United States	Region 4	EPA 904/9-84-117
Environmental Protection	345 Courtland Street, N.E.	January 1984
Agency	Atlanta, GA 30365
&EFW Environmental	Final
Impact Statement
North Carolina Barrier Islands
Wastewater Management

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
MAR 23 1984
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for wastewater management on the North
Carolina Barrier Islands.
This EIS was prepared in compliance with the National
Environmental Policy Act and implementing Agency regulations
• (40 CFR Part 6, November 6, 1979). In accordance with these
regulations, the Final EIS will be filed with EPA's Office of
Federal Activities. Availability of the Final EIS will then
be announced in the Federal Register, beginning a 30-day
comment period. (The Federal Register date is the same as
the date of this notice). This Agency will take no admini-
strative action on this Final EIS until the close of the
comment period.
We will appreciate your review of this document and any
comments you may have. Please send all comments to E.T.
Heinen, Chief, Environmental Assessment Branch at the above
address.
s \
,322/
H> .a

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FINAL
ENVIRONMENTAL IMPACT STATEMENT
NORTH CAROLINA BARRIER ISLANDS
WASTEWATER MANAGEMENT
prepared by
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV, ATLANTA, GEORGIA 30365
This Final Environmental Impact Statement (EIS) recommends a
strategy for wastewater management on the barrier islands of
North Carolina. This strategy provides assistance to barrier
island communities in planning for wastewater management. It
presents a step-by-step process that can assist facilities
planners in resolving the unique problems encountered on
North Carolina barrier islands and result in a cost-effective
and environmentally sound management system. Communities
involved in facilities planning are encouraged to use the
tools developed in this EIS wherever appropriate.
Comments or inquiries should be forwarded to:
E.T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
404/881-3776
CTTatle^'R. Jete,
Regional Admirw

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NORTH CAROLINA BARRIER ISLANDS
WASTEWATER MANAGEMENT
ENVIRONMENTAL IMPACT STATEMENT
Draft ( )
Final (X)
Environmental Protection Agency
Region IV
345 Court land Street
Atlanta, Georgia 30365
Type of Action:	Administrative Action (X)
Legislative Action ( )
EXECUTIVE SUMMARY
PART A. INTRODUCTION
This EIS provides assistance to local governments in the completion of
planning for wastewater management facilities on the North Carolina barrier
islands. It gives facilities planners a step-by-step process for wastewater
management planning. This process is intended to assist in resolving the
unique problems encountered on North Carolina's barrier islands and to result
in a cost-effective and environmentally sound management system. This
process is called the EIS Strategy in this Final EIS.
The EIS Strategy and two other strategies are examined in this EIS. The
other two strategies are the 201 Strategy, which 1s the Implementation of
existing 201 Plans without revision, and the No Federal Action Strategy,
which provides no further federal funding of any wastewater facilities on the
North Carolina barrier islands.
After careful evaluation, the EIS Strategy is recommended as the best
approach to cost-effective and environmentally sound wastewater management
planning for North Carolina's barrier islands. Communities involved in
facilities planning are encouraged to use the tools developed in this EIS
wherever appropriate.
PART B. BACKGROUND
Draft 201 Facilities Plans, which included many of North Carolina's
barrier islands, have proposed the construction of wastewater collection,
transportation and treatment facilities to serve large portions of these
islands. After an environmental review of the proposed facilities, EPA had
significant concerns about the potential impacts of these facilities.
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ThP nreoaratiori of a facilities plan is the first step in EPA's three
step Construction Grants program for wastewater facilities. To be eligible
for federal fundinq, proposed facilities must be part of an approved facil-
ities plan. steps 2 and 3 of the Construction Grants program are design and
construction, respectively.
EPA funding of the proposed facilities was determined to be a major Fed-
pral Action significantly affecting the quality of the human environment;
thus a decision to prepare an EIS was made. EPA decided that the preparation
of an areawide EIS in North Carolina would result in a consistent approach 1n
EPA's decisions on funding of wastewater facilities for the North Carolina
barrier islands. Furthermore, EPA determined that an areawide EIS would be
the most expeditious way of addressing the issues involved and promoting cost-
effective, environmentally sound decisions.
The issues that have been addressed by this EIS are.
i UatPr Oualitv - A determination of existing water quality, especially the
' documentation of water quality problems, is important. The draft 201
Plans attempted to justify the need for facilities on the barrier islands
based on the pollution of shell fishing waters by failing septic tanks.
Existing data did not support this position. Nonpoint mainland surface
runoff sources (not septic tanks) appeared to be the problem. The only
exceptions were some documented problems in finger-fill canals on several
different islands.
o Altprnati«o wastewater Techniques - All available technologies for waste-
Vater management on the barrier islands were not evaluated by the draft
201 Plans On-site and small community systems may provide appreciably
more cost-effective alternatives that could support low, medium and poten-
tially high density development.
? Financial	on Local Governments - The financial Impact on small
municipal governments of operating and maintaining centralized sewer sys-
tems is a major issue. Implementation of the draft 201 Plans by these
small qovernments with narrow tax bases and dependence on the tourist
industry mav place a financial burden on the community and its wastewater
customers or taxpayers. The draft 201 Plans have not demonstrated finan-
cial and institutional capability for these communities.
a Nnnrnlnt	Pollution - Studies 1n coastal areas 1n the Southeast
* have shown that nonpoint runoff is responsible for closure of shellfish-
ina waters where sewer systems exist. New waste disposal facilities may
promote higher density development, thus Increasing the potential for non-
point source pollution of estuarine waters. This potential adverse
impact has been addressed in the EIS.
5 Groundwater - The EIS addressed the potential impacts on groundwater hy-
dro! oav from the application of effluent to the soil. The potential for
contamination of shallow groundwater by soil absorption wastewater sys-
tems was examined. The quality and quantity of this resource, as well as
its current and potential use as a drinking water supply, were considered.
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6. Sensitive Natural Areas - The EIS has addressed the primary and secondary
impacts of wastewater management facilities on sensitive natural areas
such as dunes, wetlands and estuarine waters. The effectiveness of the
N. C. Coastal Area Management Program is an important factor in address-
ing the impacts on these systems.
PART C. RECOMMENDED STRATEGY FOR WASTEWATER MANAGEMENT
A strategy for wastewater management on the North Carolina barrier
islands was developed through the EIS process. This strategy is intended to
provide assistance to local governments in planning for wastewater management
for North Carolina barrier islands.
The process of applying the strategy to existing draft 201 Plans or in
future planning efforts will consist of investigating the various alterna-
tives available for each. 201 area by using procedures developed in the EIS as
appropriate. The primary and secondary environmental impacts, as well as the
costs, reliability, and implementabi1ity of each alternative, will be
addressed.
The EIS Strategy is that communities involved in facilities planning are
encouraged to update and revise their draft 201 Plans as appropriate using
procedures developed by the EIS. The EIS procedure focuses on refinements to
population and land use analysis, development of wastewater flows, evaluation
of alternative wastewater systems, and financial and institutional
considerations which are appropriate for barrier islands.
The procedures are consistent with the Construction Grants program regu-
lations and other facilities plan preparation guidance; however, they are
tailored and refined to address the unique environmental and socioeconomic
conditions on the North Carolina barrier islands. The procedures were
designed to address the six issue areas identified earlier. Special atten-
tion was given to two areas which were most lacking in the draft 201 Plans:
(1) a thorough evaluation of all wastewater technologies, especially on-site
and small community systems, and (2) financial and institutional impacts of
operating and maintaining wastewater management systems.
These procedures provide tools to assist the 201 applicant in; (1) deter-
mining need and estimating flows, (2) developing viable alternative waste-
water management systems, and (3) evaluating alternative wastewater manage-
ment systems. These tools are designed to identify all viable alternative
systems and to promote consideration of the major potential impacts on both
the man-made and natural environments. The use of these procedures and tools
will not mean that all 201 planning areas will end up with all on-site and
small community systems. The procedures will allow them to be fully
considered, however.
A case study analysis was performed on a hypothetical barrier island to
assist in identifying alternatives and their impacts under the EIS Strategy.
The island was designed to incorporate features common to most 201 study
areas so as to broaden the case-study's applicability. The cost impacts
shown below are taken from the-case .study-
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The EIS has identified the following potential impacts resulting from
implementation of the EIS Strategy:
1.	Costs
a.	The cost of this strategy is low to moderate. (The EIS case study
found this alternative to cost approximately $2.6 to 4.2 million.)
b.	Relatively low capital and O&M costs will not be a financial burden
on local governments and users.
c.	Additional costs will be incurred to update the draft 201 Plans.
These reasonable costs will be 75 percent grant eligible.
2.	implementabilily
a.	Draft 201 Plans may be revised through use of the EIS. These
revisions may be lengthy and costly in some cases.
b.	Existing development will continue to use on-site systems while
future development will tend to use a greater proportion of
community systems, especially with Increased condominium
development.
c.	An on-site management agency would not require a highly
sophisticated technical support system.
d.	Federal and state funds may be available to resolve existing
documented pollution problems.
e.	Septic tanks may surface 1n storm overwash, making repair necessary
for property owners.
3.	Reliability
a.	The mechanical reliability of on-site systems and small community
systems 1s high although they are susceptible to some storm damage
if erosion or flooding occurs.
b.	The reliability of treatment processes-1s high 1f systems are
properly installed, operated and maintained.
c.	Reliability of operation on a community-wide basis 1s high if
systems are centrally managed by a public agency.
4.	Primary Environmental Impacts
a.	Construction impacts will probably tend to be localized to areas of
new development and documented water quality problems.
b.	Functioning on-site and community systems are more likely to be
retained.
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c.	High density development with soil absorption disposal would raise
the groundwater table and would locally raise nitrate levels in
groundwater.
d.	The potential for pollution incidents due to storm damage may be
reduced by using on-site and community systems.
5. Secondary Environmental Impacts
a.	The strategy allows future development flexibility and desired
development density and locations.
b.	Future development will likely contain a mixture of high and low
densities in response to community land use values and the need for
environmental protection.
c.	Lower density development will minimize the volume of stormwater
runoff per developed acre, thus having less of an impact on water
quality and shellfish harvesting areas.
PART D. ALTERNATIVES TO THE RECOMMENDED STRATEGY
The EIS compared the	recommended strategy to the alternatives of no
action (No Federal Action	Strategy) and of approving the draft 201 Plans as
submitted (201 Strategy).	These two alternative strategies and their impacts
are described below.
The No Federal Action Strategy
The No Federal Action Strategy would be a decision by EPA not to partici-
pate in the further planning or funding of wastewater management facilities
in the study area. Analysis of this strategy by the EIS projects continued
growth on the barrier islands even if publicly-owned and funded facilities
are not constructed. Without additional EPA assistance, existing wastewater
management practices will continue. Localized state regulations will govern
the use of soil absorption systems. Individual property owners will be
responsible for providing adequate treatment and will bear the cost of
renovating failing systems or installing new facilities.
The EIS identified the following potential impacts should the No Federal
Action Strategy be implemented:
1.	Costs
a.	This is the lowest cost strategy. (The EIS case study found this
alternative to cost approximately $1.4 million).
b.	Costs associated with implementing this strategy willfrimarily be
the responsibility of property owners and developers with some
assistance possible from the stats for specific; studies or projects.
2.	ImpTementability
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a.	The Institutional mechanisms for implementing this strategy are
currently in place and functioning.
b.	Functioning on-site systens would be retained.
c.	Storm damage to wastewater systems should be minimal since most
systems are underground; however, septic tanks may surface in storm
overwash, causing expense to Individual property owners.
3.	Reliability
a.	Mechanical reliability of on-site and small community systems is
high when new. Reliability will decrease as the systems age due to
sporadic maintenance.
b.	Reliability of treatment processes 1s high Initially but will
probably decline over time due to sporadic maintenance.
c.	Reliability of operation on a community-wide basis 1s low since no
centralized management is likely to be provided.
4.	Primary Environmental Impacts
a.	Improperly installed and operated on-site systems could cause a
localized elevation of nitrate and bacterial concentrations 1n
surface waters. This 1s occurring in a few isolated f1nger-f1ll
canal areas.
b.	Existing water quality problems 1n such areas may not be Identified
and corrected.
c.	Construction Impacts would be confined to new developments and areas
with falling systems requiring new or modified systems.
5.	Secondary Environmental Impacts
a.	Lower density development minimizes the potential for adverse
. impacts to surface waters from stormwater runoff.
b.	High density developments must give more detailed consideration to
wastewater facilities prior to construction.
The 201 Strategy
The 201 Strategy would be the approval and Implementation of the draft
201 Plans without significant changes. The plans would have to be updated 1n
certain areas such as costs. Those plans proposing ocean outfalls (Dare
County and Carteret County) would have to Incorporate the results of
site-specific surveys. The Carteret County plan for the barrier Islands
would have to be modified since one of the two communities Involved elected
not to participate.
One of the six plans, Hatte-ras Island, proposes no action because it was
determined that a system is not economically feasible at this time. The
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other five plans exhibit several similarities. Each plan calls for the re-
placement of existing on-site wastewater systems (septic systems) with cen-
tralized collection, transmission, treatment, and disposal systems. These
plans justified the need for facilities based on reports of shellfishing
harvest area closings due to elevated fecal coliform counts. The plans also
projected additional shellfish area closings with continued rapid residential
and commercial developments using on-site systems.
Another similarity is the proposal to provide sewer lines to all areas of
these communities, regardless of the current level of development. Pumping
stations and force mains are to be used in all facilities to transport
effluent to the treatment plant. Secondary treatment is proposed for each
facility, along with ocean disposal in Dare and Carteret Counties, spray
disposal in Topsail/Surf City and Southwestern Brunswick County, and surface
water discharge to the Cape Fear River in Southeastern Brunswick County.
The impacts of the 201 Strategy as determined by the EIS are:
1.	Costs
a.	This is the highest cost alternative. (The EIS case study found
this alternative to cost approximately $12.0 million).
b.	High capital and O&M costs will mean a large local financial burden
both on municipalities and users.
2.	Implementabi1ity
a.	The costs and management skills associated with operating a central-
ized system require a more complex and sophisticated administrative
structure than now exists in most of the barrier island local gov-
ernments.
b.	Centralized wastewater systems are susceptible to storm damage.
Such damage could disrupt the entire wastewater system and result in
more severe effects.
3.	Reliability
a.	Mechanical reliability is lower than under the EIS Strategy. Sys-
tems with many above ground structures are highly susceptible to
storm damage. This susceptibility can be reduced by siting
facilities on the mainland.
b.	The reliability of treatment processes is high except in storm
damage situations where the potential for adverse environmental
impacts is high if the system fails.
c.	The reliability of operation is high in centralized systems when
well-trained operators are employed.
4.	Primary Environmental Impacts
a. Construction impacts are common Ity-wide and include effects on sur-
face and groundwater, noise Impacts, tfaffit disruption and
short-term habitat destruction.
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b.	Groundwaters will not be subject to degradation from on-site
systems.
c.	The concentration of wastewater in one location can create adverse
impacts resulting from: (1) damage of the system by storms, (2)
impacts to surface and groundwaters from disposal and (3) unsat-
isfactory operation of the treatment plant.
5. Secondary Environmental Impacts
a.	Increased population densities could result 1n Increased pollution
to surface water from stormwater runoff, thus adversely affecting
shell fishing beds.
b.	Sewering marginal land near sensitive natural areas would promote
development, adversely impacting the plant and animal resources
within these ecosystems.
c.	There would be fewer wastewater management constraints on develop-
ment activities.
d.	High density beachfront development has.the potential for reducing
habitat for shoreblrds, Including the .brown pelican, and may
adversely Impact loggerhead turtle nesting activity.
PART E. SUMMARY
The EIS Strategy 1s the recommended approach for wastewater management on
the North CarotHrva barrier Islands. The EIS Strategy is the only strategy
which will provide for each of the EIS Issues to be addressed In the planning
process. This strategy should result 1n more cost-effective and environment-
ally sound wastewater management system for North Carolina barrier Island
communities.
The EIS concluded that the 201 Strategy would likely result 1n costly sys-
tems which would produce adverse secondary impacts to the natural environment
and adverse financial Impacts to local governments. The No Federal Action
Strategy would leave certain waiter quality problems unresolved and would
increase the probability of future problems because 1t would effectively
eliminate the continuation of facilities planning.
The EIS Strategy incorporates the following beneficial features:
-	The procedures promote documenting and then resolving existing water
quality problems.
-	The procedures promote sound planning for existing and future wastewater
management needs.
-	The procedures promote maximum local decision making and provide for
disclosure of financial and institutional impacts.
-	The jwocedures minimize costs to communities by promoting consideration
of less expensive alternatives.
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PART F. DRAFT EIS COMMENTS
Comments on the Draft Statement were received from the following:.
Federal Agencies
Advisory Council on Historic Preservation
Department of Health & Human Services, Public Health Service, Centers
for Disease Control
U.S. Army Corps of Engineers, Wilmington District
U.S. Department of Agriculture, Soil Conservation Service
U.S. Department of the Interior, Southeast Region
State Government
UNC Sea Grant College Program, Marine Advisory Services
N.C. State University, School of Agriculture and Life Sciences, Department
of Soil Science
N.C. Department of Cultural Resources, Division of Archives and History
N.C. Department of Administration, Office of Policy and Planning, State
Clearinghouse
N.C. Department of Natural Resource and Community Development, Office of
Coastal Management and the Division of Environmental Management
N.C. Department of Human Resources, Division of Health Services, Sanitation
Branch, Environmental Health Section
Local Government
Brunswick County
Town of Kill Devil Hills
Town of Ocean Isle Beach
Town of Nags Head
Interest Groups
North Carolina Saltwater Fishing Federation
The Raleigh Salt Water Sportfishing Club
National Wildlife Federation
National Audubon Society, Outer Banks Chapter
Sierra Club, North Carolina Chapter
North Carolina Coastal Federation
Southern Shores Civic Association
Other
Henry Von Oesen and Associates
Alternative Systems, North Carolina
Ms. Flora R. Garrett
Mr. John Melvin
Coast land Corporation
Mr. David Clement
Mr. Steve Sawin
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NORTH CAROLINA BARRIER ISLANDS
FINAL ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS

EXECUTIVE SUMMARY
A.	Part A. Introduction	j
B.	Part B. Background	1
C.	Part C. Recommended Strategy for Wastewater Management	iii
D.	Part D. Alternatives to the	Recommended Strategy v
E.	Part E. Summary	v11 i
F.	Part F. Draft EIS Comments
List of Tables	xii
List of Figures	x11
I. INTRODUCTION	1-1
II. RECOMMENDED STRATEGY	II-l
A. Description of the Recommended Strategy	II-l
1.	Procedures for Determining Need and Estimating	II-l
F1 ows
2.	Procedures far Developing Alternative Wastewater	11-4
Management Systems
(a)	Description of Technologies Appropriate for	II-4
Wastewater Management on Barrier Islands
(1)	Individual Systems
(2)	Community Systems
(3)	Central/Regional Systems
(4)	Combination of Systems
(5)	Sludge/Septage Handling and Disposal
Systems
(b)	Procedures for Selecting Technically Feasible I1-8
Components of Wastewater Management Systems
(c)	Procedures for Determining the Hydrodynamlc	11-10
Response to On-Slte Disposal of Wastewater
(d)	Procedures for Estimating Collection System
Costs	11-11
(e)	Procedures to Identify Special Costs Incurred
on Barrier Islands	11-11
(f)	Procedures for Developing Institutional
Management Alternatives	11-11
(g)	Procedures for Developing Financial Manage-	11-12
ment Alternatives
(1)	Bonding Capacity and Sources of Operat-
ing Income
(2)	Long Term Debt and Operating Costs
(3)	Identification of Additional Sources
of Funds
(4)	Assessment of Existing Fiscal Capability
(h)	Procedures for Developing Total Wastewater	Ii-15
Management Systems Alternatives
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TABLE OF CONTENTS (Continued)
Page
3. Procedures for Evaluating Alternative Wastewater	11-15
Management Systems
(a)	Cost and Local Financial Impact	11-16
(1)	Risk Analysis Assessment
(2)	Financial Impacts of Storm Damages
(b)	Primary and Secondary Environmental Impacts	11-17
(c)	Implementability	11-18
B. Impacts of the Recommended Strategy	11-18
1. Impacts on Development Potential	11-18
(a)	Land Capability Analysis: Existing Develop-	11-19
ment
(b)	Land Capability Analysis: Appropriate Systems	11-19
for the Future
(1)	Land Capability Classification System
(2)	Land Capability of Each Study Area
(3)	Development Potential of Each Category
(c) Land Capability Analysis: Population and	11-22
Flows
2.	Environmental Impacts	11-24
(a)	Surface Water	11-26
(b)	Groundwater	11-27
(c)	Sensitive Natural Areas	11-28
(d)	Land Use/Population	11-28
(e)	Other Resources	11-29
3.	Financial Impacts	11-29
4.	Implementability	11-30
C.	Mitigative Measures	11-36
1.	Surface Water	11-36
2.	Groundwater	11-36
3.	Sensitive Natural Areas	11-37
D.	Implementation of the Recommended Strategy	11-37
1.	Recent Changes to the Construction Grants Program	11-37
2.	Development of the North Carolina Construction	11-38
Grants Funding List
3.	Barrier Island Communities' Potential for	11-39
Receiving 201 Funds
4.	Schedule of Grant Applicant Activities	11-39
II. COMMENTS ON THE DRAFT EIS AND EPA RESPONSES	IH_1
A.	Written Comments	Ill-i
B.	EPA Responses to Letters of Comment	111-45
C.	Public Hearing Transcripts"	III-55
D.	EPA Responses to Public Hearing Comments	111-123
IV. COORDINATION LIST	IV-1
V. LIST OF PREPARERS	V-l
REFERENCES	R-l
APPENDIX
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LIST OF TABLES
Table
Description
Page
II-l
Summary of Wastewater Treatment/Disposal System
11-6

Alternatives

11-2
Acres by Sensitive Area/Soil Absorption System
11-21

Suitability Category

11-3
Development Potential with Soil Absorption Systems
11-23
11-4
Average Household Income and Maximum User Charge per
11-31

Household by 201 Study Area County


LIST OF FIGURES

Figure
Description
Page
1-1
Barrier Islands within 201 Facility Plan Study Areas
1-2
II-l
Overview of the EIS Strategy
11-2
11-2
Population Projections and Developable Land Comparison
11-25
11-3
Comparison of EPA User Charge Ceil Ins with Typical
11-32

Household Cost per Month for Each Technology Group

xii

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I. INTRODUCTION
Six 201 Facilities Plans which include barrier islands have been sub-
mitted to EPA for approval. These plans are Southwestern Brunswick County,
Southeastern Brunswick County, Topsail/Surf City in Onslow County, Carteret
County Complex, Hatteras Island in Dare County and Dare Beaches Complex in
Dare County. Figure 1.1 shows the location of these planning areas.
Five of the draft 201 Facilities Plans received by EPA propose the con-
struction of wastewater collection, transportation and treatment facilities
to serve large portions of the barrier islands. The sixth plan, Hatteras
Island, recommended that two regional systems be reconsidered at a later date
when a larger population base made the systems cost-effective. After an
environmental review of the proposed facilities plans, EPA had significant
concerns about the potential impacts of these six plans on the North Carolina
coastal zone.
EPA funding for these proposed facilities has been determined to be a
Major Federal Action significantly affecting the quality of the human environ-
ment. An areawide EIS was the most expeditious way of addressing the issues
identified below and providing guidance for completing the draft 201 Plans.
This Final Environmental Impact Statement (FEIS) for North Carolina
Barrier Island Wastewater Management supplements the Draft EIS issued in June
1983. The EIS has been prepared in accordance with the Council on Environ-
mental Quality (CEQ) Guidelines and EPA Guidelines for the preparation of
Environmental Impact Statements. This EIS is also prepared in response to
the requirements of Public Law 91-190, the National Environmental Policy Act
of 1969, which requires the preparation of an EIS for any major federal
action that will significantly affect the quality of the environment. While
this summary document is intended to be comprehensive, the supporting informa-
tion furnished with the Draft EIS should be reviewed and is incorporated here
by reference. This Final EIS supercedes the Draft EIS wherever conflicts
between the two exist.
This Final EIS contains five major sections. Chapter II, Recommended
Strategy, describes the recommended strategy and mitigative measures. Steps
that grant applicants must take to implement the strategy are also included.
This discussion focuses on the policies governing the establishment of the
state 201 priority list, the potential for harrier island communities to
receive 201 funds, and the changes to the Construction Grants program that
went into effect in 1982 based on the 1981 Amendments to the Clean Water Act.
EPA's responses to comments received on the Draft EIS are tabulated in
Chapter III. The written comments and the oral comments received at the
public hearings are indexed in this section. Chapter III also contains the
transcript of the Draft EIS public hearings held on August 23-25, 1983. A
coordination list is presented in Chapter IV, and a list of preparers is
presented in Chapter V. References and the Appendix are included at the end
of this document.
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CHAPTER II. RECOMMENDED STRATEGY
The EIS Strategy is composed of procedures developed by this EIS which
are intended to refine procedures normally undertaken in the preparation of a
201 Plan. These additional procedures are proposed in response to the needs
of North Carolina barrier islands which are characterized by extensive
environmentally sensitive areas, highly fluctuating populations and limited
financial resources.
The procedures are consistent with 201 Construction Grants regulations
and other facilities plan preparation guidance; however, they are tailored
and refined to address the unique environmental and socioeconomic conditions
on the North Carolina barrier islands. The procedures were designed to
address the six issue areas identified in Chapter I of the Draft EIS (DEIS):
1.	Surface water quality impacts/closing of shellfish beds
2.	Groundwater quality impacts
3.	Alternative wastewater management technologies
4.	Economic and fiscal impacts on local citizens and governments
5.	Sensitive natural areas and potential for storm damage
6.	Nonpoint source pollution.
Special attention was given to areas which were most lacking in the draft
201 Plans: a thorough evaluation of all wastewater technologies, especially
on-site and small community systems, and the financial and institutional
impacts of operating and maintaining wastewater management systems.
A. Description of the Recommended Strategy
The supplemental procedures fall into three major groupings, and each is
discussed in turn:
-	Procedures for determining need and estimating flows
-	Procedures for developing alternative wastewater management systems
-	Procedures for evaluating alternative wastewater management systems.
An effort has been made to communicate these procedures in narrative and
graphic form. Figure II.1 presents an overview of the EIS Strategy. Each
rectangle in the flow chart represents a separate procedure. The following
sections of this chapter describe these procedures and refer to detailed flow
charts for each procedure, which are found in the DEIS and Alternatives
Development Technical Reference Document.
1. Procedures for Determining Need and Estimating Flows
The first subroutine in Figure II.1 graphically depicts the procedures
appropriate to determine the need for wastewater management systems and to
quantify flows. Determining the need and estimating flows which require
additional wastewater management consists of identifying those portions of
existing and projected populations that cannot be adequately served by
current wastewater management strategies. Essentially, population that
cannot be adequately served by current wastewater management strategies is
that population whose wastewater management strategies either cause water
quality problems or will cause water quality problems when the population
served increases.
II-l

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Determine Need and
Estimate Flows
Develop Alternative
Wastewater Hgt. Systews
Quantify
Total Waste
Flows	
Define Water
Quality Hgt.
Problems _
Determine
Existing
Population
Determine
Future
Population
Identify
Future Develop.
Patterns &
Land Use	
Conduct
Field Studies
& Sampling
Programs (opt!.)
Identify Extra
Costs Unique
to Barrier
Islands	
Develop
Central/Regional
System Alt. If
No Decentralized
Approach Feasible
Develop Several
Scenarios Using
Small Community
Systems if On-
< Site Systems
Not "Feasible:
Institutional and
Financial Analysis
Develop Total Wastewater
Hat. System Alternatives
9 9
Identify
Capabilities of
Hgt. Agencies
Evaluate
Cost Sharing
With Other
Jurisdictions
Consider
Public Mgt. of
On-Site
Systems
Assess Commity's
Ability tO-Support
a Wastewater Hgt.
System
Identify
Types of
Feasible
Hgt. Agencies
Decide if
Single or Multi-
Jurisdictional
Service Area
©
Evaluate
Financial
Impacts
Evaluate
Susceptibility
to Storm
Damages 	
Develop a
Series of Logical
Service Area
Configurations
For Each Service
Area Select a
Technical,
Institutional ft
Financial Alt.
Figure II. 1 Overview of EIS Strategy

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The first step is to quantify existing population served by existing
wastewater management strategies. This task tends to be difficult on the
barrier islands because the resident population component is a small fraction
of the summer peak which includes seasonal residents, overnight visitors and
day visitors. Thereafter, projections must be made of these population
components for five-year intervals during the planning period. Figure II.2
in the DEIS explains this methodology and shows how the four population
components are calculated.
Having determined the existing population, the future population to be
served must then be determined. This is accomplished by disaggregating the
1980 Census data for the study area and then calculating ratios of seasonal,
overnight and day visitors to permanent residents. These ratios are then
used with projections of the permanent residents to determine future
population by component. Figure II.3 in the DEIS diagrams these steps.
Next, areas of existing development which are experiencing problems and
are in need of new or improved wastewater management systems are identified.
This is accomplished by defining water quality problems and by conducting an
inventory of actual conditions in the study area. Figure II.4 in the DEIS
illustrates these tasks and shows how decisions are reached as to whether
wastewater management systems are needed.
Future development patterns are determined by conducting an inventory of
areas that can be used for future development in the study area. These areas
will be lands on which the Coastal Area Management Act (CAMA) has not re-
stricted development, but the exact nature of the development of these lands
will be affected by zoning and other restrictions. Approved population pro-
jections should be given careful consideration in defining future development
patterns. Figure II.5 in the DEIS shows these steps.
Knowing or having calculated existing and future populations, existing
development in need of wastewater management and future development patterns,
total flows requiring wastewater management can be determined. This is
accomplished by determining existing flows from either existing water use and
existing wastewater treatment records or by multiplying population components
by prescribed daily wastewater flow estimates. Similar ratios are then used
for projecting flows for future developments. The total flow is the sum of
the current and future flows.
The development of flow projections on the North Carolina barrier islands
is complicated by the fact that two types of peak flows must be considered.
First, island communities experience extreme seasonal peak flows between
winter and summer users. Then, within €he summer peak season, ddditional
peak flows result from tourism peaks such as Fourth of July weekend and other
events. Consideration should be given to peak and average flows per month as
well as expected daily, weekly or yearly fluctuations. In conclusion, the
four population components (permanent residents, seasonal residents, over-
night visitors and day visitors) are known to generate widely fluctuating
flows by time period. These fluctuations have significant implications when
user fees are being set. Figure II.6 in the DEIS illustrates a methodology
for quantifying total flows. A final step is identifying and applying flow
and waste reduction measures, as shown in Figure II.7 of the DEIS.
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2. Procedures for Developing Alternative Wastewater Management Systems
The EIS procedures systematically identify and screen all feasible waste-
water management system alternatives. The resulting strategy coordinates
information on existing systems' performance, existing and/or potential
pollution problems, physical conditions and constraints of the area, and
local governments' institutional and financial capabilities. The procedures
that make up the integrated development strategy were designed to delete
unfeasible alternatives from detailed Investigation without excluding viable
alternatives from further evaluation.
Subroutine A of Figure II.1 includes an overview of the procedures used
to develop alternative wastewater management systems. Initial steps focus on
the identification of potentially feasible subsystems. These subsystems
address the various technical components of a wastewater management system
and include facilities for the following:
-	Collection of wastewater
-	Treatment of wastewater
-	Disposal of treated wastewater effluent
-	Handling/disposal of sludge and/or septage generated by the systems.
To facilitate the process, information on existing systems along with
documentation of identified pollution problems 1s Incorporated to determine
the extent of pollution due to the Inadequacy of existing systems. The iden-
tification of reasonable alternatives to existing systems 1s then performed
based on actual conditions in the area.
After this process, combining of subsystems Into overall systems can be
initiated. This step involves the development of the technical components
previously Identified into viable system alternatives based on the charac-
teristics of the various technical components. To ensure that a complete
list of feasible alternatives is identified for projected development
densities and patterns, consideration 1s given to the various degrees of
system centralization. The overall system alternatives are therefore cate-
gorized into four types of systems: individual on-site systems, community
systems, central/regional systems and mixes of these previous three options.
The use of four categories of treatment/disposal systems 1s Intended to
facilitate the screening process which is the next step 1n the development of
alternatives. This step results 1n the development of the principal tech-
nical alternatives. Screening of the feasible alternatives Identified is to
be based on system characteristics and requirements, specified site condi-
tions and design factors, after which the system alternatives not eliminated
will be analyzed according to their implementation requirements. From this
point, the total system alternatives are to be subjected to cost-effective-
ness analysis and evaluation.
(a) Description of Technologies Appropriate for Wastewater Management on
Barrier Islands
In the identification of reasonable alternatives for wastewater manage-
ment systems, the general physical conditions of barrier islands were con-
sidered in order to include only those system alternatives that would be
11-4

