r/EPA
          United States      Regions
          Environmental Protection '- Sixth and Wai nut Streets
          Agency         Philadelphia, Pennsylvania 19106
                          August 1981
Final Environmental
Impact Statement
Buckingham, Pennsylvania
Wastewater Treatment
facilities

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           UNITED STATES ENVIRONMENTAL PROTECTION  AGENCY
                                   REGION III
   pao-
                            5TH AND WALNUT  STREETS
                       PHILADELPHIA PENNSYLVANIA  19106

                                                              AUG 1 8 196Y

TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:

Enclosed is a copy of the Final Environmental Impact Statement (EIS)
prepared by the Environmental Protection Agency (EPA) in relation to a
request submitted by the Buckingham Township Board of Supervisors for
Federal funding to plan for wastewater management facilities for the
Buckingham area of Bucks County, Pennsylvania.

This Final EIS is issued pursuant to the National Environmental Policy Act
of 1969, the Clean Water Act of 1977,  and regulations promulgated by this
Agency (40 CFR Part 6, November 6, 1979 and 40 CFR Part 35,  September 27,
1978).  Comments or questions concerning this Final EIS should be submitted
to the attention of Mr. Richard V. Pepino at the above address by September
28, 1981.

EPA has determined that alternative 4  as presented in the Final EIS is
eligible for Federal funding.  Alternative 4 was selected by EPA because it
is most consistent in supporting Agency goals of encouraging land applica-
tion of wastewater, enhancement of groundwater resources, and preservation
of prime agricultural land.  EPA anticipates that future applications
submitted by the Buckingham Township Board of Supervisors to obtain Federal
funds will be consistent with the provisions described in alternative 4.

I wish to thank the applicant for the  assistance they have provided to EFA's
staff during this EIS process.  In addition, I wish to commend the perform-
ance of the Central Contracts Committee which supplied guidance to EPA on
important technical decisions involving the evaluation of alternatives for
the planning area.  Finally, I want to especially recognize  the interest
demonstrated by the area's citizens.  Their participation throughout this
EIS Process has greatly contributed to the development of an acceptable
solution to the wastewater needs of Buckingham Township.

Sincerely yours,
George D., Pence, Jr., Chief
Environmental Impact Branch

Enclosure

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               FINAL ENVIRONMENTAL IMPACT STATEMENT

                                on

                 WASTEWATER MANAGEMENT FACILITIES
              BUCKINGHAM TOWNSHIP, PENNSYLVANIA AREA
                           Prepared By:

                US ENVIRONMENTAL PROTECTON AGENCY
                            REGION III
                    PHILADELPHIA, PENNSYLVANIA

                Richard V. Pepino, Project Monitor
                           WAPORA, Inc.
                       BERWYN, PENNSYLVANIA

                  Valdis Jurka, Project Manager
Type of Action:

  Legislative (   )
  Administrative ( X )

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EXECUTIVE SUMMARY

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                           Executive Summary

This Final Environmental Impact Statement  (EIS) has been prepared
by the Environmental Protection Agency  (EPA) to address all sub-
stantive comments that have been received on the Draft EIS issued
in May 1981.  The Draft EIS was prepared by EPA in response to a
request submitted by the Buckingham Township Board of Supervisors
for Federal funding to plan for wastewater management facilities
in the Buckingham area of Bucks County, Pennsylvania.

Of the alternatives described in the Draft EIS, Alternative 4
is EPA's preferred choice as a wastewater solution to meet the
Township's current and projected needs.

Alternative 4 includes the following:

     •  Spray irrigation of wastewaters collected from Red
        Gate Farms (Argus Drive Section) and Buckingham
        Village.  The projected capacity for this system will
        eventually reach 44,600 gallons per day.

     •  Durham Village and Apple Hill would rehabilitate their
        community subsurface system or connect to the Red Gate
        Farms/Buckingham Village solution.

     •  Canterbury Estates would rehabilitate its community
        subsurface system.

     •  Scattered malfunctioning on-site systems throughout
        the Township could take remedial measures consistent
        with appropriate land disposal technology.

     •  Areas to be developed would apply site specific land
        disposal methods of wastewater treatment as determined
        by the existing soil conditions.  (The Township's
        adopted Faciliites Plan describes the methodology that
        is to be used in selecting the appropriate land disposal
        technique.)

     •  The Township's existing sewered area, which is located
        in the western corner of the Township adjacent to the
        Cross Keys areas and has its wastewater conveyed to and
        treated at the Chalfont-New Britain wastewater treatment
        plant, is to have additional connections only if land
        disposal technqiues are neither cost-effective nor
        environmentally sound.

Alternative 4 was selected by EPA because it is most consistent
in supporting our goals of encouraging land application of
wastewater, enhancement of groundwater resources and preservation
of prime agricultural land.

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Comments received on the Draft EIS from the Pennsylvania
Department of Environmental Resources, the Bucks County Planning
Commission and Health Department express support for Alternative 4
as presented in the Draft EIS.  On August 12, the Buckingham
Township Board of Supervisors approved resolutions adopting the
Facilities Plan for Buckingham and requiring that a Step 4
(combined design and construction phases)  Construction Grant
application be prepared to obtain EPA funds for implementing the
Facilities Plan.  EPA anticipates that this application for
Federal funding will be consistent with the provisions detailed
in the Draft EIS.

During the Draft EIS comment period, comments were received
from other agencies, as well as residents of the Township.
These comments appear as   Appendix  B    to this Final EIS.  EPA
has prepared responses to these comments in this Final EIS.
Generally, these comments addressed factual material regarding
the operation and maintenance of the proposed spray irrigation
system for Red Gate Farms and Buckingham Village.

Several agencies and citizens commented on the proposed "on-site
management program" described in the Draft EIS.  EPA has obtained
the necessary assurances from the Buckingham Township Board of
Supervisors that the provisions contained in their adopted
management program will be administered with respect to all
Buckingham residents participating in the Federally funded
rehabilitation program.

In conclusion, EPA will support Alternative 4 for funding
eligibility within the guidelines of our Construction Grants
Program.  Alternative 4 will provide a cost-effective and
environmentally sound solution to meet the present and projected
wastewater needs for this community.
                                  ii

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                        TABLE OF CONTENTS
                                                             Page
EXECUTIVE SUMMARY                                              i

Table of Contents                                             ii
List of Tables                                                iv
List of Figures                                                v

1.0.  INTRODUCTION                                             1
      1.1.  Grant Award Process                                1
      1.2.  EIS Preparation                                    1

2.0.  RECOMMENDED ACTIONS                                      3
      2.1.  Recommended Actions for Clustered Problem Areas    3
      2.2.  Recommended Actions for Scattered Problems         9
      2.3.  Recommended Actions for Future Growth-Related     15
            Wastewater Disposal

3.0.  COMMENTS RECEIVED ON DRAFT EIS                          17
      3.1.  Public Participation                              17
      3.2.  Key Comments                                      17
      3.3.  Responses                                         18
            3.3.1.  Spray Irrigation                          18
            3.3.2.  Alternatives Considered                   22
            3.3.3.  Management Programs                       22
            3.3.4.  Uncertainties of Federal Funding          24

4.0.  IMPLEMENTATION OF RECOMMENDED ACTIONS                   25

5.0.  CURATIVE AMENDMENTS                                     27

References                                                    29

Preparers                                                     31

Buckingham EIS Distribution List                              33

APPENDICES
    A      Executive Summary of Draft EIS
    B      Public Hearing Comments/Comment Letters on
           Draft EIS
    C      Buckingham Township Resolutions
                               1X1

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                          LIST OF TABLES
                                                             Page
Table
  1    Wastewater flow projections for Alternative 4            6

  2    Component costs of Alternative 4                         7

  3    User costs for Alternative 4                             8

  4    Individual system alternatives                          10

  5    Individual-community system alternatives                11

  6    Community-integrated community system alternativess     12

  7    Rehabilitation costs for individual systems             14

  8    Buckingham Township Management Program                  16
                                 IV

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                         LIST OF FIGURES
                                                             Page
Figure
  1    Alternative 4                                            4

  2   Conceptual representation of wastewater systems         13

  3   Floodplains                                             21

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CHAPTER 1.0.




INTRODUCTION

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                    CHAPTER 1.0.  INTRODUCTION

1.1.  GRANT AWARD PROCESS

     Title II, Section 201(g)(l) of the Clean Water Act authorizes
the U.S. Environmental Protection  Agency's (EPA) Administrator to
make  grants  to  any  State,  municipality,  or   intermunicipal  or
interstate agency for the construction of publicly-owned treatment
works.   US-EPA regulations  for  implementing this  section  of the
Clean Water  Act  appear in  40  CFR  35,  Subpart E, Grants  for Con-
struction of Treatment Works.  These regulations define the three-
step process  that  the applicant must  comply with  to qualify for
Federal funding in support of  the public works project.

     The three-step process  is divided  into planning, design, and
construction phases.  As  the  applicant  completes each step in the
process,  their  submissions  are  reviewed,   commented  upon,  and
approved by the State  and EPA.  The lead State agency in Pennsyl-
vania  for  the Construction  Grants Program  is   the  Department of
Environmental Resources (PA-DER).

     The  initial  grant   application  describing the project  is
evaluated by PA-DER.  Once  PA-DER  determines that the project has
met  the  eligibility  requirements for  financial  assistance,  a
priority  point ranking   is  assigned  with respect  to all  other
qualified  statewide  projects.    The  individual  projects  then
receive Step 1 - planning grants from EPA according to the State's
priority point ranking scheme.  The Step  1  process culminates in
the  production of  a  Facilities  Plan.    This  planning  document
details the existing  and  projected wastewater needs for the muni-
cipality during  the  twenty year period  ending  in  the  year 2000.
The Facilities Plan,  commonly referred to as the  201 study, must
include  a  systematic evaluation of  all feasible  alternatives to
meet the existing and projected wastewater management needs in the
municipality.   The municipality's  preferred alternative  must be
demonstrated to be cost-effective and environmentally sound.

     During 1977, PA-DER  certified Buckingham Township for Federal
funding  eligibility.   A   Step  1  grant was  subsequently  issued to
Buckingham  by  EPA  giving   the  financial   assistance  needed  to
initiate the Planning Phase of the Construction Grants Program.

1.2.  EIS PREPARATION

     EPA evaluated Buckingham  Township's  Step 1 grant application
pursuant to P.L. 91-190,  the  National  Environmental Policy Act of
1969 (NEPA) and Executive Order  11514,  Protection and Enhancement
of  Environmental  Quality  and  EPA's  Prime  Agricultural  Lands
policy.   EPA  determined  that  an  Environmental  Impact Statement
(EIS)  would be  required.    An  EIS  is  required  whenever  major
Federal actions may  significantly  affect  the quality of the human
environment.   The  EIS  is  a  decision-making  document  of  EPA to
assure  that  Federal  funds will produce a  project  which will have

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maximum  beneficial effects  and  minimum  negative  impacts  on  the
planning  area's natural  and  socioeconomic environment.   The  EIS
and  facility  planning  process have been a concurrent,  coordinated
effort.   Through  such  coordination the design and  construction  of
selected  actions  can proceed  most expeditiously.

     EPA's decision to prepare  an EIS  was  based on  the  significant
environmental and  social  concerns listed below:

•  identification  of existing and future wastewater treatment
   needs

•  the maintenance of high quality surface and groundwaters

•  safeguarding the Township's  current  and future groundwater
   supply

•  identification  of potential  changes  in  land use  caused by
   increasing development pressures on  semi-urban and
   agricultural sections  of the Township

•  evaluation of general  environmental  effects such as  air
   quality, vegetation, wildlife  and aesthetics.

     A Draft  Environmental Impact Statement  was prepared  by  EPA
which contained its  independent  analysis,  evaluation,  and recom-
mendation of  the  alternatives proposed  in  the 201 Facilities Plan.
(Appendix A contains the  Executive Summary of the Draft EIS).  The
Draft EIS strongly supported  land disposal methods  for Buckingham
Township  as the best means to resolve  existing wastewater disposal
problems  and  providing a  sound  approach for meeting future growth-
related  wastewater disposal  needs.    In  addition to  its  cost-
effectiveness,  land disposal  methods  were  found  to be compatible
with the  Township's goals and objectives  of  protecting its water
resources and prime agricultural  land.

     The  Draft  EIS was  submitted for  public  and   agency comments
(Chapter  3.O.).   In  response to,  and  after carefully  considering
each comment, EPA recommends land disposal  approaches to satisfy
Buckingham Township's existing  and future wastewater needs.  These
recommended  actions  with  accompanying management programs   are
detailed  in the next chapter  (2.0.  Recommended Actions).

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    CHAPTER 2.0.




