EPA
United States
Environmental Protection
Agency
Office of Water
Program Operations
Washington DC 2O460
December 1980
Water
A Strategy for
Small Alternative
Waste water Systems
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A STRATEGY FOR SMALL ALTERNATIVE
WASTEWATER SYSTEMS (SAWS)
OFFICE OF WATER PROGRAM OPERATIONS
U.S. Environmental Protection Agency
Washington, D.C. 20^460
DECEMBER 1980
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TABLE OF CONTENTS
SECTION PAGE
I. INTRODUCTION AND BACKGROUND 1—5
TABLE I — SAWS Technological Options
II. STRATEGY FOR IMPROVING SAWS MANAGEMENT 6 1 4
Task 1: SAWS Education 7—9
Task 2: State SAWS Program Management 9
Task 3: Federal SAWS Policy ClarificatIon 9—10
Task 4: Construction Grant Program Management 10—11
Task 5: Research on SAWS Design, Regulation, and Management 11—13
Task 6: Water Quality Management Planning Coordination 13-V4
Task 7: SAWS Program Support
III. ISSUES AND OPPORTUNITIES 15—19
Issues 15—17
SAWS Program Management 17-18
Opportunities f or Encouraging SAWS 18—19
IV. EXISTING SAWS PROGRAMS 20—29
EPA SAWS Program 20—23
Other Federal and Non—Federal National Programs 23—25
State SAWS Programs 25—26
Regional and Local SAWS Programs 26—28
TABLE 2 — Clean Water Act Amendments Impacting SAWS 29
A PPENDIC ES
A. SAWS Strategy Recommended Activities by Participant, FY 1980—1983
B. State SAWS Program Activities
C. Items to be Considered in Establishing Local SAWS Programs
D. Management Dimensions of &nall Flows Institutional Arrangements
E. Evaluation Criteria for Selection of Management Agencies
REFERENCES
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SECTION I
INTRODUCTION AND BACKGROUND
The major objective of’ this Strategy paper is the development of a
comprehensive planning and management approach to promote the use of and
improve the performance of’ small alternative wastewater systems (SAWS). This
Strategy covers a wide range of technological and managerial approaches to
meet the wastewater collection, treatment, and disposal needs of small
communities. This Strategy is designed to assist participants in the 208
water quality management (WQM) planning program, 201 construction grants
program, and State and local regulatory officials in developing viable
management systems to promote SAWS.
This paper describes current Federal, State, and local SAWS prograx s”and
Identifies a number of problems and issues inhibiting implementation of
adequate SAWS management programs. The following section outlines a number of
recommenthtions to improve program coordination and communication, clarify
organizational responsibilities, and develop and implement management systems.
Until recently, wastewater facility and WQM planners generally
recommended that on—site systems be replaced by conventional systems wherever
feasible since these systems were perceived as a temporary and inadequate
treatment and/or disposal techniiue. The SAWS Strategy addresses the growing
needs for adequate and cost-effective sewage treatment for the 25 percent of
the Country’s population in small communities not served by public
conventional wastewater systems.
The Clean Water Act of 1977 included amendments to encourage the
construction and/or rehabilitation of SAWS. These Amendments are summarized
in Table 2 on page 29. The most significant change was the inclusion of two
grant allotment set—aside programs.
A set—aside of 4 percent of the total construction grant allotment for
each rural State is to be u 3ed f r SAWS systems in rural communities. This
set—aside is mandatory for •314 rural States having at least 25 percent rural
population. This set—aside program has enabled some communities low on the
State’s priority list to obtain funding which would not have been available in
the past. The level of par;icipation in this program varies widely among the
States; some States have fully committed their funds, while others stand to
lose a portion of their allotments unless legislative extension is granted.
As of September 30, 1980, $7.63 million of the total $77.1 million FY 1979
set—aside is at risk for re illotment because it has not been committed to
specific projects. The use of F( 1980 set—aside appears to be brighter.
About $,15.5 million of the year’s $60.5 million total has been obligated as of
Septein er 30, 1980.
‘he second set-aside prograLn provides that 2 percent of’ the FY 1979 and
FY 1980 total allotments and 3 psrcent of the FY 1981 allotment be used to
encourage the application o-’ innovative and alternative (I/A) technologies.
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This set—aside is used to increase the Federal share from 75 percent to
85 percent of the project capital cost. Many I/A projects are for small
communities and are primarily alternative systems such as community
leachf’ields, total containment lagoons, and land treatment.
Section 35.917 of 40 CFR, Part 35, Subpart E, Construction of Treatment
Works—Clean Water Act requires that facility plans contain a detailed
evaluation of alternative methods of sewage treatment and disposal. Facility
plans and WQM plans developed under EPA 201 and 208 programs frequently have
concluded that conventional wastewater systems are prohibitively expensive for
many small communities to build, operate, and maintain. Conventional systems
can also have undesirable secondary impacts such as induced development and
disruption of environmentally sensitive areas. In many instances they do not
improve water quality significantly beyond that provided by SAWS.
When costs, environmental impacts, and results are objectively compared,
SAWS technologies are often preferable for small communities. Some of the
SAWS technologies which should be considered by small communities are outlined
in Table 1 on pages 11 and 5. The particular technology selected would be
determined by unique site specific characteristics, the community’s wastewater
needs and financial capabilities, financial capabilities of individual users,
and the degree of treatment required to meet State standards and the
environmental objectives of the community.
Local management systems using SAWS should be designed to meet the total
wastewater needs of the community, not just those areas of the community
receiving Federal construction grant assistance. Also in this regard,
communities should examine the relationship of policies and administrative
responsibilties for SAWS and conventional wastewater systems. Given limited
resources, EPA will not be able to satisfy the total financial needs for
construction assistance. Communities are encouraged to increase the use of
alternative systems and improved management approaches even where not grant
eligible or when funding is unlikely due to limited funds or low State
construction grant priority.
Water Quality Management and facility plans have generally reflected the
traditional bias against small flows systems in recommending the sewer’ing of
large areas presently served by septic tanks and other small flows systems.
In addition, these plans have not generally documented significant on—site
system failures and related water quality problems. Despite regulatory
requirements to the contrary, conventional systems have been recommended in
many of these plans without giving adequate consideration to alternative
systems, including system rehabilitation and improved management.
As the comparative costs and environmental impacts of SAWS and
conventional systems become better understood, facility planners and water
quality managers will have to consider the application of SAWS technology to
reduce user costs and maintain environmental quality whenever feasible.
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This Strategy has been prepared by the Office of Water Program Operations
(OWPO) with the assistance of the Municipal Environmental Research Laboratory
(MERL) and Roy F. Weston, Inc. Implementation of the various recommendations
requires commitment from EPA offices, other Federal agencies, State agencies,
public interest groups, professional consultants, local elected and
administrative officials, and others involved in the planning, construction
and operation of wastewater facilities for small communities.
Section II outlines OWPO tasks for promoting SAWS through the Water
Planning Division (WPD) and Facility Requirements Division (FRD).
Sections III and IV discuss problems and current programs dealing with SAWS
management. While these sections provide background, the Strategy as outlined
in Section II can stand alone.
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TABLE 1
SAWS TECHNOLOGICAL OPTIONS
A. Treatment
1. On—site methods
a. anaerobic units (individual/cluster septic tanks, cesspools)
b. aerobic unit 3
2. Small flow treatment systems (e.g., package plants, multiple home
units, ponds, lagoons, oxidation ditches)
a. anaerobic
b. aerobic
c. physical/chemical
d. land treatment
B. Disposal
1. On—site methods
a. Conventional soil absorption systems
b. Sand filter/surface discharge
a. Evaptranspiratior techniques
— natural
- mechanical
— combined with soil absorption system
d. Othei’ soil absorption designs and techniques
— mound 53, stems
— alternating soil absorption systems
— dosing systems
— soil fi€ld rejuvenation with hydrogen peroxide
— other
2. Small flow
a. surf tce water
b. land application
a. community soil abEorption system
d. aquac ulture
e. cluster systems
f. other
C. Collection Methods
1. Conventional gravity sewers
2. Small—diameter gravity sewers
3. Pressure ewers
4 Vacuum se ers
5. Demonstrated hybrid systems
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D. Wastewater/Water Supply Flow Reduction Techniques
1. Generic water consumption/wastewater flow reduction options (low
flow, recirculating toilets, composting toilets, recycle/water
purification)
2. Generic grey water recycling options
3. Other
E. Residuals ! nagement (collection, treatment, disposal )
1. Septage
2. Package plant and on—site aerobic sludges
3. Recreational wastes (chemical toilets, etc.)
14 Other
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SECTION II
STRATEGY FOR IMPROVING SAWS MANAGE 4ENT
Subsequent sections of this paper examine current Federal, State and local
SAWS programs. This section outlines the OWPO Strategy for a more active and
effective national SAWS program. Although this Strategy focuses upon
recommended actions within OWPO’s WPD and FRD, it is recognized that key roles
are also played by other EPA offices and State and local planning and
management agencies. This Strategy outlines recommendations for strengthening
program coordination. The Strategy may need modification to be consistent
with the 1990 Construction Grant Strategy currently being developed.