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compatible with the study area. These general conditions include the
following:
-	Geology dominated by unconsolidated sediments
-	Topography generally consisting of beaches, dunes, and flats
-	Soils principally granular in structure, ranging from deep and
excessively well-drained to shallow, poorly drained and subject to
flooding
-	Moderate climate with fairly uniform temperature, precipitation, wind
speed and relative humidity with intermittent occurrences of tropical
storms, hurricanes and northeasters
-	Groundwater regime consisting of a lighter freshwater lens floating
atop the heavier salt water; water table depths highly variable but
generally tending to be very shallow due to seasonal high groundwater
levels
-	Primary surface waters are salt and brackish waters that are a mixture
of saltwater from the ocean and fresh water from inland runoffs forming
a complex hydrological system.
In order to allow for anticipated development densities and patterns, the
potentially feasible alternatives were categorized into three types of
systems. Table II. 1 is a summary of the alternatives' technical components
that were identified and include all the technical components that make up a
wastewater management system. The following subsections provide a general
description of each system type.
(1) Individual Systems
These systems are used by the individual homeowner or small commercial
establishment. Historically, they have worked well in barrier island commun-
ities. Where such systems are properly installed, operated and maintained,
they should continue to offer satisfactory service. As Table II•1 indicates,
many treatment and disposal options are available to respond to local
conditions.
Some draft 201 Plans have cited existing on-site systems on barrier is-
lands as sources of pollution of nearby surface and groundwaters and of
health hazards after rainfalls. A few field monitoring and sampling programs
have found this to be true in two isolated specific sites where they were
installed in fill material on finger-fill canals. Otherwise, on-site systems
are functioning well.
Conversion of existing conventional, on-site disposal fields (soil absorp-
tion beds and trenches) to alternative on-site systems can resolve many of
the problems stemming from excessively permeable sands and shallow soils with
a high water table. In order to attain optimum operation of existing sys-
tems, a concerted effort must also be made to repair or upgrade septic tanks
and possibly modify the soil absorption fields if insufficient renovation is
occurring within the soil medium. Also, in areas where well contamination
could be a threat to public health, renovation of on-site systems could
decrease risks of water quality degradation.
11-5

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table II.1 Sunary of Wastewater Treatment/Disposal System Alternatives
S»it
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(2) Community Systems
A community system serves a small .cluster of usually ten to several
hundred residences. It involves centralized collection in conjunction with
treatment/disposal alternatives that do not differ significantly from indi-
vidual systems, although a few more options become feasible. Small community
systems can provide a wastewater management solution in an area of failing
individual systems and preclude the need for connection to a central/regional
system, if one is available. Small community systems may also be used for
new development at densities greater than those supported by individual
on-site systems or in areas not suited for individual on-site systems due to
poor soils or seasonally high water tables. For these small systems, the
cost of collection, especially by force mains and conventional gravity
sewers, is often significant. Therefore, the alternatives identified for the
collection system are a major cost factor of the whole system. With the
larger flows from a collection system, flow equilization prior to treatment
units, particularly package plants, should be utilized.
(3)	Central/Regional Systems
These systems have comprised the traditional approach in 201 Plans to
wastewater management and involve extensive collection systems leading to a
centralized treatment facility. The main consideration is that a sufficient,
relatively contiguous development be available to make this approach financ-
ially viable. To minimize collection costs for a large-scale system, the
innovative collection alternatives used for community systems can be incor-
porated in the collection/transport system whenever possible for these
regional systems.
(4)	Combination of Systems
In many instances a community can be served most cost-effectively by a
mixture of individual on-site, small community and central/regional facil-
ities. Such an alternative should be developed and carried through the
evaluation process.
(5)	Sludge/Septaoe Handling and Disposal Systems
This has been considered an important factor in wastewater management sys-
tem development for barrier islands and is a component of all alternative
systems. Many of these disposal techniques are suitable for both septage and
sludge disposal and have limited application based mainly on constraints due
to state regulations, land area availability, awi volume of sludge and/or sep-
tage generated by the treatment components in the various system alterna-
tives. All sludge/septage disposal alternatives are generally centrally
managed and operated, regardless of the type of wastewater treatment/disposal
system utilized.
The DEIS contains a series of technical appendixes. A detailed descrip-
tion of each alternative is provided in Appendix A, Details of Wastewater
Management Options. Included in Appendix a, Wastewater Management System
Selection Criteria, are lists of advantages, disadvantages, modifications and
constraints for each alternative. Additionally, engineering design data for
each of these systems is presented in Appendix C, Wastewater Treatment
Alternatives Engineering Design Criteria.
H-7
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(t>) Procedures for Selecting Technically Feasible Components of Wastewater
Management Systems
One of the more complex problems in assessing the wastewater management
system requirements of an area or group of areas is that of determining what
portion of that area's needs can be managed with on-site systems using soil
absorption systems and what portion of the area's needs, if any, must be
managed by use of some form of transport, treatment and disposal system.
This analysis is detailed in Figure II.9 in the DEIS.
Population should be distributed to the study area based on the use of
on-site systems as consistent as possible with projected future land uses.
The next step is to compare population figures and land uses resulting from
this alternative with approved population projections and land uses. Areas
of conflict should be identified and delineated on a map:
No Conflict:
Areas where population and development densities can be supported by
on-site systems.
Conflict:
Areas where existing wastewater systems have documented problems.
Areas where development densities cannot be supported by on-site systems.
Areas not suitable for on-site systems due to soil limitations.
For areas where conflicts exist, consideration should be given to the
following measures:
-	Revise land uses and population figures
-	Select community systems for higher density areas
-	Select community systems for areas with unsuitable soils
-	select a central/regional system.
The first alternative for areas not suitable for on-site systems 1s to
consider whether the projected population numbers are realistic and desir-
able. If not, population distributions can be revised, and the new projec-
tions can be checked to see if they now may be accommodated by on-site
systems. If the new projections allow the population to be served, an
assessment is made if the projection and resulting distribution are reason-
able considering existing platting, zoning and known development interests.
(Include environmental, socioeconomic and financial impacts 1n this determi-
nation of reasonableness.) If this adjustment 1s satisfactory, the need to
publicly provide for off-site treatment may have been removed, and no further
alternatives development may be necessary.
If the population and land use adjustments and on-site systems are not
fully acceptable, several small community system alternatives should be
developed. A minimum of two alternatives should be developed. One alter-
native, utilizing on-site systems to the maximum and small community systems
to solve existing water quality problems, should be developed. A second
alternative stiould also be developed utilizing on-site systems and small
community systems for solving both existing water quality problems and
accommodating future high density development or development projected on
unsuitable soils. These alternatives should be carried into more detailed
11-8
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development and evaluation tasks along with the previously developed on-site
alternative.
If the small community systems alternatives are not fully acceptable,
consideration should be given to adjusting projected populations and/or modi-
fying the grouping of the small systems. If these developed alternatives do
not meet all needs, consideration should then be given to central/regional
systems.
The major factors in developing central/regional systems are alternative
phasing of facilities and alternative groupings of major service areas.
Intergovernmental agreements to accomplish economies of scale should be
considered.
Consideration should be given to the impacts of the various discharge
modes. Discharge to surface water bodies is frequently precluded on barrier
islands, both because of the lack of suitable receiving streams and because
of the potential negative environmental impacts of such discharges. State
law allows no discharges to SA waters. Discharges may be permitted to SC
waters where adequate assimilative capacity exists. Surface discharges to
estuaries are similarly regarded by state regulations, due to potential
impacts on shellfish and other resources. Ocean outfalls are typically not
cost-effective for disposing small volumes of effluent and may have
undesirable impacts on beach-side communities.
The typical discharge modes on barrier islands involve surface or sub-
surface disposal of effluent on the soil. Several factors regarding waste-
water disposal into groundwater deserve consideration. These factors
include:
-	Potential for human recreational body contact with bacteria and viruses
from wastewater
-	Bacterial and nitrate contamination of drinking water supplies
-	Overenrichment of the near surface waters with nutrients.
Typically, such negative impacts can be avoided by incorporating proper
elements in system design. Design criteria which can eliminate or signifi-
cantly minimize the above mentioned effects include:
-	Spatial separation of disposal areas from surface waters
-	Disinfection systems to alleviate potential for bacterial contasri nation
-	Spatial separation of wastewater discharges from potable water supply
wgI 1 s
-	Consideration of depth to water table and use of mounds or other
appropriate on-site technologies
-	Consideration of the potential uses for tne groundwater tu the area of
discharge. If no future use for potable water supply is planned, dif-
ferent loading considerations may be applicable.
At this point several on-site, smallJunMtattjr an^or r^iotnal treal^wt
systems and land areas suitable for ultimate disposal ace fe be developed for
further, more detailed evaluation,. Several reasonable ^wibinations- of system
elements may be structured which meet the volume and load requirements within
the constraints of hydrology, soils, depth to water table, topography and
11-9
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public health considerations. These systems should be examined for consis-
tency with statutory and socioeconomic requirements (i.e., are the system
components legal in North Carolina, what impact doe? the system have on neigh-
boring land uses, etc.). The feasible systems identified then receive fur-
ther consideration in subsequent tasks. Technically and identified insti-
tutionally acceptable alternatives should be evaluated for cost-effectiveness
at the volumes and loads to be handled.
Determination of the small community systems appropriate for a given
community is best done with input from local sanitarians, hydrologists or
similarly trained persons with local on-site experience. Each barrier island
area is to some extent unique in wastewater treatment needs, soil quality and
quantity available for use in treatment and disposal, financial capability to
fund part or all of the needed facility, and social and political structure.
While the needs may differ, many examples now ex^st nationally of small
communities adapting various technologies to conform to their specific needs.
At the conclusion of the technical development of alternatives, several
of the options should be evaluated further (in subsequent tasks). An alter-
native employing on-site systems with small community systems used to solve
existing water quality problems should always be developed and carried
through subsequent tasks. If this system is fully acceptable, no further
alternative development may be necessary. If not acceptable, an alternative
comprised of on-site systems and small community systems to handle existing
water quality problems and future high density areas is developed and always
carried through the remaining development and evaluation tasks. If these
alternatives are not fully acceptable, various central/regional alternatives
should also be developed and carried through the detailed development and
evaluation tasks.
(c) Procedures for Determining the Hydrodynamic Response to On-Site Disposal
of Wastewater
When determining the applicability of on-1sland disposal systems to a
given area, it is important to consider the response of the water table
aquifer to disposal of wastewater. Wastewater disposal on barrier islands
should be considered a net addition to total groundwater recharge 1f water 1s
initially obtained from mainland sources. This net addition could result 1n
physical contact between the water table and the bottom of drain field
trenches or even surfacing of effluent.
The analytical solution presented in the DEIS (pp. 11-18 ff.) describes
the hydrodynamic response of the water table to land disposal of wastewater
in an idealiied representation of actual aquifer configurations. In actual-
ity, squtfers are not homogeneous nor is the permeability of the unit the
same in all directions. Existing aquifers §n barrier Islands are created by
complex geologic processes that in.ceftaiJj cases may have led to Irregular
stratifFaphy of confined and unconfined aquifers. The prediction that can be
carMetf out with the expression presented in the DEIS is a best estimate;
this estimate approaches more closely the actual hydrogeological environment
as the actual conditions approach the idealized configuration.
EPA Region IV is currently conducting a groundwater study on North Caro-
lina barrier islands. The purpose of this study is to demonstrate the use of
this model through the collection of groundwater data, both hydrological and
11-10
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water quality related. The study plan, included in the Appendix, provides
details of the study.
(d)	Procedures for Estimating Collection System Costs
Cost estimates for collection systems should be done in stages. Alter-
native or innovative collection systems should be considered when they can be
shown to be cost-effective. The size and cost of each component must be
developed. Unit cost information should be developed from manufacturer's
data where possible. Construction costs can be developed from EPA informa-
tion or local contractors.
(e)	Procedures to Identify Special Costs Incurred on Barrier Islands
Since the soil characteristics in many areas are not suitable for the
foundations of treatment facility structures, the additional cost of pilings
or other special foundations has to be considered. Additionally, structures
have to be built to withstand the effects of weathering including high winds,
sea spray corrosion and sand abrasion. These parameters affect both the
initial construction costs and the long term operation and maintenance costs
of the system.
The investigator should determine if increased initial costs for heavy
duty coatings, more ruggedly constructed treatment equipment or the use of
stainless steel in place of other less corrosive and erosive metals can be
justified over the life of the facility due to decreased operation and mainte-
nance costs of more weather resistant facilities.
Sand and salt spray have a detrimental effect on the serviceability of
structures and equipment. Facilities constructed on the barrier islands must
be recoated or painted more often, bearings have to be repacked more often
and wear of all moving parts is increased due to the sand and corrosion
problems. Quantifying the additional costs associated with these problems
necessitates studying manufacturers' coatings data to determine the expected
lives of their coatings, determining the effects that the weather and sand
will have on the designed bearing life of critical equipment and evaluating
the effects that the corrosive atmosphere will have on electrical equipment.
(f)	Procedures for Developing Institutional Management Alternatives
The implementability of a technical wastewater management alternative
requires consideration of the legal tad Institutional requirements of each
alternative system previously developed. State enabling legislation provides
a far wider range of powers and authority to cities than are granted to
unincorporated communities. The ability of a management agency to own real
property, enter into contracts, set rates ^receive grants, employ personnel,
etc. are critical aspects of implementabllity.
Institutional considerations were not fully analyzed in most of the draft
201 Plans. Therefore, the EIS developed a series of worksheets and other ana-
lytic tools to aid grant applicants in deftnin§ their institutional and finan-
cial constraints and developing optimum management alternatives. These tools
were presented in a series of workshops during December 1981 and January
1982.
11-11
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Institutional considerations focus on what management agencies may
receive 201 funds and administer wastewater management facilities. Where
wastewater management is already a community service, an analysis of the
effectiveness of the present management structure 1s the point of departure
1n determining whether existing Institutional arrangements can be expected to
adequately manage a new or upgraded system or whether a new mechanism needs
to be devised.
Where wastewater management represents a new service, options must be
explored as to whether the community should:
-	Serve only Itself
-	Incorporate adjacent neighborhoods Into Its service area through Its
powers of extra-territorial jurisdiction
-	Be served by a larger jurisdiction such as the county
-	Make overtures to join another jurisdiction 1n a cooperative venture.
North Carolina law provides possibilities for a large number of Institu-
tional management options:
-	A city utility or public works department
-	A county utility or public works department
-	A joint management agency
-	A county service district
-	A sanitary district
-	A water and sewer authority
-	A metropolitan water district
-	A metropolitan sewerage district
-	A private water and sewerage company.
Two or more communities may sign an Interlocal agreement whereby one of
the parties provides services to all the communities. In a given 201 plan-
ning area, it 1s possible for more than one of the above agencies to be
providing services.
Figure 11.13 1n the DEIS presents a simplified methodology for selecting
one or more feasible Institutional manafement alternatives. The user should
step through the methodology once for each technical alternative developed.
This discussion 1s supplemented by an EIS task report, Implementing Waste-
water Facilities Plans In the Barrier Island Region of North Carolina: Insti-
tutional and Financial Issues and Needs (Briscoe, Maphls, Murray & Lamont,
Inc. 1981).
(g) Procedures for Developing Financial Management Alternatives
The steps a community should follow in reaching a decision about the
affordabtllty of each of the technical solutions previously documented have
been developed Into a series, of procedures shown in Figure II-l as subroutine
C. The issue of affordaMHty focuses on the ability of the community both
to raise eapttal and to meet operating costs.
The development of financial management alternatives is a particularly
important task since barrier island communities are characterized by highly
fluctuating seasonal flows. The issue of user fees requires detailed
11-12
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examination. Several options are available to accommodate the incremental
costs of providing capacity for seasonal users:
-	Peak month(s) surcharge for all seasonal users
-	Seasonal differential based on type consumer
-	Seasonal differential based on type technology used.
The analysis begins by assessing the present financial status of the
community. Whether or not a community decides to serve itself, it should
explore the alternative of cost-sharing schemes.
Before a community can consider assuming additional long term debt or
operating costs of a wastewater management system, it must first assess its
present financial condition. An understanding of the existing resource base
current practices and commitments, and fiscal capacity of the local govern-'
ment is essential.
(1) Bonding Capacity and Sources of Operating Income
The first step is to delineate the bonding capacity of the local govern-
ment. Bonds may only be used to defray capital expenditures, not operating
costs. By state law, local governments' total bonding capacity is set at
eight percent of the total assessed property tax valuation. Both general
obligation bonds and lease-purchase agreements are subject to the eight
percent ceiling although revenue bonds are not. The only exception to this
provision is that when the North Carolina Environmental Management Commission
or a court requires the implementation of wastewater treatment systems,
general obligation bond debt is not subject to the eight percent net debt
1imit.
The next step is to compile data about existing sources of revenue which
may legally be used to operate wastewater management systems. A trend analy-
sis of revenue sources should be prepared by individual source to identify
which sources can be expected to increase or decrease, particularly in
response to inflation.
Proposed tap-on fees and user charges should fee reviewed to evaluate
their economic and political acceptability. EPA regulations (July 1982)
require that the following total annual costs to iisers should not exceed cer-
tain percentages of median family income 1n the	area and at the minimum
must recover the costs of operation and maintenance and replacement:
1.00 percent when median family income is under $10,000
1.50 percent when median family tncortt fs $10,000-$17,000
1.75 percent when median family1nc«oe exceeds 417*000.
If these guidelines are exceeded, special evaluations and procedures are
necessary.
The affordability criteria should be applied only to the permanent resi-
dential population components and should not include the seasonal cdwt»nents.
If necessary, more realistic fees and charges should be cfevelupe#, There-
after, the income from proposed user fees should be computed and added to
other sources of revenue.
11-13
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(2) Long Tern Debt and Operating Costs
Projected operating costs should also be reviewed and compared against
anticipated system revenues. If a deficit results, other sources of revenues
which could serve to make up any differences between proposed user charges
for the new system and actual costs should be evaluated.
Figures should also be compiled Identifying the community's outstanding
long term debt. Thereafter, an analysis of unused debt capacity should be
made. If the community's bonding capacity is not large enough to accommodate
a wastewater management general obligation bond issue, then the community's
options include:
-	Reducing the size of the bond Issue by increasing tap-on fees
-	Reassessing the property tax base to determine 1f the debt celling can be
raised
-	Considering the use of revenue bonds
-	Exceeding the celling 1f Implementation of the project 1s required by the
North Carolina Environmental Management Commission or courts
-	Considering other user charge systems.
(3)	Identification of Additional Sources of Funds
If a shortfall is identified in either operating funds or the ability to
finance capital costs, then new sources of funds need to be found. A short-
fall in operating income generally results when the proposed user charges
must be reduced and when subsidies from other revenue sources are not enough
to make up the difference.
(4)	Assessment of Existing Fiscal Capability
Public hearings should be held to present the findings of the financial
analysis to system users and gather their comnj§nts. At a minimum, all pro-
perty owners, both permanent and seasonal residents, should be notified by
mail of the public meeting and anticipated flnahctfl Impacts.
Thereafter, local officials can decide whether.pr not the community can
afford the capital and operating costs of provldjjig wastewater management
systems. If the decision 1s negative, then community leaders should Imme-
diately Investigate the costs of entering into a Service agreement with an
existing agency or new agency. Even 1f the community can afford to serve
itself, the analysis of other financial management alternatives should
proceed to the investigation of all reasonable alternatives.
Additional financial issues which need to be examined Include:
-	Plans if outside funding sources are not available
-	Sensitivity analysis which measures the degree of uncertainty attached to
assumptions about the financial Implications of population projections,
flow volumes' over time, inflation, energy costs, costs of goods and
services, etc.
11-14
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- Refinements to the local taxation system so that system beneficiaries
more directly bear the costs. Examples include the issues 1) should
tourists be paying a larger share than they do presently and 2) the
assurance that new growth pays its fair share.
Although this discussion might seem to focus on the development of finan-
cial management alternatives for central or regional treatment plants, the
development of financial management alternatives for small community systems
should not be overlooked. Since both the costs and the benefits are likely
localized, either direct assessments or assessment bonds provide the most
reasonable financing mechanism in situations where wastewater management
systems in areas of existing development need upgrading or replacing. In
areas of future development where small community systems or individual
on-site systems are appropriate, construction costs are routinely borne by
the developer or individual homeowner.
Additional discussions about financial considerations can be found in a
task report, Implementing Wastewater Facilities Plans in the Barrier Islands
Region of North Carolina: Institutional and Financial Issues and Needs
(Briscoe, Maphis, Murray & Lamont, Inc. 1981).
(h) Prnrprfures for Developing Total Wastewater Management Systems Alter-
natives
Fiqure II.l depicts in subroutine D the evolutionary process that develop-
ing reasonable wastewater management systems appropriate for a given area
reauires This task is begun by assessing all appropriate technologies appli-
rahlp tn'anv aiven service area and then to all groups of areas that reason-
ably can be considered together. Initially the development of logical ser-
vice areas is a process of grouping subareas that a common technology such as
on-site soil absorption systems will handle. The objective of this process
is to develop the reasonable technically feasible wastewater management
systems that can handle the requirements of each service area.
Having generated a list of feasible technologies appropriate for the
area onprational and financial management schemes then should be developed
for eaTof the feasible technologies. The operational management scheme for
each technology will have to consider the political jurisdictions involved,
the ownership of the properties and treatment facilities, legal or statutory
restraints and how the particular technology will be financed.
3. Procedures for Evaluating Alternative Wastewater Management Systems
Several alternatives will have been developed, each with a technical,
institutional and financial component. The next step, therefore,.is to eval-
uate each alternative with regard to those criteria upon which system
selection depends;
-	Cost and local financial impacts
_ primary and secondary environmental impacts
-	Implementability.
The evaluation of each criteria within each alternative is conducted in
two phases. The first phase involves the documentation of impacts. The
11-15
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second phase addresses the significance of the impact. Numerous techniques
exist for evaluating significance. Some are very complex and subject to
considerable manipulation. Other methods are very simple and consist of dis-
playing Impacts in tabular form.
(a) Cost and Local Financial Impacts
Barrier island communities tend to have relatively modest tax bases, and
permanent residents are sensitive to the costs of wastewater management sys-
tems. Procedures for evaluating costs are documented extensively 1n various
EPA publications.
A detailed evaluation of all cost components in each of the alternative
wastewater management systems is required in order to perform the comparative
cost analyses. Land, construction, project (engineering, financing, and con-
tingencies), salvage value, and operation and maintenance costs are developed
for each management system for incorporation Into a net present worth cost
analysis. The present worth cost analysis establishes a basis for comparison
of total costs (capital and annual operations costs) for each of the waste-
water management alternatives. These total costs include the federal share
of the costs associated with construction grants. Comparative cost analysis
(either present worth or equivalent annual cost) is an EPA requirement and
serves as the primary cost evaluation criterion according to EPA guidelines.
The value of using present worth analysis is that the total costs of each
alternative are related to each other during the 20-year planning period.
Present worth analysis brings each total cost back to an equivalent invest-
ment cost at the beginning of the planning period, given a fixed interest
rate on the investment. Thus, alternatives with high construction costs and
low O&M costs can be equitably compared against alternatives with low
construction costs and high O&M costs.
A present worth analysis requires that both public and private costs
directly related to a project be included. Cost for laterals and ineligible
rehabilitation of private on-site facilities are examples of private costs
that should be estimated and Included In present worth calculations. Al-
though present worth analysis does not recognize the difference between
public and private costs, it is necessary for local cost estimation.
The EIS has developed additional procedures, however, which respond to
the financial profile of barrier island communities. The EIS found that sig-
nificantly different financial Impacts can be experienced at the local level,
given several wastewater management alternatives. Much depends upon the
degree to which costs are internalized or externalized. The selection of
systems eligible for state or federal grants externalize many costs. Requir-
ing tourists to pay their share of systems costs externalizes a large portion
of what would otherwise be a local burden. Dependence on the ability to
externalize costs can be dangerous for a community; provision must be made
for the eventuality that state or federal funds may not be forthcoming.
(1) Risk Analysis
Evaluation of financial impact is a matter of both the size of the finan-
cial commitment involved relative to the community resource base as well as
11-16
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the financial risk involved in the undertaking. Risk assessment is often
overlooked, particularly a systematic identification of downside risk. Risk
analysis should seek to pinpoint areas of uncertainty, and various types of
sensitivity analysis are important tasks in the overall evaluation of finan-
cial impacts to local communities. Therefore, an initial task in screening
all wastewater management alternatives should be the identification of what
percent of life cycle total costs are capital costs (relatively firm, up
front dollars) and what percent are operating costs (annual projections over
20 years). The financial impacts of both the capital costs and operating
costs of each alternative must be assessed. Table II.3 in the DEIS is a
questionnaire which should be filled out for each alternative.
(2) Financial Impacts of Storm Damage
Repair and replacement of wastewater management systems due to storm
damage can represent a major community financial burden. Every effort should
be made to minimize this type financial risk. When determining the suscep-
tibility of the various wastewater management system alternatives to damage
from storms, three system characteristics of the alternatives should be
considered:
-	Degree of centralization
-	Amount of exposed structure
-	Ability of systems to assimilate lower quality effluent in the aftermath
of a storm.
Each of these topics is discussed in the DEIS (pp. 11-39 ff).
(b) Primary and Secondary Environmental Impacts
Tmnarts mav be primary, produced by the construction, operation and
maintenance of the system, or secondary, derived in some fashion from the
existence of the system and its capacity. These effects are also termed
direct and indirect, respectively. Impacts may be characterized as short
term (construction noise) or long term (loss of a species of fish or com-
mitment of a land area for 20 years). The short or long term nature of the
imn*rt mav be important in decision making, since impacts acceptable to local
DODulace on a short term basis are frequently not acceptable indefinitely.
Impacts must also be considered either positive or negative. Effort expended
in estimating impacts accurately may be extremely beneficial, since positive
hpnpfitc not initially foreseen may emerge or potentially severe adverse
i^pacis can be avoided, mitigated or at least foretold.
The magnitude of impacts should be estimated. In some cases, quanti-
firation of the impact is possible. However, quantification can be deceptive
Lhon InniSL to svstews where the impacts differ only in degree. Arbitrary
nunerica1 quantification of magnitude may lead to reliance on small differ-
ences in nSrs which are individually not really quantifiable. The use of
Dositivp and neqative descriptions can provide a range of Identification
without the use of numbers in arbitrary situations.
Primary or construction-related impacts, tend to be relatively minor 1n
barrier' Island communities, especially when on-site and small community
systems are selected. Secondary impacts, however, can be extremely signi-
11-17
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ficant. Areas of major concern include groundwater resources, surface water
resources, and Impacts to sensitive natural areas. The EIS has developed
specific procedures to ensure that the potential Impacts on these resources
are recognized during the development and evaluation of alternatives.
(c) Implementabillty
Procedures for assessing implementabllity must focus on engineering con-
straints, fiscal and institutional feasibility and socio-political accep-
tability. The engineering evaluation focuses largely on any constraints
which must be acknowledged regarding construction or operation and mainte-
nance of each proposed alternative. Construction constraints could Include:
-	Shortages of materials
-	Shortages of construction crews trained in a particular skill
-	Local lack of experience 1n a new construction technique
-	Hazardous conditions.
Operation and maintenance concerns typically revolve around the following
factors:
-	Reliability of treatment: the ability of the process to consistently
produce uniform treatment efficiencies and meet water quality standards
-	Flexibility: the ability of the treatment process to adequately handle
fluctuating wasteloads, variable flows, and new waste streams
-	Operability: an analysis of the ease of operation and maintenance and
considerations of the availability of traine^operators and support
personnel
-	Energy usage
-	Adherence to applicable state and local codes*
The evaluation of fiscal and Institutional;-feasibility would be
accomplished by comparing the worksheets (Table fj.3 1n the DEIS) filled out
for each alternative as well as worksheets 1n the Technical Reference
Document, Financial Planning Handbook.
The evaluation of the socio-political acceptability of each alternative
is carried out mainly by means of the public participation program where
comment from local officials and other affected parties 1s gathered.
B. Impacts of the Strategy
This section of the EIS describes the Impacts that can be expected 1f the
EIS Strategy is implemented. Impacts on development potential, environmental
Impacts, financial impacts and implementabllity are discussed below.
1. Impacts on Development Potential
An Investigation was undertaken to ascertain if an adequate amount of
land suitable for soil absorption systems was available to accommodate future
growth. Concern has been expressed that development potential would be
adversely impacted 1f central/regional facilities were not provided. The EIS
analysis shows that more than adequate acreage suitable for soil absorption
systems is available to support projected population levels.
11-18
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(a) Land Capability Analysis: Existing Development
Existing development on the barrier islands has been surveyed to deter-
mine the relationship between soil suitability for on-site soil absorption
systems and historic development patterns. Aerial photographs from the USDA
Soil Conservation Service Soil Survey of the Outer Banks were used to corre-
late soils and development existing in 1977. I he general survey findings for
each community are found in the DEIS (pp 11-45 ff).
Historical development patterns, as measured by an analysis of soil sur-
vey aerial photographs, appear to support the wisdom of previous landowners
and builders in selecting the best land available for barrier island develop-
ment. The vast majority of structures existing in 1977 were built on lands
that are fully capable of providing adequate wastewater treatment using the
prevailing technology: septic tanks and soil absorption fields. Much of the
remaining land can accommodate this type of development, both raw land and
areas available for infilling with additional structures. Additional large
acreages of high land are suitable for other on-site systems (mounds, low
pressure pipe systems).
(b) Land Capability Analysis: Appropriate Systems for the Future
The six 201 study areas have been assessed by mapping two data variables:
sensitive natural areas and soil suitability for on-site wastewater manage-
ment systems. The purpose of this exercise was to determine the land use
capability of barrier islands based on the use of various wastewater manage-
ment systems. Each 201 study area was divided into lands identified as
sensitive (CAMA Areas of Environmental Concern and Registered Natural Areas)
or non-sensitive (all other lands encompassed by the U. S. Soil Conservation
Service in the Soil Survey of the Outer Banks). In addition, each study area
was divided into areas suitable for some type of on-site soil absorption
wastewater management systems (those lands with 12" or greater depth to the
seasonal high water table) and those unsuitable for any form of on-site soil
absorption systems (those lands with less than 12" depth to the seasonal high
water table). Data for depth to seasonal high groundwater was derived from
the Soil Survey of the Outer Banks and was described in Table 11.6 of the
DEIS.
(1) Land Capability Classification System
Four categories were developed which combine sensitive/non-sensitive
areas with suitable/non-su1table soils for determining the development
potential of each island. Maps showing these categories are found in the
Alternatives Evaluation Task Report. The four categories are described as
follows:
Category 1: Suitable/Non-sensitiye Lands:
These lands can support on-site soil absorption wastewater management
systems, and they are not included in lands protected by tt»e regulations
governing Areas of Environmental Concern as identified by the North
Carolina Coastal Management Program. These lands offer optimal
development potential for barrier island uses.
11-19
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Category 2: Unsuitable/Non-sensitive Lands:
These lands will not support on-site soil absorption systems, and they
are not regulated by the Coastal Management Program. These lands are
considered developable, but they will require wastewater management
systems with off-site disposal in order to utilize the land.
Category 3: Suitable/Sensitive Lands:
These lands consist of soils capable of supporting on-site soil absorp-
tion systems, but due to their environmentally sensitive nature, a use
permit is required from the North Carolina Coastal Management Program
which assures that development is compatible with the protected resource.
Therefore, while the land is considered developable in many instances,
specific siting and building criteria must be implemented to allow
project construction.
Category 4: Unsuitable/Sensitive Lands:
These lands are incapable of supporting on-site soil absorption systems,
and they are protected by regulations governing Areas of Environmental
Concern. Lands within this category are considered largely undevelopable
as they consist primarily of ocean hazard lands and marshlands.
(2)	Land Capability of Each Study Area
Table 11.2 shows the number of acres of land in each of the four cate-
gories per 201 study area. Lands with greater than 12 inches to seasonal
high water table comprise 45.0 percent of the total land area. Of the remain-
ing 55.0 percent of land, approximately 38.2 percent is marshes and wetlands.
The Alternative Evaluation Task Report discussed the land capability of each
study area in detail.
(3)	Development Potential of Each Land Category
The four land categories Identified are significant because they indicate
the relative development potential of all lands in each study area. Category
1 lands are good sites for development because they present no significant
environmental problems (erosion, wetlands, critical habitat) and also allow
on-site soil absorption wastewater management systems. Such lands range from
a low of 13.2 percent in the Topsail/Surf City area to a high of 38.5 percent
in the Southeastern Brunswick County area.
Category 2 lands can be developed without significant environmental
effects, but the builder must determine how wastewater management will be pro-
vided since on-site systems are not feasible. In this case, community sys-
tems using off-site disposal may be appropriate for multi-unit projects.
Single unit or small projects may use composting toilets or other similar
alternative and innovative wastewater treatment systems. Another potential
solution to wastewater problems on non-suitable soils 1s to transport
effluent to an adjacent site which has more than 12 inches of depth to the
seasonal high water table. In cases where communities or subdivisions use
this technique, the disposal site could be used as a park or open space for
all participating land owners. Percentages of land in Category 2 tend to be
quite small with the exception of the Dare Beaches and Hatteras Island area
where Category 2 lands represent 24.0 and 31.5 percent of total land.
11-20
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Table II.2 Acres by Sensitive Area/Soil Absorption System Suitability Category
Land Capability
Category	Category 1	Category 2	Category 3	Category 4
201 Plan	Acres Percent Acres Percent Acres Percent Acres Percent Total Acres
Southwestern Brunswick Co.
1409
20.2
317
4.5
1395
20.0
3855
55.3
6976
Southeastern Brunswick Co.
2988
38.5
372
14.8
1125
14.5
3277
42.2
7762
Topsail/Surf City
1074
13.2
905
11.2
1161
14.3
4967
61.3
8107
Carteret Co./Bogue Banks
1276
30.6
413
9.9
1340
32.2
1138
27.3
4167
Hatteras Island
2437
27.0
2850
31.5
1808
20.0
1946
21.5
9042
Dare teaches
4861
34.3
3397
24.0
1905
13.4
4007
28.3
14,170
Totals
14,045
28.0
8,254
16.4
8,734
17.4
19,190
38.2
50,224
Catego*^ 1 * >12" to groundwater and non-sensitive
Catenary 2 > <12" to groundwater and non-sensitive
Category 3 * >12" to groundwater and sensitive
Cat^ijbify 4 * <12" to groundwater and sensl ti ve
Source: ER0AS, Inc. 1981.
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Category 3 lands are considered suitable for development with soil
absorption wastewater treatment systems, but these lands display sensitive
natural features which constrain the use of the land. Siting considerations
(setbacks, land area requirements, use restrictions) and design requirements
may affect the development potential by requiring special construction or
site design features. Additional cost may reduce the development potential,
but the added design features might also increase the desirability of the
location (ocean-front, marsh view, etc.)» thereby resulting in a higher
return on investment. This category tends to include less than 20.0 percent
of the total land in each study area except Carteret County where much of
this category land has already been developed.
Environmental considerations are identified and described by the Coastal
Management Program and include ocean hazard areas, natural and cultural
resources, and public water supplies. Archeological and historical resources
listed on the Historic Register are also identified. In addition, Registered
Natural Areas as identified and designated by the North Carolina Department
of Natural Resources and Cbrcfiunity Development are included in the sensitive
areas description of this category.
Table II.3 displays the development potential of each study area if soil
absorption systems are utilized on those lands deemed developable (non-Cate-
gory 4). Category 1 lands have full potential and Category 2 and 3 lands
have partial potential as described previously. For discussion purposes, 25
percent of Category 2 and 75 percent of Category $' lands are assumed to be
capable of being developed using soil absorption systems. Table II.3 shows
that at least two-thirds of developable land (Hatteras Island - 63.5 percent)
in each study area can be developed using on-site or small community soil
absorption systems.
Development potential on Category 4 lands Js the lowest of the categories
presented because of the development costs involved in meeting environmental
standards and providing off-site Wastewater management systems. In many in-
stances the risk of developing 1n these areas is also increased as protected
resources are often more prone to flooding and stobn damage than those lands
in Categories 1, 2, and 3.,,
(c) Land Capability Analysis: Population and Flows
The impact on development potential from the widespread use of soil
absorption systems has been an ongoing issue in this EIS. The North Carolina
Laws and Rules for Ground Absorption Sewage Treatment and Disposal Systems
(effective July 1, 1982 and amended January 1, 1983) have been analyzed to
determine what minimum lot sizes will be required for single family,
townhouse and apartment dwelling units. A repair area is not required under
the following conditions (.1945 (c)) for a lot:
1.	Which is specifically described in a document on file with the local
health department on July 1, 1982, or which is specifically describ-
ed on a recorded deed or a recorded plat on January 1, 1983
2.	Which is of insufficient size to provide a repair area equal in size
to the original nitrification field as determined by the local
health department
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Table II.3 Development Potential with Soil Absorption Systems
Land Capability
Category
201 Plan
Category 1
(100%)
Category 2
(25%)
Category 3
(75%)
Acreage*
Developable
Total Acreage % of Tota
in Categories Acres
1, 2, and 3 Developab
Southwestern Brunswick Co.
1409
79
1049
2537
3121
81.3
Southeastern Brunswick Co.
2988
93
843
3924
4485
87.5
Topsail/Surf City
1074
226
871
2171
3140
69.1
Carteret Co.
1276
103
1005
2384
3029
78.7
Hatteras Island
2437
713
1356
4506
7095
63.5
Dare Beaches
4861
849
1429
7139
10,163
70.2
Totals
14,045
2,063
6,553
22,661
31,033
73.0
Category I » >12" to groundwater and non-sensitive
Category t ¦ <12" to groundwater and non-sensitive
Category I ¦ >12" to groundwater and sensitive
~This coluwrj represents the sum of those fractions of Category 1, 2 and 3 lands which can
reasonably be expected to be developed using soil absorption systems.
**Thii column represents Column 4 divided by Column 5.
NOT?: Category 2 lands are assumed to be 25% developable if adjacent suitable soils are
used for soil absorption systems.
Category 3 lands are assumed to be 75% developable under existing CAMA, cultural
resource, and natural area reflations.
Use of Category 2 lands it based on siting soil absorption systems on suitable soils in
Categories 1 and 3.
Source: Claude Terry & Associates, Inc. 1981.
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3. On which a ground absorption sewage treatment and disposal system
with a design daily flow of no more than 480 gallons is to be
installed; or on which a ground absorption sewage treatment and
disposal system with a design daily flow of more than 480 gallons is
to be installed if application for an improvements permit is
received by the local health department on or before April 1, 1983.
Thus, the 5,000 square foot lots platted prior to July 1, 1977, can still
be developed with soil absorption systems but without a repair area. Lots of
7,500 square feet appear to be the minimum size that can be developed on
sandy soils with a soil absorption system that includes a repair area. Town-
houses can be developed at the density of six to eight units per acre depend-
ing upon the amenities package offered by the complex. Apartment units can
range as high as 18-20 units per acre with no amenities. Appendix E 1n the
DEIS contains diagrams of lot layouts and supporting text.
Each community will contain different percentages of these types of resi-
dential units. For planning purposes, 40 persons (or 20 bedrooms) per acre
appears adequate for land consumption analyses.
Land acreages identified previously as suitable for development with soil
absorption systems provide a mechanism for determining the carrying capacity
of each 201 study area. Based on the number of housing units that can le-
gally be accommodated by a given parcel of platted land (assume an average of
five four-bedroom houses/acre) a maximum population can be projected. Table
11.3 shows that developable acreage of highland using soil absorption systems
ranges from 63.5 percent of available land 1n Hatteras Island to 87.5 percent
in the Southeastern Brunswick 201 study area. If these developable acres
were used for residential construction as permitted 1n the North Carolina
Division of Health Services regulations governing on-site wastewater treat-
ment systems, potential development can be quantified in terms of population
and wastewater flows.
Figure II.2 contrasts the number of persons who could be served by soil
absorption systems with the year 2000 peak population projected 1n the draft
201 Plans. As can be seen by these figures, the potential populations
greatly exceed population, projections.
The lack of centralized sewer systems should not preclude future growth,
based on technical considerations. Other factors may affect development
potential, however. Examples include downturns in the national and regional
economies, depression of the housing industry, high interest rates, future
shortages of gasoline, degradation of natural resource amenities by nonpolnt
source pollution, etc.
2. Environmental Impacts
The EIS process has Identified four major areas of impact; surface
water, groundwater, sensitive natural areas and land uses. This section
discusses the environmental impacts on these areas and provides a summary of
issues, existing conditions and impacts. A detailed description of existing
conditions on the North Carolina barrier islands is contained in the Tech-
nical Reference Document, Environmental Inventory Report.
11-24
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300,000
200.000
™ 100,000
Population
CM
I*.
CD
O
CO
W&
m
H
Study