RECOMMENDED ACTIONS

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                CHAPTER 2.0.  RECOMMENDED ACTIONS

     The  concurrent  and  coordinated  efforts  of  preparing  the
Environmental Impact  Statement  by EPA  and  201  Wastewater Facili-
ties Plan by Buckingham Township have resulted in the same program
of recommended  actions.   This program  is the  result  of separate,
independent analyses, evaluations,  and  selection  processes by EPA
and Buckingham Township.

     The  specific  actions   recommended  address  themselves  to
solving

     (1)  clustered problem areas of  individual on-site wastewater
disposal  systems (generally  malfunctioning  septic  tank-leaching
field systems);

     (2)  scattered problems  throughout the remainder of Bucking-
ham Township with individual  on-site wastewater disposal systems;
and

     (3)    providing  a  wastewater  management  system   that  will
accomodate   future    growth-related   wastewater   needs   of   the
Township.

     The recommended  actions  would  be incomplete  unless a manage-
ment  program  is established.    It  is  imperative  to  carefully
consider  not  only  what  will be built  once the  EIS  recommended
actions  are  implemented,  but also what proper  management actions
are  required  to  ensure  immediate  and  continued  success  of  the
solution.

     In  the Draft EIS,  EPA  concluded that  Alternative  4  was the
most consistent method  of  supporting EPA's goals  of encouraging
land application  of wastewater  and  preserving  prime  agricultural
land.   Therefore, EPA  identified  Alternative 4  as  its preferred
choice for meeting  the current  and  projected wastewater needs for
Red Gate Farms  and  Buckingham  Village.  Alternative 5  will meet
similar  wastewater  needs for these  sections of  the  Township but
will utilize  a  more  centralized  approach   which  will  involve  a
stream  discharge  to  Mill   Creek   at  the  Buckingham  Elementary
School.  Though this  alternative  does not present any major envi-
ronmental problems, the  stream  discharge approach is inconsistent
with the Township's and EPA's primary goals.

     The  recommended  actions   are   detailed  in  the  following
sections.

2.1.  RECOMMENDED ACTIONS TO SOLVE CLUSTERED PROBLEM AREAS OF
      INDIVIDUAL ON-SITE WASTEWATER DISPOSAL SYSTEMS

     Alternative 4 of the Draft Environmental Impact Statement was
EPA's  preferred alternative  solution  (Figure  1).    Two separate

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                       MOST  DESIRED
                     SPRAY IRRIGATION
                           SITE
BUCKINGHAM
 VILLAGE
             FIGURE  I  ALTERNATIVE 4

                   GRAVITY SEWER

             — FORCE MAIN

              •   PUMPING STATION

             ......  POTENTIAL CONNECTION  ROUTE
                   FROM NEARBY DEVELOPMENT

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areas  (Red  Gate Farms  and Buckingham  Village)  would  have  their
wastewaters collected with  treatment  by a slow-rate land applica-
tion system.  Red Gate Farms (Argus Drive Section) has  17 existing
lots with  a provision for  3  additional lots.  This  totals to 20
equivalent  dwelling  units (e.d.u.) having  a  projected wastewater
flow  of 4,600  gallons  per day  (gpd).   The Buckingham Village
incorporates  the  "Village  Center"   as  defined  by  Buckingham
Township's  Zoning  Ordinance.   The wastewater flow  projected  for
Buckingham  Village   is   40,000   gpd   (or  174  e.d.u.).     These
wastewater  flows are totaled for design purposes in Table 1.

     Alternative  4  calls  for the construction  of  a collection
system  (force  mains,  6" gravity  sewers, and  laterals)  totaling
20,400  feet, or  about 3.9  miles  in length.   Also required are  two
pumping  stations —  one  to convey wastewater from  the  Red Gate
Farms area  to Buckingham Village and a  second to  convey  the com-
bined wastewaters  from Red Gate Farms and Buckingham Village to
the treatment site.   The  treatment  system will  consist  of ponds
from which  the effluent  will  be  applied to land  by slow rate land
application  (spray/sprinkler   irrigation).    The  amount  of  land
required  is 37   acres.   The  cost of  the various  components  for
collection, treatment,  and disposal  is  listed  in  Table 2.    The
estimated annual operation and  maintenance  costs  for  the entire
system  are  $12,000 initially  and $17,100 at  the  year 2000 design
flow.

     There  are  two  community  subsurface  wastewater  treatment
systems  (Apple   Hill  and  Durham Village)  that   have  experienced
problems.   These two  community  systems  are  close enough  to  the
wastewater  collection system  of  the  recommended action  so that
they might  be able to connect.   The recommended  alternative would
permit  connection of these two developments as part of  the overall
system  if on-site  rehabilitation of these  2  community systems is
neither  feasible nor cost-effective.   The wastewater  flows from
both  of these developments can  be accommodated  as  part  of  the
44,600  design capacity of  Alternative  4.   The estimated flow from
the  currently  developed  lots  in  Apple  Hill  is 5,600  gpd which
would increase to  8,300  gpd at  full development.   Durham Village
with 60 lots has an estimated 13,400 gpd  wastewater flow.

     Alternative 4,  the  recommended  action,  would be  managed by
Buckingham  Township.   The Township  would  own  and  operate  the
wastewater  facilities,  thereby  qualifying  to  receive  Federal
funding  for the  design and construction phases.   The system would
be  financed by  a user charge  system  whereby users would pay  any
bond  indebtedness  incurred in  financing the  project  as  well as
operation and  maintenance  charges (Table 3).   Non-users  of  the
system,  i.e. those residences  who are  not  connected,  will  not be
assessed any costs or charges.

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Table 1.  Wastewater flow projections under Alternative 4, EPA's
  recommended action.
                                                  Wastewater
         Area             Number of e.d.u.        Flow (gpd)

    Red Gate Farms              20                   4,600
    Buckingham Farms           174                  40,000

    TOTAL                      194                  44,600
e.d.u. - equivalent dwelling units
gpd - gallons per day

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Table 2.  Component costs of Alternative 4 (in dollars).

COLLECTION SYSTEMS

   Red Gate Farms
   3,400 feet of 6" gravity sewer                         47,600
   800 feet of laterals                                    4,000
   10 manholes                                            10,000
   1,200 feet of force main                               14,400
   Pumping station	                         12,000
   Subtotal                                               88,000

   Buckingham Village
   7,000 feet of 6" gravity sewer                        105,000
   1,600 feet of laterals                                  8,000
   23 manholes	                         23,000
   Subtotal                                              136,000

PUMPING SYSTEM TO DISPOSAL SITE

   6,400 feet of force main                               77,000

PUMPING STATION                                           25,000

LAND APPLICATION SYSTEM

   Irrigation equipment                                  100,000
   Land	                                  550,500
   Subtotal                                              650,500

PONDS                                                    110,000

CONTINGENCIES                                             53,000

SURVEYING, SUBSURFACE INVESTIGATIONS,
ENGINEERING, ADMINISTRATION                              121,000
TOTAL CAPITAL COST                                     1,260,500

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Table 3.  User costs for Alternatives 4 (in dollars).
Estimated Total Capital Cost

Portion of Total Classified
  as Alternative

EPA Grant, if Eligible
  Alternative Portion"! (85%)
  Conventional (75%)
  TOTAL

Local Portion of Costs
      ALTERNATIVE
           4

      1 ,260,500


      1,248,500


      1,061,225
      	9,000
      1,070,225

        210,125
                                      1980
                 2000
Number of e.d.u.

Estimated Annual Cost
  Capital^
  0 & M
  Administrative
  TOTAL

Cost per Year per User
  Without EPA Funding
  With EPA Funding
   112
17,960
13,600
 2,000
33,560
 1,187
   300
   194
17,960
17,000
 2,000
36,960
   711
   190
Calculated at 85% funding
^calculated at 75% funding
Calculated at 7% over 20 years

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2.2.  RECOMMENDED ACTIONS TO SOLVE SCATTERED PROBLEMS

     To  meet  the  Township's   scattered  problems  of   individual
malfunctioning on-site  wastewater  disposal  systems, the  following
alternative collection, treatment  and  disposal options  (Tables 4,
5,  6)  are  available to  the homeowner  in  consultation  with the
appropriate authority.  These options  are to be applied  at  lowest
level —  if the problem  cannot be cost-effectively  solved on an
individual basis, then more complex organization is called  upon in
the following order  —  individual-community,  community,  and  inte-
grated community systems  (Figure 2).

     The  recommended  management  program  for scattered  problem
areas  is  a comprehensive  public  assurance  program.    Such  an
assurance  program  is designed  to  correct existing problems  while
providing  the means  to  minimize and/or avoid additional  problems.
This  assurance  program meets   EPA's  guidelines and  is  therefore
eligible  for  Federal financial  assistance.    EPA  guidelines call
for regulation and inspection of privately owned small  alternative
wastewater  systems.    A  physical  inspection   of  the  systems  is
required every 3 years with pumpouts and  system repair/rehabilita-
tion  required   as  needed.   These costs would  be  paid  by the
property owner.

     The Buckingham  Township Management  Program will identify the
malfunctioning systems  (estimated  to be 12 to  15% of all  systems).
Without the management  program, these systems  would  then need to
be  corrected  with the  property owner responsible  for  the  costs.
However, with the  Township management program, 85% of  the  repair
and/or rehabilitation costs  will be eligible  for  funding by EPA.
To be eligible for such funding  the criteria stated in  EPA  regula-
tion 40 CFR, Section 35.918 on  individual systems must  be met.

     It should  be  noted that one  of  the  key eligibility criteria
is that the principal residence or small commercial establishment
was constructed before December  27, 1977.  Thus, homes  built  after
this  date  including  new  homes  to be  built during  the planning
period would not be  eligible  for 85%  funding — the premise  being
that EPA will help remedy problems existing at  the  time the  legis-
lation passed, but will not spend  water pollution control funds to
solve future problems.

     With   85%  funding   available,  the  costs of  repairing  or
rehabilitating  existing  failing  systems  would be significantly
reduced for the property  owner.   Table  7  presents the  estimated
cost  for   the  repair/rehabilitation  program  using  400  suspected
problems.   It   is  estimated  that  with EPA  funding the  rehabili-
tation costs per homeowner would be approximately $660.

     In addition,  selected existing  potable  water wells will be
tested annually with Buckingham Township  responsible for the cost
of  testing.   The  scattered  problems  include  not  only  individual
on-site wastewater disposal systems,  but  also community  systems

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Table 4.  Alternative wastewater treatment and disposal methods
  for individual systems (Tatman and Lee Associates, Inc.
  1980).


Continue present practice of individual on-site treatment and
disposal (depending on soil and site characteristics).  Upgrade
individual private systems where conditions require.

         A - Septic tank - Soil absorption system (SAS)
         B - Septic tank - Mound
         C - Septic tank - Sand-lined bed (SLB)
         D - Septic tank - Shallow placement area (SPA)
         E - Aerobic unit - SAS
         F - Aerobic unit - Mound
         G - Aerobic unit - SLB
         H - Aerobic unit - SPA
         I - Aerobic unit - Slow rate land application
         J - Pond System - Slow rate land application
         K - Individual holding tank
                              10

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Table 5.  Alternative wastewater treatment and disposal methods
  for individual-community systems (Tatman and Lee Associates,
  Inc. 1980).
Combination of wastewater from several dwellings in collection
systems to lands that have suitable soils and size.  Lots which
could use on-site disposal would not connect to the collection
system.

    A - On-site Treatment with Central Land Disposal

        1  Septic tanks - SAS
        2  Septic tanks - Alternate disposal systems
        3  Aerobic units - SAS
        4  Aerobic units - Alternate disposal systems
        5  Aerobic units - Slow rate land application

    B - Off-site Treatment and Central Land Disposal

        1  Central septic tank - SAS
        2  Central Septic tank - Alternate systems
        3  Central aerobic unit - SAS
        4  Central aerobic unit - Alternate systems
        5  Central aerobic unit - Slow rate land application
        6  Package-type treatment unit - Slow rate land
              application
        7  Oxidation ditch - Slow rate land application
        8  Lagoon/pond system - Slow rate land application
        9  Transport to existing wastewater treatment plant -
              Upgrade to achieve disposal by slow rate land
              application.

    C - Off-site Treatment with Central Stream Discharge

        1  Package-type, treatment unit
        2  Lagoon/pond system - Overland flow
        3  Transport to existing wastewater treatment plant -
              Upgrade to achieve direct discharge effluent
              limitations

    D - Central Holding Tank
                              11

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Table 6.  Alternative wastewater treatment  and disposal methods
  for community systems and integrated community systems  (Tatman
  and Lee Associates, Inc. 1980).
Wastewater collected within designated service area to a central
treatment and disposal area.