Nonpoint source pollution and health hazards can result from the failure
of on—site sewage disposal systems. System failures are caused by improper
siting, installation, operation, m&intenance, or sizing of the system.
Construction of conventional sewerage works would resolve the problems
associated with failure of individual systems, but could create other problems
equally as difficult to solve. These problems could include the lack of’
political and public acceptability of the project caused by expensive
collection and treatment works which might not be necessary to solve the
community’s wastewater problem. In many of these instances, use of’ SAWS would
result in more cost—effective wastewater collection and treatment with reduced
negative social, econcmic, and political impacts. EPA is therefore promoting
the use of SAWS technology to make cost—effective and adequate sewage
treatment available to small commurities at more affordable costs.
The general goals of’ the SM4S Strategy are outlined below. Action
recommendations are organized in ac3ordance with these general goals. The
Strategy goals are as follows:
1. Promote expanded use of’ SPIIS where they will provide adequate and
cost—effective sewage disposal.
2. Promote acceptance of’ SAWS as viable methods of sewage treatment and
disposal by changing the attitudes of State/local regulatory agencies and the
general public.
3. Develop State and local SA iS management capabilities to include
planning, O&M, facility planning, construction grant assistance, financial
structuring, regulation, and enforc unent.
L4 Define SAWS resportsibi.lities of EPA, other Federal agencies, and
State and local agencies.
5. Evaluate, coordinate, and integrate SAWS programs to improve
communications, reduce duplication, and clarify funding eligibilities.
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6. Promote EPA funded prototype and demonstration projects to show that
SAWS will function in an effective manner. Successful prototype projects may
encourage communities uncertain of the reliability of’ SAWS to use them to
fulfil-i their sewage treatmert and disposal heeds.
Implementation of the actions recommended will help insure that the goals
of the SAWS Strategy are net. Many water pollution control, management and
planning activities are the responsibility of OWPO. These include the
following programs authorized under the Clean Water Act——overall State program
management (106); construction grant program (201); construction grant program
management (205(g)); and State and areawide planning (208). OWPO recommended
action tasks appear below.
Task 1: SAWS Education
The lack of’ awareness of’ the cost and performance characteristics of SAWS
under various conditions and management arrangements is the major deterrent to
implementation of SAWS approaches. Adequate information regarding SAWS
systems would result in more objective analyses and should lead to more
frequent selection of the SAWS alternatives.
As chscribed els where in the Strategy, various SAWS training programs
have been undertaken by OWPO, ME1L and the Center for Environmental Research
Information (CERI). These trainiig programs are designed to increase
understanding of SAWS state—of—the—art technology and management systems, and
they have assisted in SAWS implernsntation. SAWS educational programs could be
improved by the following aebions:
1. Expanding of SAWS sernina-s/workshops to include technology, financing
alternatives, management alternatives, and facility plan reviews. The
seminars/workshops should be designed specifically for the needs of the
following grcups—-WQM planners, facility planners, facility plan review
personnel, State and local SAWS program managers, EPA Regional and
Headquarters program personnel, cther Federal agency personnel, and consulting
engineers.
The educational goals, requirements, objectives, and needs for each
group mentioned above should be specifically determined. Each group should
assist EPA in detern ining their educational needs. OWPC will evaluate these
educational needs ard develop training programs as necessary to fulfill each
group’s objectives.
2. Continuing assistance b OWPO to MEBL and CERI in the design of
training materials, manuals, seminars and workshops in order to:
a. Insure consistency of WQM and facility planning policies, needs,
and objectives.
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b. Satisfy the information and training needs and requirements of
State and local engineering consultants, municipal officials, contractors and
the public in order to improve the quality and implementation of facility and
WQM plans.
3. Considering and iriplementing the SAWS Strategy by WQM agencies. This
can be encouraged by OWPO throug1 i the following activities:
a. Development of’ SAWS planning/institutional analysis methods.
b. Limited direct technical assistance, as resources permit,
through the financial management assistance program and through the
development of model State SAWS management programs (See Task 2).
c. Development and distribution of SAWS training materials, policy
papers, and guidance material to WQM agencies.
t. Providing guidance to MERL in the operation of the Small Flows
Clearinghouse at West Virginia University in order to improve identification
of educational needs, coordination of program objectives, and delivery of
educational and training services.
5. Providing technical assistance by OWPO Headquarters and Regional
Offices, as resources are available, to WQM and facility planning agencies,
local officials, and others involved in SAWS planning and implementation.
6. Promoting inclusion of SAWS information in training materials
developed by other Federal agencies, professional organizations and public
interest groups. These traLning materials include professional practice
handbooks, guidance materials, newsletters, workshop and conference agendas.
7. Promoting inclusion of SAWS in the civil/environmental engineering
curriculum of’ colleges and unive ’sities.
OWPO SAWS educabional action objectives for FY 1981 include:
1. Disseminate SAWS management manual being developed by MERL to
all facility planning and WQM agencies.
2. Develop SAWS management training materials.
3. Conduct at least t io regional SAWS workshops for WQM planning
personnel, emphasizing institutional aspects of’ developing and implementing
State and local SAW8 programs.
11. Include major SAWS presentations in at least three national WQM
professional/public interest group conferences.
5. Develop and init.iate SAWS prototype programs.
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6. Conduct ten design seminars for engineers and municipal
officials.
7. Conduct two workshops for the academic community to encourage
inclusion of SAWS technology in university and college curriculum.
8. Implement National Environmental Health Association (NEHA)
seminar/workshops for sanitarians and public officials.
Given current limited resources, OWPO must make maximum use of SAWS
educational opportunities that are available, including other EPA and Federal
agency sources. Regional Offices, WQM and facility planning agencies, and
local agencies involved with SAWS technology are strongly encouraged to
participate in SAWS training programs. Each Regional Office should
disseminate SAWS material$, identify regional SAWS training and information
needs, and identify opport.unities within the Region to disseminate SAWS
training and public information materials.
Task 2: State SAWS Program Management
Consistent with the overall WPD Water Quality Management Strategy and the
State delegation orovisions of the construction grants program, State agencies
are envisioned to play a major role in encouraging the implementation of SAWS
approaches.
States are ex.ected to proiide a localized base of SAWS expertise, provide
SAWS information, and as appro riate, advocate SAWS concepts f or small
communities and u- ban areas. tn order to carry out this responsibility,
States will need to reassess iistitutional relationships, legislation and
regulations pertaining to SAWS, available resources, and State policies and
attitudes regardi ig SAWS inanag ment.
EPA will encourage States to design and implement SAWS programs. Pursuant
to this, detailed guidance regarding alternative State SAWS programs,
including activities considered part of a minimum level program, will be
developed. Support for develcpmerit of State programs will be through the 201,
205(g), 106, and 208 programs. Initially, model State programs will be
developed in a limited number of States through a SAWS prototype program.
Implementation of State SAWS management programs will be included as part of
the State/EPA (SEA) agreements.
Recommended state SAWS prcgram activities appear in Appendix B.
Task 3: Federal SAWS Policy c:arirication
A number of’ Federal agencies have SAWS construction grant, education, or
research programs. Each agency has somewhat different polices, regulations,
objectives, and Vunding Etratogies. These differences could cause confusion
for State and local officials and hinder implementation of coordinated SAWS
programs. Progress towards irteragency cooperation has been made as a result
of’ the WhLte Houze IRural Initiatives Program.
