - Clearweed OPP; sandy-muddy SW. shore
of Nettle Lake, 9/63
Potamogeton praelongus - White-stem Pondweed OPE: SW.
end of Nettle Lake, 9/69
Sparganium chlorocarpum - Small Burr-reed OPE: shal-
low water along SW. shore of Nettle Lake, 9/69
Ambystoma tigrinum - Tiger Salamander OBST: W. side
of Nettle Lake in woods, 7/73
ID
.-I
JAMES A. RHODES. Governor • ROBERT W. TEATER, Director
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SAI #36-552-0005 COMMENTS CONTINUED
Platanthera psycodes - Small Purpled Fringed Orchid
OPT; moist woods around Nettle Lake, 8/58.
Potaaogeton amplifolius - Large-leaved Pondweed
OPP; shallow water along edge of Nettle Lake, 9/69
It 1s the opinion of the Department that implementation of
the preferred alternative will not have any sigificant adverse
impacts to the natural resources of the Nettle Lake Area.
If you have any questions, please contact Michael Colvin,
Environmental Review Coordinator, Office of Outdoor Recreation
Services, 614-466-8387.
* Notropls heterodon, collected 10/80, has been extirpated from
Ohio since 1957. The population of Notropls emiliae at Nettle
Lake is considered to be the best in the state, according to
staff zoologist, Dan Rice. The fish species in this list all
require submerged aquatic vegetation and relatively clean water.
The improvement of the waste treatment systems would be benefi-
cial to water quality. The Nettle Lake study discusses in-
creasing population growth. Care should be taken to prevent
shoreline alterations by landowners that would destroy the
gravel bars and aquatic vegetation.
OBSX—Extirpated (Ohio Biological Survey)
OWE - Endangered Wildlife
OBST - Threatened Wildlife (Ohio Biological Survey)
OPE - Endangered Plant
OPT - Threatened Plant
OPP - Potentially Threatened Plant
If.
Johnson & Anderson, Inc.
Consulting Engineers
2300 Dixie Highway
Pontiac, Michigan 48055
Telephone: 313-334-9901
October 23, 1981
Ms. Catherine G. Garra, Project Monitor
U.S. Environmental Protection Agency - Region V
230 South Dearborn Street
Chicago, Illinois 60604
Re: Draft Environmental Impact Statement
Case Study Number 6
Mettle Lake Area, Williams County, Ohio
Dear Ms. Garra:
Thank you for sending me a copy of the Draft EIS for review. Since I
received it on October 22, it was obviously impossible to send you my
comments by September 28, as the Draft requested. However, I would
still like to remark on the project in hopes that answers may help me
in my work.
I am currently developing facilities plans for two townships on the
suburban fringe of Detroit, specifically in northwestern Oakland
County. As the study areas encompass more than two dozen inland lakes,
I have found your case studies on "Alternative Wastewater Treatment
Systems for Rural Lake Projects" to be very valuable. We have used
door-to-door sanitary surveys, wellwater quality sampling, and the
septic leachate detection survey techniques in our attempts to document
water pollution and public, health problems from septic systems per PRM
79-8. I believe that the EPA made their point in the first case study
on Crystal Lake that these techniques are required for adequately
documenting the need for the project. Therefore, though interesting, I
fail to see why the EPA is planning to conduct six other (very similar)
rural lake EIS's, rather than requiring the communities' consultant to
do this work. x
Each of the three EIS's that I've seen (Crystal Lake,
and now Nettle Lake) are almost identical in approach
identical in recommended actions. The recommendation
"site-specific environmental and engineering analysis
on-site systems throughout the proposed service area"
each EIS. This would seem a better topic for a case
preparing three more EIS's providing virtually a repe
taken in the earlier works. Also, the application of
mentioned techniques to urban and suburban unsewered
communities would provide more fruitful information.
Otter Tail Lakes,
, and are
for
of existing
has appeared in
study rather than
at of approaches
the above-
inland lake
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U.S. Environmental Protection Agency - Region V
Page Two
October 23, 1981
Additionally, it doesn't appear that EPA is following the documentation
of need for action requirements that appear in the Region V guidance
entitled "Site Specific Needs Determination and Alternative Planning
for Unsewered Areas." The supplemental studies that were conducted for
determining pollution problems comprise a work program that would
appear to satisfy both Phase 1 and Phase 2 representative sampling work
conducted in Step 1. Based upon this data, the guidance calls for a
designation of residences into one of the following categories:
Residences having adequate tr
3.
This designation was not performed, however, and instead all residences
in the proposed service area are recommended to receive detailed
site-specific analysis in Step 2. It seems to me that the guidance
allows for only a 15™3Q% analysis in Step 1, accompanied by the
above-mentioned classification. However, the guidance does not explain
if this classification is supposed to cover residences on a subdivi-
sion, street-by-street, or individual basis. Perhaps some clarifica-
tion can be made on this point.