A - Central septic tank - Soil absorption field

B - Central septic tank - Alternate systems

C - Central aerobic unit - SAS

D - Central aerobic unit - Alternate systems

E - Central aerobic unit - Slow rate land application

F - Package-type treatment unit - Slow rate land application

G - Oxidation ditch - Slow rate land application

H - Lagoon/pond system - Slow rate land application

I - Transport to existing wastewater treatment plant - Upgrade
       to achieve disposal by slow rate land application

J - Transport to existing wastewater treatment plant - Upgrade
       to achieve direct discharge effluent limitations

K - Holding tank
                              12

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 Figure 2.   Conceptual representation of  wastewater  system
   alternatives.
Individual  Systems;  Combination of on-
site treatment  and disposal alternatives
on individual parcels.  No collection
alternative is  included.
Community Systems;  A combination of all
parcels in an  area  to provide treatment
and disposal of  wastewater.  Collection
alternatives are included  in the
combination of parcels in  the system.
Individual  and  Community Systems;
Individual  parcels with problems in an
area would  be combined,  parcels without
problems, would continue to use
individual  systems.
Integrated Community System;  Where
other community  systems are nearby,
several systems  may be integrated into a
larger system.
                                           13

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Table 7.  Cost of rehabilitation program for individual on-site
  systems with EPA funding.
General sites surveys 16 wks ($200/day)              $   16,000

Sites evaluations (400 locations)
    Engineering                                          20,000
    Soils analyses                                       80,000

Rehabilitation
    Soil absorption field
    (330 ft2/bdrm) (3 bdrm) ($2/ft2) (300 sites)        594,000
    Mounds (100 sites) ($5,000/site)                    500,000
                                                     $1,210,000

Contingencies (25%)                                      302,500

Engineering/Administrative (20%)                        242,000
                                                     $1,754,000

85% Funding                                           1,491,325

Local Portion                                           263,175

Cost Per Homeowner $263,175 = $658
                     400
                   locations
                              14

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(Apple Hill, Canterbury Estates, and Durham Village).  The various
elements of the management program are detailed in Table 8.

2.3.  RECOMMENDED ACTIONS TO SOLVE FUTURE GROWTH RELATED NEEDS

     The recommended action to meet future growth-related needs of
the Township is to  utilize  the  alternative collection, treatment,
and disposal options  (as previously presented  in  Tables 4,  5, and
6)  at the  lowest  level  of  wastewater  management.    The  public
assurance  program  detailed  in Table  8  would apply  to all  new
development on lot  sizes of less  than  10  acres.   A permit for the
on-lot  wastewater  disposal   system  would  be  required prior  to
occupancy.    Satisfactory  results  from  the  required  physical
inspection are necessary before the permit could be renewed.
                                15

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Table 8.  Buckingham Township Management Program.
                           Owner of
Type of Wastewater System   System

Individual on-site system1

  Subsurface System        Homeowner
            Responsible
              for O&M
             Homeowner
            Construction
               Escrow    	
               Amount    Amount
                O&M Fund
                   Time Period
              $2,500 for one year per
                 present ordinance
Frequency of
   On-site
Inspection at
  Least Once
                                Every 3 years4
  Slow-Rate Land
  Application
Homeowner
Homeowner
$8,000 for one year
    Yearly
Community System (2 or
  more units)

  Subsurface System
Homeowners   Homeowners
Association  Association
             w/certified
             operator
              120% of    3 times
              estimated  est.O&M
              const.     costs
              cost
                                  Monthly
  Slow-rate Land
  Application
Homeowners   Homeowners
Association  Association
             w/certified
             operator
              120% of    3 times
              estimated  est.O&M
              const.     costs
              cost
                                  Monthly
1-Lots greater than 10 acres have not been included in the program based on the general ability  to
easily replace malfunctioning systems and the low density of development.

2Unused funds are returned to homeowner association or homeowner.

3Time period starts after all units are (1) completed and sold, and (2) occupancy permits for all
units have been issued by Township.

Inspection shall be by Township employee or private qualified professional (such as Sewage
Enforcement Officer, Professional Engineer, etc.).  Cost of inspection shall be borne by the property
owner.

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         CHAPTER 3.0.




COMMENTS RECEIVED ON DRAFT EIS

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           CHAPTER 3.0.  COMMENTS RECEIVED ON DRAFT EIS

     Throughout the preparation of the Environmental Impact State-
ment (EIS), EPA has  continuously  sought  participation from local,
regional,  State   and   Federal  agencies;  citizen  associations;
individual citizens; and interested environmental groups.  EPA  has
considered suggestions, criticisms, and objections from the public
in  documenting  the need  for  wastewater  treatment  facilities,  in
developing  wastewater  management  strategies,   and  in  assessing
potential impacts.  EIS newsletters, pamphlets,  advertisements  and
meetings  with  the public  have  been  used  to  ensure  that   all
concerned  parties   were   involved  in   the   EIS  decisionmaking
process.

3.1.  PUBLIC PARTICIPATION

     In accordance with the National  Environmental  Policy Act  and
EPA procedures for the  preparation  of  Environmental Impact State-
ments,   the public as well as  Federal, State,  and  local agencies
were requested  to comment on  the  Draft  EIS from May  27,  1981  to
July 21,  1981.   In addition,  oral testimony on the  Draft EIS  was
received at the Public Hearing held on July 9,  1981.

     In  total,  EPA  received  written  responses  from  4  Federal
agencies, 1  State agency, 2 county  agencies and  from 1 citizen.
Oral testimony at  the Public Hearing  was  presented by representa-
tives  of one  State  agency,   one  County  agency,  three  Township
officials and eight citizens.

3.2.  KEY COMMENTS

     From EPA's  perspective,  all  comments  are  helpful  in formu-
lating   its   conclusions.    From  all  the  comments  received   the
following concerns are considered  by EPA  to  be among  the most
important:

     •  operational impacts especially health effects  of
        spray irrigation

     •  the possible use of the Buckingham Elementary  School
        system to provide wastewater treatment  for portions
        of the Township

     •  the direction of management programs for clustered
        and scattered areas of the Township with wastewater
        disposal problems as well as for  future
        growth-related wastewater needs

     •  uncertainties of Federal funding

     •  wastewater management needs
                                17

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3.3.  DISCUSSION OF ISSUES AND CONCERNS

3.3.1.  Spray Irrigation

     There are more  than 700 land  treatment  systems operating  in
the United States  with many  of  these systems  being in operation
prior to 1930  (1)(2).  More  than 500 of  these have been in opera-
tion for more than 10 years.  Studies have demonstrated that there
is no increase in harmful contaminants, no additional health risks
and  there  have  been no  reported disease  outbreaks from  any  of
these facilities (2).  A well planned and operated land treatment
system poses no  significant  health  problems,  and it is as safe  as
traditional methods  of  wastewater treatment  which discharge  into
lakes or streams (2).

     The Pennsylvania Department of Environmental Resources (DER)
adopted a Spray  Irrigation Manual (1972)  which is a guide to  site
selection and  system design,  including  preparation of  plans   and
reports which  are  to  be  used  in  conjunction with  sewerage   and
industrial waste manuals  (3).   In addition,  the Board of Supervi-
sors of Buckingham Township  have adopted  an ordinance (No.   4-78)
for  the design,  construction,  installation  and  maintenance  of
spray irrigation systems  (4).  The preparation of  these guidelines
and ordinances utilized  the  results  of over 15 years of experience
at Penn State University.  The guidelines,  rules  and requirements
of DER  and  Buckingham Township must  be  followed  in  the design,
construction  and operation  of  any   spray  irrigation  systems  in
Buckingham Township,  including  the  solutions recommended  in   the
201 Facilities Plan and Environmental Impact  Statement.

     The  following  are  answers  to  specific  questions  raised
concerning the proposed  spray  irrigation  facilities.

Groundwater Quality

Since  the  Township  is  in  the  position  of  relying  on   its
groundwater for nearly all present and future uses,  the quality of
the available supply must  be verified.   Except for the effects  of
man,  groundwater  quality  is  a  function  of   the physical   and
chemical composition of  the  soil  and  rock through  which it travels
and  the  time  the  water  spends  in  contact with  these materials.
The various influences of man on  groundwater  quality in Buckingham
Township include primarily wastewater disposal,  fertilizer use and
highway maintenance (salt).    Although   the  occurrence  of  these
factors does not imply degradation  of the groundwater, inadequate
design  and poor  management  may  result  in  adverse  impacts.    The
purpose of this  section  is  to evaluate groundwater quality in the
Township  and  to  identify any  areas where  potable water  is   not
available.

Samples were taken from  groundwater  (wells and spring) and streams
through the Township for a period of  one  year.  These samples  were
                               18

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analyzed  for the major  ions, pH and  silica.  The majority  of  these
constituents  appeared  in  levels  indicative of  the  native  rock
formations.  Only  10  percent of  the well samples exhibited  levels
in excess of  EPA's guidelines for nitrate,  while  over 40 percent
were  less than  5  ppm  which is  well  below the  allowable  limit.
This  indicates  that  only  isolated point  source  contamination  of
groundwater is  occurring  in  the  Township.   Overall water  quality,
as reflected  by the  sampling  program,  is  good.    In most  cases,
only background  levels  of water quality  parameters  were present.

In addition  to  this  program,  the Bucks County Health Department
has  been investigating  the  occurence of  trichloroethylene  (TCE)
contamination  in  several  wells  in  the Furlong area.    TCE  was
discovered in 16 wells  in the area in  December  1979.   This contam-
ination  is  limited to  the  immediate vicinity  of  Furlong  in  both
Doylestown and  Buckingham Townships.   There is  no evidence  that
this  pollutant  has  had  an overall  effect on the groundwater
quality of the Township.

Operation and Maintenance

The Township Supervisors  shall obtain  necessary financing, to own
and be responsible for  the  operation and maintenance of the  spray
irrigation facilities at  Red Gate  Farms  (Argus  Drive  section)  and
Buckingham Village.   The Supervisors may  assign  to the Sewer  and
Water Commission the  day-to-day operation  and  maintenance of  the
facilities, including collection of  revenue and payment of bills.
The certified operator  of the facilities  may report  to the  Sewer
and Water Commission.

Type of Spray Field (Disposal Site)

The  spray field will be  for agricultural  use.  The crops  grown
would be  reed canary  grass,,  corn,  hay  or other crops  suitable  for
feed  to  animals only.   No  crops  for  human consumption  will  be
grown.  A public agency (Board  of  Supervisors)  shall  be responsi-
ble and monitor  the operation of the facilities.  In  addition,  the
operational permit issued  by DER shall  establish the type of  use
for the spray field.  The Supervisors will  have an  operational and
maintenance plan incorporating  the  requirements of  DER.   DER  is
responsible for  inspecting  all  spray  operations in  Pennsylvania.
Groundwater  monitoring  wells   shall   be  installed  and  tested
quarterly.

Transport of Effluent to Spray Field (Disposal  Site)

The effluent after treatment and chlorination  shall  be pumped  to
the spray field  in a  buried  force  main.   The main  shall be buried
with  at   least  3  feet  of earth  cover  over  the pipe  to prevent
damage from freezing.
                                19

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Spray Irrigation Facilities

In general, the proposed  spray  facilities shall consist of  lagoon
treatment and  storage  system, chlorination,  pumps,  force main  and
sprinklers.   Any  noise  producing equipment  such as  pumps, com-
pressors, etc. shall be housed  to prevent any noise impacts.   The
actual  siting of  the  facilities  shall be  done  during  Step  2
(design)  of  EPA's Construction  Grant process.   The  distance  to
nearest residence  shall be  in accordance with requirements  of  the
Township  and  DER.   No residence  would be within 200  feet  of  the
proposed  facilities.   Based on  research, literature  review,  and
operational experience, the  proposed  facilities will have  minimum
environmental  impact (1)  (2) (5)  (6)  (7)  (8)  (9)  (10)  (11).   It is
possible  that  some farmland  used  for  human consumption crops will
be changed to  crops for animals only.

Freezing Conditions

The spray system  will not  operate when the  spray  fields are  not
able to  receive  the  effluent.   The spray  pumps shall be manually
operated.  Storage ponds shall be provided   to  store  120 days  of
effluent.   This  storage, in  addition  to  being used  for  frozen
conditions, can be used for wet conditions or farming  operations.

Mosquito

There  is  the  potential   that   there  could  be an   increase   in
mosquitos if  the system  is  not  designed, constructed and operated
correctly.   This   shall be  constrolled  by  following  the require-
ments of  DER  and  Township and maintaining   proper operation.    A
conventional   mosquito  control   program   shall  be  maintained,
including proper grass cutting  at the  lagoons  and  the prevention
of ponding in  the  spray fields (2).