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To build upon past and current interagency efforts, the following OWPO
activities are recommended:
1. Dissemination of’ information to WQM and facility plan reviewing
agencies regarding the SAWS program of’ other Federal agencies.
2. Establishment of contact with staff of other Federal agencies to
promote SAWS and improve program coordination as appropriate.
3. Providing assistance to the Office of the Assistant Administrator for
Water and Waste Management (OWWM) in monitoring EPA involvement in interagency
cooperation, including p’opozed interagency agreements. OWPO will provide
appropriate EPA offices .,ith suggested action items to facilitate SAWS
implementation.
Task 14: Construction Grant Program Management
The administration or the 201 construction grants program is the
responsibility of the Facility Requirements Division (FRD) and Municipal
Construction Division (MD) of OWPO. The recent reorganization of OWPO to
Include WPD will permit a clc3er relationship between the Step 1 facility
planning program and the WQM )lanning program.
SAWS management progr’ams £2ust be developed by municipalities (grantees) as
part of 201 facility plans. There applicable, these programs should be
consistent and coordinated wish SAWS management programs and policies
developed by Stabe or areawic WQM agencies. FRD will provide guidance in the
development of tnese managemeut programs and related SAWS programs.
In addition to the manageilent program aspect of 201 facility planning,
there are a number of acdvltLes which can be included as part of
comprehensive SAilS managcment projects. These activities include licensing of
septage haulers, public ‘ duca ;ion, and enforcement. Facility planning and WQM
agencies will have to deCirie rogram responsibilities and coordinate the
development of managemen: plavis to control these activities.
All wastewater treatment orks including SAWS whose construction will be
grant funded muse conf’oria to he facility planning requirements of FRD. FRD
performs a numbe’ of actLvit1 s which encourage the implementation of’ SAWS
technologies. T e folIo ing .)ngoing and new actions and activities are
recommended:
1. StreamiLne the 201 r’view and approval process, increase local
community progran partic ipati )fl, develop generic facility plans for SAWS
management, and 3horterl ;he ti.me of implementation.
2. Evaluat3 the efrectireness of’ rural and I/A set—aside programs and
the priority sys. em in g nera1; develop and implement changes as appropriate.
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3. Improve the effectiveness of small flows coordinators in Regional
Offices by clarifying responsioilities, providing special training,
distributing information materials, and developing special review procedures
for SAWS projects.
II. Encourage States through 205(g) delegation agreements to improve
their expertise in reviewing SAWS facility plans.
5. Clarify regulations and provide additional guidance regarding
acceptable management arrangemants for SAWS projects (e.g., ownership
requirements, legal aspects of inspection access, user charge systems,
maintenance, monitoring programs and septage management).
6. Continue the mon toring of small community facility plans for problem
assessment techniques, understanding of state-of—the—art technology,
cost-effective analysis, structuring of financing and adequacy of management
programs. The facility plan should demonstrate the affordability of the
project in terms of ability of the municipality and individuals to assume the
local share of the project cost. Facility plans should also be closely
examined to determine if the proposed administrative and management
institutions adequately consider 0&M, user charge systems, fee collection, and
planning for future needs.
7. Encourage States to rcview and update design criteria for SAWS
technology in order to mirdxnizc• arbitrary standards and approval procedures;
recognize varying local site conditions as appropriate.
8. Encourag ’: States through 205(g) agreements to standardize the
classification of soils ard gr’undwater, and other data collected and
presented for SAW:; facility planning.
9. Develop ;eneric model facility plans for SAWS to simplify and
decrease the time necessary fo ; facility planning.
10. Encourage States thro. gh 205(g) agreements to utilize these generic
model faciLity plans for SAWS, and to make other program changes which will
encourage and fac:.litate the i. iplementation of SAWS management programs at the
State level and, s approçriate, the areawide and facility planning levels.
11. Work wit). FarmerE Homt Administration (FmHA) to modify conflicting
EPA and FmHA requ:rements for rant and loan assistance.
Task 5: Research n SAWS tesig. , Regulation, and Management
There is a general lack of awareness of and confidence in SAWS
technologies and rianagement ap roaches among consulting engineers, State and
local officials, cater quality planners, and facility planning engineers.
This inforuationa deficiEncy nay be caused by four separate, but related
problems: (1) an inadequately designed or underfunded technology transfer
program, (2) unmet. research neds, (3) indifference on the part of engineers,
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planners, and local of ’ioiais, and ( ê) historical bias resulting from
unsuccessful experience with SAWS. The SAWS educational program will improve
the information dissem nation process, as will other SAWS activities to a
lesser degree. This Strategy element will focus upon SAWS research needs.
In general, SAWS research should address the following areas:
1. Development oi imp ’oved SAWS technology.
2. Development and evaluation of SAWS generic management programs.
3. Evaluation of field performance and costs of various SAWS technical
and management approaches.
4• Identification of the water quality, public health, environmental,
socioeconomic, and other i acts of SAWS technologies.
The focus for SAWS research within EPA is the Small Flows Research Program
of MERL located in Cincinnati, Ohio. This program has been very productive
with limited resources. ME 1L has always been responsive to the research needs
of the construction grants program; however, the increased emphasis by WQM
programs on noipoint source control programs, including SAWS, has increased
the dema.ids male upon 1ERL ‘or research support.
To meet SAWS research n eds, it is recommended to the Office of Research
and Development (ORD) that ;he following ongoing and proposed activities be
continued, enh inced or initiated:
1. Conducting of reseArch by MERL in accordance with OWPO identified
research needs developed th ough the Municipal Wastewater and Spill Prevention
Research Commictee and othei’ research committees.
2. Parti ipating in ORD research committees by OWPO and communication of
research needs and SAW3 pro ram status to ORD Headquarters staff and to the
small flows program ma. ager in MERL.
3. Explo ’ing SAW3 re arch outputs of other Federal agencies by OWPO and
establishment of a liaison, as appropriate.
14• Having OWPO a t as potential cosponsor of high priority research
efforts and to cooperate with MERL, as appropriate, in review of research
outputs, potential res .?arch projects, and educational/training materials.
5. Parti3ipating of RL with OWPO (as resources permit) in development
of educational materiais, i’iformation transfer programs, and training efforts.
6. Providing of technical assistance by MERL to OWPO program offices,
Regional Offices, States, the engineering community, WQM and facility
reviewing agencies, as apprc)priate and as resources allow; and to aid in the
development of technical a istance capabilities in the OWFO programs,
Regional, and State offices.
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7. Developing of’ ca:;e studies by MERL to assist OWPO in developing
guidance regarding acceptable SAWS management arrangements.
Although MERL is the primary research vehicle, specific projects of’ a
technical manual or “prototype 1 ’ nature may be undertaken directly by OWPO.
OWPO efforts will be coordinated with MERL in order to minimize duplication
and obtain technical input..
Task 6: Water Quality Management Planning Coordination
SAWS implementation has been limited by a lack of coordination of local,
areawide, and State WQM agencies and by the lack of explicit reference to SAWS
components in WQM plans. In addition to the development of State management
programs (Task 2), SAWS should be considered in any future State and areawide
WQM plans. To accomplish this objective the following actions are recommended:
1. WPD to formulate increased guidance concerning the development of
SAWS related work elements as applied to WQM for dissemination to Regional
Offices and WQM agencies. This guidance should:
a. Pros ide assessiier t of SAWS contribution relative to other
nonpoint source problems; identify Best Management Practices (BMP’s) and
priori ties.
b. Evaluate existing SAWS regulatory/management programs.
c. Ider.tify and sel. ct alternative regulatory/administrative
institutional arrangements as a framework for specific WQM decisions included
in 201 faci]ity p]ans.
d. Exanine Regional technical assistance and management program
approaches.
e. Assist in the implementation of legal, institutional, and
technical recommendations such as interagency agreements, model codes, and
technical assistance.
2. WPD and l egional 0ffic es to provide increased direct technical
assistance to WQM agencies in lne preparation and implementation of SAWS
management recommendations.
3. Integration of SA,IS Stt’ategy with the groundwater prototype program,
financial iranagem€rit assistance program, and other WPD programs.
