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
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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
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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.
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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.
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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.
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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.
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CHAPTER 4.0.
IMPLEMENTATION OP RECOMMENDED ACTIONS
-------
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
-------
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
-------
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.
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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
-------
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
-------
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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