Aerosols

There has been extensive  literature  reviews of potential  health
effects  from   emissions  with land application   facilities   to  the
workers and nearby population.  The results are:

     "No  adverse health effects have  been reported in
     workers or in nearby populations at wastewater
     spray application facilities  . .  .  Data  from viral
     and  bacterial monitoring of wastewater and  aerosols
     indicate  that buffer or safety zones may not be
     necessary between wastewater  treatment plants or
     spray application facilities  and the surrounding
     population ceners.n(8)

Floodplains

The  most desired  spray  irrigation  site is located  beyond  the
limits of the floodplains (Figure 3).   Also, since  the Draft  EIS
was  released, the  potential spray  irrigation   site  underlain  by


                                20

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Figure 3.  Location of most desired spray irrigation site beyond
  floodplain boundaries identified in Buckingham Township zoning
  ordinance.


                                   21
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limestone has been  eliminated  from consideration by the Sewer  and
Water Commission.

3.3.2.  Alternative to Use Buckingham Elementary School Wastewater
        Treatment Facilities Prior to Land Application

     DER  recommends  a  minimum  of secondary  treatment  prior  to
spray  irrigation.    This  secondary  treatment  level  followed  by
chlorination has been established  from  health standards (1)  (11).
However, such a  treatment  level  reduces the  economic value to  the
farmer, as nutrients  in the wastewater  are extracted.

     Mr. Kiddle's alternative  is attractive because  the Buckingham
Elementary School plant  is  an  existing  facility.  If the  existing
plant were expanded for wastewater flows up to 30,000 gpd  it  would
be  less costly  than a  new  lagoon treatment  system.    However,
lagoon systems have proven less expensive to operate and maintain.
Since  the  projcted  flows  from  Red  Gate  Farms   and  Buckingham
Village  exceed   30,000  gpd  (44,600  gpd),  a  lagoon/spray system
would  be more   economical  than  a  Buckingham  Elementary School
treatment plant/spray system.

3.3.3.  Management Programs

     In  the adopted  201  Plan,   the  Buckingham  Sewer  and  Water
Commission recommended  that the management plan require  periodic
inspection  of  all  Township  wastewater  treatment  systems;   such
inspections  to be  of the  type and frequency as described in  the
EPA Construction Grants program  [CFR 40, Section 35.918-l(i)].

     With the exception of the integrated wastewater facilities to
service  Red Gate   Farms  (Argus   Drive section)   and  Buckingham
Village,  which  will  be  owned,  operated,  and  maintained  by  the
Township Supervisors, the recommended management program calls  for
homeowner's  associations  to  own  and be  fully  responsible  for  the
operation and  maintenance of  all  other community  systems in  the
Township.

     With  the  land  disposal  approach  adopted   for  wastewater
management disposal,  homeowners's  associations may be responsible
for techniques that are  more  complicated than subsurface  disposal
methods, e.g. spray irrigation.

     In  order  to  properly construct,  operate,  and  maintain  the
systems under the  land  disposal approach a  management program  is
required.  Existing  management actions are not  adequate and  must
be improved  so that the  land  disposal  approach can be instituted.
The Facilities  Plan's recommended actions include  the  following
measures above and beyond current  practices:

     •  The Township  shall continue the present practice of
        reviewing plans and system design of all wastewater
        systems for conformance with the official Sewerage
        Facility Plan and present  ordinances.


                                22

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The Township shall implement all aspects of the
present ordinances concerning sewerage systems and
land disposal by spray irrigation and subsurface
disposal.

The Township shall prepare and adopt new ordinances
which shall provide the administrative features shown
in Table 8.  The features established in the Table
are:

-System ownership:  all individual on-site systems
 shall be owned and maintained by the owner (i.e.,
 homeowner).  For community systems, excepting Red
 Gate Farms and Buckingham Village, the ownership and
 maintenance shall be the responsibility of homeowner
 associations.  The daily operation and maintenance
 of community systems shall be by a DER certified
 operator (paid for by the homeowner associations).

-Financial aspects:  a construction escrow managed by
 the Township for all new systems shall be required
 as follows:

   individual subsurface systems $2,500 for one year
   (per present ordinance)

   individual slow-rate land application systems
   $8,000 for one year

   community systems - 120% of the estimated con-
   struction cost as approved by Township Engineer
   until construction is completed to satisfaction of
   Township Engineer

 In addition, an operation and maintenance (O&M) fund
 shall be established for all community systems.
 This fund shall be retained by Township for a 2 year
 period and be an amount equal to the estimated
 yearly operational and maintenance cost times three.
 The 2 year time period does not start until all
 units are completed and sold and occupancy permits
 for all units have been issued.

 All unused monies from the construction escrows
 and/or O&M funds shall be returned to the homeowner
 or homeowner association.

-On-site inspections:  on-site inspections of
 individual systems shall be conducted by a qualified
 individual either employed by the Township (full or
 part time) or a qualified individual from the
 private sector.
                        23

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         Community systems shall be inspected by a qualified
         individual employed by the Township.  The frequency
         of inspections shall be:

           individual subsurface systems - once every three
           years

           individual slow-rate land application - yearly

           community systems - monthly

         The homeowner or homeowner association shall pay for
         the cost of these inspections.

3.3.4.  Uncertainties of Federal Funding

     Each of the projects that competes for EPA Construction Grant
funds is assigned a  "priority point"  ranking  by PA-DER.  Projects
become  eligible  for  Federal   funding  based  on  their  priority
ranking.   Presently the Buckingham  project has been  assigned 71
points  by  PA-DER.    During  fiscal  year  (FY)   19(51,   which  ends
September 30, 1981, 70 points were required to qualify  for Federal
funding through EPA's Construction Grants program.

     EPA  anticipates  that  if  a  grant  award  offer  is made  to
Buckingham  Township  during  FY 81  sufficient  funding  will  be
available to implement the project.

     EPA's policy  is  to  encourage  and, where possible, to assist
in the development of  innovative and  alternative technologies for
the construction  of  wastewater  facilities.   Projects  or portions
of projects which the EPA Regional Administrator  determines meet
criteria for  innovative or  alternative  technologies  may receive
85-percent grants.

     All of the Buckingham project will  qualify for "alternative"
technology funding.   EPA has earmarked  special funds  to pay the
additional 10-percent of project costs  above  the conventional EPA
funding level of 75-percent.   However, this category of  funds will
no longer be available to Buckingham Township after September 30,
1981.  Therefore, if  a grant offer is  not  made  to the Township by
this  date,  these  additional   "alternative"  funds  will  not  be
available.
                                24

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             CHAPTER 4.0.




IMPLEMENTATION OP RECOMMENDED ACTIONS

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       CHAPTER 4.0.  IMPLEMENTATION OF RECOMMENDED ACTIONS

     The recommended actions described in this Final Environmental
Impact Statement represent  3 years  of coordinated efforts between
EPA  and  Buckingham  Township.    EPA  believes  that  these actions
provide  a  sound wastewater management  system  that  is  not only
cost-effective and environmentally sound, but also implementable.

     To  this end  the  Buckingham  Township  Board of  Supervisors
passed Resolutions  702  and 703  on  August 12,  1981  (Appendix C).
These resolutions adopted  the Township's  201  Plan as the official
Township Plan.   The Buckingham Township  Board  of Supervisors has
provided the necessary  funds for the  Sewer and Water Commission  to
have  a  Step 4 Construction Grants  application  prepared  for sub-
mission  to  PA-DER  and  EPA.  A Step 4   application  combines the
actions of Steps 2 and  3 within EPA's Construction Grants process.
The Step 4  phase will permit the grantee to  design  and  construct
wastewater  management  facilities for  the Township.    EPA antici-
pates this  submission of a  Step 4  application  from  the Township
during September 1981.

     Buckingham's Step  4 application  will initially be reviewed  by
PA-DER.   The State  must first  certify that  the project is accept-
able for design and construction of the proposed  facilities  before
the application is forwarded to EPA for further evaluation.   Since
PA-DER has been delegated additional  responsibilities within EPA's
Construction Grants  Program,  they  will not only  certify  that the
application  is consistent  with State  regulations and guidelines,
but also will verify that  the project is in  conformance  with the
acceptable  alternative  described in  this Final  EIS.   The  Step 4
review process  should  be  completed  within  a two week   timeframe
from the date of its official submission  to PA-DER.

     Once EPA has received  a certified application from PA-DER, a
final review of the project will be conducted for conformance with
EPA regulations and  guidelines.  Both the design and construction
proposals submitted  by  the grantee  (Buckingham  Township  Board  of
Supervisors) must be consistent with  the  recommendations  contained
in the Final EIS.    If  the project  is  approved  by EPA  staff,   it
will  be   forwarded   to   EPA's   Regional   Administrator  for   final
decision  and eventual  grant  award  to   the  Township.   EPA has
several  concerns  that must   be   addressed   during   the   review
process:

     •  EPA has a limited amount of funding set aside for
        innovative and  alternative approaches to  meet waste-
        water needs.  The total Buckingham solution will
        qualify for alternative funding.  However, the
        special funding category may  not  be available after
        September 30, 1981.  Therefore, EPA in conjunction
        with PA-DER will make every effort to obtain a grant
                                25

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award for Buckingham Township prior to this date.
This will enable the Township to obtain an additional
ten percent funding level for those portions of the
projected classified as alternative.

During the preparation of the Step 4 grant applica-
tion by the Township, EPA and PA-DER will provide
guidance to the Supervisors on that portion of the
scope of work describing the on-site management
plan.

During the design phase of the Step 4 process, EPA
will work with the Buckingham Supervisors and the
Bucks County Health Department (the monitoring
agency) to establish a coordinated program for
correcting individual on-site wastewater disposal
systems in accord with the recommended Buckingham
Township Management Program.
                        26

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    CHAPTER 5.0.




CURATIVE AMENDMENTS

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                CHAPTER 5.0.  CURATIVE AMENDMENTS

      Seven  landowners  filed amendments to  the  Buckingham Zoning
Ordinance in 1974.  These  curative amendments collectively amount
to 8,095 additional dwelling units, or an equivalent population of
nearly 26,000 or three times the preliminary  1980 census count for
the  entire  Township.   The  Buckingham  Township  Facilities  Plan
evaluated several alternatives for meeting the wastewater needs of
these  developments.    The  evaluation  concluded  that  stream dis-
charge  alternatives  are   undesirable  for   serving  the  curative
amendment developments.   The Commission stated that  stream dis-
charge  alternatives  have   the   greatest potential  to  adversely
impact the  Township's water resources.   However,  the Commission
also  acknowledges  that the  land disposal  treatment of wastewater
would  not  permit the  complete  development  of all  proposed units
unless additional lands were secured.

      EPA's  final  position  regarding  the curative  amendments is
the same as  appears in the Draft EIS.  Namely, if these projected
developments are constructed as  proposed,  they have the potential
to adversely affect the groundwater  resources of Buckingham Town-
ship.   In  addition  they   would  place  a  severe  strain  on  the
existing public and community services of the Township.

      Virtually  all  of the  land proposed for  these  developments
were  in agricultural use as of October 1975.  Furthermore,  approx-
imately 70%  of  the  land  area   for  these projected  developments
consist of prime agricultural soils.   Both the Township's  Compre-
hensive Plan and EPA's Agricultural Land Policy strongly urge that
agricultural activities be preserved.

      The  impacts  resulting  from the  seven  curative amendments
would  be  reduced if  fewer units  are constructed.   Coupled with
this,  some  type  of   land .  application   of   wastewater  could  be
utilized (spray irrigation,  subsurface disposal, etc.) which would
help  to  preserve open  space,  recharge  groundwater  supplies,  and
preserve prime  agricultural  land.    In  addition,  the  developments
would then be in closer conformance with the  non-sewered goals and
objectives of Buckingham Township.

      The wastewater   facilities  to  be  constructed to  serve  the
curative  amendments  will  not  be  eligible  for  Federal  funding.
Since Federal funds otherwise are  not involved,  resolution of the
curative  amendment   issues   ultimately  must   be  made   between
Buckingham Township and the  landowners.

      The  Chalfont-New  Britain  facility planning  efforts  have
indicated  that  the wastewater   flows  from  five  of  the  proposed
curative  amendments  sites  may  be  treated  at   an  expanded  and
upgraded Chalfont-New  Britain sewage  treatment  plant.   EPA will
further assess  the option  of accomodating the curative amendments
in its ongoing Chalfont-New Britain EIS.
                                27

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REFERENCES

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                            REFERENCES

(1)    Survey of Facilities Using Land Application of Wastewater,
      EPA 430/9-73-006,  U.S.  Environmental Protection Agency,  July
      1973.

(2)    Health Effects of  Land Treatment - Is It Really Safe?,  U.S.
      Environmental Protection Agency, March 1980.

(3)    Spray  Irrigation Manual, Pennsylvania Department of
      Environmental Resources, Bureau of Water Quality Management,
      Publication No. 31,  1972 Edition.

(4)    Ordinance No. 4-78,  dated June 1, 1978,  Spray Irrigation,
      Board  of Supervisors, Buckingham Township.