I also think that the Final EIS should explain, in much more detail,
how the cost estimate for at least the recommended alternative was
derived.
Finally, in Appendix G "Financing,11 it is stated that "Where population
density is less than 10 persons per acre, it must be shown that new
gravity collector sewer construction and centralized treatment is more
cost-effective than on~site alternatives." Does that mean, conversely,
that where population density is greater than 10 persons per acre, new
gravity sewer construction does not have to be analyzed against on-site
alternatives for cost-effectiveness?
I'm sure that answers to these comments will help me immensely in my
facilities planning, and wish to thank you again for allowing me to
comment on the report.
Sincerely,
JOHNSON & ANDERSON, INC.
Michael A. Czuprenski, P.E.
Project Manager
MAC:kip
CO
rH
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ENVIRONMENTAL IMPACT STATEMENT
ALTERNATE WASTE TREATMENT SYSTEMS
FOR RURAL LAKE PROJECTS
In res Draft EIS
Stenographic Report of Hearing
Held at Bryan-Montpelier Holiday
Inn Conference Room, adjacent to
Exit 2 of Ohio Turnpike,
Montpelier, Ohio
Friday, October 2, 1981,
2s17 o'clock p.m.
MEMBERS PRESENTS
ALSO PRESENT:
CHARLES QUINLAN, Hearing Officer
CATHERINE GRISSOM GARRA, Project Officer
J. ROSS PILLING, II, WAPORA Consultant
MAURICE BRETTHAUER, Williams County Commissioner
HARRY OSBORN, Williams County Commissioner
HOWARD SKILES, Williams County Commissioner
JACK BOOGEVEEN, Coordinator from Ohio EPA
LARRY MANAHAN, Representative
F-19
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INDEX TQ MEETING
Introduction by Charles Quinlan. Pago 3
Opening Statement by Catherine Grissom Garra........Pages 5 & 15
Opening Statement by J. Ross Pilling, II Page 10
Comment by Garry Cole Page 19
Comment by Flossie Seslar Page 25
Comment by Albert Mcllrath. Page 29
i
Comment by Bruce Kollinger. .Page 31
Comment by Perry Singer. Page 37
Comment by Louvera Eubank. .Page 38
Cozament by Harry Osborn...* Page 46
Comment by Maurice Dretthauer Page 47
Comment by Larry Manahan. .Page 49
Reporter*s Certificate. Page 59
F-20
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ENVIRONMENTAL IMPACT STATEMISTT
ALTSRHATE WASTE TREATMENT SYSTEMS
FOR RURAL LAXS PROJECTS
In ra» Draft SIS
Stenographic Report of Hearing
Held at Bryaa-Moateliar Holiday
Inn Conference Room, adjacent to
Exit 2 of the Ohio Turnpike,
Wkmtpeliar, Ohio
Friday, October 2, 1931,
7ilO o'clock p.m.
MEMBERS
CHARLES Q01HLA8, Hearing Officer
CATSERIim GRZSSOH G&RR&, Project Officer
J. ROSS PILLING, II, ff&PORA Consultant
ALSO PRESEOTi
MAURIC3 8RSTTHAUSR» Williams County Cotmissioner
BARRY OSBORN, Williams County Ccssmisaioner
HOWARD SXILESr Williama County Conaisaioner
F-21
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IHDBX TO MSETIHG
Introduction by Charles Quini&a* ««*•.«*»«•«*.*••» .Page 3
Opening Statement by Catharina Griasom Carra» »«,,«« Pages 3 £
Opening Statement by J. Boas Pilling, II ••••«••••• Paga 10
Comment by Clifford Liaday « ..«««»«. «*,*.*«0<>o«««* »?ags 14
Cocanant by Claire Kachanjaeia tar.. «»«•»*..« ..... . ««Page 21
by Ira Millar.. «..«» ....... »•*«.«».. ..... .Paga 23
Ccjvsaaent by Larry Boyer..... .»0 .,»«« 9»»<- .» *«».«. >o.oPage 23
by Mrs* Yernon Millaro^ooo ..e .. . »3 ...... ..Page 30
by B«varly Frankf orth«r« . . « •.»«.«....». »«.?aga 32
Ccsament by Russ Manaval. «.«««.. «.«••* •..,.««...». ..Page 35
Coaancnt by liarie Carep. ••......»vea..,9«.«.<,..».,« «?age 3?
Conanent by Vernon Millar* .....*«9«,9»««. .«,...»«.. .Page 39
Conaaent by Maurice 3rettha«ar».o.a.,,a »..«, .».«..» .Pago 41
Ccrament by Howard Skilas.. . . . ., «*,«.,....»...,. .«,Paga 43
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