11. WED to improve mo iitoring and results transfer of SAWS WQM project’s.
5. O ’iFO to clarify 2)1 ari 208 project funding policies; SAWS components
developed as part of WQM plans should provide background and support to
development of more detailed we3tewater facility plans. Whereas SAWS
components of WQM plans in luth. general problem identification and analyses, of
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existing and alternative institutional arrangements, 201 studies should
conduct area/site specific analyses of water quality problems, system
conditions, and technical solutions, and evaluate and select specific
management/institutjona1/1e a1 arrangements. OWPO and the Regional Offices
will promote close coordination between 201 and 208 activities regarding SAWS
implementation.
Task 7: SAWS Program Support
In addition to OWPO there are other organizations involved with SAWS
programs. Included are other EPA offices, other Federal agencies, State and
local agencies, professional associations, advocacy groups, arid public
interest groups. It is critical that the SAWS Strategy become well known and
accepted by these organizations, especially where it is recommended that they
take action (e.g., policy coordination, information transfer). Organizations
which support the Strategy are expected to become program advocates, assist in
the implementation of SAWS approaches, and leverage OWPO resources.
The following actions should assist in generating the support arid
assistance of these organizations:
1. Circulate the SAWS Strategy and subsequent guidance material to
o EPA offices, including Regional Offices
o Other relevant. Federal agencies
o Relevant national r-’rofessional and public interest organizations
o State arid local WQM, facility planning, and construction grant
agencies
2. AssIst the organizations listed in item one in implementation of the
Strategy recommendation, as appropriate.
3. Develop aria maintain corAtact with other key EPA offices and
participate in progiam and project review, as appropriate.
4. Develop and maintain working relationships with other Federal
agencies, and national professior al and public interest organizations.
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SECTION III
ISSUES AND OPPORTUNITIES
This section addresses a variety of issues and opportunities regarding the
planning, design, construction and management of small flows wastewater
systems. These concerns are discussed in this section and fall into three
general areas:
1. Issues regarding SAWS.
2. SAWS program management.
3. Opportunities for encouraging SAWS.
Issues
On—site wastewater treatment and disposal techniques have been
traditionally viewed by engineers, planners and others involved in community
development as a temporary means of sewage treatment and disposal until
conventional collection and treatment facilities became available. It is the
intention of the EPA SAWS program to change this since greater use of
alternative wastewater systems is environmentally and economically desirable.
ngineers, planners, and others involved in community development must
recognize that properly designed and constructed small alternative systems
will dispose of sewage in a cost-effective, adequate and nonpolluting manner
and are viable alternatives to conventional systems.
Although 25 percent of the Country’s population is served by small
alternative systems, there are very few examples of facilities which have been
systematically managed. Comprehensive management programs (i.e., from Initial
system approval to monitoring of system performance), for on—site and other
alternative systems would result in improved effluent quality and reduced
failure. A major thrust of the SAWS program will be to correct this
deficiency by encouraging the iniplementation of sound management practices.
Facility plans prepared and reviewed in conformance with the requirements
of’ the 1977 Clean Water Act are required to consider SAWS technology and
appropriate management arrangements. In addition to proper SAWS management,
including O&M, other concerns about the use of small flows systems include
their potential secondary impac.s and septage disposal. Since conventional
systems also have undesirable secondary impacts, local officials must also
consider the comparative secondary impacts of conventional and SAWS
technologies. One such secondary impact is the effect of sewering on an
area’s development. Although SAWS technologies generally do not share the
extensive growth inducing properties of conv ntional sewer systems, other
undesirable secondary effects may result such as scattered development,
“leapfrog” subdivisions, and in ’ringement on environmentally sensitive areas.
These growth patterns sharply increase the costs of providing water,
utilities, and other public and private services.
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Local planners are concerned that changes in on-site sewage disposal
criteria and management designed to encourage the installation of SAWS systems
may result in large scale scattered development. Undesirable growth patterns
need not result if adequate land use controls are utilized. In some
communities the only controls on land use are large lot zoning, siting and
building requirements, and strict control of on—site sewage disposal
facilities. While these controls may recognize land use and water quality
relationships, site specific application of these controls may be
unnecessarily restrictive. Wastewater management policies should be
coordinated with other public service facilities and land use policies and
controls. Communities should not rely solely on on-site sewage disposal
policies as a technique to guide development. Through adoption of appropriate
land use control policies and controls, communities should be able to meet
both local wastewater management and land use objectives.
Septage management must be considered in a SAWS Strategy as septage is
sometimes inappropriately disposed of in unsecured landfills or surface
waters. If ’ discharged to a publicly—owned treatment facility, septage can
upset the plant’s performance if’ the plant was not designed to accept the high
strength waste, or if it is currently operating at design capacity. The
septage disposal problem is further aggravated by increasingly stringent
landfill siting and operational requirements. Facility plans and WQM plans
should provide for septage management.
SAWS failures can generally be attributed to:
1. Unsatisfactory design/site evaluations including improper location,
unsuitable soil, and inappropriate technology.
2. Inadequate review of system proposal by regulatory agency.
3. Unsatisfactory construction of’ system.
I L Hydraulic overloading resulting from inadequate capacity or improper
homeowner utilization of’ the sy ;tem.
5. Discharge of inapçropriate substances such as solvents, toxic
materials, and large quantities of nondegradable materials to the system.
6. Lack of appropriate O&M resulting in migration of’ solids to soil
absorption system and subsequent clogging.
7. Lack of backup treatm&tt units or pumps during period of power
failure.
8. Structural deterioration caused by age or improper use.
The prevention of’ system fatlures must be an important consideration in
the development of’ SAWS management programs. Improved system performance and
reduced system failures can be .-Lchieved through the implementation of a SAWS
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management program including design standards, review and approval procedures,
inspection prograu , O&M procedures, monitoring and enforcement programs, and
educational programs.
Proper construction of an approved alternative system should be given
special consideration in SAWS management systems to insure maximum system
life. SAWS management systems must contain provisions for insuring that SAWS
are constructed in accordance with approved plans.
SAWS Program Management
Current efforts to regulate small flows systems are highly fragmented
among a number of different agencies at different governmental levels.
Although a multi—tiered approach may be desirable under a comprehensive,
well—structured management system, the existing SAWS institutional structures
have generally been arrived at in de facto fashion. Undesirable management
arrangements typically have:
1. Programs, policies, and procedures that are neither coordinated,
mutually supported, nor consistent with those other agencies.
2. R€sponsibilities that overlap, are duplicated, or may not be
specifically assigned.
3. Programs that lack accountability and program evaluation.
14 Certain functions that lack legal authorization.
5. Significant delays arid additional costs resulting from a lack of
clear and specific policy and organizational structure.
In addition to organizational constraints, management agencies may have
other limiting factors including budgetary and staffing constraints. These
may limit agency capabilities to adequately administer inspection, review,
enforcement, operation, and ot1 er responsibilities. Given limited resources,
philosophical objections, or perceived low priority, some agencies are
reluctant to accept additional SAWS responsibilities. Acceptable SAWS
management programs need not be prohibitively complex arid expensive.
Specific procedures, policies, and design standards vary widely, even in
the same State. In some areas there is a lack of’ published uniform design
criteria and guidance. Many existing criteria are not based on performance
data and are unnecessarily restrictive, contributing to arbitrary rejection of
many SAWS projects. This lack of uniformity in design criteria and approval
procedures inhibits technological innovation and restricts marketing, thus
reducing potential cost savings and limiting the availability of improved
systems. As more flexible standards and approval procedures are adopted by
State and local governments, the growing acceptability of SAWS technology and
management approaches should b come known to the engineering community and
equipment manufacturers. Acceptance of SAWS by State and local governments
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will be greatly enhanced b ’ demonstrating that SAWS can perform as well or
better than conventional t; ’eatment works under specific operational
circumstances.
Opportunities for Encouraging SAWS
Recent facility plans : ave more comprehensively evaluated wastewater
treatment and disposal needs of and options available for rural and urban
fringe areas. Implementation of the SAWS Strategy recommendations will
enhance the construction grants and WQM programs as applied to rural areas by
a systematic consideration of SAWS.
A number of opportunities exist for encouraging the utilization of SAWS.
Many of these opportunities center around solving existing problems. The
problems listed below provided direction to the formulation of the Strategy
recommendations in Section II. Opportunities exist to promote SAWS and
improve 201 facility plans by overcoming the following:
1. Bias against SAWS approaches by local officials, engineering
consultants, and plan revi w personnel. This attitude may reflect a lack of
understanding, and a belie that SAWS are technically inferior to conventional
systcms, or are a nanagerial ani/or administrative burden. As a result,
facility plans may only include a token analysis of SAWS. Unwarranted
assumptions may be made in such areas as cost—effective analyses to insure the
selection of conventional systems.