(5)    Recycling Treated  Municipal Wastewater and  Sludge through
      Forest and Cropland, the Pennsylvania State University,
      1973.

(6)    D.R. Tatman, D.P.  Lee,  "Recycling of Water  at Kendal,
      Pennsylvania" at Joint Annual Meeting of Chesapeake Water
      Pollution Control  Association and Water  and Waste Operators
      Association of Maryland, Delaware and District of Columbia,
      Ocean  City, Maryland, June 5, 6, and 7,  1974.

(7)    An Approach for Comparing Health Risks of Wastewater
      Treatment Alternatives,  A Limited Comparison of Health  Risks
      Between Slow Rate  Land Treatment and Activated Sludge
      Treatment and Discharge, EPA 430/9-79-009,  U.S.
      Environmental Protection Agency, September  1979.

(8)    A History of Land  Application as a Treatment Alternative,
      EPA 430/9/79-012,  U.S.  Environmental Protection Agency,
      April  1979.

(9)    Environmental Changes from Long-Term Land Application of
      Municipal Effluents, EPA 430/9-78-003, U.S. Environmental
      Protection Agency, June 1978.

(10)   Vimala A. Majeti,  C. Scott Clark, "Potential Health Effects
      from Viable Emissions and Toxins Associated with Wastewater
      Treatment Plants and Land Application Sites".

(11)   Dr. Abel Wolman, "Public Health Aspects  of  Land Utilization
      of Wastewater Effluents and Sludge", Journal  Water Pollution
      Control, November  1977.
                                29

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                            PREPARERS

This Final Environmental  Impact  Statement was prepared  by  the US
Environmental Protection Agency - Region  III,  Philadelphia, Penn-
sylvania with assistance from WAPORA, Inc.

Key personnel from EPA included:


        Richard V. Pepino         Project Monitor
        Barbara D'Angelo          Construction Grants Program
        Rosemarie Baldino         Production Advisor
Key personnel from WAPORA, Inc. included:
        David J. Lechel           Project Administrator
        Valdis Jurka              Project Manager
        Joseph Andrea             Biologist
        Elizabeth M. Kolb         Graphics Specialist
        Susan B. Beal             Production Manager
                                31

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BUCKINGHAM EIS DISTRIBUTION LIST

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     BUCKINGHAM EIS DISTRIBUTION LIST

FEDERAL AGENCIES

US Department of Transportation
  Federal Highway Administration
  Marine Environmental Protection Division

Council on Environmental Quality

US Department of Agriculture
  Soil Conservation Service

US Department of Treasury

US Department of Defense

US Department of Health, Education,
  and Welfare

US Department of Interior
  Bureau of Outdoor Recreation
  Fish and Wildlife Service
    National Water Resource Analysis
      Group/Eastern Energy Land Use Team
  National Park Service

US Department of Commerce
  Office of Environmental Affairs

Advisory Council on Historic Preservation

Water Resources Council

US Department of Housing and Urban
  Development

US Department of Energy
  Office of the Secretary for the
    Environment

US General Services Administration

National Agricultural Lands Study

US Bureau of Prison

Federal Emergency Management Agency

PENNSYLVANIA STATE AGENCIES

Department of Environmental Resources
  Bureau of Water Quality Management
  Bureau of Air Quality
  State Health Center
                   33

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PENNSYLVANIA STATE AGENCIES (Cont.)

Department of Health

Department of Community Affairs

Department of Commerce

State Clearinghouse

Historical and Museum Commission

Fish Commission

Game Commission

REGIONAL AGENCY

Delaware Valley Regional Planning Commission

BUCKS COUNTY AGENCIES

Bucks County Planning Commission
Bucks County Health Department
Bucks County Water and Sewer Commission

LOCAL AGENCIES

Buckingham Township
  Supervisors
  Sewer and Water Commission
  Planning Commission
  Zoning Hearing Board
  Park and Recreation Board
  Historical Commission

CITIZENS GROUPS

Bucks County Farmers Association
Buckingham Village Neighborhood
  Association
Durham Village Neighborhood Association
Wycombe Residents Association
Buckingham Township Civic Association
Buckingham Taxpayers Association
Buckingham Business Association
League of Women Voters
Wycombe Village Association
Bucks County Conservancy
Bucks Township Civic Association Board
Bucks County Builders Association
Buckingham Civic Association
                   34

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ELECTED OFFICIALS

Honorable Richard Thornburgh
  Governor of Pennsylvania

Honorable H. John Heinz, III
  United States Senator

Honorable Arlen Specter
  United States Senator

Honorable James K. Coyne
  United States Representative

Honorable Edward L. Howard
  Pennsylvania Senator

Honorable James Greenwood
  Pennsylvania Representative

MEDIA

Newspapers

Daily Intelligencer
Today's Post
North Penn Reporter
Time Herald
Bulletin
Daily News
Inquirer
Montgomeryville Spirit
Bucks County Courier Times
Beacon News
Bucks County Tribune
Today's Spirit
New Hope Gazette
Bucks County News Bureau

Radio                TV

WCSD-FM              WCAU-TV
KYW-AM               WKBS-TV
WCAU-AM              WPHL-TV
WDAS-AM              WTAF-TV
WFIL-AM
WFLN-AM
WHAT-AM
WZZD-AM
WIP-AM
WRTI-FM
WXPN-FM
                   35

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                      CITIZENS
Aungst, Robert E.
Beddington, Tom
Boerneer, Rich
Boyle, Rich
Bready, Ed
Burch, Mr. & Mrs. Dale
Bye, Mary
Coburn, Forrest
Colie, George
Denoon, Jr., C. F.
Driedant, Charles E.
Eisner, Judy
Ely, Ms.
France, Howard B.
Gwertletz, Earl
Huang, Susan
James, Tom
Jennings, William
Kalinowski, Ed
Kiddle, Bradley D.
Kinney, Charles K.
Kiser, Warren
Knight, Ernest II
Long, Judy
McKinney, Mary
McNeely, Stephen
Malriat, J. P.
Morris, John R.
Niedhardt, Dave
Pierce, E. Taylor
Reid, Norman
Salvadore, Tome
Scott, Herb
Sharp, Jamie
Shurday, Charles E.
Smith, Gerald
Smith, Kinney
Smith, Mikle
Szabo, Fred
Teel, Mr. & Mrs. Robert
Thorrick, Joseph
Valimont, Robert
Warren, Hazel
Week, Dan
Weisel, Don
Wnukowski, Linda
Wojcik, John
Wydro, Walter
Yerkes, William
Ziesel, John G.
OTHER

WAPORA, Inc.
International Research & Evaluation
Tatman and Lee Associates, Inc.
                         36

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          APPENDIX A




EXECUTIVE SUMMARY OF DRAFT EIS

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                       EXECUTIVE SUMMARY
           National
      Environmental
         Policy Act
Buckingham Township
   Priority Funding
      of Wastewater
         Facilities
Identified Problems
       Alternatives
          Developed
The National  Environmental  Policy Act  (NEPA)  requires all Federal
aqencies to  prepare  Environmental Impact Statements  (EIS)  on each
major Federal action that has the potential to significantly  affect
the quality of the human environment.  A major purpose of an  EIS  is
to  explain  the  environmental  consequences  of  pending  Federal
actions, such as  funding  for construction  projects,  in order that
government officials and the public can make responsible decisions.
Federal  funding  for  wastewater  treatment  facilities  through the
U.S. Environmental Protection Agency's  (US-EPA) Construction  Grants
Program  is one of  the Federal actions  subject  to the requirements
of NEPA.

This Draft Environmental  Impact Statement  (EIS)  has  been  prepared
by  US-EPA  in relation to  a request  submitted   by  the Buckingham
Township  Board  of  Supervisors  for  Federal  funding  to  plan for
wastewater management  facilities for the Buckingham  area of  Bucks
County, Pennsylvania.

Each of  the  projects  that  competes  for US-EPA  Construction  Grant
Funds  is assigned  a  Priority  Point ranking  by  the Pennsylvania
Department of  Environmental Resources.   Projects  become  eligible
for Federal  funding  based on their  priority ranking.   The State  is
currently reevaluating its  ranking.   Depending on the  "new" ranking
assigned  to  Buckingham Township,  its  likelihood for  funding may
increase or decrease.  It is important  to note that at  the  time the
Facilities  Plan  was  initiated  the  project  did have  sufficient
priority points to qualify  for US-EPA funding eligibility.

Though  Buckingham Township  has  traditionally maintained  a  rural/
agricultural  character,  the changing land  use  patterns associated
with increased  urbanization have become  apparent.   Since Federal
funds were utilized  for  the preparation of the  wastewater manage-
ment plan  (Facilities  Plan),  a  review of  the project was conducted
in  accord with NEPA.   US-EPA1s  evaluation  concluded that sensitive
environmental features,  such as surface and  groundwater  quality,
Township  water  supplies,  and prime  agricultural land,  should  be
given  special  attention during  the  preparation  of  the Facilities
Plan.    These environmental concerns  coupled  with  the   existing
development  pressures prompted  US-EPA to  prepare an  EIS concur-
rently with  the facilities  planning activities.

The Red Gate Farms (Argus Drive  Section) and the  Buckingham Village
sections  of  the Township were   identified  in  the Draft Facilities
Plan as  experiencing  individual septic tank malfunctions.    Apple
Hill  and  Canterbury  Estates,  which  have  community  subsurface
systems,  received  citations during the  Facilities Plan's  prepara-
tion requiring appropriate  corrective measures  to be taken.   Also,
scattered  throughout  the  Township   are  a  significant  number   of
individual  malfunctioning   on-site   systems.     Estimates  of the
failures on  a Township-wide basis  are  in  the range  from 12  to  15
percent.   This  means  that  the total  number of individual  failures
could easily exceed  300 homes.

In  response  to these identified  problem areas the following  alter-
natives were presented in the Draft Facilities Plan:

    Alternative  1.   The no-action  alternative describes  the
    continued  utilization  of  existing  wastewater treatment
    facilities   in   conjunction  with   current  management
    practices.
                                          A-l

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                          Alternative 2.   Spray  irrigation of wastewaters collected
                          from Red Gate  Farms and Central  Buckingham Village.  The
                          design  average  wastewater  flow  under  Alternative  2  is
                          12,800 gpd.

                          Alternative 3.   Use of  an upgraded  and expanded  package
                          treatment plant  at  Buckingham Elementary School to  accom-
                          modate  Red Gate  Farms   and   Central  Buckingham   Village
                          (16,800 gpd).

                          Alternative 4.   Spray  irrigation of wastewaters collected
                          from Red Gate Farms and Buckingham Village  (44,600  gpd).

                          Alternative 5.   Use of  an upgraded  and expanded  package
                          treatment  plant at  the  Buckingham  Elementary  School  to
                          accommodate Red  Gate Farms  and Buckingham Village  (48,600
                          gpd).

                      Included with  Alternatives 2  through 5, which  solely  address  Red
                      Gate  Farms  and Buckingham  Village,  are  the  following proposed
                      actions:

                      •  Apple Hill would  rehabilitate  its  community  subsurface system or
                         connect to the Red Gate Farms/Buckingham  Village  solution.

                      •  Canterbury Estates would rehabilitate  its community  subsurface
                         system.

                      •  Scattered malfunctioning on-site  systems  throughout  the Township
                         could take remedial measures consistent with  appropriate  land
                         disposal technology.

                      •  Areas to be  developed would  apply  site specific  non-sewered
                         techniques as determined by  the existing  soil  conditions.

                      •  The Township's existing sewered area,  which  is located in the
                         western corner of the Township  adjacent to the Cross Keys area
                         and has its  wastewater  conveyed to and treated at the Chalfont-
                         Mew Britain  wastewater  treatment  plant, is to  have  additional
                         connections  if and only if land disposal  techniques  are neither
                         cost-effective nor environmentally sound.