SW BRUNSWICK
COUNTY
SE BRUNSWICK
COUNTY
TOPSAIL/
SURF CITY

Vv-?•••• •

CARTERET
COUNTY
HATTERAS
ISLAND
Area
Year 2000 Population Projected by 201 Plans
Total Number of Persons Who Can Be Supported On Soll-Absorptlon System
In the Study Area (Based On 5 Units/Acre of Developable Land)
f&SgTotal Number of Persons Who Can Be Supported On Soll-Absorptlon System
In the Study Area (Based On 5 Units/Acre of Developable Land)
Figure II.2 Population Projections and Developable Land Comparison


Sit!
V&M
DARE
BEACHES
Source: Claude Terry & Associates, Inc. 1981
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(a) Surface Water
A major Issue of the EIS is the impact of alternative strategies on the
surface waters associated with the North Carolina barrier islands. It is
difficult to overemphasize the resource value of the coastal surface waters.
They provide recreational opportunities for boating, swimming and sport fish-
ing. In addition, they support a large commercial fishing industry based on
shellfish and finfish populations. Another primary consideration is the
importance of the estuarine systems' dynamics and the dependence of many
ocean finfish on the system.
The State of North Carolina has recognized the importance of the coastal
waters near barrier islands by classifying most of them as shellfish waters
(Class SA) and prohibiting the discharge of wastewaters regardless of treat-
ment level. The use of surface discharges is therefore largely restricted on
barrier islands. However, even with the most stringent water use classifica-
tion, there are still major water quality problems in coastal surface waters.
Approximately 46,170 ha (1;14,G0G ac) of shellfish waters within the study
area are currently closed to harvesting. Areas of concern include bacterial
contamination, nutrient levels and heavy metal contamination. However, most
of these problems appear to be generally associated with mainland activities
such as land use changes, specific coastal areas such as marinas or discrete
environmental phenomena such as flocks of migratory waterfowl.
Few cases have been documented of surface water pollution directly attri-
butable to barrier islands wastewater management practices. A study of nu-
trient pollution resulting from man's use of the barrier islands was conduct-
ed at Surf City, North Carolina (EPA 1975, Shiver and Register 1978). The
study concentrated on identifying pollution from septic tanks located on
finger-fill canals. This study found that nitrogen compounds, total phos-
phorus and total organic carbon exceeded background counts 1n groundwaters
and surface waters in proximity to the septic tante. Contamination of the
groundwater is attributed to the fact that the septic tank drain field was
placed directly into the aquifer. Little or na separation was found between
the nitrification field and the groundwater tJ&le, and adsorption of
nutrients by soil particles was very poor (Shiver 1981).
It is possible that some surface discharges would also occur under the
EIS Strategy. State regulations prohibit discharges to SA waters but do
permit discharges to SC (fishery use) waters where adequate assimilative
capacity can be documented. However, few future point source discharges are
expected since few waters near barrier islands are classified SC. Due to
costs, the number and volume of discharges would also be expected to be few.
Current water quality standards would be expected to be met under all
strategies examined by the EIS.
Degradation of surface water resources by urban runoff 1s an increasingly
serious problem on barrier islands. Development has produced documented
negative impacts on shellfish beds bordering several southeastern barrier
islands. In some cases these impacts, Initially attributed to point source
discharges, have been shown to be due to nonpoint sources. A significant
nearby example 1s Hilton Head Island, SC (USEPA, Gannett Fleming Corddry and
Carpenter, Inc. and Claude Terry & Associates, Inc., 1981).
11-26
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(b) Groundwater
A major issue associated with groundwater on the barrier islands is the
potential contamination of shallow groundwater resources by on-site waste-
water management facilities. Additional concerns include the potential
impacts from land application sites, increased surface runoff and salt water
intrusion.
The major value of groundwater is as a potable water supply. Groundwater
is essentially the only on-island supply of freshwater for the barrier
islands. However, groundwater is not generally a limiting resource south of
Beaufort Inlet. Most public water supplies are obtained from the deeper lime-
stone aquifer or from deep inland wells on the mainland in this southern
area. Use of the barrier island surface aquifer for potable water purposes
is not widely practiced, and instances of public water supply contamination
by on-site systems have not been recorded on the North Carolina barrier
islands. For example, Ocean Isle Beach, which uses the surface aauifer for
part of its supply, has not shown any public health problen associated with
septic fields in the area. Since ultimate disposal of treated wastewater is
to the groundwater for most systems, groundwater quality and quantity remains
a major issue in the EIS. However, if the probable use for the surficial
aquifers on barrier islands is not potable water supply, the significance of
the introduction of nitrates, bacteria and virus into the aquifer must be
re-examined.
The EIS Strategy will result in continued discharge to groundwater. Use
of upgraded surface and subsurface land disposal should reduce impacts of
existing discharges to groundwater. An on-site management agency and the
local health department could promote future systems being installed and
managed properly. In addition, an agency or health department could detect
and eliminate or upgrade existing sources of contamination. In areas where
on-site systems are not suitable, the EIS Strategy will provide for the use
of small community systems or other off-site disposal. In all cases OEM's
groundwater standards must be met.
The quantity of groundwater is influenced by many factors including
recharge from precipitation and effluent disposal and withdrawal for potable
water use. In areas which use the surface aquifer as the potable water
supply, the use of on-island land disposal techniques helps maintain the
level of the aquifer. In areas where off-island water supplies are utilized,
the use of on-island land disposal techniques can lead to a net gain in
aquifer recharge.
This net addition could possibly result In physical contact between the
water table and the bottom of drain field trenches 1o marginal Installations
causing septic tank soil absorption system malfunctions. This potential
adverse impact was evaluated by applying the methodology described in Section
4.2.2.3 of the Technical Reference Docwent, Alternatives Development Report,
to a hypothetical barrier island case §tudy. The results from the study show
that the response of the water table to wastewater disposal can be estimated
and used to evalute the potential for water table contact with drain fieW
trenches across a given section of Island. The case study analysis indicates
that this situation 1s not likely to be extensive and occurs only for very
marginal Installations.
11-27
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In addition, EPA Region IV is conducting a study designed to demonstrate
the use of a mathematical model that is the basis of this methodology. The
study plan is included in the Appendix.
(c) Sensitive Natural Areas
A number of environmentally sensitive features occur on the barrier
islands of North Carolina. A primary issue considered by this study is the
potential impact on these sensitive areas, including ocean hazard zones,
biologically productive coastal waters, wetlands, wildlife nesting areas,
protected species, maritime forests, designated natural areas and significant
historic/archeological sites. These features warrant particular considera-
tion for qualities such as uniqueness, rarity, hazardous conditions, high
ecological value and low tolerance to disturbance.
Environmentally sensitive areas have been discussed in detail in the
Technical Reference Document, Environmental Inventory Report, along with the
existing regulatory and legal structures which currently provide protection
for some of these areas. These structures include the EPA 404 permit pro-
gram, the National Pollutant Discharge Elimination System, the National
Environmental Policy Act of 1969, North Carolina Environmental Policy Act of
1977 and the North Carolina Coastal Area Management Act. While some protec-
tion is provided by this framework, there are many environmentally sensitive
areas which are not protected from private development. It is not possible
for any of the strategies considered by the EIS to provide blanket protection
to these areas.
Primary impacts to sensitive areas could occur during construction of
wastewater management systems. The installation of collection systems, inter-
ceptors, ocean outfalls and septic tank drainfields could cause adverse im-
pacts without careful siting of development and implementation of mltigative
measures. Secondary impacts of growth in the form of increased urban runoff
pose a greater danger to sensitive natural areas, however.
The EIS Strategy will lead to lower densities per developed acre than
will implementation of the draft 201 Plans, and therefore more acres will
undergo development to serve the projected population. This assumes the
increase in population to be the same with and without a central/regional
system. Such low density development may lead to low level degradation of
the sensitive areas. However, low density housing has been constructed in
forests on barrier islands such as Hilton Head, South Carolina and Saint
Simons, Georgia without the unnecessary clearing of trees. No strategy will
guarantee the protection of the environmentally sensitive areas. In fact,
long term adverse impacts are anticipated to several environmental features
under all strategies. However, the EIS Strategy would provide for the
possible protection of many categories of environmentally sensitive areas
through the planning process. The planning and management functions of the
EIS Strategy would provide the necessary framework to correct existing
pollution problems and avoid or mitigate future impacts.
(d) Land Use/Population
Land use and development densities will interact with projected popula-
tion levels in several ways. It is generally assumed by state and local
officials that the same numbers of persons will be attracted to the North
11-28
-------
Carolina barrier Islands regardless of what type wastewater management
systems are provided. Higher residential densities with accompanying lower
housing unit costs would likely result from the provision of central/reqional
systems. Although a given prospective purchaser might refuse to pay the
higher housing costs of low density development, market demand in hiqher
income brackets may be adequate to absorb the projected number of units pro-
posed by developers under the EIS Strategy.
The second land use/population impact is the increase in urban runoff
that will result from future development regardless of which strategy is
implemented. The EIS Strategy would lead to lower density developments and
less concentrated urban runoff would be anticipated. If the citizens of the
area desire a management agency, this agency could serve to promote a series
of best management practices to mitigate these impacts.
(e) Other Resources
No effects are anticipated on climate or air quality levels. Proper
systems operations will eliminate odor problems. Construction noise is
temporary.
Alterations to terrain are expected to be negligible. Original contours
will be restored after construction. Properly installed and maintained soil
absorption systems and land surface disposal systems are not expected to
produce adverse impacts on soils.
Impacts to aquatic ecosystems are included in the discussion of surface
water quality impacts.
Impacts to terrestrial ecosystems are included in the discussion of
sensitive natural areas.
Because population levels will not differ significantly under the three
strategies considered by the EIS, the communities' economic profile and
demand for community services will be approximately the same.
3. Financial Impacts
The financial impacts to be evaluated are twofold. First and most import-
ant are overall total costs regardless of who is to pay (total present worth
and/or total annual average). These are the prime cost criteria defined by
EPA regulations. Second, it is necessary to evaluate local costs in term of
affordability. This considers distribution of costs (for example, grants
received reduce local shares)• EPA defines affordability 1n terms of percent
of median household income for costs of proposed systems. This is the aver-
age cost for the average residential household. Projects which exceed the
defined criteria are not necessarily prohibited, but they would call for
special re-evaluation and procedures.
Financial impacts are a major area of concern in this EIS. Local finan-
cial bases are small, and question? have been raised In discussion! wftli
local officials and citizens about the ability of island communities to bear
the capital and operation and maintenance costs of central or regional waste-
water management systems. As a consequence this section of the'EIS explores
in considerable detail the costs and local financial burden of a variety of
11-29
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on-site and small community soil absorption systems which might be alterna-
tives to systems proposed by the draft 201 Plans.
A case study of a hypothetical barrier island was developed as a mech-
anism to simulate various cost scenarios. First, costs were developed for a
variety of potentially appropriate technologies. Then, several service
scenarios using these technologies were developed, and the costs of each were
analyzed. Details of the case study are found in the Alternatives Evaluation
Task Report; major points are summarized 1n the DEIS (pp. 11-56 ff).
Typical household monthly charges were developed for the draft 201 Plans
and various small community and individual on-site systems. A major concern
of the EIS is how affordable are these monthly user charges.
Table II.4 shows estimated average family income in 1980 in the four coun-
ties making up the 201 planning areas. Median county income figures were not
available, nor were figures for specific island municipalities available. As
a general planning guideline, 1t appears that the maximum user charges for
systems funded by 201 Construction Grants program monies should range between
$18.74 and $24.82. Such figures will need further refining at the detailed
planning level to relate them more specifically to the median Income of
permanent residents of each barrier island community.
Figure 11.3 Is a bar chart relating the typical household monthly charges
of various wastewater management technologies in each study. A range of
charges is shown for groups of technologies. Monthly charges with and with-
out federal and state funding assistance are shown as appropriate. Indi-
vidual on-site systems are assumed to be ineligible for funding assistance 1n
this comparison. (Systems 1n place before December 1977 are eligible; future
individual on-site systems are not eligible.)
Monthly user charges were calculated by dividing total annual user costs
by 12. Local governments may chose alternative methods of distributing
costs.
In all of the planning areas, the costs of th^, draft 201 Plans exceed the
EPA user fee ceiling by a significant margin 1f no federal and state funds
are available. Many of the small community systems and some of the modified
individual on-site systems appear very expensive relative to the local re-
source base. The reader should not be misled regarding individual or commun-
ity systems, however. The EPA percent of Income criteria applies to the
average cost to all households 1n the area. While a few residences might
require the more expensive on-site systems, the average cost for the area
should be determined and compared with the percent of Income criteria. In
such cases, on-site systems may be easily affordable.
Federal and state assistance, however, brings many small community
systems down in cost into the affordable range. Monthly user charges for
three of the five draft 201 Plans also fall below the EPA guideline celling.
The Southeastern Brunswick County, Southwestern Brunswick County, and
Hatteras Island proposed 201 Plans are significantly higher than the EPA
guideline celling.
4. Implementability
Difficulties in implementing the strategy can be anticipated mainly in
the areas of financial and institutional arrangements. The limited
11-30
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Table II.4 Average Household Income and Maximum User Charge per Household by 201 Study
Area County.
County
1980 1979
1980 Housing Persons/ Per Capita
Population Units	Household Income**
Estimate Ave.
Countywide
Household
Income
Maximum
User Charge
/Household***
Brunswick 35,377	12,409	2.85
Pender 21,537	7,511	2.87
(Topsail/Surf City)
Carteret 39,324	15,128	2.60
Dare 13,169	5,359	2.46
5,598
5,224
6,545
6,559
$15,954
14,993
17,017
16,135
Annual Monthly
$239.31 $19.94
224.90
18.74
297.80 24.82
242.03 20.17
*U. S. Department of Commerce. Bureau of Census. 1981. 1980 Census.
**U. S. Department bf Commerce. 1979. Bureau of Economic Analysis.
***EPA regulations set a maximum user charge of 1.5 percent of median household income for households
of $10,000-17,000 per year and 1.75 percent for households over $17,000 per year.
If cost? are higher, special evaluations and procedures are necessary.
Source: Claude Terry & Associates, Inc. 1981.
-------
FIGURE II.3
SOUTHWESTERN BRUNSWICK COUNTY
COMPARISON OF EPA USER CHARGE CEIUNG WITH TYPICAL HOUSEHOLD COST PER
MONTH FOR EACH TECHNOLOGY GROUP
EPA USER
CHARGE CEILING
i i
0 2
19.94
0 3
0 4
0 5
0 6
0 7
0 8
0 9
0 10
0 11
0 120
201 PLAN
( FUNDING ASSISTANCE )



36.35
I








201 PUN ( NO
FUNDING ASSISTANCE)





.
09.68
I





SMALL COMMUNITY
SYSTEMS
( FUNDING ASSISTANCE )
8.00
mi
13.85
inn










SMALL COMMUNITY
8Y8TEMS (NO
FUNDING ASSISTANCE )

«
ii
,30
UWHItl
3M4
mtfin

m






IND. ON-SITE
SYSTEMS (NO
FUNDING ASSISTANCE )
i
i
1.47
IH1UIUD
29.72
HRimii









SOUTHEASTERN BRUNSWICK COUNTY;
COMPARISON OF EPA U8ER CHARGE CEILING WITH TYPICAL HOUSEHOLD COST PER
MONTH FOR EACH TECHNOLOGY iQRQUP
EPA USER
CHARQE CEILING
• 1
fr 2
19.9'
o a
0 4
0 8
0 8
r 7
o a
0 0
0 16
0 i\
ft m
201 PUN
( FUNDING ASSISTANCE)



34.33
1








201 PLAN ( NO
FUNDING ASSISTANCE )









94.48
I


SMALL COMMUNITY
SY8TEMS
( FUNDING ASSISTANCE )
S.00
llll
13.65
llll










SMALL COMMUNITY
8YSTEM8 (NO
FUNDING ASSISTANCE)

1
1
.30
llllllllll
39.44
mum








IND. ON-SITE
SYSTEMS (NO
FUNDING ASSISTANCE)
l
I
I.4T
llllllllll
29.72
iinmiii









11-32
-------
FIGURE 11.3 (CONT.)
TOP8AIL / 8URF CITY:
COMPARISON OF EPA U8
MONTH FOR EACH TECHK
ER CH/
JOLOQ
\RGE C
YGRO
JEILING WITH TYPICAL HOUSEHOLD C08T PER
UP
EPA USER
CHARGE CEILING
9
18,74
I

0 4
0 1
0 1
16
rd
J6
0 H
5—r
ii lie
201 PLAN
< FUNDING ASSISTANCE)

18.39
1










201 PLAN ( NO
FUNDING ASSISTANCE)




4««
1







SMALL COMMUNITY
SYSTEMS
( FUNDING ASSISTANCE )
8.00
(III
13.89
iiiii










SMALL COMMUNITY
SYSTEMS (NO
FUNDING ASSISTANCE )

T
1
.30
llllllllll
36.44
lltllli!








