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 ------- 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 ------- 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 ) ------- EXECUTIVE SUMMARY ------- 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. ------- 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 ------- 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 ------- 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 ------- LIST OF FIGURES Page Figure 1 Alternative 4 4 2 Conceptual representation of wastewater systems 13 3 Floodplains 21 ------- CHAPTER 1.0. INTRODUCTION ------- 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 ------- 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). ------- CHAPTER 2.0. RECOMMENDED ACTIONS ------- 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 ------- MOST DESIRED SPRAY IRRIGATION SITE BUCKINGHAM VILLAGE FIGURE I ALTERNATIVE 4 GRAVITY SEWER — FORCE MAIN • PUMPING STATION ...... POTENTIAL CONNECTION ROUTE FROM NEARBY DEVELOPMENT ------- 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. ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- Table 7. Cost of rehabilitation program for individual on-site systems with EPA funding. General sites surveys 16 wks ($200/day) $ 16,000 Sites evaluations (400 locations) Engineering 20,000 Soils analyses 80,000 Rehabilitation Soil absorption field (330 ft2/bdrm) (3 bdrm) ($2/ft2) (300 sites) 594,000 Mounds (100 sites) ($5,000/site) 500,000 $1,210,000 Contingencies (25%) 302,500 Engineering/Administrative (20%) 242,000 $1,754,000 85% Funding 1,491,325 Local Portion 263,175 Cost Per Homeowner $263,175 = $658 400 locations 14 ------- (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 ------- 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. ------- CHAPTER 3.0. COMMENTS RECEIVED ON DRAFT EIS ------- CHAPTER 3.0. COMMENTS RECEIVED ON DRAFT EIS Throughout the preparation of the Environmental Impact State- ment (EIS), EPA has continuously sought participation from local, regional, State and Federal agencies; citizen associations; individual citizens; and interested environmental groups. EPA has considered suggestions, criticisms, and objections from the public in documenting the need for wastewater treatment facilities, in developing wastewater management strategies, and in assessing potential impacts. EIS newsletters, pamphlets, advertisements and meetings with the public have been used to ensure that all concerned parties were involved in the EIS decisionmaking process. 3.1. PUBLIC PARTICIPATION In accordance with the National Environmental Policy Act and EPA procedures for the preparation of Environmental Impact State- ments, the public as well as Federal, State, and local agencies were requested to comment on the Draft EIS from May 27, 1981 to July 21, 1981. In addition, oral testimony on the Draft EIS was received at the Public Hearing held on July 9, 1981. In total, EPA received written responses from 4 Federal agencies, 1 State agency, 2 county agencies and from 1 citizen. Oral testimony at the Public Hearing was presented by representa- tives of one State agency, one County agency, three Township officials and eight citizens. 3.2. KEY COMMENTS From EPA's perspective, all comments are helpful in formu- lating its conclusions. From all the comments received the following concerns are considered by EPA to be among the most important: • operational impacts especially health effects of spray irrigation • the possible use of the Buckingham Elementary School system to provide wastewater treatment for portions of the Township • the direction of management programs for clustered and scattered areas of the Township with wastewater disposal problems as well as for future growth-related wastewater needs • uncertainties of Federal funding • wastewater management needs 17 ------- 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 ------- analyzed for the major ions, pH and silica. The majority of these constituents appeared in levels indicative of the native rock formations. Only 10 percent of the well samples exhibited levels in excess of EPA's guidelines for nitrate, while over 40 percent were less than 5 ppm which is well below the allowable limit. This indicates that only isolated point source contamination of groundwater is occurring in the Township. Overall water quality, as reflected by the sampling program, is good. In most cases, only background levels of water quality parameters were present. In addition to this program, the Bucks County Health Department has been investigating the occurence of trichloroethylene (TCE) contamination in several wells in the Furlong area. TCE was discovered in 16 wells in the area in December 1979. This contam- ination is limited to the immediate vicinity of Furlong in both Doylestown and Buckingham Townships. There is no evidence that this pollutant has had an overall effect on the groundwater quality of the Township. Operation and Maintenance The Township Supervisors shall obtain necessary financing, to own and be responsible for the operation and maintenance of the spray irrigation facilities at Red Gate Farms (Argus Drive section) and Buckingham Village. The Supervisors may assign to the Sewer and Water Commission the day-to-day operation and maintenance of the facilities, including collection of revenue and payment of bills. The certified operator of the facilities may report to the Sewer and Water Commission. Type of Spray Field (Disposal Site) The spray field will be for agricultural use. The crops grown would be reed canary grass,, corn, hay or other crops suitable for feed to animals only. No crops for human consumption will be grown. A public agency (Board of Supervisors) shall be responsi- ble and monitor the operation of the facilities. In addition, the operational permit issued by DER shall establish the type of use for the spray field. The Supervisors will have an operational and maintenance plan incorporating the requirements of DER. DER is responsible for inspecting all spray operations in Pennsylvania. Groundwater monitoring wells shall be installed and tested quarterly. Transport of Effluent to Spray Field (Disposal Site) The effluent after treatment and chlorination shall be pumped to the spray field in a buried force main. The main shall be buried with at least 3 feet of earth cover over the pipe to prevent damage from freezing. 19 ------- 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 ------- Figure 3. Location of most desired spray irrigation site beyond floodplain boundaries identified in Buckingham Township zoning ordinance. 21 - ------- limestone has been eliminated from consideration by the Sewer and Water Commission. 