        Land Based    In the Draft Facilities Plan  the  Buckingham  Sewer and  Water  Commis-
Treatment Approach    sion emphasizes the collection  of wastewater through  a non-sewered
                      approach  and  the  treatment  of wastewater   by  land  disposal  tech-
                      nology.  These  approaches  to  wastewater management  are  in contrast
                      to  the  concept  of  regionalization whereby   all  wastewater  is
                      centrally  collected and treated.   The  land disposal,  non-sewered
                      methods of wastewater  handling  allow for development  in accordance
                      with existing  zoning and  rely on  the following approaches to solve
                      present and future  wastewater management  needs:

                      •  limited expansion and/or upgrading of  existing wastewater
                         facilities as necessary;

                      •  future needs to  be accommodated at a  decentralized  level  of
                         wastewater treatment (no stream discharge);

                      •  wastewater recycling to be accomplished as much  as  possible  by
                         septic tank  systems  and other  wastewater  renovation techniques
                         using land as part of the  treatment process.
                                            A-2

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   Management Plan
          Curative
        Amendments
     Evaluation of
      Alternatives
US-EPA's Preferred
       Alternative
In  order  to  be  eligible  for  Federal  funding on  a Township-wide
rehabilitation program  for  individual  on-site system  failures,  a
State  and  US-EPA  approved  Management  Plan   is   required.     The
approach  endorsed  in  the Draft Facilities  Plan retains ownership,
operation, and maintenance functions with the  individual.  However,
a Township authority must oversee the administration of  the Manage-
ment Plan.  The Hater and Sewer Commission proposes that individual
on-site subsurface disposal  systems  be  inspected  every three years
with more frequent  inspections  scheduled  for community and commer-
cial  wastewater  treatment  systems.     Such  an  inspection program
would be phased during a 3 year period.  Properties in excess of 10
acres  would  be  exempt  from  the  inspection  program.    A  permit
inspection system  would  be  established at  the Township level,  and
paid for  by  all  residents  with an annual fee  of  $12.   The obvious
economic  advantage of having  an  approved Management  Plan is  that
US-EPA will  fund  up  to  85%  of eligible costs  to  repair the 300  to
400  individual   residences   currently  experiencing  septic   mal-
functions.

Seven  landowners  filed  amendments to  the Buckingham  Zoning Ordi-
nance  in  1974.   These  curative amendments  collectively amount  to
8,095  additional  dwelling  units,  or  an  equivalent  population  of
nearly 26,000 or  three  times the  preliminary 1980 census count  for
the entire Township.  These  projected  developments, if  constructed
as  proposed, have the  potential to   adversely  affect  the  water
resources of  Buckingham  Township.   In  addition  they  would place  a
severe strain on  the  existing  public and  community services of  the
Township.

The Buckingham Township  Facilities Plan evaluated  several alterna-
tives for meeting  the wastewater needs  of these developments.   This
evaluation   concluded  that  stream   discharge  alternatives   are
undesirable   for   serving   the  curative   amendment  developments.
Stream  discharge  alternatives  have   the   greatest  potential  to
adversely  impact  the Township's  water resources.   The Commission
acknowledges  that  the land  disposal treatment of wastewater would
not permit  the complete development of  all  proposed  units unless
additional lands were secured.

The most  significant  issue  addressed  in  the Draft Facilities  Plan
and Draft EIS  is  the  land  disposal  method of  wastewater treatment.
As a result of the EIS investigations,  US-EPA  clearly  supports  this
approach  of  wastewater management  for  Buckingham Township in order
to maintain  the Township's rural/agricultural  character, as well as
minimize  the likely  development  pressure.    US-EPA's  analysis  of
these land application techniques for Buckingham Township  indicates
that they are environmentally sound  and cost-effective.

Of the five  alternatives presented  in  the Draft EIS, only alterna-
tives 4 and  5 are  eligible for Federal  funding consideration within
EPA's  Construction Grants  Program.   Alternative  1,  the  no-action
alternative,  can  be  dismissed  because  it does  not  address  the
existing water quality needs of the  Township.   Alternatives 2 or 3,
which  address  the wastewater needs  of Red  Gate  Farms and Central
Buckingham Village,  can  be  eliminated  because they are too costly
to implement and do not allow for reasonable growth.
Alternative 4 is US-EPA's preferred choice  as  a wastewater  solution
to  meet the  current  and proiected  needs  for Red Gate  Farms  and
Buckingham  Village.    This  alternative   is  most   consistent   in
supporting US-EPA's goals of encouraging  land  application of  waste-
water  and  preserving  prime agricultural  land.  Alternative  5 will
meet  similar  wastewater needs  for these sections  of the  Township
                                        A-3

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 Federal Funding
and User Charges
but will  utilize  a more centralized  approach  which will  involve  a
stream discharge to Mill Creek  at  the Buckingham  Elementary  School.
Though  this  alternative does  not  present  any ma3or  environmental
problems,  the  stream discharge  approach is  inconsistent with  the
Township's and US-EPA's primary goals for this  type of community.

Since  Alternative  4   conforms  to  US-EPA's  guidelines  for  small
community  systems, US-EPA  will  provide  funding up  to  the  85%  level
for much  of  the alternative's  implementation;  while,  Alternative  5
will be  funded only at  the 75% level.   The net result to the  user
of the  system will be  lower charges to individual  residents of  Red
Gate Farms and  Buckingham Village.   US-EPA's projection  indicates
that Alternative  4  will  cost  customers  S30  less per  year  than
Alternative  5.    The  following table   compares  some  of  the  key
economic  features of Alternative 4 and  5:
                    Estimated Total Capital Cost

                    Buckingham Portion of Costs

                    Cost Per Year (1980) Per User
                      Without US-EPA Funding
                      With US-EPA Funding
                                   Alternative
                                        4   	

                                     1,104,000

                                       188,900
                                         1,015
                                           294
Alternative
     5

  766,000

  191,500
      741
      324
       Potential
  Health Effects
      Conclusion
Because different technologies, such as  spray  irrigation,  are  asso-
ciated with  the  land  disposal  approaches to wastewater  management,
residents  are suspicious  that  additional  health  hazards  may  be
inherent with such  systems.   However,  no evidence currently exists
that  supports these  claims,  providing  that  the  implemented  land
disposal techniques are properly managed and maintained.

In  conclusion,  the Draft  EIS  findings  strongly support  the  land
application method of wastewater treatment  Cor  Buckingham  Township.
This  approach will surely  supply  the  greatest protection  to  the
Township's water resources and  prime agricultural land.
                                         A-4

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         APPENDIX B

  PUBLIC HEARING COMMENTS/
COMMENT LETTERS ON DRAFT EIS

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                     PUBLIC HEARING COMMENTS

Organization/Individual;  Robert Valimont

                                                          Addressed
                     Concern/Issue                         On Page
If a house was built after December 27,  1977  then  its         9
owner would not be eligible to receive Federal  funds to
help correct any malfunctions in the  house's  on-lot
disposal system?

It was suggested that all septic tanks be  pumped out by       9
the Township on a 3 or  4 year, regular basis; so
ordered by a Township ordinance.  This would  save  the
money otherwise to be spent on an inspector who isn't
going to be able to determine groundwater
contamination.

Who is liable for the inspections made on  private            16
property, the Township, the Board of  Health?

Who is going to require repair of failing  on-site          16,  19
wastewater disposal systems?

The ten acre exemption  allows some persons to be             16
excluded from the management plan.  Why  can't people on
smaller lots receive exemptions.

Is a public referendum  by ballot a feasible alternative    25,  26
to any part of the 201  or EPA studies?   Is November too
late for the Water and  Sewer Commission  or EPA  to
complete their studies?

If the funding was requested and granted,  and the            yes
referendum took place afterwards and  (the  vote
indicated) that funds should be rejected.  Can  they be
returned to the Federal Government?
Organization/Individual;  George Collie
                                                          Addressed
                     Concern/Issue                        On  Page
Although it was discussed that prime agricultural  land      19
should be protected, forty to sixty acres of that  land
would be taken for spray irrigation.

It is of concern that funding would only be available       5, 6
for plans to treat 44,000 gallons  (per day) or more of
sewage which is more than just the Village of
Buckingham produces.

There is a controversy whether Red Gate can take care       10
of their problems on their own land.  If they can, then
there would be no need to bring it to the Buckingham
(Village solution)?
                               B-1

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Organization/Individual;  George Collie  (cont.)

                                                          Addressed
                     Concern/Issue                        On  Page
The plant in Buckingham should be upgraded  to produce       22
99% pure water which can then be used  for land
application.

A second choice in disposal of the water would be  to        12
apply it underground (directly).  The  third choice
would be to discharge to surface waters, and only  as a
last resort use a spray system.

Costs to personally correct wastewater problems  amount      14
to $2,000 to $2,500 whereas if solutions involve the
Federal Government it's probably going to cost $3,000
to $3,600 per lot although only approximately $600 will
be from the resident.  However the personal financing
approach is preferred because the Federal monies are
out of the resident's pockets indirectly.

The population estimates for the year  2000  are too high     27
and should be nearer to 16,700 not 48,000.

The holding lagoon shown on the map is over an area           4
where there is limestone.  There should be  no lagoon on
limestone because of possible caveins.

Are the 71 DER points with which the Township qualifies     24
for funding with or without the management  plan?  And
are they based on a 44,000 gallon system or would  a
15,000 gallon system also quality?  Is DER  currently
favoring larger or smaller treatment facilities?

What must be done to the Buckingham Elementary Plant to     22
enable it to handle the effluent from  Central
Buckingham Village?

Organization/Individual;  Brad Kiddle

                                                          Addressed
                     Concern/Issue                        On  Page
Would the elementary school treatment  plant with            22
additional effluent flows require upgrading if the
effluent were spray irrigated?
                               B-2

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Organization/Individual;  Norm Reid
                     Concern/Issue
What treatment or chemical reaction takes care of the
viruses coming from the wastewater to be spray
irrigated?
Addressed
 On Page
   20
Organization/Individual;  Dr. Taylor
                     Concern/Issue
Would the School Board tolerate spraying and accept the
responsibility for spraying live viruses within 1/2
mile of the school?
Addressed
 On Page
   20
Organization/Individual:  Bill Jennings
                     Concern/Issue
At what time in the decision making process does the
community make the decision as to whether or not it
wants funding?
Addressed
 On Page
   25
Organization/Individual;  Bill Yerkes
                     Concern/Issue
What was the source of information used by Mr. Tatman
as the basis in determining the underground water
supply figure?  Also, where does the underground water
supply come from; is it actually recharged in
Buckingham Township?
Addressed
 On Page
Draft EIS
  8-10
Organization/Individual;  Gerald Smith
                     Concern/Issue
A major concern was that the problem within the Town-
ship concerning on-lot systems, groundwater, and
surface waters was not properly surveyed and that  it
isn't understood by anyone.

It was suggested that evaporation from on-lot systems
could be used to eliminate wastewater faster than
percolation.
Addressed
 On Page
 9, 26
   10
                               B-3

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                    SYNOPSIS OF WRITTEN  COMMENTS


Letter Number;  1

Organization/Individual;  Dr. Frank  Lisella,  Chief
                          Environmental  Affairs Group
                          US Public  Health  Service

                                                          Addressed
                     Concern/Issue                         On Page

The potential  impacts of  spray irrigation on  surface       18,  19
and groundwater supplies  were not adequately  addressed.
Isn't current  water quality information  necessary to do
this?

How is the effluent to  be treated prior  to  spraying?         20
Is the holding pond part  of the treatment or  are there
settling tanks?  If so  where will the  sludge  be
disposed of?

What are the characteristics of the  sprayfield  in          19,  30
relation to runoff and  soils?  Who will  monitor surface
and groundwaters?

It is suggested that the  Final EIS indicated  whether      20,  21,  22
the proposed area can be  used for spray  irrigation
(based on the  incidence of sink holes) or if  an
alternate site will be  required and  where it  might  be
located.

Who is going to operate the spray system?                    19

What types of  increases in insect populations may be         20
expected from  spray irrigation and the proposed holding
pond?  What measures will be used to control  pest
species and who will be responsible  for  these
measures?

What vegetation control procedures will  be  utilized and     19,  20
who will be responsible for them?

How will present residents and future  developers in the      16
area be required to use the proposed system?
                                B-4

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Letter Number;  2

Organization/Individual;  Lee Thomas, Director
                          Bureau of Environmental Health
                          Bucks County Health Department

                                                         Addressed
                     Concern/Issue                        On Page

Are "adequate" areas of suitable soils to be available      21
for spray irrigation.

With regards the proposed management plan, the Depart-    16,  22
ment supports options 3 and 4 for the individual on-
site systems, but prefer option 1 for community and
integrated community systems.

It is unlikely that all malfunctioning individual           26
systems can be corrected by a SAS or elevated sand
mound as implied in Table 21.  Holding tanks may be
required on some sites.  No costs of construction,
operation, and maintenance of holding tanks have been
included in Table 21.

Letter Number;  3

Organization/Individual;  Staff
                          Bucks County Planning Commission

                                                         Addressed
                     Concern/Issue                        On Page

Can failing community on-site sewage systems be             12
rehabilitated?

A public assurance program and on-site management plan      16
is favored.

Concern was expressed about the homeowners associations     22
being responsible for operation and maintenance of
community on-site systems.

It is suggested that the Township apply for Federal         25
funds to implement their wastewater facilities
program.

Development over limestone areas should be regulated.     20,  22

It is recommended that there be a maximum recharge of       i
groundwater in an environmentally sound manner.

It is urged that there be careful implementation of the   16,  26
non-sewered approach to ensure proper design and
installation followed by on-going proper operation and
maintenance of wastewater facilities.