2. Lack of technology transfer, understanding and inexperience in
applying SAWS state—of—the-art technology, including limited information on
performance and reliability; ca3ital, O&M, arid management system costs;
cost—effective analysis teohniq.ies; environmental and public health effects;
secondary impacts; legal, adminLstrative and institutional implications; soil
capabilities and maintenance requirements. This information gap represents
research deficiencies, information transfer problems, and limited coverage of
SAWS technology in engineering 3chool curricula and technical literature.
3. The lack of adequate analysis of existing system failures in Step 1
facility plans. If sanitary surveys and site evaluations are included in
facility plans, they may not show the true extent of’ system failures. If
system failures are carefully e raluated in a facility plan, the actual number
of’ failures may be well beLow the perceived number; all that may be necessary
to improve wastewater treacment and disposal would be the renovation of failed
systems, upgrading of other on-3ite systems, and implementation of appropriate
monitoring, maintenance, aid ot ier management activities.
i Poorly understood and inadequately evaluated management systems.
Improved guidance is needed for engineers and planners concerning specific
acceptable management approaches including ownership requirements, maintenance
programs, monitoring, inspectiois, user charges and other financing
techniques, and types of managenent agencies.
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5 Existing local or State regulations which discourage or prohibit SAWS
implementation.
6. Inadequate State and local capabilities and commitment to effective
SAWS management programs; lack of clear and consistent responsibilities and
policies among State and local agencies.
7. Lack of consistency and clarity among various Federal and State SAWS
funding programs (e.g., eligibilities, procedures, terms, objectives).
8. Lack of program coordination/clarity and consistent policies between
SAWS and related EPA programs including WQM.
9. Reluctance of small communities to participate in the grants program
because of time delays, red tape, anti—Federal feelings, lack of’ perceived
problems, and lack of awareness of the grants program.
10. Inadequate consideration of areawide SAWS management approaches
resulting from lack of legislative authority or institutional feasibility.
11. General reluctance of project officials already awarded a Step 1
grant to consider SAWS requirements and to respond to additional OWPO
guidelines.
12. The initial resistance faced by the I/A and rural set—aside
programs. This resistance stems largely from lack of understanding, concern
for public health and systems reliability/risk, and delay in establishment of
administrative procedures. A number of States may experience loss of grant
funds through reallocation; ho ever, the picture for FY 1981 appears to be
improving.
13. Inadequate ORD resources for SAWS analysis.
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SECTION IV
EXISTING SAWS PROGRAMS
Many agencies are involved in SAWS planning and technology. Activities
include setting of’ standards and criteria, planning, research, approval of
facility plans, O&M, grant support, technical assistance, and enforcement.
Approaches to SAWS management and distribution of program responsibilities
vary widely, especially at the State and local levels. This section provides
an overview of current Federal, State and local programs.
EPA SAWS Programs
The major offices dir’ec tly involved in SAWS activities are WPD and FRD of
OWPO, and MERL of’ the Office of Environmental Engineering Technology of the
Office of Research and Development.
Water Planning Division
The Water Planning Division has general responsibility for WQM programs
under Sections 106 and 208 of Public Law 95—217. Section 208 is a State and
areawide planning grant program which includes problem assessments, analysis
of’ improved management systems, and technical solutions.
Although there have already been many SAWS studies funded through
section 208, many of the initial plans were insufficiently detailed in terms
of scope, level of analysis, and specificity of recommendations.
Implementation of this SAWS Strategy should result in more effective
guidance and monitoring of’ WQM SAWS projects and should be useful in making
funding decisions.
Groundwater Strategy, other related prototype projects and the financial
management assistance program are other WPD priority work areas related to the
SAWS Strategy. In each case improved SAWS management is being examined
through case studies and related methodology development. Improved SAWS
management is considered a best management practice when used in conjunction
with a comprehensive groundwater management plan.
Facility Requirements Division
In 1976 the continuing quaiity review of facility plans revealed that some
small communities might nct be capable of bearing the costs of conventional
sewers and treatment plants. To conf’irrn this a survey of 258 facility plans
in 119 States was conducted that summer. This survey revealed that
conventional treatment works could result in high user costs for some small
communities. In an effort to deal with the serious problems of’ these high
costs, the EPA Administrator issued a policy statement in December 1976
requesting that the Regional Acministrators promote less costly vastewater
treatment for srna]l cormnuniti& through measures including small alternative
systems.
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Since enactment of the Clean Water Act of 1977 EPA has vigorously
encouraged the implementation of SAWS approaches through the 201 construction
grants program. Much effort has been expended in developing appropriate SAWS
regulations and promoting SAWS technology through educational and public
information efforts. A Nation ]. Conference for Less Costly Wastewater
Treatment Works for Small Communities was held in April 1977 to emphasize
small system technology. EPA has actively participated in the White House
Rural Initiatives Program by suggesting ways less costly wastewater treatment
can be delivered to rural America. Additional educational and public
information efforts have included 50 presentations at meetings, conferences,
workshops, and seminars over the past 2 years; more than 50 seminars designed
to support SAWS and innovative and alternative technology; a descriptive
foldout for alternative systems for extensive national distribution; and five
handbooks concerning the use arid management of’ alternative wastewater
systems. A total of four separate series of seminars and workshops are being
prepared by the Small Flows Clearinghouse at West Virginia University, the
University of Wisconsin, and the National Environmental Health Association.
Municipal Construction Division
The Municipal Technology Branch (MTB) of the Municipal Construction
Division (MCD) ha played an ai tive role in the development and evaluation of
SAWS technologies. MTB interacts with SAWS programa in the following areas:
I. Ongoing evaluaticn of low level technologies such as land treatment,
ponds, wetland application, anc aquaculture. These technologies may be
appropriate for u e by small ccmmunities.
2. Management of’ the lnncvative and alternative technology program.
3. Technica] and policy E.upport.
Municipal Environmental ReL.earch Laboratory
Research on the performance characteristics of’ small alternative
wastewater systen has been corducted by MERL for a number of years. Since
the enactment of’ Public Law 95 217 the efforts of’ MERL have become
increasingly visible and eces ary for SAWS program development.
With limited funding P ERL conducts SAWS research in the following areas:
Ongoing :
1. Evaluation of alterna ive technologies including aspects of
performance, costs, applicability under varying site and climatic conditions,
health and environmental Impac.s.
2. Development of au I/A system manual; providing technical support to
Regional Offices in revie ’ of lA proposals; development of I/A seminars.
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Currently being developed :
1. “Planning Wastewater ! nagement for &nall Communities”
(EPA—600/8—80—030) available at General Services Administration (8BRC),
Centralized Mailing Lists Services, Denver Federal Center Building 1 1,
Denver, Colorado.
2. SAWS institutional/management manual and case study analysis; final
report available mid 1981.
3. Septage management manual.
14 “Design Manual, On—Site Wastewater Treatment and Disposal Systems ;“
final report available from EPA Center for Environmental Research Information.
5. Evaluation of new SAWS concepts including waste utilization,
recycling, and advanced treatment and disposal.
6. Inclusion of SAWS technology in civil/environmental engineering
curricula.
7. Evaluatioi of on—site i onstruation methods; report due late 1980.
8. Administration of Smafl. Flows Clearinghouse at West Virginia
University.
9. Accelerated field performance evaluation of SAWS technology; output
commencing FY 1981.
To be developed :
1. Evaluation of cost—effective site evaluation and sanitary surveys to
improve problem assessment and system design; anticIpated 198 1—82.
2. Evaluation of SA S management systems; anticipated 1981—82.
3. Cost—eftectivene s evaluation procedures for SAWS options;
anticipated 1981—82.
. Impact of and cortrol requirements for toxic substances; anticipated
198 1-82.
The institutional/mafl gemerLt manual currently In preparation by MERL will
be of particular interest to W M and facility planners in developing State and
local SAWS programs. Th1 manual will do the following:
1. Develop State and boil case studies of existing SAWS management
practices.
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2. Identify issues, problem constraints, and opportunities for
management.