IND. ON-SITE
SYSTEMS (NO
FUNDING ASSISTANCE )
I
I
.47
Ullllllll
29.72
llllllllll









CARTERET COUNTY; 	_ titmj
COMPARISON OF EPA USER CHARGE CEILING WITH
MONTH FOR EACH TECHNOLOGY GROUP
TYPICAL HOUSEHOLD COST PER
EPA USER
CHARGE CEILING
1 1
o a
0 3
4.82
1
0 4
0 8
o a
0
0 fi
0 fi
0 1?
6 11
4 "133
201 PLAN
( FUNDING ASSISTANCE )


21.10
I









201 PLAN (NO
FUNDING AS8I8TANCE )



37.2C
I








SMALL COMMUNITY
8YSTEM8
( FUNDING A8SI8TANCE )
1.00
13.68










SMALL COMMUNITY
8Y8TEMS (NO
FUNDING ASSISTANCE )

t
M
8444






/

IND. ON-SITE
8Y8T6M8 < NO
FUNDING ASSISTANCE)
I
1,47
2*72






¦-





11-33
-------
FIGURE 11.3 (CONT.J
HATTERA8 I8LAND: A) Avon/Buxton/Frlico/Hatt#ra« B)Rodinth«/Wavtt/3«lvo
COMPARISON OF EPA U8ER CHARGE CEILING WITH TYPICAL HOU8EHOLD C08T PER
MONTH FOR EACH TECHNOLOGY GROUP
EPA USER
CHARGE CEILING
« 1
0 i
20.17
0 3
0 4
0 B
0 i
6 7
o a
0 9
0 10
P H
a no
201 PUN
(FUNDING ASSISTANCE )




w
•0
(M
00 I7.(
1
•





201 PUN ( NO
FUNDING ASSISTANCE)









(•)
100
oo
(A)
114.1*
I
8MALL COMMUNITY
SY8TEM8
( FUNDING ASSISTANCE )
5.00
IM
MM
llil










SMALL COMMUNITY
SYSTEMS (NO
FUNDING ASSISTANCE )

1
1
'.30
Muim
38.44
HHHin








IND. ON-SITE
SYSTEMS (NO
FUNDING ASSISTANCE )
1
1.47
20.72











DARE BEACHES COMPLEX:
COMPARISON OF EPA USER CHARGE CEILING WITH TYPICAL HOUSEHOLD COST PER
MONTH FOR EACH TECHNOLOGY GROUP
EPA USER
CHARGE CEILING
i 1
0 2
20.17
0 3
0 ^
0 8
o e
6 y
» e
0 9
0 10
0 11
» 110
201 PLAN
( FUNDING ASSISTANCE )

17.10
1










201 PLAN ( NO
FUNDING ASSISTANCE )



30.47








SMALL COMMUNITY
SYSTEMS
( FUNDING ASSISTANCE )
S.00
III!
i3.es
nm










SMALL COMMUNITY
SY8TEMS (NO
FUNDING ASSISTANCE )

r
I
.30
HIUMfl
36-44
HHHW








IND. ON-SITE
SYSTEMS (NO
FUNDING ASSISTANCE)
'
I
1.47
Milium
28.72
mirniii




•




11-34
Source: Gannett Fleming Corddry and Carpenter, Inc. 19B1
-------
resources of local governments to meet the wastewater management needs of
highly fluctuating seasonal populations are the major constraint. The
provision of central or regional wastewater treatment systems, even with
federal and state assistance, may prove to be beyond the financial capacity
of some of the barrier island communities given the existing tax base and
presently incurred debt service obligations. A decentralized approach to
wastewater management which emphasizes the continued use of on-site and small
community systems poses significantly less financial risk to local govern-
ments and will be relatively easy to implement.
Based on the expected federal 201 program funding for the next four
years, the highest ranked community would not expect funding until 1987 or
later'depending on availability of funds. The remaining communities are
considerably lower on the North Carolina Department of Environmental
Management's list. However, a special situation exists where innovative and
alternative wastewater management systems are proposed for use in a 201 study
area. The federal government has designated four percent of the total amount
of 201 funding for use on innovative and alternative systems. Therefore, if
a 201 Plan had a low ranking and had completed all information requirements,
and in addition was an innovative or alternative system, the project could be
funded before higher priority conventional sewer projects. Communities that
ran riwnnnctrate innovative solutions to wastewater treatment problems would
therefore be more likely to obtain 201 project funding If and when further
orants are approved. Such decisions will be made by the North Carolina
Division of Environmental Management.
ImnlPmentation of the EIS Strategy involves updating the draft 201 Plans.
The uodate program will address population, land use, flows, system selec-
tion and institution and financial arrangements. In several 201 planning
Troac the selected alternative could be a combination of on-site soil absorp-
tion svstems and small community systems. In large part, this scenario
reS?esents a continuation of present practices and as such poses no barriers
tn imnwntation. The present mix of on-site and small community systems
could shift toward a higher percentage of small community systems to serve an
increased density of development.
nnanojal	«dVSS c'aMi SKS'So?
nSlfwere implemented as presently proposed. Total project costs should be
Plans were imP|e , th svstems may be eligible for innovative and
aUernative* system funding of grant-eligible portions. Again, however, each
community s $ace on the state priority list could cause delays in
implementation.
,.^nn nf receiving 201 Construction Grant money would be the
t	oc™governments establish public on-site and small
requirement tn«	management agencies where such systems are selected.
community	"HSllshld elsewhere 1n the country and may offer
Such agendes na	A £pA ^^3^00$ antj program requirements
benefits. The .	, rlv Prm #79-8) require that applicants for construction
memoranda (particu y SyStems establish public management agencies,
grant money to fund sucn
r-*aMi«h a comprehensive program for regulation and inspection of
- Estab^sh atemsPthat Wni include periodic testing of existing stable
11-35
-------
water wells and, where a substantial number of on-site systems exists,
more extensive monitoring of aquifers
-	Certify that a public body will be responsible for the proper installa-
tion, operation, and maintenance of the funded systems
-	Obtain assurance of unlimited access to each individual system at all
reasonable times for inspection, monitoring, construction, maintenance,
rehabilitation, and replacement.
Several months would likely be required to establish such agencies, but
this task does not represent a barrier to implementation. The Alternatives
Evaluation Task Report contains case studies describing the activities of
several of these existing agencies which could serve as models for barrier
island communities, if desired.
C. Mitiqative Measures
Measures are suggested below to mitigate the significant adverse impacts
which have been previously identified. These measures are intended to supple-
ment existing development controls such as zoning ordinances, subdivision
regulations, the Coastal Area Management Program and the National Flood
Insurance Program. Many of these measures would be the responsibility of the
local management agency.
1.	Surface Water
-	Conduct additional sampling programs so as to adequately document the
extent and sources of water quality pollution in shell fishing waters.
-	Renovate any known failing soil absorption systems and establish mechan-
isms for early identification of incipient failures.
-	Assure routine inspection and pumping of soil absorption systems on a
community-wide basis so as to reduce failures.
-	Control runoff from developed and developing areas by greater use of
on-site retention facilities and avoid storm sewering and curbs and
gutters.
-	Control discharges from bilges and sanitary facilities of commercial and
pleasure boats, particularly within estuarine and marine waters. More
stringent enforcement of Coast Guard regulations 1s required.
-	Minimize the use of impervious surfaces in new development.
-	Preclude surfacing of septic tank effluent and overland flow by proper
installation, operation and maintenance of soil absorption systems.
-	Implement or enforce best management practices for all new construction.
2.	Groundwater
-	Implement a water conservation program to reduce hydraulic loading on
11-36
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soil absorption systems. Increase public education and modify local
plumbing codes.
-	Establish a monitoring network to assure detection of any contaminated
groundwater or saltwater intrusion in potable water supplies or surface
water bodies.
-	Use the groundwater modeling tool developed by the Draft EIS to predict
the hydrodynamic response to soil absorption disposal of wastewater
This model is being demonstrated through additional studies now underlay
(see Appendix;.	J
3. Sensitive Natural Areas
-	Encourage developers to refrain from unnecessary clearing of vegetation
especially in maritime forests, so as to preserve wildlife habitat and*
decrease urban runoff.
-	Encourage buffer zones and greenbelts to preserve open space and reduce
noise impacts on wildlife and humans.
D. Implementation of the Recommended Strategy
The Construction Grants program was delegated by EPA to the Division of
Environmental Management (DEM) of the North Carolina Department of Natural
Resources and Community Development in 1980. EPA makes annual grants to DEM
for distribution to local grant applicants according to the state-developed
funding list.
Based on the delegated authority, DEM certifies 201 plans when they are
completed and prepares a Finding of No Significant Impact (FNSI). EPA then
reviews the FNSI and provides for a 30-day comment period on the FNSI. If no
negative comments are received, EPA approves the FNSI, and DEM issues a final
approval of the grant application. At that point, the grant applicant may
receive funds subject to his position on the funding list and availability of
funds.
Before developing a work plan to update their draft 201 Plans, grant
applicants should be aware of recent changes made to the Construction Grants
program, the criteria used by the state to develop its priorities and funding
list and the present potential for each barrier island grant application to
receive 201 monies. Each of these topics is discussed below.
1. Recent Changes to the Construction Grants Program
Certain procedural and administrative aspects of implementing the Clean
Water Act of 1977 were altered by the provisions of the Municipal Wastewater
Treatment Construction Grants Amendments of 1981, enacted December 29, 1981,
and its implementing regulations published as an interim final rule in the
Federal Register on May 12, 1982. Guidance is furnished in an EPA publica-
tion, Construction Grants 1982 (CG-82) (EPA 1982). Highlights of the changes
effective October i» 1^34, are as follows.
11-37
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-	EPA funding of conventional wastewater management systems will drop from
75 percent of grant-eligible components to 55 percent. Funding for
innovative and alternative systems or components will be reduced from 85
percent to 75 percent.
-	Grant-eligible components are restricted to intercepting sewers, waste-
water treatment facilities, outfall sewers, and infiltration/inflow
rehabilitation. Collection systems and correction of combined sewer
overflows will no longer be eligible routinely, except that the governor
may choose to use up to 20 percent of the state's allocation for these
previously eligible components.
-	Eligible treatment capacity will be based on existing population at the
time of the Step 3 grant award or planning area population in 1990,
whichever comes first.
-	Step 2 grants will no longer be made separately. Instead, Step 3 grants
will contain an allowance for design, plans and specifications. Small
communities may apply for an advance on this allowance.
2. Development of the North Carolina Construction Grants Funding List
DEM prioritizes grant applicants and maintains a funding 11st for the
administration of its 201 program. Communities are placed on the list if
they meet one or more of'the following criteria:
-	Mater quality problems are documented.
-	An application for an EPA or state grant Is on file.
-	The community 1s under orders by the NC Environmental Management
Commission to initiate construction within the year or to hook on no new
flows.
-	If the existing treatment facility provides only primary treatment or
less.
Communities are ranked based on the number of points assigned to their
project. The scoring system 1s described 1n detail in 15 North Carolina
Administrative Code 2F.0100. Factors considered Include:
-	Water quality impacts
-	Area population
-	Basin impacts
-	Water use restoration factor (use attainability considerations)
-	Size of proposed facility
-	Urgency of the need to upgrade services
-	Existing degree of treatment provided
-	Community's compliance schedule, if any
-	Regionalization: percent of planning area to be served, number of
municipalities served, size population to be served, and availability of
any agency adequately authorized to provide wastewater management
services.
The community's rank on the funding list is dictated by its score: the
higher the score, the higher the place assigned on the funding list. A
community moves up the funding list as preceding projects receive approval of
their 201 plans and grants are made.
11-38
-------
schedu?e-f"ndin9 11St iS developed each year according to the following
January:
February 15:
April:
June:
July:
August:
October 1:
Start the update process in the regional offices
DEM Raleigh receives update information
Draft funding list developed
Public hearing held on draft list
Draft list approved by DEM
Draft list transmitted to EPA Region IV for review
Effective date for new funding list
3. Barrier Island Communities' Potential for Receiving 201 Funds
According to the draft FY '84 funding list, the Barrier Island draft 201
Plans are ranked as follows;
Plan Name
Rank
Est. Funding Year
Southwestern Brunswick Co.
Southeastern Brunswick Co.
Topsail/Surf City
Carteret Co. Complex
Dare Co. Complex
219-221
Not listed
116
115
114
FY 1988
FY 1987
FY 1987
FY 1987
These rankings were assigned prior to the completion of this EIS and the
completion of the update program defined by the EIS Strategy. It is not
likely that rankings will change after the 201 plans are updated (Batten
1982). In the case of the draft Southeastern Brunswick County 201 Plan
Southport was allowed to proceed to serve its own needs and is ranked as #80
on the list with funding estimated in FY 1986. The barrier island communi-
ties of Long Beach, Yaupon Beach, and Caswell Beach do not constitute a
project and thus have no ranking (Batten 1983).
4. Schedule of Grant Applicant Activities
OEM has defined the following schedule of activities to be undertaken by
barrier island communities in updating the draft 201 Plans (Batten 1983):
-	The grant applicant will send DEM a plan of study for the update project.
-	DEM will review the plan and approve the tasks to be undertaken.
-	The community will negotiate with its engineer to establish the study's
cost and apply for an increase in its original Step 1 grant.
-	The Environmental Management Commission will approve the increase if
funds are available. (The state no longer makes new Step 1 grants but
can increase old Step 1 grants.)
-	The community completes Its update program and goes through the standard
Step 1 review and approval procedures.
-	The community applies for an advance on its Step 3 monies to undertake
the design phase.
-	When plans and specifications are approved by DEM, Step 3 monies will be
granted as available.
11-39
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III. COMMENTS ON THE DRAFT EIS AND EPA RESPONSES
EPA conducted three public hedrinos in Wnr+K r- i •
to present the Draft EIS and gather comments	3 coastal communities
included Bolivia on August 23, 1983. Pine Knoll	and locations
and Manteo on August 25, 1983.	Knoll Shores on August 24, 1983,
This section of the Final EIS contains Wi™ *
responses to them, followed by the transcriDts nf thl ?ent and EPA'S
and EPA's responses. Indexes are provided for h„thJ.three 1c meetings
separate index precedes the written comments- an indlv ?! Soments' A
appears on the first page of each transcript	MCh
letters and transcripts are bracketed and numbered	on the
"W" refers to a written comment; the prefix "T" ro# f	The prefix
transcript.	M ' refers t0 a comment in a
Written Comments
The following index to the written comments is DrovidAH	'
locating specific letters.	^ vided to facilitate
Comment	Name	Agency
UNC Sea Grant College Program
Marine Advisory Services
N.C. Marine Resources Center
Advisory Council on Historic Preservation
School of Agriculture and Life Sciences
North Carolina State University
Div. of Archives and History
N.C. Dept. of Cultural Resources
N.C. Saltwater Fishing Federation
Public Health Service
Centers for Disease Control
Town of Kill Devil Hills
The Raleigh Salt Water Sportflshlng Club
W-l + W-5
W-6
W-7 W-16
W-l 7
W-18
W-19
W-20 + W-24
W-25
W-26, W-27
W-28 + W-32
W-33
W-34 W-38
Name
S. M. Rogers, Jr.
Don L. KHma
Craig Cogger
John J. Little
Robert 6. Stryker
Frank S. Lisella
Ray Sturza
Robert N. Vinay
LaDane W. Bullington Town of Ocean Isle Beach
Paul S. Denison
William E. Burnett
Wayne A. Hanson
Bruce Leighty
Henry von Oesen and Associates
Corps of Engin€er, Wilmington District
Department of the Army
National Wildlife Federation
f
III-l
-------
Comment
Name
Agency
W-39
N/A
W-40
W-75
George C. Norris
Chrys Baggett
John J. Little
W-41 ¦+• W-47 Anne Taylor
W_48 -»¦ W-74 James H. Lee
Larry Bray
Soil Conservation Service
U.S. Dept. of Agriculture
State Clearinghouse
N.C. Dept. of Administration
Div. of Archives and History
N.C. Dept. of Cultural Resources
N.C. Dept. of Natural Resources and
Community Development
Office of Environmental Project Review
U.S. Dept. of the Interior
Outer Banks Chapter
National Audubon Society
111-2
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UNC SEA GRANT COLLEGE PROGRAM
MARINE ADVISORY SERVICES
N.C. Marine Resources Center
. Kure Beach, N.C. 28449
Marine Agent (919) 458-5498
Coastal Engineer (919) 458-5780
August 8, 1983
Mr. W. Bowman Crum, Jr.
EIS Project Office
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, GA 30365
Dear Mr. Crum:
Please consider the following comments on the NC Barrier Islands Waste-
water Management Draft Environmental Impact Statement (EIS). While I have
reviewed the entire EIS, its length precludes detailed comments, ify comments
are limited to overall impressions and the more serious differences of opinion.
The EIS does not adaquately address many of the concerns expressed in
my earlier correspondence dated 13 April 1981 and 6 November 1931. Barrier
islands are still portrayed as narrow low sand spits rapidly migrating towards
the mainland and frequently cut by new inlets. While gradual erosion problems
are significant, most of the barrier islands in North Carolina have not been
found to be significantly migrating by overwash processes as presented in the
EIS. Contrary to the EIS, within the design lifetime of new development and
any of the wastewater treatment alternatives, the threat of a new inlet opening
is highly remote along most of the islands and is usually not an important
consideration in design. Furthermore, when an inlet is opened it will most
likely be caused by ocean storm surge and waves moving inland to breach the
island. The only exception is along Pamlico Sound where the size of the storm
surge in the sound makes a breach possible from either direction.
Barrier island as well as mainland barrier beaches experience particular
hazards due to storms and long term erosion not common, in other areas. The
severity and extent of those hoards is highly dependent on the shoreline top-
ography and the design storm conditions. The EIS does not offer adaquate
assistance in selection or Biting of the appropiate alternative methods of
wastewater treatment. The tables comparing the levels of damage susceptibility
are distorted by the overly simplistic view of barrierislands mentioned earlier.
While boats and boats in marinas are an obvious and highly visable potential
source of pollution, to ray knowledge, no detailed study has been able to clear-,
ly isolate boats as "a major contribution to the closure of shellfish waters'1 tn the
EIS Environmental Inventory Report, 2.12.4, page 2-18. Many marines, are located 3
in enclosed basins with reduced circulation, which, by their nature, accumulate	j
The University of North Carolina is comprised of the sixteen senior institutions in North Carolina.
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Mr. W. Bowman Crum
Page 2
August 8, 1983
pollution from falling septic tanks, industrial discharges, surface runoff
and the other various sources including boats. In those detailed studies
where efforts were made to isolate all of the various sources of pollution,
boats were not found to be the major contributors. Although boats are po-
tential sources of pollution it is not conclusive that they are a significant
actual source. The vast majority (roughly 98%) of boats registered in NC
are too small to have marine toilets. Among larger boats, the majority,
(roughly two thirds) are not in use even on the busiest summer weekends. When
in use, they are not usually in the marina. Untreated discharge of sewage
from all boats in inland waters has been in violation of federal statutes since
1980. Compliance with those regulations has been less than total, but many
boats how have installed marine sanitation devices to treat or hold waste to
meet federal standards. Marines often have available on-land facilities as
an alternative to using marine toilets in the marinas.
The study of several Brunswick County marinas by Bane and Walker, conclud-
ed only that there were higher coliform counts near the marinas. It does not
conclude the source of the higher counts and in fact reports "a low correlation
was observed between boating activity and fecal coliform counts". The EIS con-
clusion that boats in marinas are a "major contribution" to shellfish closures
is not supported by existing studies.
After reviewing the draft NC Barrier Island Wastewater Management EIS,
my impression of the major findings are the following: 1) Low density commu-
nities should seriously evaluate alternative wastewater management technologies
including on site treatment rather than assumethat regional collection and
treatment systems are always more effective. 2) Better financial planning is
advisable to determine realistic construction and operation expenses earlier
in the planning process. I do not disagree with these findings. However, the
major efforts of the EIS are in no way unique to barrier islands but are in
fact common to every inland community with low density areas of developement
where a wastewater treatment system is considered. It remains unclear to me
why so mueh effort and project delay has been directed at barrier island
communities when the primary EIS.concerns are equally appropriate in all .
communities nationwide. _ .
There are unique problems for wastewater treatment methods on barrier
islands as well as mainland barrier beaches. In my opinion, the effect of
coastal storm hazards and long term coastal erosion on wastewater treatment
has never been adaquately addressed. Unfortunately, the EIS offers no assis-
tance for communities, designers, or EPA to evaluate the effect of storm hazards
and long term erosion on proposed wastewater systems. The natural hazards for
development on barrier islands are not explained in sufficient detail. The
III-4
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Mr. W. Bowman Crum
Page 3
August 8, 1983
susceptability for damage to components of the various wastewater treatments
are not evaluated adaquately. Shorelines with different topographies and
different locations relative to the shoreline will experience differina
coastal hazards. The draft EIS does not significant address thelssues
that are of most importance to barrier island communities.
Sincerely,
Spencer M. Rogers, Jr
Coastal Engineer
Enclosures
AUG10 1983

GA;
in-5
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Barrier dynamics and landward
migration with Holocene sea-level rise
Stephen P. Leatherman
Department of Geography, University of Maryland, College Park,
Maryland 20742, USA
Barrier beaches (islands and spits) have become the subject of
mounting interest1-3 due to human development on these land-
forms. It is commonly thought that barrier beaches continuously
migrate landward in response to sea-level rise, often by over-
wash processes, maintain mass through time, and that these
processes are occurring at a rate commensurate with human
(100 yr) time frames. While some barriers are naturally migrat-
ing quite rapidly1'4, other barriers decidedly are not. Here I
present data which illustrate that many US Atlantic Coast
barriers are not evolving over the short term in accordance
with generally accepted hypotheses and argue that the pre-
sumed norm may actually be the exception.
Geomorphical and historical evidence shows that most bar-
riers are presently experiencing seaside erosion. In fact, shore
erosion is a prevailing worldwide phenomenon along sandy
coasts, except where ample sand supplies are readily available5.
Initiation of the current transgressive phase is not precisely
known, but most scientists agree that it began within the past
200 yr (refs 6,7). The forcing function for landward shoreline
retreat is sea-level rise8,9.
Prevailing theory holds that barrier response to sea-level rise
is landward and upward migration through time10 " (Fig. 1).
Without sand movement from the ocean beach to the bayshore,
the barrier feature would be forced to drown in place . Pro-
ponents of the overwash hypothesis13 argue that overwash is
the principal process of landward migration, maintaining barrier
integrity and relative elevation with respect to a rising sea.
More recently, the predominant role of inlets in landward
sediment transfers has been recognized14,15.
There is geomorphic logic for this theory of barrier dynamics,
but the precise mechanisms and rates for barrier rollover have
not been properly assessed. Much speculation exists on this
point at present; for instance, some scientists16 envision that
barrier translocation can occur extremely rapidly (within 50-
100 yr). Implicit in their basic argument is that barriers move
as a virtual unit with conservation of mass.
Quantitative studies (ref.. 17; and work in preparation) have
shown that many barrios are* actually .eroding on both sides
and experiencing bays{dte. submergence, fire 4sl$Qd (Fig. 2), a
barrier island along the south shore of Long Jslaiyl, New York,
has been studied in detail(refs 18,19 and Work in preparation).
Geomorphic information from >100 shallow vibracores indi-
cate that the western half of the island has been relatively stable
in its centroid position during at least the past millenia. Radio-
carbon dates on in situ salt marsh peat deposits yield ages
greater than 1,000 yr at relatively shallow depths (1.5-2.5 m
below ground surface) near or at the barrier bayshore. As the
depth of the enclosed bay (Great South Bay) ranges from 1.2
to 3.0 m, it appears that essentially no landward migration has
taken place in this section of Fire Island during this time
period .
Stratigraphical correlation of dated peat layers at depth along
bay to ocean transects also show that the salt marsh was dis-
placed seaward during the past 500 yr. If the barrier were
experiencing little or no landward migration, then sea-level rise
would cause submergence of the backbarrier flats, which would
be reflected in the stratigraphical record as seaward encroach-
ment of salt marshes towards the barrier nucleus. Other
geomorphic evidence, including truncated inlet ridges and tree
stumps in situ on the barrier bayside, provide conclusive
evidence of bayside erosion and barrier submergence.
Landward barrier migration is a time-averaged phenomenon
due to sporadic and sitc-speciflc storm-generated events over
the long term. Radiocarbon dating of peat deposits encountered
at depth show a discontinuous record of deposition. For in-
stance, at one site along Fire Island (Fig. 2, point A) only 0.8 m
of sediment were deposited between 1,350 and 350 yr BP, while
1.1 m of sediment accumulated during the past 350 yr. Other
cores containing datable material illustrate similar chronologies
and sequences. This barrier island is clearly not continuously
migrating landward during human (<100 yr) time frames in
response to sea-level rise.
The historical record confirms and provides detail on this
geomorphic trend. Quantitative shoreline mapping shows that
between the 1830s and 1979 bayside erosion equalled ocean-
side erosion along some sections of Fire Island (Fig. 2). There-
fore, the barrier is eroding from both sides, narrowing through
time, rather than migrating landward. Previous studies at
Assateague Island, Maryland15 showed that barriers must nar-
row to some critical width before initiation of migration. In the
case of Assateague, emplacement of updrift jetties has sand-
starved the northern end of this island, resulting in extremely
high erosion rates exceeding 10 m yr"1. This artificially-manipu-
lated island continued to erode in place until the critical barrier
width (200-250 m in this locality) was reached. At this point
overwash is effective in transporting enough material over the
island to compensate for shoreline losses so that a low, narrow
barrier is being maintained with landward translocation. While
ephemeral inlets and overwash to a lesser degree are effective
in barrier rollover in these special conditions, the island section
so affected has apparently not maintained mass as it has been
drastically reduced in subaerial size with migration
Quantitative studies along the Outer Banks of North Carolina
(ref. 17 and C. Everts, work in preparation) confirm the Fire
Island results and indicate the general applicability of these
findings to a wide geographical area. During a 94-yr period
(1852-1946), there was no substantial sand deposition along
the bayside by overwash processes, and the barrier experienced
both ocean and bayside erosion along much of its length. There
was also a general decrease in total subaerial landmass such
that the island is continuing to narrow through time and is
apparently not maintaining volume. Due to the relative rise in
sea level, Hatteras Island, North Carolina, is being submerged,
producing favourable conditions for salt marsh growth towards
the barrier nucleus; significant new salt marshes have developed
Fig- 1 Within a geological time
frame, barriers must migrate land-
ward or be drowned in-place with
aea-level rise. Large-scale barrier
migration is associated with small
increases in sea level due to the
low, gradual slope of the coastal
plain. This article defines the short-
term dynamics of this long-term,
time averaged phenomenon. H,
rise in sea level; D, horizontal
migration of barrier island where
D is 100-1,000 times H; T,, past
sea level; T2, present sea level.
J">P« ¦» COO.,,,,
Pot* iocollen
of bofrw
fckond
nlln.n,.,
o< mo'ftiond
Pott locofion of
bOrri«i tfiOnd Ot
post M0 lovfl
Pftitnl
Prtttrrt locohon
of mlfrotkng
borrlor itiond
ot molniond
III-6
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^ ^	

¦"MsSf
m>-isij
shore Uoe
fig. 2 A new, automated tech-
nique of mapping was utilized to
generate this computer-plotted
representation of the ocean and
bay shorelines for the Sunken For-
est area of Fire Island, New York
(located at Point B on insert). The
barrier centroid has remained
essentially static during the past
150 yr as both shorelines exhibit
an erosional trend.
^'lanti'c
Ocean
on the backbarrier flats by seaward expansion. By comparison,	dominated by aperiodic inlet breaching15 occurring in a discon-
overwash processes have been largely insignificant in providing	tinuous step-like fashion. The evidence presented here has been
new sandy substrate for salt marsh colonization. Note that this	derived from the well-studied US Atlantic Coast barriers, but
microtidal barrier system has been cited as a classic washover	these findings may have worldwide application in similar
barrier1316, wherein overwash was'believed to be chiefly respon-	environmental settings.
sible for landward migration and salt marsh development during It is not certain whether the present rise in sea level21 is a
short time frames (<100 yr)30. In practice, coastal investigators	momentary upward blip on an essentially flat curve or the
have often relied on qualitative data and observations of local	initiation of a major, long-term transgression. What is becoming
events to formulate general models of barrier migration without	increasingly evident is that many islands are eroding on both
recognition and full appreciation of transport mechanisms and	sides, not actually migrating as popularly believed. These bar-
time frames.	rier beaches will probably continue to 'slim down' for at least
It is clear that barriers, such as Fire Island, New York and	some time in the future; even if sea level stabilizes, the time
Hatteras Island, North Carolina have been essentially static for	lag in response variables will entail erosion and submergence
quite a long period of time (up to 1,000 yr), and migration is	for a period lasting from at least decades to a century.
Received 1 September; accepted 23 November 1962.
1.	Leatberman. S. Barrier Islands (Academic, New York. 1979).
2.	Leatherman, S. Ovtrwash Processes (Hutchinson Rom, Pennsylvania, 1981).
3.	Leatherman, S. & Zaremba, R. U.S. Army Corps af Engineers Tech. Pap. (in the press)
4.	Pcnland, S. & Boyd, R. Oceans I981, 209-219 (1981).
5.	Bird, E. Proc 23rd 1m. Geofr. (1976).
6.	Bakker, J. Deulsch. Geogr Verh. 31,233-237 (1957).
7.	Tanner, W. Geotimes 27,16-17 (1982).
8.	Hicks. S. J. gfophys. Res. 83, 1377-1379 (1978).
9.	Emery, K. Proc nam. Acai. Sci. V.S.A. 77,696# (1980).
10.	Kraft, J. Bull, geol Soc. Am. 82,2131-21J8 (1971).
11.	Leatherman. S. Barrier Island Handbook (National Park Service, Boston 1979).
12.	Rampino, M. & Sandere. J. Snflmmiotogy 28,37-47 (1981).
13.	Do)an, R„ Godfrey, P. A. Odum, W. Am. Scient. 61,152-162 (1973).
14.	Armon. J. in Barrier Islands .
20.	Godfrey. P. U.S. National Park Service Rep (1970).
21.	Rampino. M. Nature 280,132-134 (1979).
111-7
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VK m i
produce any significant upgrading
marine advisory »ervice_,R9 -:^L"""he^allcy 1 'ay Rh<"ie I,land
qewsletteiT
a university of rhode island sea grant project
January/February 1982 No. 89
in this issue
MSDs NO HELP ON WATER QUALITY
NMFS-MAS JOIN IN FISHERIES GEAR RESEARCH
SCIENTISTS UNRAVELING MYSTERY OF ASIAN
IMMIGRANT
1982 RI MARINE SPORT FISHING PROGRAM
UNCERTAINTY INCLUDED IN FISHERIES ANALYSIS
EXTENSION OF SHELF LIFE OF FRESH FISH FOCUS
OF PRO-JECT
SEA GRANT FELLOWS HELP OUT CONGRESS
SEAL CENSUS UNDERWAY AGAIN
WIRE, ROPE SPLICING WORKSHOP OFFERED
URI MARINE LOG
IN PRINT
TDcnl study conducted in tlie summer
of 19R0 Burveyed boat owners in Rhode
lsl.'ind to examine the effect of MSD
operation on environmental quality and
the. coHt of compliance by boat and marina
operators. "Our results suggest that
the amounts of effluent generated by
boats would not be likely to affect
water quality of Narragansett Bay and
that installation and operation costs
of MSDs are not being reflected in an
increased improvement in water quality,"
stated Dr. Niels West, University of
Rhode Island, associate professor of
geography and marine affairs.
Dr. West was assisted in the study by
Charles Heatwole, of the Hunter College
Department of Geology and Geography,
and Lindsey Smith, a student in the
URI Department of Geography and Marine
Affairs. Their results will appear this
spring in the Coastal Zone Management
Journal.
MSDs were required on boats after Janu-
ary 30, 1980, when legislation made it
illegal to pass untreated human wastes
from boats into the water. Types 1 and
2 MSDs treat sewage chemically before it
is released into the water. Type III
MSDs, much less expensive to purchase
initially and favored by the boaters
surveyed, are holding tanks which are
pumped out to land-based receiving tanks
and treated in sewage systems.
MSDs NO HELP ON WATER QUALITY
Regulations requiring boats to install!
marine sanitation devices (MSDs) to
treat sewage appears to have been a
costly requirement which is not likely
Since no environmental impact of this
legislation was conducted prior to pas-
sage of the law, Dr. West decided to
examine the benefits of the law to Narra-
gansett Bay and its boaters. The criteri-
on chosen to measure the effectiveness of
MSDs was the amount of BOD (biological
oxygen demand) required to break down
the effluent discharged. In a worst-
case approach, Dr. West used the estimate
of sewage produced per person ashore,
much higher than would be generated by
boaters, in his calculations. He then
determined that the maximum potential
II-I-8
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daily discharge to the Bay would total
3,018 pounds of BOD, or the amount pro-
duced by about 686 persons.
"For an estuary which is as heavily used
as Narragansett Bay, this amount of organic
waste would appear insignificant, particu-
larly in view of the fact that this water
body is characterized by heavy tidal action
having a flushing cycle of between 20 and
60 days," Dr. West stated.
The researcher also makes the point that
the Type III MSDs may actually be aggra-
vating a problem, not solving it. He
explains that, prior to the law, boat
sewage was dispersed and degraded very
quickly. "The MSD regulation forces con-
centration of the effluent, which may or
may not be adequately treated depending
upon the quality of the treatment plant
receiving the effluent," he states.
A final point Dr. West and his assistants
make is that the costs imposed on boat
owners have not appeared to produce any
environmental improvements. Pump-out faci-
lities for handling the effluent from Type
III MSDs run about $10,000 and are a siza-
ble investment for a marina owner; there-
fore, there are few facilities in existence.
Full compliance by the estimated 5,111
boaters in Narragansett Bay during 1980
would require an investment of more than
half a million dollars. Another $115,000
would be added per year for operation of
the devices.
Aside from impacts on water quality and
the pocketbook, Dr. West points out that
the controversy over the MSD regulations,
and the belief that these regulations
would be rescinded, has produced wide-
spread disregard of the law. Rhode Island
"may furnish an example of what happens
when a piece of legislation is written
without assessing the socio environmental
impacts," he says.
The researchers do offer a solution to tlie
problem. This is to restrict of fluent
discharges only in ecologically sensitive
areas and to concentrate on the enforce-
ment of this regulation. The result
would be protection of the areas that
need it and a reduction of the regula-
tory burden imposed on the U.S. Coast
Guard, which has to implement this law,
they point out.
NMFS-MAS JOIN IN FISHERIES GEAR
RESEARCH
A demonstration showing that two fishing
vessels of dissimilar sizes can jointly
pull a trawl in the fuel-efficient pair
trawling method got underway in February.
The demonstration involves the National
Marine Fisheries Service fisheries engineer-
ing group, which recently moved to the
URI Narragansett Bay Campus, and the URI
Sea Grant Marine Advisory Service. The
vessels being used in the project are the
NMFS steel stern trawler, the 65-foot
Gloria Michelle, which is berthed at
tJavisville, and the 47-foot Gail Ann,
operated by the URI Department of Fisher-
ies and Marine Technology.
Crucial to the pair trawling demonstration
is an instrument called a warp tension
meter. This allows a skipper to monitor
the amount of pull on his vessel's trawl
lines and thus ensure that he and his part-
ner are pulling the net straight through
the water.
After the tests aboard the two vessels
are completed this spring, the meters
will be available on loan to owners of
commercial fishing vessels who might
want to try pair trawling.
The pair trawling project is one of the
first joint projects that the NMFS group
and MAS have undertaken. A larger coopera-
tive program in gear research and develop-
ment is being planned for the two units.
Tl|s includes testing of a model of the
NqFS bottom survey trawl in the tow tank
futility operated by the- URI Department
of Ocean Engineering: evaluation of a
large mesh bottom trawl; vessel stability
and safety tests; on-board fish handling
II1-9
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Advisory
Council On
Historic
Preservation
1S22 K Street NW
Washington. DC 20008
KJ6 111983
Mr. E. T. Heinen
Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street NE.
Atlanta, GA 30365
Dear Mr. Heinen:
We have received and reviewed the draft environmental Impact statement
for North Carolina Barrier Island Wastewater Management. It appears
that the proposed strategy emphasizing development of on-site and small
community wastewater management systems would probably result in the
fewest overall impacts to historic and archeological properties and
provide considerable flexibility in future development. We understand
that further site-specific data on wastewater management system effects
on historic and archeological properties will not be available until
sometime during future community-specific planning or in Step 2 Design
grants. Since this development would be permitted through the North
Carolina Coastal Management Program we have tio further comments at this
time. EPA and the local communities should /continue to cooperate and
consult with the North Carolina Coastal Management Program, and the
North Carolina State Historic Preservation Offfiqer on the need for field
or other investigations to identify and evaluate specifically-affected
historic and archeological properties, as well as to assess any system
construction effects on them. As EPA considers any construction grants
for Steps 2 or 3 that could affect properties listed in or eligible for
the National Register, EPA should request the specific comments of the
Council at that time in accordance with Section 106 of the National
Historic Preservation Act and 36 CFR Part 800.
Thank you for providing the opportunity to comment. If you have
questions or wish future assistance, please contact Ronald D. Anzalone
at 202-254-3974 (an FTS number).
m L. Klima
def, Eastern Division
of Project Review
111-10
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North Carolina State University
School of Agriculture and Life Sciences
Academic Affairs, Extension & Research
Department of Soil Science
Post Office Box 5907
Raleigh, NC 27650
(919) 737-^55
August 23, 1983
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Heinen:
Attached are written comments for the review of the draft environmental
impact statement EPA 904/9-83-108a, entitled "North Carolina barrier
island wastewater management".
Sincerely yours
Craig Cogger
Associate Researcher
CC/dlp
Enclosure