                               B-5

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Letter Number:  4

Organization/Individualt  Harry Staller
                          Acting Regional Administrator
                          Department of HUD

                                                         Addressed
                     Concern/Issue                        On Page

The 100 year floodplain of Mill Creek  in relation  to        21
the land proposed for spray irrigation has not been
properly indicated.  Therefore, it  is  recommended  that
in the Final EIS the location of the floodplains and
the potential spray irrigation sites be mapped together
on a scale suitable to show that there will not be an
impact on the 100 year floodplain.  The source of  the
floodplain information should be included.

Studies have not thoroughly examined the operation and      20
maintenance of the system sufficiently to indicate that
there would be no odor or health problem.

It is recommended that a one page description of the        20
spray system and its operation be included.  This
should address the potential for active agricultural
use of the site, the crops, and how they will be moni-
tored.  It also should discuss the effluent transport
system, the facilities required for effluent disposal,
the distances between facilities and residences, and
possible environmental impacts.  Operation of the  spray
facility during sub-freezing weather should be
included, noting the lowest temperature the facilities
can be operated at and how long the operation can  be
shut down without serious impacts.

Letter Number;  5

Organization/Individual;  Bradley Kiddle


                                                         Addressed
                     Concern/Issue                        On Page

It was suggested that by piping wastewater from Buck-       22
ingham Village to the elementary school's treatment
plant for treatment, and then spraying the treatment
plant's effluent on farmland, could decrease the cost
of Alternative 4 by over one-half million dollars  or
more.  The savings would involve the 37 acres which
would not need to be purchased for  the spray fields and
the reduction in the upgrading of the  treatment plant
required to meet present EPA stream discharge
standards.
                               B-6

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Letter Number:  5 (cont.)

                                                         Addressed
                     Concern/Issue                        On Page

It was further proposed that the treatment plant at the     22
elementary school be operated as a pilot project by the
Township under the supervision of the County Board of
Health until the system has proven that it complies
with EPA and Health Department regulations.
                               B-7

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                                                              (404) 262-6649

                                                              June 30, 1981
Mr. Richard V. Pepino
U.S. Environmental Protection Agency
Region III
6th and Walnut Streets
Philadelphia, Pennsylvania  19106

Dear Mr. Pepino:

We have reviewed the Draft Environmental Impact Statement (EIS) for Buckingham,
Pennsylvania, Wastewater Treatment Facilities and have numerous serious
concerns.  We are responding on behalf of the Public Health Service.

The Draft EIS does not provide adequate information about the existing quality
of surface and ground waters and the potential impact of spray irrigation on
these water supplies.  The EIS states that the most recent surface water infor-
mation was collected in 1971.  It is further stated that data on groundwater
quality is limited.  Without current water quality data, how are beneficial or
adverse effects of the proposed system going to be documented?

While a holding pond is mentioned, there is no discussion of the treatment that
will be used for the effluent.  Is the holding pond actually an oxidation
pond?  Is so, how will it be operated?  Is there more than one stage?  What
degree of treatment will be achieved?  If some type of settling tanks are used
before the effluent goes in the holding pond, what happens to the sludge?

There is no information provided about the characteristics of the proposed
spray field.  What conditions would cause runoff?  What are the subsurface soil
conditions?  What type of monitoring will be conducted to ensure surface and
groundwaters are not being contaminated from the spray field?  Who will be
responsible for this monitoring program?

The EIS states that the proposed spray area may be located in an area of
limestone formations and that at least two sinkholes are known to have
occurred in this vicinty.  The Pennsylvania Spray Irrigation Manual cautions
that in such areas, application of additional water by spray irrigation is
likely to cause accelerated sinkhole development and surface collapse.  The
Draft EIS says that if underlying limestone is found during the actual design
of the  spray field, another area will be used.  The final EIS should provide
information that clearly indicates whether the proposed area can be used or
if an alternate site will be required.  If an alternate site is required, that
location should be stated.
                                   B-9

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Page 2 - Mr. Richard V. Pepino

While a series of options is given on how the system could be operated, there
is no statement of who or what authority is responsible for day-to-day operation
and maintenance of the system.  Will it be the township government, a separate
sewage treatment authority, volunteers, etc.?

No mention is made of existing or potential vectors.  There should be a
discussion of mosquito or other vectors that can result from the holding pond.
What vector populations will this project encounter and what methods of control,
types of insecticides, application methods, and application rates are antici-
pated?  Who will be responsible for this treatment?

What vegetation control measures are anticipated?  What application methods,
types of herbicides, and application rates are anticipated?  Who will be
responsible for this activity?

What requirement will be employed to ensure existing homeowners use the pro-
posed system?  What restrictions will be employed to ensure use by future home
developments?

Thank you for the opportunity to review this Draft EIS.  We would appreciate
receiving a copy of the Final EIS when it is issued.
                                   Sincerely yours,
                                   Frank S. Lisella, Ph.D.
                                   Chief, Environmental Affairs Group
                                   Environmental Health Services Division
                                   Center for Environmental Health
                                    B-10

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                         COUNTY  OF  BUCKS
                                   DEPARTMENT OF HEALTH
                         Neshaminy Manor Center, Doylestown, Pa. 18901 - 215-343-2800
                                        FIELD OFFICES
                               410 Bath Road, Bristol, Pa.  19007 - 788-0491
                    SIS West End Blvd., County North Annex Bldg., Quakertown, Pa. 189S1 - 536-6500
 County Commissioners
ANDREW L. WARREN
ELAINE P. ZETTICK,
CARL F. FONASH
            Edmund K. Lindemuth, MJD., M.P.H.
Chairman            Director
                             July 21, 1981
    Board of Health

Paul W. Mcflvaine, M.D., Chairman
John Jacoby  V\ce Chairman
Mrs. Charles Benhayon
Francis L. Rickards, Jr., D.O.
Joseph J. Ryan
  Mr. Richard V.  Pepino
  U.S. EPA Region III
  6th & Walnut Streets
  Philadelphia, Pa.  19106

  Subject: Draft  EIS; Buckingham Township
           201 Study
           Buckingham Township,  Bucks County

  Dear Mr. Pepino:

       We have reviewed  the subject draft EIS transmitted by Mr.
  Schramm's letter of May  6,  1981.

       We generally  support the  findings and recommendations of
  the EIS and the non-sewered approach presented, provided that
  appropriate and adequate management of the various components  of
  the plan is implemented  and 'adequate areas of suitable soil  can
  be made available  for  the various land disposal options proposed.

       We support management option 3 or 4 for the individual  on-site
  systems, but strongly  support  option 1 for community and integrated
  community systems.

       With respect  to that portion of the study dealing with  reha-
  bilitation of existing malfunctioning individual systems, we feel
  that it is not  reasonable to assume that all malfunctions can  be
  corrected by a  conventional SAS or elevated sand mound as implied
  in Table 21.  A few may  need holding tanks if no space is available
  for a replacement  system or soils are completely unsuitable  for a
  long term repair.  The cost of construction and O & M of such  tanks
  has not been included  in this  table nor has any proposal to  assist
  the individual  home owner in bearing the 0 & M (pumping) costs been
  included.
                                   B-ll

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Page 2
Richard V. Pepino
Draft EIS-Buckingham Township
July 21, 1981
     In addition to the above comments relative to the draft EIS, I
feel some comments are in order regarding statements made in Mr.
John Morris1 letter of July 6, 1981 to you re: Buckingham Township
Facility Plan.  These comments are listed essentially in the order
of paragraphs in Mr. Morris1 letter.

    1.  Paragraph 1; No comment except that Mr. Morris is not approved
       to design on-site systems in Bucks County.

    2.  Paragraph 2; This Department offers the best advice we can
       relative to repair of malfunctioning systems, however, we
       are under no obligation  to provide homeowners with "a
       corrective method of correcting their defective inground
       system", as stated by Mr. Morris.  Also. Mr. Morris is in-
       correct when he states that if the Department does not
       suggest a solution the homeowner is "free to install any
       system in order to correct his problem".  While State
       regulations permit some latitude in approving a permit for
       a repair, all repairs must be done under permit.  Further,
       the suggestion that any system can be corrected with "5000
       square feet of open ground, regardless of soil conditions"
       is erroneous and certainly is not supported by this Depart-
       ment.  Geology, soil, and water well location may dictate
       to the contrary.  It is therefore appropriate that the
       approach for solving individual lot problems as outlined
       in the Facilities Plan and EIS be followed.

    3.  Paragraph 4;  This was the subject of  the current Facilities
       Plan and EIS and should be resolved in the final report.

    4-  Paragraph 5 &  6;  Mr.  Morris is  incorrect in stating  that
       the Apple Hill and Durham Village systems are  under
       designed.   In  fact, Apple Hill  has 640 sq.  ft.  of excess
       absorption area and Durham Village has 4209 square feet
       of  excess absorption  area as  required  by Pennsylvania
       DER regulations,  Chapter 73.  While this Department  stands
       ready to assist the homeowner associations  involved  or
       their engineers in resolving  their problems,  it  is basically
       the system operators  responsibility to select  the best method
       of  correction.   For this reason,  we have strongly supported
       construction and operation of community  systems  by some
       municipal  entity (Management  Option 1  of the EIS).   This
       would enable the  municipality to  be involved from the very
       beginning  of the  planning  and design process and represent
       future homeowners within the  areas  to  be served.
                                 B-12

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Page 3
Richard V. Pepino
Draft-El S - Buckingham Township
July 21, 1981


       5. Paragraph 7 & 8:  Mr. Tatman proposal was not offered as
          a final design solution.  This is determined in Step II.
          We would oppose "oversizing" any sewer line, especially
          when a non-sewered approach is proposed.  An 8" line on
          minimum grade can carry in excess of all projected flows
          from the proposed service area, including Apple Hill and
          Durham Village.

     I believe most of the other comments in Mr. Morris1 letter have
been addressed in the Facility Plan and EIS.

     If you have any questions concerning this matter, please feel free
to call.
                                   Very truly your
                                       -           «*~~
                                    Jee W. 'Thomas,  P.E.,  Director
                                   Bureau of Environmental Health
LWT/dh
cc: Roy Kolb, Buckingham Twp. W & S Commission
    Buckingham Twp. Supervisors
    D. Russel Tatman, P.E.
    Charles Rehm, Pa. DER
    Robert Moore, B.C.P.C.
    T.J. Salvadore
    D. J . Bauer
    File
                                    B-13

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                COUNTY   OF   BUCKS
     ANDREW L. WARREN
         Vice Chairman
County Commissioners

ELAINE P. ZETTICK
    Chairman
CARL F. FONASH
                                               July 9,  1981
MEMORANDUM
TO:        Richard  V.  Pepino,  Project Monitor
           U.S. Environmental  Protection Agency

FROM:      Dennis P.  Livrone,  Facilities Planner
           Bucks County Planning Commission

SUBJECT:   Review of  Draft Environmental Impact Statement/  Buckingham
           Township 201 Facilities Plan.

      The following comments were developed from staff  review of EPA's
draft EIS.  The draft EIS  was  reviewed by the Bucks County  Planning
Commission staff on a technical basis and these comments  are  based on
that technical review.   The comments are not a statement  of position
by the members of the Bucks County Planning Commission.

Comments

1)    The content and organization of the draft EIS is, for the most
      part, complete.

2)    Staff comments  concerning the issues discussed  in the draft EIS
      are essentially the  same as those for the review  of the Draft
      Detailed Summary of  201  Facilities Plan for Buckingham  Township
      prepared by Tatman and Lee Associates.(See memorandum of June
      29, 1981 from me to  Buckingham Sewer and Water  Commission.)
      Briefly these comments were:

      A)   The "non-sewered approach" adequately addresses  the water
           quality  and land use goals outlined in the Bucks County
           Comprehensive Plan.

      B)   Staff is concerned  about the rehabilitation  of failing
           community  on-site sewage systems.
      MICHAELS. MORRISON

         Vice Chairman

       JOHN E. ALLEN. JR.
       JOSEPH J. BONARGO
      HAROLD O. GROSS. JR.
A. KATHERINE LATTOMUS
     Chairman

 ROBERT E. MOORE

   Executive Director
   RALPH R. PISANI

      Secretary

   ANNA C.SIMONS
 WILLIAM R. SNYDER
 CARL N. WALLNAU.JR
                                  B-1A
           BUCKS  COUNTY PLANNING  COMMISSION
               22-28 SOUTH MAIN STREET. 2ND FLOOR   (215) 348-2911
                      DOYLESTOWN, PENNSYLVANIA   18901

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Richard V. Pepino, Project Monitor
Page 2
      C)   Staff sees a need for a public assurance program and
           on-site management plan.

      D)   Staff has reservations about homeowners' associations
           being responsible for operation and maintenance of community
           on-site systems.