3. Develop and evaluate generic management alternatives.
II. Make recommendations for implementation procedures for local planners
and public officials.
Center for Environmental Research Information (CERI )
The Technology Transfer staff of CERI assembles research findings and
distributes this information to the field. CERI has published a number of
important manuals in recent years including, “Wastewater Treatment Facilities
for Small Communities.” CERI administered the Small Flows Clearinghouse prior
to it being administered by MERL.
Other EPA Programs
The Robert S. Kerr Environmental Research Center (Office of Research and
Development) at Ada, Oklahoma is conducting research to evaluate the effect of
on—site wastewater treatment on groundwater. The results of this research
will b€ used to determine the reliability of criteria used in the design of
on—site wastewater systems. Thc Center is also involved in a series of
workshops with OWPO on overload flow.
The National Training and Operational Technology Center (NTOTC) of OWPO
located in Cincinnati, Ohio is preparing for presentation in FY 1981 two SAWS
seminars for the academic commur ity and ten for the engineering community.
Other Federal and Non-Federal Nt tional Programs
At the Federal level, other agencies with significant programs of interest
in small flows systems include:
1. U.S. Department of Agriculture (Farmers Home Administration, Forest
Service, Soil Conservation Service, Agricultural Research Service).
2. U.S. Department of Houz.ing and Urban Development (Federal Housing
Administration; lead on special interagency study of’ Modular Integrated
Utility Systems).
3. U.S. Department of’ Commerce (Economic Development Administration,
National Bureau of Standards).
. Community Services Administration.
5. Appalachian Regioral Ccimmission and other regional economic
development commissions.
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6. U.S. Department of Int ior (Office of Water Resources Technology,
National Park Service, Bureau of Indian Affairs, Fish and Wildlife Service,
Bureau of Land Management, Hwl.bage Conservation and Recreation Service).
7. U.S. Department of Transportation (Federal Highway Administration).
8. U.S. Department o:’ Def se (Army Corps of Engineers, Army and Navy
Environmental Research Progranm).
9 • National Science Foundation.
The EPA SAWS Strategy should be closely coordinated with other Federal
programs in terms of funding priorities, eligibilities, procedures,
consistency of policy objectives, environmental objectives and research
priorities. Coordination : s necessary to eliminate inconsistent objectives,
reduce confusion among local constituencies, promote joint programs, reduce
duplication of effort, and facilitate Federal funding of projects.
Perhaps the most significant recent interagency effort is the White House
Rural Initiatives Program. A Federal agency task group was assembled to
coordinate the numerous program involved in the technology, management, and
financing of small commun it.y wa .er and was tewa tar projects. For example,
through these ooopcrative tfor s Federal agencies are developing common
criteria for conducting co ;t-effectiveness analyses and instituting
coordination procedures ane interagency facility plan reviews. Interagency
efforts are underwny to enc oura ;e cost-effective areawide management of 0&M
aspects of rural water and wastewater projects. As these interagency efforts
are implemented at the Federal ind State level, low—cost technologies will be
given greater expo: ure and preference in small towns and rural areas.
A variety of n ’tional crganzatic is have an interest in SAWS technology
and management. These grot pa include:
1 Water Pollution Control Federation
2. American society of Cic ii Engineers
3. Association of State ard Interstate Water Pollution Contr9l Agencies
Ij National Issociation of Conservation Districts
5. National I ssooiation o Regional Councils
6. National Conference of State Legislators
7. Council of State Governments
8. National Association of Counties
9. National Association o; Towns and Townships
10 • Internatic.nal City ! n gement Association
11. American Public Wcrka :ssociation
12. American Planning Association
13. American Society of Agricultural Engineers
11$. National anitation Foi ndat1on
15. Water and Wastewater Ecuipment Manufacturers Association
16. A1ternati’ e Wastewater t nagement Association
17. Land Improvement Contrz ctors Association
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18. National On—site Sewage Treatment Association, Inc.
19. National Association of’ Home Builders
20. National Environmental Health Association
21. American Clean Water Association, and other environmental groups
22. Regional Engineering Design Standards Committees
These organizations have the capabilities of assisting in the
implementation of the SAWS Strategy and improving management programs by
providing public and professional education, research, testing, certification,
and political support.
State SAWS Programs
States are currently involved in a wide variety of’ SAWS regulatory and
management activities; however, most State efforts are generally neither
comprehensive nor effectively organized. This section provides an overview of
existing State SAWS programs to aid in developing program recommendations.
This SAWS Strategy calls upon all States to assume a major leadership role.
Currently the responsibility f’ or small system management may be shared by
the State departments of natural resources, coastal zone management, plumbing,
health, environmental protection and planning. After the formation of EPA,
many States reorganized so that i’esponsibility for construction grants
management programs was more centralized. The responsibility for on—site
sewage disposal, however, has generally remained a separate program area.
This split could present institutional and management problems in the State’s
administration of the construction grants program. In addition, the
development and enforcement of State wastewater standards could present
problems if there is insufficient cooperation among State offices.
Many State agencies (primari:y health departments) involved with the
administration of’ SAWS programs have delegated portions of their
responsibilities to regional and local agencies. These local agencies are
largely responsible for providin ; the technical expertise for facility plan
design review and supervision of facility construction.
Many of the local agencies providing SAWS project review are not
responsible to the State wat.er pollution control agency. Since it is usually
the State water pollution control agency that administers the EPA’s
construction grants program, it is necessary that reliable lines of
communication and coordination be established between the water pollution
control agency and the State agency that regulates SAWS projects. If’ the
State has delegated responsibility to the local level, reliable lines of
communication must also be extended to the local level. In this way, the
State and local water pollution control agency could be more attuned to the
wastewater needs of rural communities and appropriately include them on State
construction grant priority lists.
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Since responsibility for the technical review of SAWS has largely been
delegated to State and local agencies, the utilization of SAWS technology
hinges on the acceptance of SAWS technology by these agencies. EPA
educational efforts have helped in convincing local authorities that SAWS are
viable sewage treatment arid disposal systems. State and local authorities
should institute legislation if ’ they have not already done so to specifically
allow ulitization of alternative technologies and establishment of necessary
management agencies.
The wastewater management programs in many States have recognized the need
for educational programs and technical guidance. In addition to educational
and technical guidance, several States are considering modification of their
statewide plan review procedures to include SAWS projects as a separate and
distinct item with specialists in facility plan preparation and Federal
funding acting on behalf of small communities. An overview of State programs
is provided in “Management of On—site and Small Community Wastewater Systems,”
published by MERL as part of its institutional research project.
Regional and Local SAWS Program
Responsibility for regulating and managing SAWS has traditionally been
delegated .Lri large part tc local government units, homeowners, and the private
sector (e.g., developers, septage haulers, and septic tank system
installers). Since SAWS management requires more comprehensive and structured
administrative procedures, altvrnative local management systems must be
evaluated as part of WQM and facility plans. The following broad options are
available for local SAWS planners:
1. Strengthening existing institutional arrangements through additional
authorities (e.g., new enabling legislation and interagency agreements) and
resources (e.g., ncreasec staiT and budget).
2. Realignment and clarification of agency responsibilities combined
with establishment of new publ c or private management agencies.
3. Re—evaluation of State and local SAWS responsibility to provide
greater guidance and accountability.
Agencies that operate at the regional level will have a major role to play
in the management of SAWS. They are involved in the planning, technical
assistance, public education, arid operating aspects of SAWS. While not all of
these agencies have operational responsibilities, they may have other roles to
play in facilitating impl€ mentation of SAWS programs. Possible management
agencies include:
1. Regional planning comrAissions
2. Watershed association
3. Interstate cooperativos
1 L Regional sewer auth ’.ties, districts, or utilities
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Many regional planning commissions and watershed associations are involved
in the preparation of WQM plans that address the need for improved SAWS
management programs.
Interstate cooperatives such as the Northwest States Task Force For
On-site Disposal and the Ten State Standards Committee on Individual Sewage
Systems of’ the Great Lakes—Upper Mississippi River Board of State Sanitary
Engineers provide technical assistance and/or set standards. The cooperatives
are involved in evaluating research and developing criteria and standards for
on—site systems.