3.3.2. Alternative to Use Buckingham Elementary School Wastewater Treatment Facilities Prior to Land Application DER recommends a minimum of secondary treatment prior to spray irrigation. This secondary treatment level followed by chlorination has been established from health standards (1) (11). However, such a treatment level reduces the economic value to the farmer, as nutrients in the wastewater are extracted. Mr. Kiddle's alternative is attractive because the Buckingham Elementary School plant is an existing facility. If the existing plant were expanded for wastewater flows up to 30,000 gpd it would be less costly than a new lagoon treatment system. However, lagoon systems have proven less expensive to operate and maintain. Since the projcted flows from Red Gate Farms and Buckingham Village exceed 30,000 gpd (44,600 gpd), a lagoon/spray system would be more economical than a Buckingham Elementary School treatment plant/spray system. 3.3.3. Management Programs In the adopted 201 Plan, the Buckingham Sewer and Water Commission recommended that the management plan require periodic inspection of all Township wastewater treatment systems; such inspections to be of the type and frequency as described in the EPA Construction Grants program [CFR 40, Section 35.918-l(i)]. With the exception of the integrated wastewater facilities to service Red Gate Farms (Argus Drive section) and Buckingham Village, which will be owned, operated, and maintained by the Township Supervisors, the recommended management program calls for homeowner's associations to own and be fully responsible for the operation and maintenance of all other community systems in the Township. With the land disposal approach adopted for wastewater management disposal, homeowners's associations may be responsible for techniques that are more complicated than subsurface disposal methods, e.g. spray irrigation. In order to properly construct, operate, and maintain the systems under the land disposal approach a management program is required. Existing management actions are not adequate and must be improved so that the land disposal approach can be instituted. The Facilities Plan's recommended actions include the following measures above and beyond current practices: • The Township shall continue the present practice of reviewing plans and system design of all wastewater systems for conformance with the official Sewerage Facility Plan and present ordinances. 22 ------- The Township shall implement all aspects of the present ordinances concerning sewerage systems and land disposal by spray irrigation and subsurface disposal. The Township shall prepare and adopt new ordinances which shall provide the administrative features shown in Table 8. The features established in the Table are: -System ownership: all individual on-site systems shall be owned and maintained by the owner (i.e., homeowner). For community systems, excepting Red Gate Farms and Buckingham Village, the ownership and maintenance shall be the responsibility of homeowner associations. The daily operation and maintenance of community systems shall be by a DER certified operator (paid for by the homeowner associations). -Financial aspects: a construction escrow managed by the Township for all new systems shall be required as follows: individual subsurface systems $2,500 for one year (per present ordinance) individual slow-rate land application systems $8,000 for one year community systems - 120% of the estimated con- struction cost as approved by Township Engineer until construction is completed to satisfaction of Township Engineer In addition, an operation and maintenance (O&M) fund shall be established for all community systems. This fund shall be retained by Township for a 2 year period and be an amount equal to the estimated yearly operational and maintenance cost times three. The 2 year time period does not start until all units are completed and sold and occupancy permits for all units have been issued. All unused monies from the construction escrows and/or O&M funds shall be returned to the homeowner or homeowner association. -On-site inspections: on-site inspections of individual systems shall be conducted by a qualified individual either employed by the Township (full or part time) or a qualified individual from the private sector. 23 ------- Community systems shall be inspected by a qualified individual employed by the Township. The frequency of inspections shall be: individual subsurface systems - once every three years individual slow-rate land application - yearly community systems - monthly The homeowner or homeowner association shall pay for the cost of these inspections. 3.3.4. Uncertainties of Federal Funding Each of the projects that competes for EPA Construction Grant funds is assigned a "priority point" ranking by PA-DER. Projects become eligible for Federal funding based on their priority ranking. Presently the Buckingham project has been assigned 71 points by PA-DER. During fiscal year (FY) 19(51, which ends September 30, 1981, 70 points were required to qualify for Federal funding through EPA's Construction Grants program. EPA anticipates that if a grant award offer is made to Buckingham Township during FY 81 sufficient funding will be available to implement the project. EPA's policy is to encourage and, where possible, to assist in the development of innovative and alternative technologies for the construction of wastewater facilities. Projects or portions of projects which the EPA Regional Administrator determines meet criteria for innovative or alternative technologies may receive 85-percent grants. All of the Buckingham project will qualify for "alternative" technology funding. EPA has earmarked special funds to pay the additional 10-percent of project costs above the conventional EPA funding level of 75-percent. However, this category of funds will no longer be available to Buckingham Township after September 30, 1981. Therefore, if a grant offer is not made to the Township by this date, these additional "alternative" funds will not be available. 24 ------- 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 ------- 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 ------- 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 ------- 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. 29 ------- 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 ------- BUCKINGHAM EIS DISTRIBUTION LIST ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX A EXECUTIVE SUMMARY OF DRAFT EIS ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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 ------- 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. ------- (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 ------- 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 ------- 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 ------- 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 ------- 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 ------- APPENDIX C BUCKINGHAM TOWNSHIP RESOLUTIONS ------- 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 ------- (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 ------- 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 ------- |