\""1. i	Si ,,<¦ University m lhh>i»h is a criffivQgimtltuliou „{ the University of Xorth ( \,rolin„.
-------
ENVIRONMENTAL IMPACT STATEMENT
North Carolina Barrier Island Wastewater Management
Written Comments
Craig Cogger, Ph.D.
Research Associate, On-Site Waste Management
Soil Science Department
North Carolina State University
Raleigh, NC
August 23, 1983
General Comments
Overall, this environmental Impact statement (EIS) 1s thorough. Informative,
and well done. The recommended EIS strategy using on-site systems with small
community systems 1n sensitive or higher-density areas appears to be the best
overall for most of our barrier Islands.
Several of the assumptions and conclusions should be reexamined, however,
to make this EIS a better assesment of the monetary, health, and environmental
costs of waste treatment on the barrier islands.
Specific Comments
Several specific commerfts are described below. Most pertain to
material which appears a number of times in the document, so specific page
references are not given.
1.	Separation to Water Table
NC rules require a minimum one-foot vertical separation between the bottom
of the absorption area and the seasonally high water table (SHWT). As little
as one foot from the surface to the SHWT can be used with a mound system.
Data we have collected from.experiments on West Onslow Beach suggest that a
one-foot separation 1s not adequate for effluent treatment under barrier
island conditions (See Table 1 1n Appendix).
I suggest that the EIS recommend a more conservative two-foot separation. 7
The EIS already points out that much developable land meets this requirement,
and that alternative systems are available which can be used to increase the
separation to the SHWT. A two-foot separation requirement should not have
a large effect on development.
2.	Cost
a. System installation. For low-pressure pipe (LPP) and mound systems,
absorption areas are more expensive and pumping systems less expensive than
listed 1n the EIS. Also, 1n areas where these systems are not Widely used o
costs will be much higher, because of a lack of competition and expertise	i
among installers.
I
II1-12
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2
i
The EIS cost figures appear to assume free designs done by the health o
departments. There is no guarantee that this will be the case, so design ®
costs by consultants may also need to be included.
b.	Maintenance. The EIS allows only $20/year for pumps and controls.
For the $700 pump system they envision, this assumes a replacement, interval
of 35 years (disreagarding interest and inflation). Even for a $300
system, the replacment period would be 15 years, which is probably too long.
c.	Management. In areas where there are substantial numbers of LPP
and mound systems, management to assure proper maintenance and monitoring will 10
be necessairy for long-term proper operation of the systems. Yet, I do not i
see where costs for this management are listed.
d.	Other costs. In addition to management, the EIS lists other
priorities such as gound water monitoring. But, where are the costs for	H
these? _J
e.	Mater supply. The EIS assumes that ground water may be polluted 1n ~l
some areas as density of development increases. Should the cost of hook-ups
to deep well or off-island systems for shallow well users in pollution-prone i
areas be included in the overall EIS costs?	I
3. Density of Development
a.	Effect of on-site systems on density. The EIS states that lower den-
sity development will occur with on-site systems compared to regional systems.
It is true that on-site systems will not allow densities such as those at
Myrtle Beach, but very high densities are still allowed by current state rules.
Market forces still play an important role in obtaining high density develop-
ment.
I believe that the current defacto density requirements may allow serious
pollution of the shallow aquifer, and that more conservative density require-
ments should be recommended. One approach would be to designate areas for
high or low density development. In this way the degradation of the shallow
aquifer would only be limited to high-density areas.
b.	Ground water quality. The EIS questions the concern about the pollu-
tion of the shallow ground water aquifer. But, there is still some use of the
shallow aquifer for drinking water and the cost of losing this aquifer should
be considered in the economic analysis.
;3
Also, the NC Division of Environmental Management has proposed rules
which would set standards for ground water quality. If they are accepted in
a I°r?Jsi'rn^arLto Pr0P°sed °ne, and if an enforcement mechanism is
established, these proposed rules will reduce the allowable density of devel-
opment with on-site systems.	.
. EIS vs. 20] plan. The EIS states that the effluent loading rate for
anJ off-site spray irrigation (SI) system would be higher than for on-site 16
subsurface systems. For soils typical of barrier islands, this is incorrect. [
I11-13
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There 1s currently no requirement to consider the loading rate of nitrogen
or any other constituent except water when designing subsurface systems.
All constituents must be considered when designing a SI system, however,
For domestic-type effluent on a sandy soil, a large subsurface system (such
as that for a condominium complex) can be loaded at several times the
rate used for a SI system, because of this difference in design criteria.
4.	Pollution Potential of On-site Systems
The EIS states that few cases of pollution by on-site systems on the
barrier islands have been documented. It notes problems with a "few isolated
finger canal areas". But, the report does not state how many finger canal
areas were given a clean bill of health, or how extensively the movement
of effluent into the shallow aquifer and surface waters has been studied.
It is likely that the few isolated cases are due to few isolated studies,
and the potential problems are more wide spread.
As mentioned earlier, we have seen rapid movement of pollutants into
the ground water when the separation to the water table is inadequate, and
rapid movement of nitrate when the water table separation is adequate
(Appendix Table 1). We have also sampled one developed and one undeveloped
finger canal area at Atlantic Beach, and found substantial differences in
time-averaged ammonium and fecal coliform levels in the ground water between
the two.
There just hasn't been enough data collected to conclude that potential
pollution problems are few and Isolated.
5.	Conclusions
As stated in the general comments, this EIS 1s basically well done.
Although I agree with Its general conclusions, I feel that 1t falls short 1n
assessing the costs of the maintenance and management of the on-site strategy
and 1n evaluating the pollution potential of on-site systems. If management
and maintenance are not carried out, pollution of the shallow ground water
and surface waters will become an ever-Increasing problem, as development of
these areas continues.
II1-14
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APPENDIX
Table 1. Movement of pollutants into the ground water beneath experimental
septic absorption trenches in a Corolla soil. May, 1982 - May, 1983
Loading Fecal	Bovine
Rate	NHjj-N	N05-N	P	Col i forms Enterovirus

_ . _ . . mg/L - - 	
MPN/100 ml
PFU/L

2-foot separation
Conservative
<0.5 1.9 0.1
<2
<1
Normal
0.6 4.2 0.1
7
<1
Overloaded
0.8 14.6 1.9
25
<1

1-foot separation


Conservative
6.1 0.9 1.5
700
2,000
Normal
9.2 1.0 2.8
3,000
3,000
Overloaded
14.0 2.0 3.9
10,000
4,000

Septic-tank effluent



29 <0.5 5.6
300,000
50,000
IJI-1S
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NOTCIH
OIROUNK
DETRIMENT
OF
CUJURAL
RESOURCES
Raleigh.
North Carolina
¦27611
(Division of
/vchives and Histoiy
William S. Price. Jr. Director
Sara W. Hodgkins.
Secretary
James B. Hunt. Jr..
Governor
August 25, 1983
Mr. E. T. Helnen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: North Carolina Barrier Island Wastewater
Management, DEIS, Multi-county, Coastal,
CH 84-E-0000-5040
Dear Mr. Helnen:
We have received notification from the State Clearinghouse concerning
the above Draft Environmental Impact Statement.
We are unable to comment on the potential effect of this project on
cultural (archaeological, architectural, ^nd historic) resources until
we receive further information. Within the DEIS reference 1s made to an
Atlas which Identifies the locations of ". . . known sites of historical
and archaeological Importance ..." (pages II1-27, 2-120, 3-132).
Please forward a copy of the Atlas so we may complete our review.
The above comments are made pursuant to Section 106 of the National
Historic Preservation Act of 1966, the Advisory Council on Historic
Preservation's Regulations for Compliance with Section 106, codified at
36 CFR Part 800, and to Executive Order 11593, "Protection and Enhance-
ment of the Cultural Environment."
Thank you for your cooperation and consideration. If you have questions
concerning the above comments, please contact Ms. Renee Gledhlll-Earley,
Environmental Review Coordinator, at 919/733-4763.
Sincerely,
I
»hn J. Little, Deputy State
listoric Preservation Officer
JJL:s1w
cc: Clearinghouse
tt a**.,*,
^	' ¦¦ «_*• ¦ . i	» wad I | I
& AL ^ 9 1983 ||||
Li L .
IV '
AiLAi'ilA, GAi -
I11-16
-------
NORTH CAROLINA
SALTWATER FISHING FEDERATION
August 25, 1983
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Heinen:
In reviewing the summary of the Draft Environmental Impact State
ment, North Carolina Barrier Islands Wastewater Management sianed
by Charles R. Jeeter, Regional Administrator on May 24, 1983- the
North Carolina Salt Water Fishing Federation supports the EIS for
the following reasons.
The NCSWFF is dedicated to the management and enhancement of the
recreational salt water fishery along the North Carolina coast
it's sounds and estuaries. The 201 plan which proposes large '
scale, regional wastewater treatment systems, not only beinq
costly as pointed out in the EIS, would promote high density
development on the barrier islands. The increased number of
dwellings, condominiums, and businesses would increase surface
runoff and untreated effluent from parking lots, roads and
new construction sites.	'
rw?Har irlJhe EIS'and supported by surface run-
off studies in Florida, this runoff could have more unsatisfactory
Influence on the water quality of the estuaries and on-shore
waters than the treated wastewater. The NCSWFF is in favor of
the small package treatment plant concept, where practical, or
retaining individual treatment systems, i.e. septic tanks, where
that is the more logical approach.
I would hope the final EIS will place additional emphasis on the
practicality of package treatment plant concept economically, as
well as being the best alternative for assuring Improved water
quality. The success or failure of reproduction of many recrea-
tional and conmerclal fin fish and shell fish depends upon suit-
ale water quality 1n the estuaries and near-coastal waters.
Sincerely,	tiMMl
18
lSJ	1
M AUG 2 9 1983 !
Robert G. Stryker
President
1106 MANCHESTER DRIVE, CARY, N.C. 27511
IT T«, 17
-------

DEPARTMENT OF HEALTH & HUMAN SERVICES	Public Hsalth Service
Cantsn for DiitaM Control
Atlanta GA 30333
(404) 452-4257
August 26, 1963
E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtlend Street, N.E.
Atlente, Georgie 30365
Deer Mr. Heinen:
We heve reviewed the Dreft Environmental Impact Statement (EZS) for North
Ceroline Barrier Ieland Wastewater Management. We ere responding on behalf
of the Public Health Service.
We heve reviewed thie document for poeeible health effects and find that
potential problem! are identified. However, we believe that mitigetion of
theee problems ie not edequately aaaured. Mitigetion meeeuree ere stated as
being "the reaponaibility of the local planning agency." It appears that the
communities would have the option of passing and/or revising codes, ordinances
and other regulatory meeeuree only if they so desired. As steted on pege IV-5*
"The NFA and BIS Strategies would leed to lower density developments and less '
concentreted urban runoff would be anticipated, if the citisena of the area
desire a management agency, this agency could serve to promote these best
management prsetices."
While the responsibility for edoption of thes* measures may be that of an
existing local agency or the responsibility of;some additional (^ency that
should be established, the mitigation measures identified to prevent potential
problems that would result from this action must be ensured. Implementation
of theee mitigation measures should be made a condition for staking the EPA
grant monies eveileble for these projects.
Thank you for the opportunity to review this Draft EI8. Pleaee send ue a copy
of the finel document when it becomes available. If you have any questions
about our comments, please contact Mr. Lee Tate at 452-4161.
Sincerely yours,
Frank S. Lieella, Ph.D.
Chief, Environmental Affairs Group
Environmentel Health Services Division
Center for Environmental Health
111-18
wr,-	mutt
llUU'. .. .	,,, ? |
if* mzam '
/1 , .y	'"IT? v' ¦ ;
Ui.' ...
-------
TOWN OF KILL DEVIL HILLS
P.O. BOX 719
KILL DEVIL HILLS. N.C. 27948
(919) 441-7236
August 29, 1983
KN P. HILL, M
Ma;or
UJRAMA J. COWAN
OAWDMNAKtlt
JAMH r. MURPHY
LAURA PAXWA
MCHAHDMW
lloyd iauanci
Manager
I
CLMRB It. MfATVVmO
Financa Otl»c#f/Ct§fk
I
•HARONL. COMOLVO
Tax Collector
I
JOHN a SAW, JR
Altornay
RAYMOND J. STOMA. ¦
Planner
Supanntmdant ol Walar Services
I
IMUIMOUN
Suparintandant ol Public Worn,
W.C.(MU.Y)<1RAY
Building Irwpactor
W.LOARO
Fir* Chief
C. I. MAY, M
Owl ol Pohc#
MEMORANDUM:
TO: Mr. B.T. Heinen, Chief
Environmental Assessment Branch
U.S. Environmental Protection Agency
345 Courtland St.* N.E.
Atlanta* Georgia 30365
FROM: Ray Sturza
Town Planner
Town of Kill Devil Hills
P.O. Box 719
Kill Devil Hills, NC 27948
RE: Comments on N.C. Barrier Islands Wastewater Management
Draft Envrlonmental Impact Statement
Please find enclosed «y comments on the above referenced
document, as presented pursuant to 0MB Circular A-95 at the
August 18, 1983 meeting of the Albemarle Commission, LRO
for Northeastern North Carolina. Thank you for the opportunity
to comment.
cc: Lloyd Ballance, Town Manager
Enclosure
flWIWMMTJll tiSESStPT BUND
MOST

n
AUGS11983
111-19
BiWli ¦ 11
ieisedtc
EFA-REOIO'.i T.V
ATLANTA, GA.
A.
-------
UN f. HILL, M
Mayor
I
COMMISSIONERS
LUSAKA J. COWAN
OAVIO MENAKEft
J AMU ft MURPHY
LAURA PAXHIA
RICHARD BUR
I
LLOYO BALLANCK
Town Manager
I
CLAIRE M. WATERFELD
Finance OHicer/Qerk
r
SHARON U CONSOLVO
Tat Collector
I
JOHN a QAW, J&
Town Attorney
I
RAYMOND P. STURZA, I
Town Planner
I
DARRELL MERRELL
sjoenrtenaeni oi Waiar s«rvicti
I
MIKE LUHOU8E
Suoerreenoant ol Public Worts
I
W. C. (BILLY) GRAY
Building msoector
TOWN OF KILL DEVIL HILLS
P.O. BOX 719
KILL DEVIL HILLS, N.C. 27948
(919)441-7236
August 10, 1983
MEMORANDUM
TO: Ruth Leggett, Albemarle commission
FROM: Ray Sturza, Kill Devil Hills Town Planner
RE: EPA N.C. Barrier Island Wastewater Management EIS
In reference to the clearinghouse review of the EPA's draft EIS
concerning the N.C. Barrier Islands, I offer the following comments:
1.) The EIS reaches conclusions that conflict with the Kill
Devil Hills Land Use Plan (pg.9), which favors the imm-
ediate construction of a regional wastewater treatment
facility. This policy was adopted because:
a.) Many of the lots already platted in Kill Devil Hills
are too small for ground absorbtion systems.
b.)	Many of the soils in Kill Devil Hills are unsuitable
for ground absorbtion systems.
c.)	At the time the policy was adopted, there was a concern
that septic tank infiltration was having deleterious
affect on estuarine waters.
While the draft EIS addresses item (c) above, it seems to neglect
the considerations associated with (a) and (b) above.
*
2.) The Kill Devil Hills Land Use Plan does, however, indicate
that the Town will investigate the feasibility of package
plants. The EIS fails to take into consideration the
following when examining the package plant alternative:
a.) Package plant standards for construction and manage-
ment are insufficient to insure quality construction
and operation of the plant and its lines.
b.)	Staff is currently unavailable for sufficient moni-
toring of maintainence on equipment and effluent dis-
charge .
c.)	Parties dependent on a package plant that fails, is
over capacity, or is unable to meet health and safety
regulations are in effect "locked in" on the dysfunc-
tional plant and such plants are rarely shut down due
Birthplace of Aviation
111-20
-------
MEMORANDUM
Page 2 -
to the degree of hardship such action would create. As such,
plants in violation often continue in violation, many times
for years, until a solution is reached.
3.) If information has been generated that documents effectively
and with reliable data that non-point surface runoff is the
primary source of the continued degredation of the estuarine
waters of Coastal North Carolina, I recommend that information
be forwarded to the N.C. Department of Natural Resources and
Community Development, Division of Environmental Management
and that a moratorium be placed on any further authorization
of new drainage projects pending the development of satisfac-
tory management plans to mitigate the adverse inpact of massive
drainage on the estuarine waters of Coastal North Carolina.
cc: Lloyd Ballance, Town Manager
RS/bb
[11-21
-------
THE RALEIGH SALT WATER SPORTFISHING CLUB
4818 North Hills Drive
Raleigh, N.C. 27612
(919) 787-2836
August 29, 1983
E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E,
Atlanta, Georgia 30365
Dear Mr. Heinen:
This is in response to public notice requesting comments concerning
the draft Environmental Impact Statement for future wastewater
treatment on the North Carolina barrier islands. We support the
EIS Strategy that recommends barrier island communities consider
on-site and community wastewater treatment systems in lieu of the
regional systems recommended by draft 201 Facilities Plans.
We feel regional plants with ocean outfalls or land application
discharge of treated wastewater will promote higher density
development on the barrier islands, leading to a decline in
both ocean and estuarine water quality, due to an increase in
wastewater loading and surface runoff. A decline in water quality
would certainly have a damaging affect on the future of sport-
fishing on the North Carolina barrier islands.
Sincerely,
Raleigh Salt Water Sportfishing Club
Robert N. Vinay
Barrier Island Wastewater Committee Chairman
RNV:lj
I11-22
a?.r:W WW*
£ 1' - £
;.v* SEPiU 1363 Ijh

jy
A TLA K"'ft >
-------
TOWN OF OCEAN ISLE BEACH
ROUTE 2, BOX 0-8
OCEAN ISLE BEACH, N. C. 28459
August 29, 1983

>>a-segioh iv
ATLANTA, 6A;
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
U. S. Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Ga 30365
Dear Mr. Heinen:
Regretfully, we were unable to attend the public hearing
held recently in Brunswick County.
Having been Mayor of the Town of Ocean Isle Beach for over
ten years, and having faced the reality of the great need this
community has for a centralized municipal wastewater treatment
system, the futile delays which have been caused by the Environ-
mental Protection Agency's exercises in bureacracy have been most
unhealthy for our town.
Since 1973 the Town of Ocean Isle Beach has been attempting
to face the facts that septic tank systems are inadequate means of
waste disposal for the varied types of development a progressive
coastal town experiences. The people of Ocean Isle Beach feel they
have been and continue to be victims of unrealistic suppositions by
a network of job-making bureacrats.
We invite you to expend some of your extensive Environmental
Impact Statement planning budget to come live among us and witness
the reality with which we are trying to responsibly deal.
To our knowledge Congress has not legislated to instruct
the Environmental Protection Agency to cause development to stop
on barrier islands. We ask that you be honest about your intent-
ions and consider data based on the mandates Congress has officially
given your agency.
Enclosed is a copy of Comments on the North Carolina Barrier
Islands Wastewater Management Draft Environmental Impact Statement
by Paul S. Dennison of Henry von Oesen and Associates. We totally
agree with his excellent analysis of this pitiful situation.
Re: Comments on the North Carolina
Barrier Islands Wastewater
Management Draft Environmental
Impact Statement
26
II1-23
-------
Page 2
August 29, 1983
Mr. E. T. Heinen
We realize this letter is frank; we are most frustrated
and only want what is best for our people—we want to be treated
with fairness and honesty.
With best regards, I am
LWB/at
Enclosure
cc: Congressman Charlie Rose
Senator Jesse Helms
Senator John East
Sincerely
L^fDane W. Bullington
TOWN OF OCEAN ISLE BEACH
Mayor
II1-24
-------
HENRY VON OESEN AND ASSOCIATES
CONSULTING ENGINEERS
AND PLANNERS	Telephone (919) 763-0141
611 PRINCESS STREET P.O. DRAWER 2087 WILMINGTON, NORTH CAROLINA 28402
COMMENTS ON THE
NORTH CAROLINA BARRIER ISLANDS WASTEWATER MANAGEMENT
DRAFT ENVIRONMENTAL IMPACT STATEMENT
I am Paul S. Denison of Henry von Oesen and Associates,
Consulting Engineers & Planners of Wilmington, North Carolina.
We represent not only our own views based on many years of
engineering planning and design experience on the entire
southeastern seaboard, but also the interests of the numerous
communities we serve in the coastal area. Thus, we appreciate
this opportunity to comment on the North Carolina Barrier Islands
Wastewater Management Draft Environmental Impact Statement.
We feel that this EPA EIS exercise has imposed an unconscionable
three-year delay in resolving the wastewater treatment and disposal
problems on the North Carolina barrier islands. During this delay
period, the costs for all alternative solutions to the problem
have escalated considerably. The total amount of federal funds
allocated to the State of North Carolina for corrective actions
have been diminished by attritional use and budgetary cuts. The
state's Clean Water Bond Act grant fund which is used for matching
federal grants has been depleted. As a primary result of the
moritorium on actions imposed by the EIS, all barrier island
projects on the North Carolina Construction Grants Funding List
have slipped in priority so that funds for facilities design and
construction will not now be available until fiscal year 1986	28
or after. By that time, federal participation will be limited
by law to 55% of the eligible project costs, rather than the 75%
at present.
1
2\
J
In view of these developments it is impossible to accept
the fact that the "EIS Strategy" calls for further revisions to
the 20! Facility Plans which will result in further bureaucratic
delays in resolving the problems that exist. Several local units
of government, completely frustrated by these events, have wisely
elected to abandon the 201 Facilities Planning process entirely
and to pursue other viable solutions independent of the EPA
Construction Grants process. This may be an EPA objective, but	_
it wasn't Congress' intent when they passed Public Law 92-500.
In summary (and as an over simplification), the EIS recommends
the continued use of septic tanks and so-called "community systems"
as the least-cost solution to existing wastewater disposal problems. '
This position is inconsistent with recent scientific research	30
and even prior EPA studies which show that septic tanks do cause I
pollution of surface and ground waters (see references attached).
II1-25
-------
We feel that the inadequately supported and less than scientific
position taken by the authors of the EIS will only exacerbate ,
existing problems - not solve them.		|
Many of the Barrier Island 201 Facility Plans which preceded |
the EIS showed that central sewer systems could be designed and 31
constructed with federal and state grant assistance for user fees 1
in the range of $12 to $18 per household, in all proposals we
are familiar with, wastewater contaminants were effectively removed
from the barrier islands, their related groundwater systems, and
their adjacent fragile estuarine waters. We get the impression I
that EPA simply did not want to fund any of these solutions	I
recommended in the 201 Plans based on the fear that solving the 32
sewage disposal problems would "stimulate growth" on the barrier
islands. However, despite the delays and lack of aggressive
action to resolve wastewater disposal problems, significant
growth has occurred on all of the barrier islands. This in spite
of EPA's defacto withdrawal of federal funds over the past three
years.
Now the federal funding picture has altered to a state of
unfavorable economics, but the development and increasing pollution
potential goes on. More septic tanks and so-called community ...
systems are simply not the answer. We need to get on with the
business of truly resolving the problem - not re-studying it.
Enough time and money have been wasted already. We are confident
that time will continue to demonstrate that this EPA Barrier
Island SIS expenditure of time and money has been another futile
bureaucratic exefrcise that produces no solutions to a serious
and growing problem.
Thank you for this opportunity to present our views in this
matter.
Paul S. Denison, P. E
Vice President
WilliamJB. Burnett, Env. Planner
-------
3
REFERENCES
Carlile, B. L., Etal (October 1981) "Movement and Fate of Septic
Tank Effluent in Soils of the North Carolina Coastal Plain".
N. C. State University, Raleigh, N. C.
Carriere, G. D. and Canter, L. W. (October 1980) "Effects of
Septic Tank Systems on Ground Water Quality". Report No.
NCGWR 80-8, National Center for Ground Water Research,
Norman, Oklahoma.
Duda, A. M. and K. D. Croraartie (December 1982) "Coa»tal Pollution
from Septic Tank Drain£ield8N. Journal of Environmental
Engineering Division, Proceedings of ASCE. 108 (S£6) pp.
1265 to 1279.
NCDEM (April 1978) "The Influence of the Water Table Aquifer on
Shellfish Waters Near Surf City and Old Settler1* Beach,
Pender and Onslow Counties, N.C." Raleigh, N. C.
USEPA (1975) "Waste Source and Water Quality Studies, Surf City,
N. C. and Vicinity". Athens, Ga~
II1-27
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VWrnlmHuii Morning Star / Wednesday. August 24.1983
Afew Hanover/Brunswick
IB
Stock prices sink, 4B
EPA's approach to coastal development criticized
By Kim McGoire
Stair Wittar
A Brunswick County official and ,
a local engineer blasted the U S. I
Environmental Protection Agency I
Tuesday night, saying the agency is I
trying to halt development and en-
courage the proliferation of septic
tanks on the state'* barrier islands. ,
The two speakers made state-
ment! at a public hearing on the j
EPA's draft environmental impact
statement on the management of |
wastewater on North Carolina's
barrier i>l»nds.
The EPA document calls far far-
ther rei-Mon of 201 plana, which
have pr:posed construction of
wastewcrr collection, transporta-
tion and treatment facilities with
the helpfederal fund*. The EPA
recommended that future plan* for
«itr«wr treatment likumi sgn
septic tar.kj and smell-scale com-
munity ¦•¦.stems, rather than die
more cc«!iy regional projects pro-
posed or anally.
John Hirvey. assistant comity
manager tor
aatftbeEPA
false
Btunowtch County,
i* "lull of
growth oa die
"We are auailMiisiiF that more
uiusaduatiow has beea given to na-
ture than to aum," Harvey conclud-
ed.
Paul S. Deaison, sf the Wilming-
ton engineering firm Hony von Oe-
sen and Aaasriats*. charged that
the EPA has spent One year* de-
laying a
that
time, he said, costs have increased
dramatically and projects planned
far the barrier islanda have slimed
oil the p»imity list lor public
ing. The van Oesen '
201 plana far mum
ties *n the barrier
"Several local units of govern-
ment, completely frustrated by
these events, have wisely elected to
irttandtrn "¦* frrilfti-t planning
process entirely to pursue other via-
ble eolations." Deniaon said. "This
may be an EPA objective, but it
waaat Congress* intent...
"We get the impression that EPA
afanpiy did not want to^fand^any of
>01 plans based an the fear that
solving the sewage disposal prob-
lems would stimulate growth on the
barrier islands,' he said.
Denison asked die EPA officials
leading the bearing how much mon-
ey has been spent on developing the
environmental impact statement
over the past three years.
A response of $545,000 spurred
shaking heads in die crowd of about
a dsaen citizens. Bowman Cram,
EPA project amnager, said die ex-
pense is justified, howesei, because
it produced valuable information on
natural reaounea and ground wa-
ter.
The EPA offiriaU will hold hear-
ings at Bogua Banks tonight and at
Rnannkr Island Thursday. They ex-
pect a final drrwion on policies far
wastewater management on North
Carolina's barrier islands to be"
made before die end of 1963.
-------
DEPARTMENT OF THE ARMY
WILMINGTON DISTRICT. CORPS OF ENGINEERS
P. O. BOX 1890
WILMINGTON. NORTH CAROLINA 28402
IN REPLY REFER TO
August 31, 1983
Environmental Resources Branch
Mr. E. T. Heinen
Chief, Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Mr. Heinen:
We have reviewed the draft Environmental Impact Statement
for North Carolina Barrier Islands Waste Water Management and
find it to be well prepared. The report represents much needed
and timely guidance foy the planning of wastewater management
facilities in coastal areas. Our only comment of note is that the
individual strategies do not include flood plain management
impacts or considerations of EO 11988.
Thank you for the opportunity to review and comment. We will
follow the progress of this report with great interest.
Sincerely,
Wayne M Hanson
Colonel! Corps of Engineers
District: Engineer
Copies Furnished:
SADPD-R/Cooper
DAEN CWP-P/Hand
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NATIONAL WILDLIFE FEDERATION
1412 Sixteenth Street, N.W., Washington, D.C. 20036 202—797-6800
August 31, 1983
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Heinen;
The National Wildlife Federation (NWF) submits the
following comments on the draft Environmental Impact
Statement (EIS) concerning North Carolina's Barrier Island
Wastewater Management. The Federation supports the
No Federal Action (NFA) alternative.
The National Wildlife Federation is the nation's
largest conservation organization, with affiliates in
51 states and territories. Our four million members and
supporters are dedicated to the wise use and conservation of
our nation's natural resources, including barrier islands
and beaches. As an ardent supporter of the Coastal Barrier
Resources Act (CBRA), the Federation has a strong interest
in federal policies affecting coastal barrier management.
While on a theoretical basis the EIS strategy (the
preferred alternative) recommended by the Environmental
Protection Agency (EPA) is an improvement over adopting the
present, environmentally unsound, 201 plans for wastewater
management on North Carolina's barrier islands, the
practical result of implementing the EIS strategy will differ
little.
The EIS strategy calls for more and better planning
of wastewater management facilities by revising draft 201
plans, which currently recommend large centralized collection
facilities, using procedures and criteria developed by the
EIS. The desired result of these revisions is to encourage
a full consideration of alternative wastewater management
techniques. There is, however, no guarantee that alternatives
will be adopted, nor can there be any protection from the
natural tendency to overestimate the future need for
wastewater treatment capacity.
\\:\
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' V '
irX SEP0E1SG3
11 i-3o	\\\Yrr rK/iXtnTT
iiUi^ ,
48th ANNUAL MEETING MARCH 15-18,1984 Omni International Hotel.Q&IAnta, CconfM
700% reclaimed paper	k * ¦ '
-------
E. T. Heinen
-2-
August 31, 1983
In large part, this tendency is caused by the
availability of federal financial assistance. With the
knowledge that the federal government is willing to pay for
a large portion of the construction costs, small communi-
ties are encouraged to overbuild treatment capability to
cover future needs, whether anticipated or not.
The EIS procedures may dampen this tendency, but
there will still be pressure and a natural inclination to
inflate population assumptions and alter land-use
designations to favor the construction of larger, centralized
collection facilities. Once built, the excess capacity of
these facilities will promote greater, if not excessive,
development densities with resultant environmental harm.
Therefore, the National Wildlife Federation urges
EPA to adopt the No Federal Action alternative. The
elimination of federal financial assistance will encourage
community planners to appraise future wastewater treatment
needs more realistically and to adopt more reasonable
patterns and levels of growth.
The people living on North Carolina's barrier islands
should be internalizing the costs of living there. It is
more expensive to build and maintain facilities on shifting,
storm-prone barrier islands. Those people who benefit most
from the construction of wastewater management facilities
should shoulder the burden of paying for them—not the federal
taxpayer. This was a central concept recognized by Congress
and signed into law by the President with the enactment of
the Coastal Barrier Resources Act (CBRA).
Also, since the No Federal Action alternative will
likely lower development densities more than the EIS strategy,
the NFA alternative more effectively addresses the problem
of non-point pollution. Non-point pollution was identified
in the EIS as a principal water quality problem in North
Carolina, usually associated with higher density developments.
In the executive summary of the draft EIS (page vi),
EPA notes that the adoption of the No Federal Action alterna-
tive could result in some environmental degradation from
improper operation or maintenance of local treatment systems.
While it is possible, in the absence of federal involvement,
that some communities may neglect their responsibility for
adequately managing wastewater pollution, the Federation believes
that other mechanisms are available to deal with this problem
if it arises, without the necessity of federal financial
involvement.
III-31
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E. T. Heinen
-3-
August 31, 1983
The National Wildlife Federation appreciates this
opportunity to comment.
Sincerely,
c.*..
Bruce Leight^, Coordinator
Barrier Islands Project
II1-32
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United States
Department of
Agriculture
Soil
Conservation
Service
P.O. Box 27307
Raleigh, NC 27611
August 31, 1983
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Heinen:
We have reviewed the North Carolina Barrier Islands Wastewater Management
Draft Environmental Impact Statement (DEIS).
It appears that the EIS Strategy will offer waste management planning
definite cost-effective and environmentally sound alternatives. We are
pleased that soil survey information is included in the strategy as a tool
for evaluating and revising existing 201 plans. Although not site
specific, the soil survey information can be valuable in community and area
planning. Detailed soil investigation are necessary for all on site and
community site systems as well as for many of the treatment facilities.
We appreciate the opportunity to review this DEIS and offer our assistance,
consistent with conservation district work priorities to the local
region wastewater management units in the technical phases of their erosion
and sediment control.
Sincerely,
cc:
Director, Office of Federal Activities
Peter Myers, Chief, SCS
Billy M. Johnson, Director, SNTC
Dr. Maurice Cook, Director, SWCD
Sam Cox, AC, SCS
David Combs, AC, SCS
r
The Soil Conservation Service
is an agency of the
Department of Agriculture
II1-33
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North Carolina
Department of Administration
116 West Jones Street	Raleigh 27611
James B. Hunt, Jr., Governor
Jane Smith Patterson, Secretary
Margaret C. Riddle
Coordinator
Office of Policy and Planning
(919) 7334131
August 31, 1983
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E,
Atlanta, Georgia 30365
Dear Mr. Heinen:
RE: North Carolina Barrier Island Wastewater Management
DEIS, Multi-County - SCH File #84-E-0000-5040
The State Clearinghouse has received and reviewed the above
referenced project. As a result of this review, the State
Clearinghouse has received the attached comments from the
North Carolina Department of Natural Resources and Community
Development and the Department of Cultural Resources.
Thank you for the opportunity to review the above referenced
document.
Sincerely,
Clearinghouse Director
CB/jcp
Attachments
II1-34
An Equal Opportunity Affirmative Action Employer
REGION IV
ATLANTA, OA".
-------
N0R1H
OKPUNK
DB^TMBVT
OF
CULTURAL
RESOURCES
Raleigh.
North Carolina
27611
0