Regional sewer authorities have traditionally been involved in providing
conventional sewerage service to urban and suburban areas. Some of these
authorities have begun to recognize a role they could play in SAWS management
by undertaking the following tasks—-planning, construction, design, O&M, and
septage management. The broad jurisdictional base and available technical
expertise of regional authorities may make them well suited to provide these
services. Many sewer authorities, however, have negative views of’ SAWS
projects and are reluctant to accept additional responsibility for SAWS
planning and management. Consequently these authorities are not inclined to
pursue grant funds for these systems.
In recent years the responsibility for SAWS program management has begun
to shift from the State to local levels. In many instances county units of
government are viewed as the most appropriate level to provide services
through a line department or special district. SAWS services may be provided
by the following public and pri,ate entities——health department,
planning/development department, building/plumbing department, 208 planning
agency, soil and water conservation districts, wastewater districts, public
utilities, homeowners associations, installers, and septage haulers.
The SAWS services provided by some of the local governmental organizations
include management, O&M, and regulation for the systems in their
jurisdictional areas. Regulations are generally promulgated by State and
local health/environmental departments. Enforcement is carried out by State,
county, or town health and/or environmental departments, or special wastewater
districts.
One of the most important functions of the local regulatory and management
agency is technical assistance and education aimed at homeowners, developers,
and others interested in community development and environmental protection.
Brochures and manuals which describe local approval procedures, SAWS
technologies, and O&M should be made available. Local agencies can also
conduct seminars/workshops on S.P.WS management and 0&M in order to improve the
state—of—the—art knowledge of engineers, homeowners, and installers.
In some areas wastewater’ mar agement districts have been formed to manage
and enforce regulations. Such SAWS management programs are administered by
newly formed or pre—existing saritary districts, special management districts,
public authorities, municipal public works agencies, as well as private
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organizations such as homeowners associations, publicly regulated utilities,
rural cooperatives, private installers, and septage haulers. These locally
organized management programs can own, operate, and maintain-noncentral
wastewater systenm, or can contract with individuals to provide maintenance
services. Case studies of local efforts to improve SAWS management are
outlined in an interim study report titled “Management of On—Site and Small
Community Wastewater Systems,” (M687) prepared by MERL.
Although Federal and State agencies have important roles to play in SAWS
management, it is the local agency which provides the necessary one—to—one
interaction with the service area resident. The visibility and performance of’
the local representative is the key ingredient in developing and operating a
successful management program. The most successful programs result when
consensus exists regarding the nature of the local problems and the methods of’
solution. There is no substitute for strong, committed local leaders In the
planning, design, and administration of a SAWS management program.
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TABLE 2
CLEAN WATER ACT P MENDMENTS
IMPACTING SAWS
A set—aside of 2 percent (FT 1979 and 1980) and 3 percent (FY 1981) for I/A
systems; 85 percent funding (as opposed to the usual 75 percent for capital
costs of alternative technologies (Section 17; Section 202(a)).
A cost—effectiveness bonus of 15 percent for such technologies when publicly
owned. That is, they can be 15 percent more costly and still be selected
(Section 16; Section 201(j)).
A set—aside of up to 14 percent of the total grant amount for grants to small
communities implementing alternative technologies. The set—aside will be
14 percent in the States with 25 percent or higher rural population, and may be
negotiated at up to 14 percent for States with lower rural populations upon a
governor ‘s request (Section 27; Section 205(h)).
Assignment of higher priority to I/A project (Section 2014(a)(3)).
A grant to fund all of the costs for modification or replacement of any
facilities constructed with an 85 percent grant if such facilities have not
met p formance specifications unless negligence is involved
(Section 202(a)(3)).
creation of a clearinghouse for information on alternative technologies to aid
in technology transfer (SectIon 7; Section 1014(q)).
A requirement that such technologies be more systematically considered in the
grants process, specifically in the facility plans (Section 12, Section 141,
Section 201(g), Section 217).
Revised procedures for the evaluation of collection systems (Section 36,
Section 211).
Provisions making individual systems grant eligible for rehabilitation under
certain conditions (Section 114, Section 201(h)).
Provisions to reduce water consumption and sewage flow (Section 21;
Section 2014(a) and to study requirements for coordinating water supply and
wastewater treatment (Section 72; Section 516).
Eligibility of alternative systems to serve existing private homes and
businesses If a public agency applies for a grant, gives assurances of
adequate maintenance, develops a monitoring program, and initiates a user
charge and cost recovery system (Section 114; Section 201(h)); publicly—owned
alternative systems are also grant eligible.
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APP END ICES
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APPENDIX A
SAWS Strategy Recommended Activities by Participant, FY 1980-1983
Office of Water Program Operations Activities
Fiscal Year(s) Perf -med
Activity FY 1980/1981 F! 1982 FY 1983
Develop new training
materials (Task 1) X X X
Disseminate training inate-ial
(Taski) X X X
Conduct workshops/seminars (Task 1) X X
Develop SAWS State
prototypes (Task 2) X X
Develop SAWS program
guidance (Task 6) X X
Provide technical £ssistance
to WQM & facility planning
agencies (Tasks 1,11,6) X X X
Coordinate prototype
prograri , (Task 6) X X
Maintain and develop liaiscn with
other EPA offices, other Federal
agencies, public ir.tterest
-groups, States and professional
associations (Tasks 3,7) X X X
Streamline construction grants
program procedures (Task 11) X X
Coordinate with other
EPA offices in promoting
SAWS (Tasks 11,6,7) X X X
Develop generic model facility
plan (Task 14) X
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EPA Regional 0 f ice Activities
Fiscal Year(s) Performed
Activity FY 1980/1981 Fl 1982 FY 1983
Identify SAWS training need ;
(Task 1) X
Review proposed training
materials (Task 1) X
Disseminate training materials
(Task 1) X X X
Develop technical assistance
capabilities (Task 1) X
Provide technical assistance to
WQM arid facility planning agencies
(Tasks 1,k,6) X X X
Develop Regional SAWS
guidance (Task 6) X X
Promote support for
SAWS approaches (Task 7) X x X
Coordinate with review of
small community facility
plans (Task ‘$) X X
Identify candidates for SAWS
prototypes; cooperate with
SAWS prototype program (Task.3 2,6) X X
State and Areawide Water Quality Management
Agency Activities
Fiscal Year(s) Performance
Activity FY 1980/1981 Fl 1982 FY 1983
Participate in training workshops
(Task 1) X X X
Develop SAWS components in
WQM Plans (Tasks 2,6) X X X
Participate in SAWS prototype
program (Tasks 2,6) X x x
Implement SAWS management program
(Tasks 2,’ ,6) X X X
Provide technical assistance to
local agencies (Task 1)
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Other Office Activities
Fiscal Year(s) Performance
Activity FY 1980/1981 FY 198 FY 1983
MERL direct Small Flows
Clearinghouse (Tasks 1,5) X X X
MERL conduct SAWS management
research (Task 5) x x x
CERI conduct SAWS workshops
and publish inar uals (Task 1) X x x
Office of Research and Development
conduct SAWS research X X X
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APPENDIX B
State SAWS Program Activities
A. Planning/Plan Review
o Community Wastewater Management Plans (including 201 plans)
o General Problem Assessments and Priority setting
o Analysis of SAWS nonpoint source best management practices
o Generic Model Facility Plans
o Facility Plan Review criteria
— evaluation of alternatives guidance
- economic and technical criteria
— impact assessment methodology
o Special Facility Planning Units
o Guidelines for Facility Plan Preparation
o Guidelines for Sanitary Surveys
o Guidelines for Land Development Plan Preparation
o Land Development Review Methodology and Impact Criteria
B. Regulations
o Program Guidance Manials (institutional issues)
o SAWS Technology Approval critwia and Procedures
o Design Standards Development
o Enforcement Prooedures Guidance
o Regulatory/Enforcement Program Evaluation Criteria
o Enabling Legislition for Alternative System Management
o Evaluation of L3cal Program Management (capabilities, effectiv” ss)
o Monitoring of Ground and Surface Water Impacts of SAWS
C. Financing
o Facility Planning and Design
o Facility Construction
o 0&M (e.g., partial support regulatory/enforcement programs)
o Institutional/Management Studies
o Private System Rehabilitation/Replacement Loans
o Priority List System for Small Communities
o Uniform Financing Policy and Funding Criteria
D. Education/Training
o Workshops/Seminars/Training Sessions
o Technical (instruction) Manuals
o Information Dissemination
o Training/Certif’icati on/Licensing
E. Research arid Development
o Demonstration Projects (technology/management)
o Monitoring of Full— .cale Operating Systems
o Field Testing cf Units
o Surveys of Operating Systems
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PLPPENDIX C
Items to be Corl3idered in Establishing Local SAWS Programs
A. Planning
1. Development of WQM and facility management plans.
o Research and Development on noncentral system costs and performance.
o Integrate land use planning and wastewater management program needs
and objectives.
o Determine most cost—effective and technologically feasible method
of sewage disposal.