      E)   Staff feels that the Township should apply for Federal
           funds to implement their wastewater facilities program.

      F)   Staff recognizes the need to regulate development over
           limestone areas.

      G)   Staff recommends maximum recharge of groundwater in an
           environmentally sound manner.

      H)   Staff urges that there be careful implementation of the
           non-sewered approach to ensure proper design and installation
           followed by on-going proper operation and maintenance of
           wastewater facilities.

3)    From a technical stand-point, the Staff is in agreement with
      EPA's preferred choice of Alternative 4 as outlined in the draft
      EIS.  We feel that this Alternative along with the general non-
      sewered approach can meet the wastewater facilities needs of the
      Township and preserve groundwater resources and the rural
      agricultural nature of the community.

      If you have any questions concerning the above comments, feel
free to contact me or Tom Kelso at 348-2911, extension 301.


DPL/aes

cc:   Buckingham Township Water & Sewer Commission
      Mr. D. Russell Tatman
      Mr. John Fabian, PA DER
      Mr. Lee Thomas, BCDH
      Buckingham 201 File
                                 B-15

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                    DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
                              PHILADELPHIA REGIONAL OFFICE                    .
                         CURTIS BUILDING. SIXTH AND WALNUT STREETS              *UG J Q
                             PHILADELPHIA, PENNSYLVANIA 19106


REGION III                                     „-.                         IN REPLY REFER TO
                                     AUG 3 1981
Dr. Alvin R. Morris
Acting Regional Administrator
U.S. Environmental Protection Agency
Attn.:  Richard V. Pepino
Curtis Building
6th & Walnut Streets
Philadelphia, PA  19106

Dear Dr. Morris:

We have completed our  review of the DEIS for the Buckingham, Pa. Wastewater
Treatment Facilities and offer the following comments.

1.  Although reference is  made on p. 49 to the relationship oil the Mill Creek
    floodplain to land used for spray irrigation of wastewater, the document's
    environmental inventory has, unfortunately, not indicated the extent  of  any
    floodplains.  Figures  7 and 9, which indicate the location of potential  spray
    irrigation sites,  suggest that floodplains could, in fact, be affected.
    We recommend that  the  Final E1S include the location of the floodplains  in
    the environmental  inventory and show the actual location of potential
    spray irrigation sites in relation to mapped floodplains at a scale
    suitable to support  the conclusion of no impact on the 100 year floodplain.
    We also recommend  that the source of the floodplain information be clearly
    shown.

2.  The text states that studies done by WAPORA, Inc. indicate that if the
    system is properly operated and maintained, there should be no odor or
    health problem.  However, this critical element of proper operation and
    maintenance is not thoroughly examined.

3.  We appreciate the  effort made by EPA to keep the document brief and issue-
    oriented.  However,  the reader who has not also reviewed the Facilities
    Plan is left to guess  about some of the critical elements of the proposal.
    We recommend that  EPA  include a one page description of the spray system
    and its operation.  This might answer some of our outstanding questions:

    (a)  Will the disposal site be utilized for active agricultural use?   If
         so, what type of  crop, and how will it be monitored?
                                       B-16


                                     AREA OFFICES
      Baltimore, Maryland - Philadelphia, Pennsylvania • Pittsburgh, Pennsylvania - Richmond, Virginia • Washington, O.C.

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     (b)  How will the effluent be transported to the disposal site?

     (c)  What sort of facilities will be required for disposal?  What is
          the distance between these facilities and the nearest residence?
          Will they generate noise or any other environmental impact?

     (d)  Will the disposal operation function on days when the temperature
          is below freezing?  If so, how?  If not, how long a period can the
          operation be suspended?

Thank you for the opportunity to comment and we look forward to receiving a
copy of the Final EIS when it is completed.

Sincerely,
Harry wrS taller
Acting Regional Administrator
                                      B-17

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                                      Bogart'a Tavern Road
                                      Buckingham, Pennsylvania 18912
                                      July 7, 1981
 United States Enviromental Protection Agency
 6th and Walnut Streets
 Philadelphia* Pennsylvania 19106

 Attentions  Mr.  Richard Pepino

 Dear Ur, Peoinos

 This statement is prepared for the public hearing to solicit
 testimony concerning the Draft EIS, Buckingham, Pennsylvania
 Wastewater Treatment Facilities to be held at the Buckingham
 Elementary School on July 9,  1981.

 I propose an additional alternative to solve the acute sewage
 problsms that exist  in our over 200 year old village.   It  com-
 bines the essentials of Alternatives 4 and 5 as presented  in the
 EPA "Draft Enviromental Impact Statement".  I suggest  piping the
 wastewater from Buckingham Village and surrounding areas as  neces-
 sary to  the treatment plant serving the Buckingham Elementary
 School.   Treat the water at the plant to bring it  to a level of
 purity to enable it  to be of  economic value to the farmer.   The
 water could be sprayed upon land suitable for cattle grazing and
 growing  of crops for animal consumption*   This option  would  de-
 crease the cost  of Alternative 4 by over one-half  million dollars
 based  upon 37  acres  of land at $15,000 per acre and  may decrease
 the degree of  upgrading of  the treatment  plant that  would be re-
 quired to meet present  EPA  standards  for  stream discharge*

 I further propose  that  the  program for this  treatment  plant  be
 a pilot project  for the  township operated  under the  close super-
 vision of the County Board  of  Health  and that  no permanent manage-
 ment authority be  established  until the system has operated  for a
 sufficient period  of time to ensure compliance with EPA regulations
 and all Health Department regulations*

A number  of Buckingham residents have assisted me with ideas for
this proposal*  There will be a copy of it at my place of business,
Kiddle Cyclery, available for any Buckingham resident to read and
 sign if he or she  supports this course of action.

I will submit this letter formally to the Buckingham Sewer Conmissioi
and the Enviromental Protection Agency by July 20, 1981.

                                     Tours truly,
                                     Bradley D. Kiddle

cc:  Buckingham Sewer Commission

                            B-18

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                      COMMONWEALTH OF PENNSYLVANIA
                 DEPARTMENT OF ENVIRONMENTAL RESOURCES
                                P.O. Box 2063
                            Harrisburg,  PA  17120

                                     July 31, 1981
Albert Morris
Acting Regional Administrator
U.S.  Environmental  Protection Agency
6th & Walnut Streets
Philadelphia, PA  19106

Dear Mr. Morris:

         The Department has reviewed the Draft Facilities Plan and Environ-
mental Impact Statement for Buckingham, Pennsylvania and we support and concur
with the conclusions and recommendations.

         Thank you for the opportunity to comment.


                                     Sincerely,
                                     CLIFFORD L./JONES
                                     Secretary of Environmental 'Resources
                                                              CESVED

                                                              S 6   1S8J
                                                          EPA, REGION III
                                                         a
                                  B-19

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                      FEDERAL EMERGENCY MANAGEMENT AGENCY
                                     REGION III
                                  CURTIS BUILDING
                               6th and WALNUT STREETS
                          PHILADELPHIA, PENNSYLVANIA  19106
                                             June 16, 1981
Mr. Richard V. Pepino
EIS Preparation Section
U.S. Environmental Protection Agency
Region III
6th & Walnut Sts.                            Re:  Buckingham, Pennsylvania
Philadelphia, PA  19106                           Wastewater Treatment Facilities
                                                  Draft EIS
Dear Mr. Pepino:

We have reviewed the above referenced document and have not found any need to
comment.

For any assistance that we may be able to provide concerning the project please
contact Joseph Gavin at 8-597-9581.

                                             Sincerely yours,
                                            -Walter P. Pierson
                                             Director
                                             Insurance and Mitigation
                                       B-20

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               United States Department of the Interior

                         OFFICE OF THE SECRETARY
                          WASHINGTON, D.C.  20240
ER-81/1383

   Mr.  Jack J.  Schramm
   Regional Administrator,  Region 3
   Environmental Protection Agency
   Sixth and Walnut Streets
   Philadelphia, PA 19106

   Dear Mr. Schramm:

   Thank you for sending the ten copies of the Buckingham draft
   environmental impact statement that our office had requested.

   As we received the DEIS's on July 13,  1981, we will not be
   able to complete the review by the July 27, 1981,  deadline
   for comments.  We anticipate completing our review by mid
   August and forwarding our comments by August 17,  1981.

   Thank you for your consideration in this matter.

                                   Since
                                   Bruce Blanchard,  Director
                                 '^Environmental Project Review
                                 B-21

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           APPENDIX C




BUCKINGHAM TOWNSHIP RESOLUTIONS

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                RESOLUTION FOR 201 FACILITIES PLAN
RESOLUTION OF THE' SUPERVISORS OF BUCKINGHAM TOWNSHIP,  BUCKS
COUNTY, PENNSYLVANIA (hereinafter "the municipality").

     WHEREAS, Buckingham Township is a Second Class Township;
and

     WHEREAS, the Second Class Township Code, Act of May 1, 1933,
P.L. 103, as amended, authorizes the establishment, construction,
acquisition and/or maintenance of public sewers and public water
system in Chapter XV (53 P.S., ss 66501 et seq.)  and Chapter XVI
(53 P.S. ss 66601 et seq.); and

     WHEREAS, Section 5 of the Act of January 24, 1966, P.L.
1535, No. 537 known as the "Pennsylvania Sewage Facilities Act",
as Amended and the Rules and Regulations of the Pennsylvania
Department of Environmental Resources adopted thereunder, Chapter
71 of Title 25 of the Pennsylvania Code, require the municipality
to adopt an Official Sewage Facilities Plan providing for sewage
services adequate to prevent contamination of waters and/or en-
vironmental health hazards with sewage wastes; and

     WHEREAS, the safe treatment and disposal of sanitary sewage
and wastewater is essential to the health, safety and general
welfare of the present and future residents of the Township of
Buckingham; and

     WHEREAS, it is essential to coordinate the disposal of
sanitary sewage and/or wastewater; and

     WHEREAS, Buckingham Township is interested in the recharge
of the groundwater table underlying the Township; and

     WHEREAS, the Supervisors of.Buckingham Township have attended
and/or had access to transcript of a public hearing held on
June 29, 1981; and

     WHEREAS, the Supervisors of Buckingham Township find that
the 201 Facilities Plan for Buckingham Township conforms -to
applicable zoning, subdivision, other municipal ordinances and
plans, and to a comprehensive program of pollution control and
water quality management,

     NOW, THEREFORE, BE IT RESOLVED that the Supervisors of the
Township of Buckingham hereby adopt and submit to the Department
of Environmental Resources for its approval as the water quality
management plan of Buckingham Township, the above referenced
201 Facilities Plan which is attached hereto.

                              1 of 2

                                C-l

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        (Name)                       (Title)
Buckingham Township Board of Supervisors hereby certifies that
the foregoing is a true copy of the Township Resolution #	
adopted 	, 19	.
                                         SEAL OF

                                        TOWNSHIP
                               2  of  2

                                C-2

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                  RESOLUTION FOR PLAN REVISION
RESOLUTION OF THE SUPERVISORS OF BUCKINGHAM TOWNSHIP, BUCKS
COUNTY, PENNSYLVANIA (hereinafter "the municipality").

     WHEREAS, Section 5 of the Act of January 24, 1966, P.L.
1535, No. 537, known as the "Pennsylvania Sewage Facilities
Act", as Amended and the Rules and Regulations of the Pennsyl-
vania Department of Environmental Resources (Department)  adopted
thereunder. Chapter 71 of Title 25 of the Pennsylvania Code,_
require the municipality to adopt an Official Sewage Facili-
ties Plan providing for sewage services adequate to prevent
contamination of waters and/or environmental health hazards with
sewage wastes, and to revise said plan at least once every five
years.

     WHEREAS, the municipality has reviewed the 201 Facilities
Plan for Buckingham Township and has determined that the proposed
method of sewage disposal does not conform to and is not in-
cluded in the approved "Official Plan" of the municipality.

     WHEREAS, the Supervisors of Buckingham Township find that
the 201 Facilities Plan for Buckingham Township conforms to
applicable zoning, subdivision, other municipal ordinances and
plans, and to a comprehensive program of pollution control and
water quality management.

     NOW, THEREFORE, BE IT.RESOLVED that the Supervisors of the
Township of Buckingham hereby adopt and submit to the Department
of Environmental Resources for its approval as a revision to the
"Official Plan" of the municipality the above referenced 201
Facilities Plan which is attached hereto.  The municipality
hereby assures the Department of the complete and timely imple-
mentation of the said plan as required by law.   (Section 5,
Pennsylvania Sewage Facilities Act as amended).

     I, 	, 	,  Buckingham
         (Name)                     (Title)
Township Board of Supervisors hereby certifies that the foregoing
is a true copy of the Township Resolution #	, adopted
                      , 19   .
                                              SEAL OF

                                              TOWNSHIP
                              C-3

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