If
iaraW Hodgkins.
iecretory
lames B Hunt. Jr..
kvemor
August 25, 1983
Mr. E. T. Helnen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: fbrth Carolina Barrier Island Wastewater
Management, DEIS, Multi-county, Coastal,
Crl 84-E-0000-5040
Dear Mr. Helnen:
We hav:i received notification from the State Clearinghouse concerning
the above Draft Environmental Iwpact Statement.
We are unable to consent on the potential effect of this project on
cultural (archaeological, architectural, and historic) resources until
we receive further information. Within the DEIS reference 1s made to an
Atlas which Identifies the locations of *. . . known sites of historical
and archaeological Importance . . .* (pages 111*27, 2-120, 3-132).
Please forward a copy of the Atlas so we may complete our review.
The above comments ere made pursuant to Section 106 of the National
Historic Preservation Act ef 1966, the Advisory Council on Historic
Preservation's Regulations for Compliance tilth Section 106, codified «t
36 CFR Part 800, end to Executive Order 11S93, "Protection end Enhance-
ment of the Cultural Environment."
Thank you for your cooperation and consideration. If you have questions
concerning the above consents, please contact Ms. Renee 61edM11-Earley»
Environmental Review Coordinator, at 919/733-4763.
Sincerely,
John J. Little, Deputy State
Historic Preservation Officer
^W^slw
S^V c lear1n9houia
111-35
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North Carolina Department of Natural
Resources &Community Development
James B. Hunt, Jr., Governor	Joseph W. Grimsley, Secretary
MEMORANDUM
FROM:	Anne Taylor
SUBJECT: 84-5004 N.C. Barrier Island Wastewater Management
DATE:	August 30, 1983
TO:
Chrys Ragget
State Clearii
The Department of Natural Resources and Community Development
has completed its review of the N.C. Barrier Islands Wastewater
Management Draft Environmental Impact Statement.
Considerable time has evolved since this projects' beginning
and there is a strong need in addressing all comments and finalizing
the EIS process at the earliest possible date. As this process proceeds,
we feel that significant questions need to be addressed concerning
availability of funds, the ability to manage these systems and the
responsiveness of EPA in reviewing and approving the alternative and
innovative systems. These questions are highly important and the
timeliness of this resolution cannot be overemphasized.
To assist in continued development of this project, specific
comments from the Office of Coastal Management and the Division of.
Environmental Management have been attached for your consideration.
Thank you for the opportunity to review. I-p questions arise.or
we can be of further assistance, please notify me at 919-733-4984.
P 0 Bov 2/087	27011-7687
An Equal Opportunity Attirmjtivv Action Employer
-------
COMMENTS
The final EIS should discuss in detail the modifications that were
made in the 1982 Municipal Wastewater Treatment Construction Grant
Amendments in relationship to the feasibility of local carmunities
to receive funds to update and implement 201 facility plans. That
is, three specific areas of concern should be examined more thoroughly:
1) a reduction in the federal share, 2) a change in the method of
federal participation of funding plans and design work, and 3) a
change in policy whereby reserve capacity shall be restricted to
existing flows.
Since it is EPA's policy that administrative action be taken to reduce
the inventory of 201 facility plans and sane of the local ccmrtunities
will be impacted by this policy, it appears the "No Federal Action
Strategy" is the most realistic strategy for several ccnmunities
covered by the EIS. Should the EIS give more attention to the
reality of fewer federal and state dollars to implement anything
for seme carmunities?
The model on hydrodynamic response to on-site disposal of wastewater
should be tested on one or two barrier island camrunities to indicate
its validity and reliability for projecting the overall impact on
groundwater.
The EIS has been delayed significantly beyond EPA's projected target
dates for completion. Therefore, every step should be made to finalize
this process (expeditiously.
Ill-37
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MEMORANDUM
TO:	MEIBA STRICKLAND
FRCM:	DANIEL SMALL
SUBJECT:	EIPA'S GENERIC EIS, BARRIER ISLAND 201 FACILITY PLANS
DATE:	AUGUST 23, 1983
(1) Chapter III, Section B,- b. (1), is devoted to an overview of the
North Carolina Coastal Management Program and the various manage-
ment tools available to assist in implementing the 201 strategies.
This section does not, however, discuss the mechanism that would
be used to implement the 201 strategies with the Coastal Program.
We recamend that EPA coordinate more closely with the N. C. Office
Coastal Management in this area to ensure that which ever 201
alternative is chosen can be meshed with our program.
(21 Chapter I, Section A.I.- states that draft 201 plans endeavored
to justify the need for wastewater facilities - on the barrier
islands based on the pollution of shellfish ing waters by failing
septic tanks. It is then stated that (EPA?) analysis of the data
does not support this position except in a very few cases involving
development on finger-fill canals. It is further stated in the
Executive Surtnary (Part B Background, under issues addressed) that
non-point mainland surface runoff sources (not septic tanks)
appeared to be the problem. We were not able to find the data
used by EPA to draw this conclusion. If non-point mainland sur-
face runoff is truely the cause, instead of failing septic tanks,
it should be substantiated in the EIS document or associated
appendices.
(3) The EIS presents a number of on-site and cannunity wastewater
treatment strategies that could substitute or be more reasonable
than a centralized 201 facility. Our first question is have
these treatment alternatives being discussed with Local Sanitation
Specialists as to their practicality and feasibility within their
areas?
111-38
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United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
Southeast Region / Suite 1384
Richard B. Russell Federal Building
7S Spring Street, S.W. / Atlanta, Ga. 30303
SEP 2 1983
ER-83/879
Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Heinen:
The Department of the Interior has reviewed the Draft Environmental
Impact Statement (DEIS) on North Carolina Barrier Island Wastewater
Management and has the following comments.
General Comments
Fish and Wildlife Resources
Financial considerations of local governments were given a prominent
role in the selection of the preferred alternative, while fish and
wildlife resources were not adequately assessed in the impact
sections. The DEIS does not include a cost-benefit analysis, or
discussions on the costs of potential impacts to commercial and sport
fisheries and other environmental impacts.
The DEIS should evaluate other alternatives such as:
1.	A nonstructural alternative which would examine the control
of density and/or development on barrier islands and consider
the local coastal management land use plans.
A nonstructural approach would reduce the scope of the
impacts associated with wastewater management and, thereby,
decrease the problems associated with management of
wastewaters. Local zoning ordinances potentially would
reduce impacts to fish and wildlife and other environmental
resources. A monitoring program to assess environmental
impacts of development could be used for directing and
setting limits on future growth.
2.	An alternative which evaluates tertiary treatment of
wastewater. To avoid potential storm damage, floodproofing of
wastewater facilities would be needed. The marine and
estuarine environments adjacent to the barrier islands
II1-39
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support a varied and economically important commercial
fishery, sport fishery and associated tourism industry. Fish
and wildlife resources are part of a dynamic system and an
alternative that insures protection of these valuable
resources should be evaluated.
One of the basic premises of the DEIS is that nonpoint runoff sources,
not septic tanks, appear to be the problem regarding water quality.
During rain events septic systems may contribute to runoff and
adversely influence water quality. Based on information contained in
the DEIS, it would be premature to recommend a septic system when the
amount of nonpoint runoff pollution attributable to these systems has
not been assessed. The DEIS contains findings from several locales
that associate high bacterial counts with septic systems. Conversely,
some areas with sewered systems have the lowest bacterial counts.
Consequently, statements which imply that septic systems are not a
problem are misleading and should either be documented or revised in
the Final Environmental Impact Statement (FEIS).
The DEIS assumes that secondary adverse impacts to the natural
environment associated with the 201 strategy coupled with adverse
financial burdens to local governments are valid reasons for selecting
the preferred alternative. The environmental impacts associated with
continued use and construction of septic systems may be a more
immediate and profound potential environmental problem than the
development of centralized wastewater treatment facilities. The
secondary environmental impacts identified for the 201 strategy
include: higher levels of pollution from expected increased
population densities; impacts to sensitive natural areas; and, loss of
beachfront habitat. All of these impacts are also either associated
with septic systems or easily rectified by simple zoning regulations.
In fact, the 201 facilities are proposed to alleviate water pollution
from septic systems and improve shellfishing as described in the
DEIS's Alternatives Development Report (page 2-3). The development
costs associated with wastewater treatment should be weighed against
the total costs resulting from a reduction in environmental quality.
Although initial investments may be higher with a centralized system,
costs associated with long-term direct, indirect and cumulative
adverse impacts to fish and wildlife resources and other components of
the environment could dwarf these initial expenditures.
Adverse impacts to wetlands and fish and wildlife resources should be
in more detail. We recommend that a worst case analysis assessing
impacts to fish and wildlife resources by the various systems of
wastewater management should be completed and included in the FEIS.
The results should be used to reevaluate the existing alternatives and
to evaluate any additional alternatives prior to decisionmaking.
111-40
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We believe that a cumulative impacts section is essential and should
be included in the FEIS. This is especially important because of the
areawide wastewater disposal issues for barrier islands throughout
North Carolina. If the present alternatives will result in long-term
adverse environmental impacts, then the identification and evaluation
of more environmentally acceptable alternatives also is warranted.
Water Resources
In regard to septic tank/soil absorption treatment of wastewater, a
confining layer at relatively shallow depths limits downward movement
in infiltrating waters. Thus, the volume and effectiveness of
permeable materials that can absorb contaminants and transmit
effluents within the water-table aquifer are limited. In places, as
little as 5 feet of sandy materials overlie the confining bed, which
commonly consists of lagoonal mud deposits. Because of the limited
volume and moderately high permeability of the sediments comprising
the water-table aquifer, even if coliform concentrations are reduced,
nitrates, phosphorous, and organic carbon travel laterally
considerable distances to enter downgradient wells and surface waters
significant for shellfish and recreation. We suggest that the
analysis of environmental impacts should include consideration of the
limitations imposed by the relatively thin water-table aquifer in many
places on the barrier islands and by the comparatively small volume of
permeable sediments in the water-table aquifer that is to receive the
effluents. Partial mitigation might include test drilling at
prospective sites to define the volume of absorptive materials
available and evaluation of the efficiency of the sediments in
removing pollutants.
In addition, the evaluation of the various alternatives and 201 plans
should address potential effects on ground-water recharge and movement
of the sal twater-freshwater interface that would result from the
export of treatment effluent to the mainland or through offshore
outfalIs.
Specific Comments
Page II-l; third paragraph, last sentence: The document indicates
that the North Carolina barrier islands are characterized by limited
financial resources. Some areas do have significant development and
should be recognized. Further, the commercial fishery, sport fishery,
and other recreational opportunities significantly supplement the
economy and this should be recognized in the FEIS.
Page 11-14; second paragraph; second sentence: The need for
continual repair and/or upgrading of septic tanks should be included
in the analysis of the preferred alternative.
III-41
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Page 11-14 and 11-15; Combination of Systems: Although a community
may be served most cost-effectively in the short-term by a mixture of
individual systems, the cumulative impacts to the environment and
long-term costs should be evaluated.
Page 11-18; first paragraph: A nonstructural alternative of |
limiting density and/or development should be included in the &Lf
discussion.		|
Page 11-39; Degree of Centralization: The centralized system should |
include safety features to alleviate much of the anticipated damage 65
resulting from storms.		|
Page 11-49; II-50 and 11-51: It appears that the assumption is made
that no significant environmental problems are anticipated from septic
systems, or other potential systems, if the high water table is
greater than 12 inches from the soil surface. This appears to be an
unreasonable risk for groundwater contamination. The septic field <£>£>
will be inches away or adjacent to the groundwater table for at least
part of the year. This could pose a significant adverse effect on
groundwater resources, and we recommend the greater than 12 inch
standard used to determine areas subject to development be increased 	,
substantially. The areas identified as being suitable for development —i
compose 62 percent of the surface of the barrier islands. If runoff, |
as identified by the DEIS, is the primary pollution problem, the
development of this large a portion of the barrier island system will ,
present a potentially significant environmental impact.
Page 11-62; Affordabilit.y Analysis: A more accurate representation I
of existing conditions would result if the "second home" residents are /o
included.	|
Page III-8; High Energy Beach Habitat: Fish occur in the fauna! ~)
community and should be discussed.	67
Page III-8; Open Water Habitat: Amber jacks are not a commercially
important species in North Carolina.	70
Page IV-2; second line: This statement asserting that waterfowl	I
populations con tribute to water pollution problems is undocumented.	I
Further, it is contradictory to observations stated on page 6-22 of	7'J-
the Environmental Inventory Report. This discrepancy should be
reconciled.

111-42
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Page IV-4 arid IV-5: We believe it is appropriate to consider ana
develop alternatives which would not have significant long-term
environmental impacts. An alternative previously suggested would curb
density and/or development thereby reducing the magnitude of impacts
to the valuable commercial and sport fisheries resources.
Page IV-5;	Other Resources; third paragraph:- The statement that
alterations	to the terrain will not be significant should be
qualified.	Some terrain will be covered with impervious surfaces and
dwellings and	vegetation will be substantially modified.
Page IV-9; Mitiqative Measures: The limiting of density and/or
development based^on evaluations of concurrent monitoring studies is a
potential mitigative measure that should be included. Other
mitigative measures could include: (1) floodproofing of central
wastewater management facilities; and (2) development of tertiary
treatment facilities at wastewater treatment sites to reduce
environmental impacts, particularly if these measures are not included
as alternatives.
Thank you for this opportunity to provide comments on this document.
We would like to discuss our questions and concerns with you prior to
the preparation of the FEIS.
James H. Lee
Regional Environmental Officer
Sincerely yours,
111-43
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OUTER BANKS CHAPTER
NATIONAL AUDUBON SOCIETY
S.R. BOX 321
KITTY HAWK, N.C. 27919
September 3. 1983
E.T.Heinen, Chief
E.T.A.
3^5 Courtland St., N.E.
Atlanta, Georgia
30365
Dear Mr. Heinen,
Speaking for the Outer Banks Audubon Chapter,
We want to thank you for this opportunity to
comment on this important issue.
We feel that barrier islands are fragile systems
that are not suited for heavy, or high-density deve»
lopment. For this reason, we feel that the Federal
Government should discontinue their policy of promoting
development on Barrier Islands by supplying sewage
systems, Federal flood insurance, etc.
Feeling this way, we are in favor of "the no
Federal action strategy". with the state imposing
tight regulations on present systems. We agree with
you that private septic tank systems have their
drawbacks, but to use taxpayers money to fund more
central sewage systems on Barrier Islands, appears to
promote growth in an area that is fragile and vulnerable
and unable to support such growth.
Thank you again for the chance to respond to
this important issue.
Sincerely,
Outer Banks Audubon
111-44
mm tm
frii SEPC8 083 I
ft '.La 3 a
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B. EPA Responses to Letters of Comment
W-l. Erosion and accretion are continuous processes along the barrier
island chain. The redistribution of sediment which takes place
within the sand sharing system is generally acknowledged. EPA
agrees that these processes tend to be gradual except during storms
when the effects can be significant in scope.
In recent decades, the North Carolina coast has been struck by fewer
storms than the historic average. These numbers can expect to
balance out over time, and severe damage to public infrastructure
and private property can be expected. The EIS suggests that local
governments base their wastewater management decisions not only upon
knowledge of gradual erosion processes but upon the inevitability of
significant storm damages in the coming years.
W-2. It is beyond the scope of the EIS to provide detailed engineering
information about damage susceptibility. Only general guidelines
were provided.
W-3. Many studies of the impact of boating on water quality have been
undertaken (Barbaro et al. 1969, Cossin et al. 1971, Faust 1982, Fur-
fari 1968, Furfari and Verber 1969, Mack and D'ltri 1973, Udell
1956, Udell 1957). Although findings are not consistent, there is
widespread recognition that recreational boating activity can con-
tribute to increased bacterial levels in localized areas (Bowerman
and Chen 1971, Kidd 1975, Mack 1971, Seabloom 1969). Studies under-
taken by the U.S. Food and Drug Administration indicate that only a
small number of boats can exist in relatively large, deep marinas
and still maintain the water quality necessary for shellfish to be
safely grown (USFDA 1972, USPHS 1967). USFDA guidelines used by
state shellfish officials state that pollution from boats is a
public health problem and because of the highly variable and unpre-
dictable contribution of fresh fecal material, it is necessary to
close areas subject to boat pollution in the vicinity of shellfish
beds during the boating season (USDHEW 1965). Many state and
federal agencies require a 1000 foot closed buffer area around any
marina. In some states the growth in marina development and the
buffer requirement has resulted in the loss of significant amounts
of shellfishing area.
The use of approved marine sanitation devices (MSDs) could further
decrease the significance of this problem. Unfortunately, many boat-
ers have not refitted older boats, and on many boats with approved
MSDs, the devices are not being used as intended. Adding to this
problem is the enforcement of reglations on MSD's and the limited
number of marinas with pumpout facilities. A recent survey of North
Carolina and Florida marinas noted such facilities at only 13
percent of the marinas and mentioned further that many pumpout
facilities may not be operable because of infrequent use (Taylor
1983a, Taylor 1983b).
W-4. It is true that the sensitive natural and manmade environments of
barrier islands have much in common with nearby coastal communities.
Ill-45
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Five draft 201 Plans proposed similar facilities, and similar issues
were raised during environmental review of these plans. These
issues were unique in the barrier island setting. In addition,
these five 201 Plans were submitted to EPA for review by barrier
island communities within a few months of each other. EPA made the
decision that the resolution of the issues raised by these plans
should be carried out in a consistent and expeditious manner; hence,
the decision to prepare an areawide EIS.
W-5. See W-2. In addition, natural processes are covered extensively in
the Environmental Inventory Technical Reference Document.
W-6, Comment noted.
W-7. The North Carolina soil absorption system regulations require at
least 48 inches of suitable soil for use of conventional ground
absorption systems. These regulations allow for soil depths between
36 and 48 inches when special design and installation modifications
can be made and at least one foot of naturally occurring soil is
provided below the bottom of the nitrification trench. EPA has
begun a study of North Carolina barrier island groundwater 1n areas
served by soil absorption systems. This study will provide
hydrological and water quality data which should help 1n the
resolution of this question. (See Appendix.)
W-8. Costs were obtained from the EPA I and A Manual, EPA 430/9-78-009,
updated to represent costs during November - December 1981 using the
ENR cost Index. Cost for pumping includes design of the pressurized
distribution system. Attempts were made to obtain local costs for
innovative systems, but installers generally had little experience
with the systems.
W-9. Annual 0&M of $20 1s for power and minor repair parts. The pump and
tank construction costs are comprised of:
$ 200	Pump
100	Controls
300	Tank
400	Design and Labor
TT7JDU	TOTAL
The pump 0&M cost represents 10 percent of the purchase price per
year. Typical life expectancy of these pumps is five to ten years;
allowing an additional $20 per year for replacement, annuity will
not change the EIS's conclusion.
W-10. With proper siting, design, installation and maintaining isolations,
problems with on-site treatment and disposal should be minimal.
These quality control measures should result in treatment systems
with good performance and offset the need for special monitoring.
Also, many previously platted small lots which may be developed
have, in many instances, access to existing water supply mains and
will not have to rely on individual wells. Therefore, groundwater
monitoring costs were not included in the EIS.
Ill-46
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W-ll. Groundwater monitoring costs were not included in the EIS. Pressure
dosing in traditional as well as mound type soil absorption system
has, through field tests, produced a high quality effluent prior to
movement in the local groundwater system. Nitrate concentrations
may indeed need monitoring in light of systems being constructed
solely on well drained, coarse textured sands which do not promote
denitrification. If suitable space for a replacement system is
provided and proper isolation distance requirements are maintained,
then high concentrations of nitrates should not occur.
W-12. The EIS Strategy assumes public water for the principal source of
supply since a much smaller percentage of individual wells are util-
ized on the islands. Most of the islands in question are going to
off-island supplies since the limited island supplies cannot meet
the demand.
W-13. Control of development densities is an important mitigative measure.
However, the designation of areas for high and low density uses is a
land use/zoning decision that is reserved by law to local
governments.
W-14. On September 8, 1983, the Division of Environmental Management (DEM)
adopted a set of rules which sets standards for groundwater on a
state-wide basis. These rules will become effective January 15,
1984. Under these rules, a zone of treatment is defined as being
the area 0.0 - 20.0 feet below the ground surface. Dilution stand-
ards are set for a series of parameters (nitrate, nitrite, chlor-
ides, total coliform, etc.) which may be discharged in this zone of
treatment. Standards were developed so that when discharges reach a
depth of 20.0 feet, they constitute no adverse impacts on
groundwater.
Those communities or individuals using the freshwater lens for drink-
ing water supply should draw their supplies from below the 20.0-foot
level. Where this depth is not feasible, a community may petition
the DEM to declare the zone of treatment to be 0.0-10.0 feet below
the surface and enforce standards accordingly. Given proper manage-
ment and enforcement, the shallow aquifer should not be lost for
drinking water purposes.
Developers and individual homeowners will have to size their drain-
fields and assure the distribution of effluent so that adequate
renovation occurs in the zone of treatment. DEM is not able to
project, however, whether or not the implementation of the new rules
will alter prevailing development densities on the barrier islands
(Mouberry 1983).
W-15. In the design of a spray irrigation facility, a detailed water
balance is computed to assist in developing application rates. When
proposing to dispose of sand filter effluent, fairly high loadings
are possible per unit of surface area. In subsurface disposal
schemes, wastewater applications are normally expressed in gallons
per foot squared (gals/ft2) of trench or bed bottom area. An
II1-47
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application of 1.0 to 1.2 gals/ft2 in this mode would be less 1f
expressed 1n terms of ga1s/ft2 of actual surface area. Thus,
applications 1n subsurface soil absorption systems are higher per
unit of area.
W-16. A range of pollution levels has been detected in f1nger-fill canal
developments. In a number of cases, levels were high enough to
warrant closing nearby shellfish areas. Mr. Bob Benton, NC Shell-
fish Sanitation Office in Morehead City, can furnish more detailed
information about the surveys his agency has conducted
(919/726-6827).
The groundwater study now underway on several of North Carolina's
barrier islands will provide additional information on the effects
of on-site systems on groundwater level and quality.
W—17. An Atlas was sent to Mr. Little on September 6, 1983 for his review.
W-18. Comment noted.
W-19. The Construction Grants program has been delegated to the state of
North Carolina, and through the review of facilities plans, mitl-
gatlve measures are identified by the state and are included in
these plans as part of a project. Mltigative measures are described
in Environmental Assessments and Findings of No Significant Impacts
(FNSIs) which are published by EPA on all projects receiving grants.
In addition, EPA regulations require that a grant involving a waste-
water management system using on-site systems be made to a manage-
ment agency which could Implement mitigation measures.
W-20. Many smaller lots such as those measuring 50' x 100' can be devel-
oped using on-site systems when certain conditions are met. See the
Draft EIS, Appendix E, page E-3, for a lot diagram. Other typical
lot configurations are also shown 1n this Appendix. The suitability
of soils for development with soil absorption system 1s addressed 1n
the DEIS on pages 11-45 through 11-54.
W-21. Many vendors have preassembled package treatment plants that only
need a supporting concrete pad, electricity and minor plumbing work
completed to be made operational. Local sanitarians or sanitary
engineers could inspect a variety of systems and pre-qualify their
design and construction.
Highly skilled individuals are not needed to inspect for proper oper-
ation of pumps and whether or not the chlorinator has run out of
tablets (chlorine).
W-22. Technician(s) assigned to inspect the treatment unit on a daily
basis can obtain a sample of the treated effluent and then utilize
the services of a commercial laboratory for analysis and submittal
to the reporting agency. Training of personnel is often provided by
the vendor.
W-23. The agency responsible for the purchase, permitting and utilization
II1-48
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of the treatment works should, through user charges, collect suffi-
cient rentals to address hardware problems with the unit. NPDES
permits regulate the volume and quality of discharge from such
treatment plants. Therefore, local agencies, in the review of pro-
posed subdivision plans or additions to existing development, can
also evaluate the sewage treatment and disposal needs. Prior plan-
ning and municipal or local agency involvement with proper waste-
water management can ward off potential problems with lack of
maintenance and overloading due to unregulated customer usage.
W-24. Comment noted. Ongoing monitoring programs of the North Carolina
Shellfish Sanitation Office (in the Div. of Health Services of the
Dept. of Human Resources) continues to show that the closing of over
90 percent of the shellfish acres are caused by nonpoint source
pollution from the mainland (Benton 1983).
W-25. Comment noted.
W-26. On-site systems (septic tanks) have been a satisfactory means of
wastewater disposal on the North Carolina barrier islands for years
when used with suitable soils and when properly sized, constructed
and maintained. On-site systems are unsatisfactory in a few areas
on the barrier islands where unfavorable conditions exist, such as
finger-fill canal areas. The closed shellfishing waters throught to
be caused by malfunctioning septic systems were determined to be a
result of mainland activities rather than barrier island activities.
W-27. The EPA's charge is protecting water quality, not encouraging or dis-
couraging growth. This EIS is designed to assist local communities
in finding an affordable, environmentally sound means of providing
wastewater management. This EIS addresses procedures for federally
supported planning and grants related to resolving water quality and
public health problems. It does not preclude communities from
providing locally funded wastewater treatment facilities. The EIS
approach allows flexibility for local governments to accommodate
desired growth. The EIS neither promotes nor discourages
development on the barrier islands.
W-28. The state of North Carolina determines the priority of proposed pro-
jects mainly on the basis of demonstrated water quality problems and
the ability of the project to solve these problems and restore the
intended water use.
W-29. See W-27.
W-30 Studies such as the one by B. L. Carlile and C. G. Cogger, Movement
and Fate of Septic Tank Effluent in Soils of the N. C. Coastal Plain
document that the most important factor affecting movement and treat-
ment of effluent was the location of the water table. "Those sys-
tems which were nearly continually saturated had the highest con-
centration of contaminants in the groundwater and the farthest
movement."
This study also showed that renovation of the wastewater was im-
II1-49
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proved 1n shallow, somewhat poorly drained, coarse textured soils
with the low pressure pipe (LPP) distribution system. This report
concludes that with proper siting, design, and construction LPP
systems can provide good levels of wastewater treatment. One case
study with a mound system demonstrated to the study team that it was
capable of providing excellent treatment.
W-31. Much of the cost Information contained in the draft 201 Plans was
incomplete, and the average user costs were therefore Inaccurate.
These costs were recalculated in the Draft EIS and are shown 1n
Figure 11.21. Typical household monthly user charges with funding
assistance range between $17.10 and $36.35. These costs are
premised on 75 percent matching funds from EPA. However, this level
of assistance will drop to 55 percent on October 1, 1984 for
grant-eligible components. At that time, costs will be signifi-
cantly higher than those mentioned above.
W-32. See W-27.
W-33. EPA expects all barrier island communities presently enrolled in the
National Flood Insurance Program to fully comply with Its
provisions. Enforcement provisions lie with the Federal Emergency
Management Agency.
W-34. Comment noted; see W-35.
W-35. EPA agrees that there are no guarantees that on-site or small commun-
ity systems will be the selected alternative after any 201 Plan is
updated. However, these alternatives will be fully considered, and
EPA will participate only in the funding of an alternative that is
environmentally sound and cost-effective.
After October 1, 1984, the 201 Construction Grants program will
place a prohibition on the use of federal funds for conveyance or
treatment capacity beyond that necessary to serve existing
population at the time of the Step 3 grant award or 1990, whichever
comes first. Very little latitude will exist, for overestimate of
future population.
W-36. EPA shares your concerns; however, the agency believes that the
procedures developed by this EIS will require a realistic appraisal
of wastewater treatment needs for barrier island communities. The
No Federal Action Strategy would leave certain water quality prob-
lems unresolved and would increase the probability of future
problems. EPA believes that the beneficial features of the EIS
Strategy of solving existing problems and preventing future
problems, along with the safeguards built into the procedures, make
it the best approach to take.
W-37. Development densities will be approximately comparable under the EIS
Strategy and the No Federal Action Strategy. The EIS Strategy pro-
vides a better planning framework, however, and it is expected that
local land use decisions will be based on more accurate information.
As a consequence, nonpoint source pollution is expected to be less
II1-50
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severe under the EIS Strategy than under the No Federal Action
Strategy.
W-38. Regardless of the provision or lack of provision of federal funding
assistance, it is expected that the North Carolina Division of
Environmental Management or the North Carolina Division of Health
Services will require that water quality standards be met by local
wastewater facility operators.
W-39. Comment noted.
W-40. See W-17.
W-41. Since the EIS began, several significant changes have occurred in
EPA's Construction Grants program. In December, 1981, Congress
enacted and the President signed amendments to the Clean Water Act.
Among other actions, these amendments provided for 1) a lower author-
ization for construction grants than had occurred in previous years;
2) a reduction in the federal share of construction costs from 75
percent to 55 percent for all projects approved after September 30,
1984; 3) a prohibition on the use of federal funds for conveyance or
treatement capacity beyond that necessary to serve the population
existing at the time of the grant award, or 1990, whichever comes
first; and 4) elimination of grants for conventional collector sys-
tems after September 30, 1984, except that a governor may elect to
use up to 20 percent of a state's allocation for collectors or other
previously eligible projects. These changes and others are des-
cribed in detail in Construction Grants 1982 (EPA 1982). See Final
EIS Chapter II.D, Implementation of the Recommended Strategy.
W-42. Projects which have been in the planning stage and have a low
priority on the N.C. State Priority List have been administratively
closed. Should the priority change, the applicant can elect to
reopen the project and proceed with planning.
EPA recognizes the reduction in funding levels from both federal and
state governments. The state's priority system should assure that
the projects which have demonstrated water quality problems and the
ability to restore intented water uses will have priority over other
proposals for use of these limited funds. The funding situation
should not preclude communities from providing locally funded
wastewater management systems.
W-43. EPA Region IV has initiated work on a program to test the ground-
water model at three sites along the barrier island chain. The
findings should be published toward the end of 1984. (See
Appendix.)
W-44. Comment noted.
W-45. The Construction Grants program was delegated to Division of
Environmental Management (DEM) in 1980. The 201 program will be
coordinated with the Office of Coastal Management, also within the
N.C. Department of Natural Resources and Community Development.
II1-51
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W-46. See W-16 and W-24.
W-47. Local sanitarians have attended some of the EIS workshops and have
had an opportunity for comment.
W-48. EPA believes that the potential impacts to commercial and sport
fisheries and other environmental impacts were discussed in as much
detail as necessary to evaluate the alternative strategies consid-
ered in this EIS. The EIS Strategy has been determined to have the
greatest benefit to the environment among the alternatives consid-
ered. Since this is an areawide EIS which is considering strategies
for wastewater management planning and is not evaluating the
site-specific projects (which are yet to be determined), 1t would
not be possible to produce meaningful cost figures for impacts to
specific resources.
W-49. EPA agrees that sound land use planning practices are important
nonstructural tools in the provision of wastewater management
services. However, federal agencies may not usurp the prerogatives
of local governments. See W-13.
W-50, North Carolina does not permit surface discharges to SA waters, and
the use of ocean outfalls requires only secondary treatment. The
issue of tertiary treatment does not arise.
W-51. Flood proofing of wastewater facilities in flood prone areas 1s a
sound engineering practice which would undoubtedly be required by
state agencies.
W-52. The evaluation of impacts on fish and wildlife resources was an
integral part of the EIS process.
W-53. Septic systems which were not properly installed, operated and
maintained were found to be associated high bacterial counts. EPA
believes that septic system technologies (conventional as well as
innovative and alternative systems) are fundamentally sound and work
well when properly managed. In addition, see W-16.
W-54. See W-53.
W-55. EPA does not agree that properly managed septic systems will produce
higher levels of pollution, more Impacts to sensitive natural areas
or greater loss of beachfront habitat than will the implementation
of the 201 Strategy. The authors of the draft 201 Plans claim that
central systems are needed to alleviate water pollution and improve
shellfishing; the EIS did not substantiate these claims.
W-56. The EIS Strategy is designed to assist communities in planning for
the most cost-effective and environmentally sound wastewater
management system for their specific situation. The EIS determined
that the adverse impacts to fish and wildlife resources will be min-
imized with the EIS Strategy and the least cost alternative would be
determined.
111-52
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W-57. See W-48. In addition, a worst case analysis would not be meaning-
ful in an areawide EIS which is providing a strategy for wastewater
management planning.
W-58. The EIS Strategy is designed to result in planning for wastewater
management systems which are the most environmentally sound. Also
see W-48.
W-59. With the continual use of septic tank soil absorption systems, it is
assumed that this system will be properly sited, designed, and
installed. Providing these conditions are satisfied and that normal
routine maintenance is performed on the systems, a fairly good
quality effluent would be all that would percolate downward to the
local water table. In a properly functioning soil absorption
system, all of the required biological and chemical treatment takes
place in the overlying, unsaturated one to two feet of soil.
When the effluent reaches a moist or anaerobic environment, such as
the mud deposits, some nitrates will be reduced by denitrification,
resulting in lesser amounts of nitrates available for movement to
adjacent waters. Also, as the waters flow toward the back bays
during low and neap tides, the carbon-rich and anaerobic wetland
vegetation should afford an additional opportunity for denitrifica-
tion and loss of N2 gas.
W-60. The procedures and tools developed by the EIS should provide for the
identification of the potential effects on groundwater recharge and
movement of the saltwater-freshwater interface resulting from export
of treated effluent whenever on-island water supplies are used. The
groundwater model developed for this EIS and now being demonstrated
by an additional study is designed to provide this information.
(See Appendix.)
W-61. Comment noted. However, the personal incomes of most year-round
residents remain relatively low, and they cannot afford high user
charges for wastewater management systems.
W-62. "...continual repair and/or upgrading of septic tanks" appears to be
an exaggeration. All mechanical systems, whether small scale or
centralized facilities, require a certain amount of maintenance and
repai r.
W-63. The EIS has determined that for certain situations a combination of
systems may be the most cost-effective in the long term as well as
short term. In addition, this combination of systems may also
provide the most benefits for the environment.
W-64. See W-13 and W-49.
W-65. Comment noted.
W-66. Soil absorption systems in North Carolina must, by law, maintain a
minimum of 1.0 foot separation between the bottom of any proposed
111-53
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system and seasonally high water. Therefore, 1f properly Installed,
most soil absorption systems will have greater than 1.0 foot of un-'
saturated soil above the water table for much of the year. For
example, the Corolla fine sand has a seasonally high water table 1.5
to 2.0 feet from the surface, and during the drier summer and early
fall months, the water table may be as deep as 6.0 to 8.0 feet below
the surface (see W-7).
Improper interpretation of the water table location 1n this soil
could result 1n flooded trenches and widespread movement of contam-
inants during the wetter months. Therefore, the key to proper
placement of these systems 1s to have detailed soil Interpretation
from trained soil scientists who can properly Identify the upper
limits of groundwater movement in the soil profile. The Draft EIS
Identified certain modified on-site systems which could be placed 1n
an area with 12 inches or greater to the seasonal high water table.
Conventional systems without any modification require a minimum of
48 Inches to seasonal high water table. (See W-7.)
W-67. EPA agrees that increased development under any of the strategies
will lead to increases in nonpolnt source pollution, although at
differing levels. Sound land use planning and Best Management
Practices (typically recommended 1n a 208 Areawide Water Quality
Plan) should be Implemented by local governments to reduce and
control such problems.
W-68. Income figures for second home residents are not available since the
U.S. Census counts them at their primary residences. Moreover, many
second homes are only used a few weeks per year, and the real
economic burden falls on the year-round residents,
W-69. Comment noted.
W-70. Comment noted.
W-71. Documentation concerning impacts caused by waterfowl populations is
found in the Environmental Inventory Technical Reference Document on
page 2-15. Morris and Benton may be contacted for further
information.
W-72. See W-13 and W-49.
W-73. The intent of the paragraph was to state that topographical
modifications will be minor.
W-74. Limiting density is a valid mitigative measure and must be implement-
ed by local governments, not EPA. Floodproofing of central facil-
ities was addressed in W-51. Development of tertiary treatment
facilities 1s a moot point; see W-50.
W-75. Comment noted.
111-54
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C. Public Hearing Transcripts
This section of the Final EIS contains the transcripts of the three
public hearings. The following corrections have been made by EPA Region IV
for ease of reading.
Bolivia Transcript
p. 15, line 7	"page 330" should be "page 111-30"
p. 18, line 21	"pervading" should be "prevailing"
p. 41, line 15	"choliform" should be "coliform"
Pine Knoll Shores Transcript
p. 2, line 8	"Gallveci" should be "Galucci"
p. 20, line 22-25	"Gallveci" should be "Galucci"
p. 23, line 1 "package plan small septic tanks" should be "package
plants and small septic tanks"
p. 28, line 8	"cenogenestic" should be "synergistic"
p. 29, line 10	"Denton" should be "Benton"
p. 29, line 13	"qualitary associates" should be "Claude Terry & Associates"
Manteo Transcript
p. 1, line 19 ff	"Crumm" should be "Crum"
p. 1, line 21 ff	"Claud" should be "Claude"
p. 14, line 18	"fate complete" should be "fait accompli"
II1-55
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
NORTH CAROLINA BARRIER ISLANDS WASTEWATER
MANAGEMENT ENVIRONMENTAL IMPACT STATEMENT
DRAFT BIS PUBLIC HEARING
August 23, 1983
Bolivia, North Carolina
The public hearing in the above-captioned matter
commenced at 8:00 P.M., in the Public Assembly Building,
Brunswick County Complex, Bolivia, North Carolina,
Howard Zeller, Assistant Regional Administrator, United
States Environmental Protection Agency, presiding.
PROCEEDINGS REPORTED BY:
AURELIA RUFFIN, Certified Verbatim Reporter
and President, AURELIA RUFFIN t ASSOCIATES, INC.
Post Office Box 2025
Wilmington,. North Carolina 28402
Transcribed by: Yvonne Pinette
TABLE OF CONTENTS
1 OPENING STATEMENT BY MR. ZELLER	Page 3
3 SUMMARY OF DRAFT EIS BY MR. CRUM	Page 6
STATEMENTS OF:
JOHN HARVEY, ASSISTANT COUNTY
MANAGER, BRUNSWICK COUNTY	Page 14
PAUL S. DEN I SON, HENRY VON
OESEN t ASSOCIATES	Page 21
I?
13
14
15
16
17
18
19
70
21
22
23
24
25
DONALD WILLETS, ALTERNATIVE
SYSTEMS, NORTH CAROLINA	Page 26
COMMENTS	Page 32 - 45
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MR. ZELLER: It is a little after 8:00. I think I
would like to go ahead and formally open the hearing. If
anyone comes in late, we can still accommodate them.
I am going to come up here and use this area for giving
my statement, and ask all of you that give statements to
please do the same, to come up to the podium and identify
yourselves and whom you may be affiliated with so that we
will have your name on the record and we can respond accord-
ingly to you when the final Environmental Impact Statement is
completed.
Can everybody hear me all right?
First of all, let me welcome all of you to the public
hearing on the draft Environmental Impact Statement which
addresses wastewater management for the North Carolina
barrier islands. Let me introduce myself to you. My name
is Howard Zeller, and I am the Assistant Regional Adminis-
trator for the Southeastern Region of the United States
Environmental Protection Agency. My office is in Atlanta.
We are holding, as most of you know, a series of public
hearings on the barrier islands EIS. This is the first in
a series of three hearings that we will be holding on this
EIS.
With me is Mr. Bowman Crura. Bo Crum is the project
officer for the Environmental Impact Statement and has been
heavily involved in a lot of the scoping meetings and
activities that have taken place relative to development of
the document. Bo will be speaking a little bit later on
some of the technical aspects of the- EIS.
I would like at this time also to rccognizo Bob Jamison,
who is Regional Manager for the Department of Natural
Resources and Community Development for the State of North
Carolina. He is in the audience and we may ask you, Bob,
i
to respond to an issue should something conio up. We are very j
J
happy to have you here. As you know, we believe very strongly'
in a Federal-State partnership as we pursue our environmental
activities throughout the Southeast Region.
The purpose of the hearing tonight is to receive	¦
public and other agency comments on the Draft Environmental
Impact Statement for the North Carolina Barrier Islands.
This EIS provides guidance and procedures for local govern- j
ments and their contractors to assist in planning for waste-
water treatment facilities. The preparation of a facilities
plan is the first step in EPA's three construction grants
programs for wastewater treatment. To be eligible for Federal
funding, proposed facilities must be a part of an approved
facilities plan. The plan must identify the least costly
means of resolving public health and water quality problems
resulting from improperly treated sanitary wastewater.
Steps two and three of the construction grants program
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are for design and construction, and these steps follow