2. Coordination of plan preparation, plan review, enforcement and
maintenance procedures.
o Coordination among various agencies.
o Arrange flow of project review among regulatory authorities to
provide the most expeditious review.
o Act as coordinator among agencies to facilitate plan review and
system installation.
o Eliminate duplication of effort.
B. Site Evaluation and Syst.em Design
1. Determination of site lim..tations for noncentral systems.
o Develop procedures and data requirements to conduct site
evaluations.
o Conduct site inspection and evaluation to ascertain unique site
characteristics.
2. Develop guidelines for syutem design.
o Establish/evaluatE pert’ormarice standards, construction
specifications, etc.
o Formulate requirements for licensing, certifying, and training
system designers.
3. Issue permits for system construction.
II. Provide design assist.ance: design publicly-owned systems.
C. Installation
1. Establish program for site inspections during system installation.
o By local public health or environmental departments.
o By licensed professional engineer or other qualified individuals.
o Develop procedures and guidelines for installation supervision.
2. Establish requirements for licensing, certifying and training system
installers.
3. Issue final inspection approval and/or permit.
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D. Operation arid Maintenance
1. Establish O&M procedures and responsibilities.
o Develop program of routine O&M.
o Conduct periodic inspections and evaluations of system operation.
o Develop enforcement and regulatory mechanism as required.
o Establish emergency maintenance procedures.
?. Develop program for septage handling, treatment, and disposal.
o Reporting mechanism to show amounts hauled, origin, method, and
location of disposal.
o License septage haulers.
o Acceptable methods and locations of treatment and disposal.
3. IdentIfy failing systems.
o Clearly define what constitutes a failure.
o Develop methodology of locating failed systems.
o Develop enforcement and regulatory mechanisms to correct failed
systems.
o Initiate rehabilitation efforts.
E. Financing
1. Identify available sources of funding.
2. Secure funds for system construction and initial upgrading.
3. Set and collect user fees for O&M.
1 L Establish and collect fees for permit issuance, plan review,
monitoring, etc.
F. Monitoring
1. Monitor surface and groundwater conditions.
2. Monitor existing syst€.ms for failure.
3. Monitor construction to determine if it is being done in accordance
with approved plans and specifications.
G. Public Education
1. Determine most productive method of educating engineers, developers,
and general public in SAWS technology and benefits.
2. Develop programs to convey to general public, engineers, and
developers informatic’n on SAWS technology, management systems, and
benefits.
3. Inform public of maintenance procedures, proper operation and water
conservation techniq es.
1 L Develop 3ystem fcr putlic reporting of system failure.
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APPENDIX D
Management Dimensions of Small Flows Institutional Arrangements
A. Type of Management Agency
o Municipality (including cooperative agreements)
o County Government
o Regional Planning Agency
o State
o Soil and Water Conservation District
o Special District or Service District (single or multiple purpose)
o Public Authority
o Private Utility/Contractor
o Homeowners Association
o Rural Cooperative
B. Selection of Management Entity Responsibilities Through Consideration of :
1. Service Area Characteristics
o Multiple or singular jurisdictional area
o Land use and population distribution
o Growth prospects
o Governmental tructure
o Willingne3s of local agencies to accept new responsibilities
o Responsiveness of private homeowners to assume certain
responsi’Di lities
o Management entity norm for locale
o Socioeconomic characteristics of service area
2. Type of Wastewater System Applied
o On—site o ’ cluster versus community
o Surface versus subsurface disposal
o Traditional versus alternative/innovative
o Domestic waste versus industrial, commercial, institutional
wastewater generation
3. Scope of Manage.nent Function
o Short-term or long—term system approach
o Remedial versus preventive solutions
o System ow ierslip/operation and maintenance responsibilities
o Regulatory or advisory perspective by management entity
C. Forms of Management Approaches
1. Local Programs
o Management of on—site systems through site design and evaluation
o Management of on—site systems through O&M
o Management of on-site systems through combination of above
o Small community settings (e.g., lakes, rural developing areas,
etc.)
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2. State Programs
o Strong State programs promoting individual and small community
systems management
o Combination of’ State and local participation in the management
of’ individual and small community systems
o Strong local programs promoting individual and small community
systems management
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APPENDIX E
Evaluation ( iteria for Selection of Management Agencies
A. Administrative Feasibili
1. Legal basis
2. Statutory authority
3. Relative complexity of SAWS program
IL Staffing requirements——number and level of expertise
5. Start—up time
B. Institutional Feasibility
1. Organizational changes required of existing institutions to implement
program
2. Required coordination among existing institutions to implement program
3. Existing functional capabilities
II. Ability of institution to accommodate change
5. Flexibility of management agency to deal with operational problems
6. Ability of management agency to attract and maintain professional and
nonprofessional staffing
o level of compensatirn in line with norm
o job satisfaction prcvided by position
7. Organization of management agency
o ratio of management to staff
o advancement for personnel built into organizational structure
C. Political and Public Acceptability
1. Attitude of public towards additional governmental intervention
2. Local government autonomy
3. Public participation in design and administration of program
. Accountability
5. Demonstration that SA4S programs require professional management due
to the needs and comDlexities of the program
6. Demonstration that the SAWS program is consistent with other plans,
policies, and objectives of the jurisdictional area
D. Effectiveness in Meeting -1ealth and Environmental Objectives
1. Attitude of jurisdictional agency towards enforcement of
health/environmental regt’lations
2. Scope of health/environmental problems-—State, local, regional or
national significance
3. Existence of appropriate l3gislation to meet health/environmental
needs
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E. Cost—Effectiveness
1. Availability of grant assistance
2. Ability to obtaLn maximum grant assistance
3. Relative cost of alternative management programs (type of agency,
public/private relationships, scope of service)
F. Financial FeasibilitI
1. Ability of management agency to act independent of budget constraints
caused by rapidly changing or politically expedient decisions
2. Ability of management agency to raise revenue
o assessments
o permit fees
o user charges
o inspection fees
o connection fees
3. Ability of users to pay for system O&M, rehabilitation, or replacement
Z • Distribution of costs to various user groups
5. Impact of SAWS programs on
o present and future local community budgets
o provision of other public services
G. Secondary Socioeconomic iffects
1. Nature, extent, and iistribution of impacts
2. Potential amelioration of impacts
3. Ability of management agency to cope with reaction of users to
adverse ef’fect:3 of’ SAWS program
LI. Ability of management agency to respond to changing user needs
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REFERENCES
FY 1980 WQM Funding Policy Sections 106 and 208, WQM Policy Memorandum A—2,
USEPA Water Planning Division, December , 1979.
Draft Innovative and Alternative Technology Assessment Manual (MCD—53), USEPA,
Municipal Environmental Research Laboratory and OWPO Municipal Construction
Division, (EPA—’t30/9—78—009), 1978.
Water Quality Management Five-Year Strategy, FY 1981 Baseline, USEPA, Water
Planning DIvision, January 1980.
Small Wastewater Systems: Alternative Systems for Small Communities and Rural
Areas, USEPA, Facility Requirements Division, January 1980.
Small Wastewater Systems, Program Requirements Memorandum 79—8, USEPA,
Facility Requirements Division, May 9,1979.
Interim Project Report, Management of On—Site and Small Community Wastewater
Systems, USEPA, Municipal Environmental Research Laboratory, (Prepared by
Roy F. Weston, Inc., West Chester, Pennsylvania) November 1979.
Small Commuflity and Rural Development Policy, White House, December 1979.
Rural Development Initiatives, Making Water and Sewer Programs Work,
White House, December 1970.
Planning Wastewater Management Facilities for Small Communities, USEPA,
Municipal Environmental Research Laboratory, (Prepared by Urban Systems
Research and Engineering, Cambridge, Massachusetts), August 1980.
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