2
completion and approval of the facilities plan.

3
All but one of the draft 201 facilities plans for the

4
North Carolina barrier islands have proposed the construction

5
of extensive wastewater treatment, collection, transportation

6
and treatment facilities to serve large portions of these

7
islands. After an environmental review of the proposed

a
facilities, the Environmental Protection Agency has some

9
significant concerns about the potential impacts and the

10
cost of these facilities on the user public. ^

11
The National Environmental Policy Act, or NEPA as it isffi
<

t2
u
called, requires Federal agencies to prepare an environmental §

13
O
impact statement on major Federal actions that significantly 5
H
—<
—4
14
affect the quality of the human environment. Because of the 2
1
00
15
environmental complexities and the water quality issues in- %
<

16
volved in these projects, the Environmental Protection Agency

17
made a decision to prepare an environmental impact statement.

IP
Accordingly, in September of 1980 the notice of intent to

19
prepare an EIS was issued. The public hearing is being held

20
here tonight to receive comments on that draft EIS. EPA

21
wishes now and always to encourage public participation in

22
the Federal decision-making process and to develop improved

23
public understanding of Federally-funded projects.

/.4
The draft EIS was made available to the public in

2S
EPA's Office of Federal Activities on July 11, 1983, and it
P - 5
70
?1
77
73
24
«
was listed in the Federal Register on July 15, 1983. The
draft BIS comment period will extend until August 31, 1983.
Comments received this evening and during the comment period
will become a part of the record.
Before I take any testimony from the floor, and a
number of speakers have indicated they wish to present
testimony, I am going to ask Nr. Crum who is with me to
provide us a summary of the Environmental Imnact Statement,
and I hope that all of you here will feel free to raise
questions at any point in the proceedings here to facilitate
your understanding of what the Environmental Impact State- s*
<
0
ment is to cover and what we hope to accomplish. So in the [:
V
C:
process of discussing with you and letting you know the	~
7
government's intent, let me ask Mr. Crum to come up here and
1
give a statement which will summarize what is in the Environ-5
mental Impact Statement.
MR. CR0M: Thank you, Mr. Zeller. This draft Environ-
mental Impact Statement, or EIS, has been prepared in response
to issues raised during the review of five 201 Facilities
Plans. These plans, as Mr. Zeller indicated earlier, propose
the construction of wastewater collection, transportation and
treatment facilities to serve large portions of North Caroline
barrier islands.
Through the EIS process, wastewater management alterna-
tives for the barrier islands were developed and evaluated,
—	i> - 6
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13
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12
13
I
CT>
O
18
19
20
21
22
23
24
25
the ability to predict the impact on groundwater from soil
absorption disposal. The results from this study should be
available by the end of next year.
6. Sensitive Natural Areas. The primary and secondary
impacts of wastewater facilities on sensitive areas such as
dunes, wetlands and estuarine areas should be considered in
planning for wastewater management or wastewater facilities.
The EIS process included several steps. First, an .
inventory of existing conditions was prepared. Next,
alternative wastewater management strategies were developed.
Third, the strategies were evaluated, aided by using a case
study. Finally, the entire process was summarized and pub-
lished in the draft EIS.
I would like to now summarize the strategies addressed
by the EIS. They include the proposed EIS strategy, the 201
strategy, and the no federal action strategy.
A special strategy is developed in this EIS. This
approach is intended to provide assistance to local govern-
ments in planning for wastewater management. The approach
encourages communities involved in facilities planning to
update and revise their draft 201 plans as appropriate using
special procedures developed by this EIS.
The procedures developed by this EIS refine those nor-
mally undertaken in the preparation of a 201 plan. The
procedures are consistent with 201 construction grants
P - 9
regulations and other facilities plan preparation guidance
and are tailored to address the unique environmental and
socioeconomic conditions on the North Carolina barrier
islands. The procedures are designed to address the six
issue areas identified earlier. Special attention is given
to two areas: a thorough evaluation of potentially reasonable
wastewater technologies, especially on-site and small communi-
ty systems} and the financial and institutional impacts of
operating and maintaining wastewater management systems.
The procedures fall into three major groupinqs:	(
7
determining need and estimating flows; developinq alternative »
wastewater management systems; and evaluating these alterna- ^
tive systems. An overview of these procedures, which is	I
Figure 11.1 in the draft EIS, is part of the handout you
received tonight. The procedures are described in detail
in the draft EIS and the Alternatives Development Technical
Reference Document.
The EIS has compiled information and developed tools
which will be helpful to those planning for wastewater manage-
ment. These tools include a computerized data base of natural
resource information, details on wastewater management options
on-site wastewater treatment and disposal system siting
criteria, a financial planning handbook with worksheets, and
a predictive groundwater model. These procedures and tools
are designed to allow identification of all viable alternative
P - 10
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systems and to promote consideration of the major potential
impacts on both the man-made and natural environments.
The EIS compared the proposed strategy to the alterna-
tives of no action, or the no Federal action strategy, and
of approving the draft 201 plans as submitted, the 201
strategy.
The no Federal action strategy would be a decision by
EPA not to participate in further planning or funding of
wastewater management facilities in the study area. The
analysis of this strategy concludes that there would be con- I
2
tinued growth on the barrier islands regardless of whether g
<
publicly-owned and funded facilities are constructed. With- §
O
out additional EPA assistance, existing wastewater management <
z
practices are likely to continue. Localized state regulation^
<
would govern the use of soil absorption systems. Individual |
property owners would be responsible for providing adequate
treatment and would bear the cost of renovating failing
systems or installing new facilities.
The 201 strategy would be the approval and implementation
of the draft plans without significant changes. The plans
would have to be updated in certain areas such as costs.
Those plans proposing ocean outfall, Dare County and Carteret
County, would have to incorporate the results of site-specific
outfall surveys. The Carteret County plan for the barrier
islands would have to be modified since one of the two
communities involved elected not to participate.
One of the six plans, Hatteras Island, proposed no
action because it was determined that a system is not eco-
nomically feasible at this time. The other five plans
exhibit several similarities. Each plans calls for the
replacement of existing on-site wastewater systems, the
septic systems, with centralized collection, transmission,
treatment and disposal systems. These plans justified the
need for facilities based on the belief that shellfishing
harvest area closings were caused by existing on-site systems.
The plans also projected additional shellfish area closings ;
with continued residential and commercial development using •
on-site systems.
Another similarity is the proposal to provide sewer 1
lines to most areas of these communities. Pumping stations '
and force mains are to be used in all facilities to transport
effluent to the treatment plant. Secondary treatment is pro-
posed for each facility. Ocean disposal is proposed in Dare
and Carteret Counties, spray disposal in Topsail/Surf City
and southwestern Brunswick County, and surface water dis-
charge to the Cape Fear River in southeastern Brunswick County'
The EIS developed strategy is proposed as a means of
assisting local communities in finding a cost effective
affordable means of providing wastewater management. The
approach is designed to allow maximum flexibility for local |
p - 12
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governments to accommodate desired growth.
The EIS concludes that the 201 strategy could result in
costly systems which could produce adverse secondary impacts
to local governments. The no Federal action strategy would
leave certain water quality problems unresolved and could
increase the probability of future problems. Ho Federal
action would likely eliminate the continuation of facilities
planning.
The EIS strategy incorporates the following beneficial
features: the procedures promote documenting and then re- t ^
solving water quality problems; the procedures provide flexi- a
bility for meeting existing and future wastewater management ^
O
needs; the procedures promote maximum local decision-making <
and provide for disclosure of financial and institutional ^
impacts; and the procedures minimise costs to conmunities by ?
promoting consideration of less expensive alternatives.
The construction grants program has been delegated to
the state of North Carolina. Any future wastewater management
projects will have to meet state requirements. To receive
funding, any project must be eligible for funding based on
its position on the state priority list. Also, any project
to be funded must meet the construction grant regulations
applicable at the time of funding.
1 look forward to receiving your comments. Suggestions
for improving the methods proposed in this EIS for wastewater
P - 13
management are most welcome.
Mr. Zeller.
MR. ZELLER: Thank you very much, Mr. Crum. Before we
go ahead and ask for cannents from the audience, I would like
to remind all of you that we would like to have you register
at the front desk so we can have a complete attendance list
of everybody that is here tonight. If you wish to speak, I
am assuming you so indicated on the registration cards. I
will call on speakers that have indicated their interest in
speaking in just a little while. If you have not indicated
an interest in making a statement, and after the hearing pro- ^
ceeds if you would like to make a statement, you will be
given an opportunity to do so.
I would like to start off now with the real purpose of ,
this hearing, which is to receive conments from the public
relative to the draft Environmental Impact Statement, and I
would like to ask the first speaker who has registered with
me, Mr. John B. Harvey, who is Assistant County Manager
representing the Planning Board of Brunswick County, to
please come forward. As you cone forward, Mr. Harvey, would
you please identify yourself for the record and proceed with
your statement.
STATEMENT OF JOHN B. HAKVES, ASSISTANT
COUNTY MANAGER, BRUNSWICK COUNTY, N.C.
MR. HARVEY: I am John Harvey, Assistant County Manager
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Brunswick County. My remarks are made as an official pre-
sentation on behalf of the Planning Board of Brunswick County
with the concurrence of the Board of County Commissioners.
Mr. Zeller, the future posed to Brunswick County by
Alternative 3 selected in this EIS is, in our opinion, full
of false assumptions on the part of EPA. First, the popula-
tion projection used, page 330, shows EPA using an estimate
of 68,500 persons as permanent residents of Brunswick County
by the year 2000. In the recent publication, "The Future of
North Carolina: Goals and Recommendations for the Year 2000" u
z
by the Commission on the Future of North Carolina, which	£
<
commission has as a resource the Research Triangle Institute ^
o
and the major universities of the state, and includes among 5
its membership such personages as the President of the	s?
<1
Consolidated University System of North Carolina, the permanerft
<
resident population of Brunswick County to the year 2000 is
projected at over 82,000 permanent residents. That is just
17 years from now.
By careful documentation, we find that over 4500 housing
units have been added to the inventory of Brunswick County by
April 1, 1983, over the number reported just 3 years before,
April 1, 1980, by the Census. That is way over a 20 percent
increase in the total housing inventory in a three-year period.
He find that of these new housing units, 2300 were occupied
by new permanent year-round residents. This was an increase
__	p - 15
of 19 percent in a three-year period over that reflected in
the 1980 Census.
The number of permanent residents increased by April 1,
1983, from 35,777 reported as of April 1, 1980, to over
42,000. That was a significant increase, over six percent a
year, for each of these three years. That growth rate is now
accelerating. EPA should be aware that with a permanent
resident population of this size, in addition there are over
75,000 separately owned land parcels in Brunswick County.
We just sent out our tax bills — I have the records. Most
of these are small lots, 50 by 100 feet. That is all they
are, and they are going to live on them some day, these
retired people as they come in.
There is no way that septic tanks can be erected under s1
<
the laws of North Carolina in such conditions. The munici- J
pality of Long Beach, as one illustration, has over 10,000
lots of record already, separately owned.
On page 45, the statement is made: "It is generally
assumed by state and local officials that the same number of
persons will be attracted to the North Carolina barrier islands
regardless of what type wastewater management systems are
provided." Mr. Crum, you repeated this in your preliminary
remarks. I can assure you that assumption is not shared by
the health officials of the state or of Brunswick County.
Before your deadline one week from today, of August 30,
P - 16
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Steven B. Martin, who was Health Director of Brunswick County
until early in August, and is now in charge of the Division of
Health Services for the eastern one-third of North Carolina,
will file a report with you testifying to the effect that de-
velopment not only of the barrier islands but also of related
mainlands — a term we still wonder what you mean by — will
not be possible under the present pattern of land ownership
and lot ownership with septic tanks as the general mode of
wastewater treatment without major increase in water pollution
Me are not sure what you mean by "related mainlands." I
/
have personally asked that question since the inception of thes
<
Eis, and asked that you define that term so that we would knowjjj
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o
what we are dealing with and what you are dealing with in our 5
7
county as to the impacts upon us.		=
—i.
We again point out that over 76 percent of the permanent?
residents of this county are not in any of these 14 munici-
palities, these barrier island communities, but are permanent
residents in a definitely emerging urban confluence that would
have over 80,000 people in it on the mainland across from the
islands, and with 50 by 100 foot lots, which is all they have,
septic tanks or even the most innovative systems imaginable
are not an acceptable substitute.	_
I have not dealt with the issue yet of the seasonal
resident numbers. There are too many cohflicting opinions as
to what that increase in our population is. I am not sure,
-	P - 17
but I hope you are aware, that the so-called "cottages" along
our beaches are indeed commercial operations ranging in some
municipalities from an average of eiqht bedrooms per cottage
to, in others, an average of 12 bedrooms per cottage. That
is a significant increase in population for what has been a
five—month season and is an expanding season from alJ reports.
That is a lot of additional people for peak loads.
Septic tanks, innovative individual wastewater treatment
sytems, and packaged treatment plants for individual apart-
ments or condominiums or malls or what have you are an
inadequate future. He must have as a minimum coirnnuiiity
wastewater treatment systems. We urge this EIS be xe-
evaluated as to its findings. We are apprehensive of the
impact of this EIS. We are aware that domestic programs are
a thing of the past. We are not looking to that. The joint
municipalities of Oak Island (phonetic), which includes
Caswell Beach, Yaupon and Long Beach, are today and have been
for some months in dialogue as to the public sector at least
providing a community traditional wastewater treatment system
for that 12-mile long urban area. Is the impact such that
inadvertently the pervading process would not permit local
governments to meet their destiny regardless of the fact that
we know there will be no Federal monies available?
Recently we have had to "close out" the 201"s in
Brunswick County. We did so with an understanding with the
P - 18
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1
2
1
4
5
6
7
8
9
10
11
i?
13
14
15
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'7
IP
19
20
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27
23
24
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state that these were left open ends, at our demand. I
received a call yesterday from the EPA office in Atlanta
that we had to bring five forms assuring this was a total
close-out.
In your draft. Technical Reference Document Alternative:
Development Report, page 46, you make the statement: "BPA
proposes to make additional step funds available." Walter
Taft, Head, Construction Grants Section, Environmental
Management Division, North Carolina Department of Natural
Resources and Community Development, assures me at my re- o C.
peated calls that in March, and April, May, June and July i|
EPA has demanded that the 201's of the barrier islands	sj
o
related mainlands be closed out. At first, we thought	<
perhaps the left hand of EPA did not know what the right hand *
of EPA was doing. Here you are saying, "We are going to move J
onward," and you are going to give us more money to do it.
On the other hand, the state tells us they absolutely and
and totally are to be closed out and that is the end of it.
We need answers to these things.
This was the end of what I had prepared. Until review
with others, we are apprehensive that the study has been done
with more consideration to nature than to roan.
MR. ZELLER: Let ne make a brief comment.
MR. HARVEY: I will have no further comments.
MR. ZELLER: Fine. Let me comment then on your comments.
p - 19
The reason we are here, of course, is to receive a reaction
from you and others and to raise whatever questions that you
think are pertinent in terms of the document that we have
presented. You have raised some very cogent issues, in my
opinion, and very clearly the purpose of our holding a hearlnc
on a draft EIS is to assess on the part of you and other
individuals whether our data base needs to be modified in
some cases, as you pointed out in population projections,
and whether we need to address certain issues in the final
EIS when it is finally promulgated, and it will be promul-
z
gated in a short period of time after we hold the hearing s
<
u
on the draft.	S>
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Secondly, let me just simply comment by saying that <
Z
I do not believe that we meant to imply, or did not imply — s
let me clarify that. We did not intend to imply in any way I
in the process of presenting the strategy that septic tanks
were the only system that was available in terms of waste-
water treatment. We simply implied that a strategy should
be applied on a case-by-case basis to all particular
situations, and combinations of whatever is the best environ
mental solution to that problem should be utilized rather
than accepting an up front assumption that the only way we
could accomplish what we want to accomplish is by building
a regional system and a regional collection system which
could be very costly and not as effective in terms
P - 20
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of getting the job done.
MR. HARVEY: I no longer advocate a regional system.
My remarks said "community systems," Mr. Seller.
MR. ZELLER: Thank you. I appreciate your comments.
They are good comments and they will be responded to in the
final EIS. Thank you very much.
Next I would like to ask Mr. Paul Denison, who is Vice
President of Henry von Oesen and Associates. He is repre-
senting several of the coastal communities here. Mr. Denison
please state your name for the record, and we will be pleased
o
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to receive your comments.	is
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X
STATEMENT OF PAUL S. DENISON,	£
HENRY VON OESEN AND ASSOCIATES	|
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MR. DENISON: Mr. Seller, Mr. Crum, ladies and gentlemen*
<
as mentioned, I am Paul Denison of Henry von Oeson and Asso- 5
ciates. Consulting Engineers and Planners in Wilmington, North
Carolina. We represent not only our own views, based on many
years of engineering planning and design experience on the
entire southeastern seabord, but also the interests of numerou^
communities that we serve in the coastal area of North
Carolina. Thus, we appreciate this opportunity to comment on
the North Carolina Barrier Islands Wastewater Management Draft
Environmental Impact Statement.
We feel that this EIS exercise by EPA has imposed what
we feel is an unconscionable three-year delay in resolving
21
treatment and disposal problems on the North Carolina barrier j
islands. During this delay period, the costs for all alter- |
native solutions to the problem have escalated considerably.
The total amount of Federal funds allocated to the state of
North Carolina for corrective actions has been diminished by
attritional use and by budgetary cuts. The state's Clean
Water Bond Act grant fund which is used for matching Federal |
I
grants has been depleted. As a primary result of the mora- J
torium on actions imposed by the IES drill that we have been j
I
going through, all barrier island projects on the North	k',
Carolina Construction Grants Funding List have slipped in r
priority so that funds for facilities design and construction 2
<
C
will not now be available until Fiscal Year 1986 or after. i
7
By that time, the Federal participation portion will be	p
limited by law to 55 percent of the eligible project costs,
rather than the 75 percent enjoyed at present.
In view of these developments, it is impossible to
accept the fact that the so-called EIS Strategy calls for
further revisions to the 201 Facility Plans which will result
in further bureaucratic delays in resolving the problems
that exist. Several'local units of government, completely
frustrated by these events, have wisely elected to abandon
the 201 Facilities Planning process entirely and to pursue
other viable solutions independent of the EPA Constructions
Grants process, as just mentioned by John. This abandonment
P - 22
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t
2
3
4
5
6
7
8
9
10
11
12
13
0"> is
20
21
22
23
actually may be an EPA objective, but in our opinion it was
not Congress' intent when they passed Public Law 92-500.
In summary, and as a considerable oversimplification,
the BIS recommends the continued use of septic tanks and so-
called "community systems" as the least-cost solution to
existing wastewater disposal problems. Mr. Crura gave us a
very concise run-down, 1 think, on the ingredients included
in the barrier islands strategy. As Mr. Zeller just men-
tioned, this does not finitely conclude that septic tank
sytems must be used, but I think the EIS strategy proposed
in the report is pretty implicit in its intent.
We feel that this position is inconsistent with recent
scientific research and even prior EPA studies which show
that septic tanks do cause pollution of surface and ground
waters, and we have attached to this letter a series of
references which we think are extremely pertinent, only a
part of the reference files that are available on this subject
We feel that the inadequately supported and less than
scientific position taken in the EIS will only exacerbate
existing problems, not really solve them.
Many of the Barrier Island 201 Facility Plans which
preceded the EIS showed that central sewer systems could bo
designed and constructed with Federal and state grant assist-
ance for user fees in the range of $12 to S18 per household.
In all proposals we are familiar with, wastewater contaminants
P - 23
were effectively removed from the barrier islands, their
related groundwater systems, and their adjacent fragile
estuarine waters.
We get the impression — and I think it was reiterated
again — that EPA simply did not want to fund any of these
projects or solutions recommended in the 201 Plans based
on the fear that solving a sewage disposal problem would
stimulate growth on the barrier islands. However, despite
the delays and lack of aggressive action to resolve waste-
water disposal problems, significant growth has occurred in
all areas, all the barrier island areas along the North
Carolina coast. Again, I think that John's very concise
summary of what has happened in Brunswick County is only
partially exemplary of what we have been experiencing during
the three-year hiatus that we have been in along the entire
North Carolina coast.
Now the Federal funding picture has altered to a state
of unfavorable economics, but the development and increasing
pr^lution potential goes on and increases. More septic tank
ar 1 so-called community systems, the cluster systems describ
in the EIS strategy, are sinply not the answer. We need to
get on with the business of truly resolving the problem,
not restudying it.
Enough time and money has been wasted already. We are
confident that time will continue to demonstrate that this
P - 24
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proposed EPA Barrier Island EIS expenditure of time and money
has been another futile exercise that produces no solutions
to what we feel seriously is a continuing and growing problem.
Mr. Seller, we thank you for the opportunity to make
this statement.
MR. ZELLER: Thank you for your statement. We would
be very much interested in pursuing the technical references
that you cited. Certainly we will make every effort to be
sure that our technical and scientific data base is accurate
in terms of the statements that we have made. I appreciate
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your providing that information and your opinions are also £
5
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appreciated.	£
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I agree that the growth issue clearly has to be analyze^
and if what we are talking about in terms of population pro- i
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sl
jections is different than what we proposed in the EIS, then 5
that absolutely has to be looked at.
The other issue I will not try to get into in detail
because it is a very complex issue, and I do not have to
tell you, Mr. Denison, you are very familiar with how priority
lists work relative to receiving grant dollars to build
needed facilities throughout the state of North Carolina,
and through the Southeast and throughout the United States.
There simply are not enough grant dollars to go around for
all of the projects that have been identified, and the
priority list is a process whereby the state implements a
'	P - 25
procedure of placing projects on priority lists and funds
those in accordance with a certain formula. There have been
problems, as I understand it, relative to facilities reaching
the stage where they could be funded on a priority list,
which is no one's fault. We are simply short on dollars
and have need for facilities. Perhaps we might want to have
some comments on that.
Mr. Jamison, do you have anything by way of a comment
along those lines? Hopefully, you agree with the general
j
statement that I made. The priority system is a system in i
place in North Carolina and one that we all have to operate j?
G
under, but certainly we want to do everything we can relatives
O
to this strategy to try to see that we get the job done.	*
Thank you very much for your statements, and we will ='
respond to those in the final EIS.	i
The next speaker that I have is Mr. Don Willets, who |
I
represents Alternative Systems in North Carolina.
Mr. Willets, are you here, sir?
STATEMENT OF DONALD WILLETS,
ALTERNATIVE SYSTEMS, NORTH CAROLINA
MR. WILLETS: Mr. Chairman, distinguished guests,
ladies and gentlemen, I am not a speaker; I am a country boy.
You will have to excuse me for not having my jacket on up here.
I represent Alternative Systems. We hold the franchise
the territory for Jet, Incorporated. Jet carries our own
P - 26
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I
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VO
11
\7
13
14
t5
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21
77
23
plant system, as you are referring to in 201.
Let's go back for a few minutes, and let me say this.
The situation here reminds me of the preacher who moved to
the mountains. It took him all week to get his family moved
so he could hold services on Sunday. He got up Sunday morning
real early, at the crack of dawn, took his mule and went over
to the church and, lo and behold, there sat one parishioner
sitting on the church steps waiting for him. They talked and
carried on until something after 10:00, and the preacher
turned to the farmer and said, "Sir, what do you do in a
z
situation like this?"	i?
He says, "Well, when I go out to feed my cows, I take a
Q
a load of hay." He said, "Whatever cows show up," he says, <
"I feed them."	~
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The preacher says, "I understand. Let's go inside." Z
They went in and the preacher commenced to put on his sermon,
and he done a real good job, and he come out at the end and
he said, "What do you think of my sermon?"
He says, "Preacher," he says, "I didn't tell you if
only one cow showed up I gave him the whole durn load of hay.
Now, with that in mind, X am not going to try to get
into full details of what the Jet system does or does not do,
and try to get into any arguments about wastewater treatment
versus septic tanks.
Let's take a short look at the span of life we have
-	p—
come here in. When we landed on these eastern shores of
North Carolina, when we hit the land it was a relief to get
off the boat. We found from farmers that we had made a mess
that they had to avoid. So then we found if we got near a
stream, water, or whatever, we disposed of that, because only
.004 percent of your waste is solid; the rest of it is all
I
water.	i
I
From there, they learned what the Indians did. They
camped near the watergrounds, or whatever, and let the streams
take care of it. In the Boy Scounts, along those lines, you
find that if you walk downstream for 100 feet or so, you can £
drink the water and it is purified and it is clear and it is s
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good water. DEM tells us this today. We can dispose of it S
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if.it is treated properly.	|
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With this in mind, we made a great contribution to the 3
history of America. We found out that everybody could not
live on a stream. Some of us had to live inside. So we
went and built what are called privies. Today, under North
Carolina state health regulations, privies are permitted
but septic tanks are not in hard pan and soil clay today
still.
He found out from that that he could dig a drainage
ditch, and today you still carry that form, a drainage ditch,
and I believe it is probably notified as a nitrification
field. It is not a drainage ditch; it is a place to treat
P - 28
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the sewage that you are disposing out there.
So from there, he found out that he could close it up
and he could move it inside, and we came up with our septic
tanks for today. From our septic tanks, we still have our
nitrification fields even today, that we started years ago
with, and our effluent is literally trapped in the rocks
that you burn in the bottom of this nitrification field.
This throws your water up so that it mixes with other water
The ground does not absorb any water. The water runs free.
It flows to its natural source. It only mixes with that
water or diluting factor.
With the Jet system, on a home plant site, we treat
this water in the tank, the same methods used by using your
streams. We trap the solids and retain the solids. Then
we put in aeration, the same thing that you are getting from
here, the air. We put the air in and we stir it, the same
effect you have got running down the stream.
Your septic goes in, on the septic tank side of it,
and the approximate BOD goes about 200, 250, somewhere in
that category. After it has set in and is settled in, it
increases a little bit and goes into the 300 category, 350.
On the Jet site, it comes in from the same side, but through
aeration and treatment from the home system side of it, then
we come out with a BOD from 30 to 50. You can see there is
quite a reduction.
_	pVii"
According to the Soil Conservation people in Brunswick
County, we can take a hard pan or clay area and use evapora-
tion, transportation and these type items to dispose of the
water well. We come out with NSF-approved water. By the way,
we are one of the six NSF-approved, aid we are larger than all
five of them put togehter.
With this in mind, we come out with a treated effluent.
We can put chlorination to it. In some states they are using
chlorination behind it and using the same water because it is
definitely good fertilizer.
In Mississippi, the low-lying areas, they are using it
extensively down there, which is about all they could put in.
In the western part of North Carolina, you have got over 300
systems, according to the distributor over there, and they
are taking it to the nearest lying stream and dumping this
water. This water comes out with 86 or 87 percent removal.
You can put on up-close filters and bring in 97, 98 or 96,
in that category of treated effluent, treated water, so you
come out with good, clean water. No, we do not meet the
water qualification records with it yet because they are
saying you have got to have it clean within 10 feet; we
cannot quite do that.
But all we are doing is taking this water out of the
Jet tank, putting it through some small gravel, small rocks,
and in turn, every so often if you take the manual side, you
P - 30
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go in and you rake these rocks, wash them with a water hose,
and, lo and behold, you are ready to treat some more water
well. You could put in an automatic system that automatically
backwashes with it.
Now, when it backwashes, all it is doing is taking and
washing these particles back off of the rocket trap. This is
what your nitrification field is doing today. You get the
torrential rains, you get the low water tables you have got
around here, all you are doing is backwashing. So then you
have got all of your effluents consolidated into one overflow
going to your rivers and streams. So a home waste water	to
treatment can eliminate a portion of what you are doing, and ji
O
what we are going through today is this: Does the individual <
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pay for it at his own home, does the Federal Government pay |
<
2?
for it through tax dollars, or do we keep on polluting.	|
Thank you.
MR. ZELLER: That is all of the people that indicated
they wanted to speak when they registered. Since we have had
some discussion here, is there anyone here that has changed
their mind and would like to make a statement? I think it is
important that you do so.
Would you like to make a statement?
MR. FURGER: Yes, sir. Would you prefer that I be up
there?
MR. ZELLER: Yes. Please come up and identify yourself
so I can get your name on the record. I want this on the
record.
MR. FURGER: It might take me longer to walk up there
and back than to make the statement.
MR. ZELLER: If you want to give me your question, then
X will repeat it for the record.
Could you give me your name, please?
MR. FORGER: I am Jim Furger, F-u-r-g-e-r. X live in
New Hanover County, and my remark was in the vein that this
report, I did not ever receive the report. I want to and I
want to read it. I think part of the report referred to
groundwater runoff as being a special form of pollution of
shellfish beds, fisheries beds, and having a bad effect on
perhaps the groundwater later on, maybe having an effect on 3
the reserves; is that right?	5
«
MR. ZELLER: You are talking about generally surface
runoff?
MR. FURGER: Yes, surface runoff. So I think that most
of the people here seem to be inclined or agree to the effect
that many of the water site areas and barrier island areas
are going to be extensively developed, which I agree that
they probably will, but I think that it is incorrect, accord-
ing to this report, to make all of your comments referring
only to central sewage system plants when, in fact, your
problems on barrier islands and problems where development is,
					 "			 " P - 32~
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there is concern over development in the areas along waterways
and such as that, is that there are many forms of pollution.
If you are going to worry about pollution, there are a lot of
ways it is going to be polluted, and what it ultimately is
going to boil down to is the density of development. There
is more than one study that has been done that talks about
the density of development on barrier islands and other places
like that. Wildlife nuts like me have been talking about this
sort of thing through the years and the problems that are in
this report that we are talking about right now, these enviroi^
Z
mental extreme people have been talking to the rest of you 8
, H
for more than 20 or 25 years, and 1 think what you are going a
o
to have to face is that each local area, in order to preserve 5
z
and have nice places around the streets and the houses and j|
4	<
motels and condominiums, if you came down here just for a g
<
building, then you can go anywhere and get that, but the
people who come here to live in the buildings that you build
for them to live in came down here probably because there
were not quite so many buildings to begin with. So my con-
tention is that this study points really, if you think about
the study, it points a lot further than sewage disposal. It
points on down the road to the fact that people who live in
these areas are going to have to force themselves to limit
the number of buildings, the number of spaces for people to
live in their communities.	__
p _ 33
MR. ZELLER: Thank you. That is a very good point, and
I guess one that all of us recognize that have been working
professionally in this area for any number of years, that
wherever you have the most people you have the most pollution
problem, and I think you have correctly pointed out one of the
most serious problems that we are facing in the country today
that we generally record under the heading of nonpoint source |
pollution, but it involves those things that run off from
the land, whether it be pesticides or fertilizer or bacteria
that cause shellfish areas to be closed, or whatever the case.
The nonpoint source of pollution is a very, very serious
problem in the ccftintry right now, and drainage from agricul- '.i
O
tural lands and mining areas and a great many other problems J
like that are significant contributors to the overall problem iv
and indeed need to be recognized. As we have increasingly
-t
built up, we have increasing problems. I think we all have
to face those kinds of issues.
Is there anybody else who would like to make a statement
at this point, or comment, or ask a question?
MR. BURNETT: I am Bill Burnett, with von Oesen Associ-
ates. What is the schedule from this point on?
MR. ZELLER: Let me ask Bo Crum to respond to that.
MR. CRUM; Okay. Bill, I think, as mentioned earlier,
the comment period ends August 31, and just as soon as we can
respond to the comments at public hearings and comments that
P - 34
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we receive through the mail, we will put together a final EIS
and getting that mailed out. As far as the schedule and that
goes, I would estimate that surely by the end of the year,
the end of this calendar year, we will have a final EIS pub-
lished, or close to publication. It takes four to six weeks,
once we get all comments in and put together, to file them
and then we have to have it published and so forth, and that
takes a while. But I would guess that by the end of the
calendar year we should do that.
I want to point out, in case everyone does not realize o
it, that we will respond to each and every comment made by S
8
each speaker tonight and at the other two hearings, and also 3
O
each comment received by mail. The public hearing transcript <
will be published in the EIS, as well as all the comment	2
<
letters we receive, and each comment will be responded to. |
MR. DENISON: Paul Denison here, and I would remind
Mr. Crum when we started this exercise of drafting three years
ago, we were going to have a draft EIS in less than nine month 1.
I hope we will do better in maintaining this schedule.
MR. ZELLER: Mr. Denison, I am going to continue to
remind Mr. Crum of the statement he made here tonight, and I
assure you that the final EIS will be out before the first of
the year.
MR. DENISON: To continue my question, I hope that I
will not be considered out of order if I ask what is the
			- - 			35
current cost of this study we are discussing?
MR. ZELLER: Of the EIS?
MR. DENISON: Yes.
MR. ZELLER: I simply do not know the answer to that.
MR. DENISON: Maybe Mr. Crum knows.
MR. CRUM: The cost at this point in time, and it will
not increase any, is 5545,000.
I see some people shaking their heads, and I would like
to point out that that cost is not only the research that went
into publishing the EIS, but it includes a number of tools
that we mentioned earlier, and this is a natural resources
data base, which we will be providing the computer tapes to
the state agencies or anyone else who wants to use them. It
includes a number of technical reference documents. There is
a lot of good information concerning design and criteria for
various types of systems, and so forth. I think probably the
financial handbook and work sheets that we put together is
part of that cost, which, I might add, was very well received
at the workshops that we held up and down the coast a while
back. I think some of you attended those workshops. We
found that those responsible for financial planning for small
communities were very interested in that, and I think it will
be one of the tools that is well used. I think the groundwate,
predictive model and method for predicting the effect on
groundwater level and on the groundwater quality will be a
*	 "	' "	" P- 36
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very useful tool. In fact, that Is one area where no good
hard data exists today, and It makes it difficult to assess
the impact of these systems when you plan for wastewater
management and, therefore, the development of that tool alone
through the BIS process, which is included in that cost, will
be a very significant tool in wastewater management planning
in the future.
. MR. ZEIiLER: The groundwater studies, I think, were a
significant cost to this whole project. However, I think
that was one of the most important areas, obviously, that had,;
to be analyzed in order to determine what kind of an impact r
the septic tank systems have on water quality, and water i
O
quality impacts obviously the groundwater. This is the place |
we have to go to get answers to those kinds of questions and 2
UJ
we need to have those questions answered. Anything you do 3
relative to sampling of groundwater is costly, but as Mr. Crust
mentioned we came up with some very important information that
is going to be applicable in many, many other areas of the
country in assessing these same kinds of problems. It is very
difficult to always come up with an answer and say for the
dollars that you spend on scientific, technical engineering
investigation, do you get a return for that. I cannot always
answer those questions but as we continue to develop informa-
tion in science and environmental engineering, we are much,
much better able to do our jobs. We simply have to proceed
P - 37
in this vein.
MR. DENISON: Mr. Zeller, as a user of these tools, I
heartily endorse what you and Mr. Crum have both said in that
respect.. I think our only point is that this vehicle has
been a difficult way to accomplish these tools, and then
again, from our experience in the use of those modeling
systems, we find that they are evolutionary and constantly
changing, and I think that each step that we take is a step
in the right direction, and we welcome those new options. j
If I might, I would like to respond to your comments ^
on the prioritizing and priority list. It was not clear in j?
ij
my first statement, but I think the point that I was trying |
C
to make was that a number of these communities that we are "
concerned with, coastal communities, were on the priority ^
list at the time the decision was made to prepare the EIS. %
That, in fact, became an effective moratorium. They com-
pletely rearranged the state list, and these communities
which were in pretty good shape at that time in getting a
handle on the problem were denied that opportunity, and now
are told to come back and get on the new list beginning in
1986.
One other point again that I think was not explicitly
clear. He are talking about basic philosophical and technical
differences of opinion in the use of subsurface disposal
methods for wastewater effluent in the barrier islands
P - 38
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systems. Of course, there is some other possibly more tried
and true, and admittedly more expensive alternative, to remove
those contaminants from the barrier islands themselves. A
key point that we cannot accept is the insinuation in the EIS
that it has been determined that the contamination of our
shellfish waters in the sound area is a result of point source
discharge from the mainland, ignoring the fact that the same
situations do exist on the barrier islands. We are prolifera-
ting that problem head over heels in a fashion that you cannot
believe until you get out there on those islands and look, and^
we are still talking about the reanalysis, the costly re- J
analysis of going back through an exercise to conclude again *
that we should either continue this process of subsurface
disposal through septic tanks methods, the minor alteration
thereof, or ultimately conclude to go back to a more simple 3
system, whether it is regional or subregional, whatever it
might be, to provide a more lasting and more viable solution.
I think that really is the gut of our concern from a technical
point of view, and certainly reflects the opinions of the
boards and commissions that we are constantly meeting.
MR. ZELLER: X appreciate that concern very much. Your
point is very well make. Throughout the EIS process, in dis-
cussing strategy and the process of following the strategy, we
have put forth certain options and alternatives we looked at.
In some of the case studies that were utilized, it appeared to
P - 39
15
1	be a significant cost saving and indicated an apparent
2	better route to follow. As I indicated earlier, I do not
3	think the EIS intends to propose any set system in any way.
I think we are trying to address the issue of saying — which
I think we need to do much more of in our total environmental
6 programs, is look at the problems on a case-by-case basis afel
' there will be many circumstances, I am sure, where regional
8	collection systems — not necessarily regional collection
9	systems, but collection systems afid treatment systems are
,0 . going to be the answer to the problem. There will be other
7.
instances when subsurface treatment will be the answer to the t
<
c
problem. I think we should feel free to go in and use the |
C
'3 best possible combination for least cost to the user of these *
u systems, to the government and to everyone concerned, if we i
'5 can meet those same objectives in maintaining water quality, "
16	and that is what we hope to do in the process of developing
17	this document. I think it is helpful in that regard, and
18	will be useful in that regard.
Again, I appreciate your comments. I understand
exactly what you are saying. They are well taken, and I
21 think we should try, Mr. Crum, in our response in the final
?? EIS, I think we should address that priority list issue in
23 some detail, and get back and clear the air of that issue.
I am not prepared to do that at this time, but I think we
5 should do that in the final EIS, and we will.
p - 40
.M
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MR. ZELLER: Is there anyone else who wishes to speak?
MR. CLARK: Question of information in the water
quality statement, the only exception that has been documented
is problems in several different houses. Any of those in my
particular area?
MR. CRUM: As I recall, in an area adjacent to Ocean
Isle Beach was the one area, I believe, in Brunswick County
that was a documented case.
MR. CLARK: Any monitoring of those now?
MR. CRUM: Ongoing at the present time? Not that I —
7
well, excuse me. The shellfish sanitation people that	2
y
operate out of Beaufort peridically monitor all those areas. ^
»	a
In fact, it is their determination which decides whether an 5
Z
area is to be open or closed, so they do take samples for |
choliform bacteria.	5
MR. CLARK: That is not practical for a private person
to monitor?
MR. ZEIAER: Really what we are talking about is monitor-
j ing for bacteria, largely for water quality, and that requires
| a special facility for culturing organisms and counting those
j organisms to determine the number that will be involved.
MR. CLARK: Is that done by Public Health?
MR. ZELLER: Yes.
MR. DENISON: Mr. Zeller, because there is an interest,
we are in the process right now of establishing a monitoring
		 	p _ 4I	
program in the area described by Mr. Cmm as a cooperative
effort between local interests and the Division of Environ-
mental Management. We hope to have that program on the line
in the next 30 to 45 days.
MR. ZELLER: I am pleased to know that. That is very
good.
MR. CROM: Very good. That data will be useful.
MR. ZELLER: Anybody else?
Again, our purpose for coming here and meeting with you
is to try to answer your questions and clarify all the issues
anybody wants to raise.
MR. V&UGHAN: I ought to keep my mouth shut because it
is philosophical, but if nobody else is going to ask any more
questions, I would sort of like to go. I am not much of a
poet, but scne poet said, "What fools we mortals be," did he
not?
MR. ZELLER: Some poet did, yes, sir.
MR. VAOGHAN: Obviously what you people are dealing
with is people pollution. Have you made- any studies as to
whether or not in Brunswick County the population on the
beaches and the sound continues to accelerate at the present
rate? Say by the year 2000 will pollution have reached the
point where everything will be so nasty"that nobody will
want to cone here anyway? Are there any studies of that
kind?
P - 42
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MR. ZELLER: I do not know of any specific studies of
that type that have been made. Again, your point is well
made and X appreciate and understand what you are saying.
1 think we intend to address these kinds of problems on the
development of adequate waste treatment systems. That is the
only way in the world we are ever going to survive as we
increase in population and we, of course, continue to do that.
We talked about a system here tonight of strategies that
J would be responsive to increases in population. I do not knov
j that anybody has at this point in time made any specific	o
studies to project what kinds of environmental impact we mightiS
expect in Brunswick County by the year 2000 in anything other sj
O
than a general sense. Mr. Denison, maybe you know of some <
studies that I do not know of.	2
<
MR. VAUGHAN: So the poet was all right when he said, |
! "What fools we mortals be"?
|	MR. ZELLER: He was not all wrong, no, sir.
|	Could I have your name for the record?
MR. VAUGHAN: M. H. Vaughan, V-a-u-g-h-a-n.
MR. ZELLER: Thank you, Mr. Vaughan.
MR. DENISON: I think Mr. Shakespeare was more known
for writing than poetry, but Mike's point is well taken.
In answer to your question on case studies, there is
the coast of New Jersey. In answer to Mike's point, people
still go there by the millions.
P - 43
MR. ZELLER: Yes, sir? Let me have your name again for
the record, please.
MR. FURGER: Jim Furger. I guess this is more of a
philosophical question, too. As the gentleman pointed out —
Mr. Denison — in the case of New Jersey, the people are
still coming to New Jersey. But what are they coming there
for, if they are still coming? Isn't it gambling?
lLaughter.]
MR. ZELLER: I think we have about covered the material
Thank you. Thank you all very much. This has been a small
U
Z
meeting, but I think a good meeting, and I appreciate your £
being here and the comments you have made. Hopefully, this |
<
c
has been worth your time. It certainly has been worth my S
z
time in hearing what you have to say, and I appreciate your £
turning out.	•
Let me make a few statements for the record to formally
close this out. As Mr. Crum indicated earlier, the hearing
record will remain open until August 31. If anybody here
would like to provide a written comment during that period,
please do so. We will accept any written comments. They
should be sent to Mr. E. T. Heinen, whose name and address
appears at the bottom of the Agenda that was given to you
when you came in. So if you have any written comments, send
them to Mr. Heinen at that address.
Again I want to thank you all for being here, and we
p - 44~"
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appreciate your comments. EPA is committed to assisting
local governments in resolving public health and water
quality problems in a cost-effective way, and your constants
are going to help us meet that goal*
All of the words that were spoken tonight will be put
into the transcript and responded to in the final BXS, and
it will be the final decision in the summary of the draft EIS
and any pertinent additional information or evaluation
developed since publication of the draft, cownents received
and EPA responses. A transcript of this hearing will also ^
be included.	g
<
Those of you who coranented tonight or who submit	|
o
written comments will receive a copy of the final EIS. That |
is one of the reasons why we wanted you to register.	3
<
3
Thank-you again for being here. We will be here for |
a little while and would be pleased to talk to you if you
would like to do so after we adjourn the meeting.
No other information cooing forth-for the record, I am
going to close the hearing.
(The public hearing in the
above-entitled matter was
adjourned at 9:15 P.M.)
P - 45
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NORTH CAROLINA BARRIER ISLANDS
DRAFT ENVIRONMENTAL IMPACT STATEMENT
PUBLIC HEARING
HELD AT
NORTH CAROLINA MARINE RESOURCES CENTER
BOGUE BANKS
PINE KNOLL SHORES, NORTH CAROLINA
AUGUST 24, 1983
8:00 P. M.
PRESIDING:
MR. HOWARD ZELLER
and
MR. BOWMAN CRUM
Eaitctn Court ^Reporting <5ezoice
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INDEX
OPENING OMMMENTS, MR. ZELLER:
COMMENTS, MR. CRUM:
MR. CRAIG COGGER:
MS. KATHY GALLVECI:
MS. FLORA H. GARRETT:
MR. TODD MILLER:
MR. STEVE J. STEINBECK:
MR. JOHN MELVIN:
MR. BILL PRICE:
MR. DAVID CLEMENT:
CLOSING COMMENTS, MR. ZELLER:
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The hearing was called to order at 8:10 P. M.
Mr. ZELLER: It's a little after eight o'clock, ao I would
like to go ahead and open the public hearing. If any other
individuals cone in late, they can register and become a
part of the hearing as we move along. First of all, I
want to welcome you to this public hearing tonight. He are
very pleased to have you here, and receive your comments on
the Draft Environmental Impact Statement, which addresses
wastewater management for the North Carolina barrier islands.
My name is Howard Zeller, and I am the Assistant Regional
Administrator with the Southeastern Region of the United
States Environmental Protection Agency. My office is in
Atlanta, Georgia. With me is Mr. Bowman Crum, who is the
project officer for this EIS. I would also like to intro-
duce Doctor Claude Terry, who is at the registration table.
Dr. Terry was our consultant, who was involved in the
preparation of the Environmental Impact Statement. The
purpose of this evening's hearing is to receive public and
other agencies comments on the draft environmental impact
statement for the North Carolina barrier islands. The EIS
that we are talking about provides guidance and procedures
for local governments and their contractors to assist in
planning the wastewater facilities. Preparation of the
facilities plan is the first step in the EPA's three step
construction grants program for wastewater management.
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To be eligible for Federal funding, proposed facilities
must be part of an approved facilities plan. The facilities
plan must identify the least costly means of resolving
public health and water quality problems resulting from im-
properly treated sanitary wastewater. Steps two and three
of the construction grants program will offer design and
construction respectively. These steps, of course, follow
completion and approval of a facilities plan. Only one of
the Draft 201 Facilities Plans for North Carolina barrier
islands has proposed a construction of extensive wastewater
collection, transportation and treatment facility to serve
large portions of these islands. After an environmental
review of the proposed facilities, EPA has significant con-
cern about the potential Impacts, and the cost of these
facilities. The National Environmental Policy Act, or NEPA,
requires Federal agencies to prepare an Environmental Impact
Statement on major Federal actions that significantly effect
the quality of the human environment. Because of the en-
vironmental complexities and the water quality issues that
have been involved in these projects on the barrier islands,
EPA made a decision to prepare an Environmental Impact State-
ment. In September of 1980, the notice of Intent to prepare
an EIS was issued, and this public hearing tonight is being
held to receive comments on the Draft Environmental Impact
Statement. EPA, as always, wishes to encourage public
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participation in the Federal decision making process, and to
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develop improved public understanding of Federally funded
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projects. Draft EIS was made available to the public in
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EPA's office of Public Activities, on July 11th, 1983, listed
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in the Federal Register on July 15th, 1983. The comment
S
period on the Draft EIS will extend until August 31st, 1983.
6
Comments received this evening and during the comment period,
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will become a part of the official record of this Environ-
8
mental Impact Statement, and all of the questions that are
0
raised here tonight will become a part of the final Environ-
10
mental Impact Statement when it is issued three or four
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months from now. Before I receive testimony from the floor,
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we have an indication that quite a number of people wish to
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testify tonight, I'm going to ask Mr. Crum if he will pro-
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vide us with a summary of the pertinent issues in the
15
Environmental Impact Statement. If you would do that, Mr.
16
Crum, I would appreciate it.
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MR. CRUM: This Draft Environmental Impact Statement, or
18
EIS, has been prepared in response to issues raised during
19
the review of five draft 201 facilities plans. These plans
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proposed the construction of wastewater collection, trans-
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portation, and treatment facilities to serve large portions
22
of North Carolina's barrier islands. Through the EIS pro-
23
cess, wastewater management alternatives for the barrier
24
islands were developed and evaluated and a strategy is
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proposed. The review of these draft 201 plans and the
scoping process for the EIS, identified six basic issues to
be addressed. The issues and the major conclusions of the
EIS are as follows:
Issue number one - WATER QUALITY- It is important to
identify existing water quality problems in order to deter-
mine the need for additional wastewater facilities. The
draft 201 plans pointed to septic tanks on barrier islands
as the reason for closed shellfishing waters. The data
reviewed through the EIS process do not confirm this con-
clusion. Surface runoff from the mainland appears to be
the cause of the closings except in a few isolated cases.
ALTERNATIVE WASTEWATER TECHNIQUES- Issue number two.
The draft 201 plans do not fully evaluate on site and
community system technologies for wastewater management on
barrier islands. The EIS has found that these systems may
provide more cost effective solutions to solve existing
water quality and public health problems, while providing
for desired development. The EIS proposes additional site
specific analyses of these alternatives.
Number three - FINANCIAL IMPACT ON LOCAL GOVERNMENTS -
Providing wastewater treatment is a major financial under-
taking for a community and its residents. The financial
and management implications to the local governments and the
system users can be significant. The draft 201 plans do
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not demonstrate the financial and institutional capability
of these communities to support the proposed system. The
EIS provides guidance for local governments to evaluate and
resolve the9e potentially severe Impacts.
Number four - NONPOINT SOURCE POLLUTION - Shellfishing
waters have been closed where sewer systems exist in
coastal areas of the Southeast. Studies have shown many of
these closures to result from nonpoint runoff. New waste-
water facilities may promote higher density development,
thus increasing the potential for nonpoint source pollution
of estuarine waters.
Issue number five - GROUNDWATER - The potential impact
on groundwater hydrology and goundwater quality is a mjaor
issue when considering soil absorption wastewater systems.
Although few of the barrier island communities use the sur-
ficial acquifer for water supply, the effects of any pro-
posed system on groundwater should be carefully considered.
The EIS proposes a method for determining the water table
response to soil absorption disposal of wastewater. The EIS
also recommends collection of data in certain instances.
EPA has initiated a study which will demonstrate this water
table response method, and will collect groundwater quality
data for three locations on the North Carolina barrier is-
lands. The information from this study, along with the
method developed by the EIS, should significantly improve
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the ability to predict the impacts on groundwater from soil
absorption disposal. Results from this study should be
available by the end of next year.
Issue" number six - SENSITIVE NATURAL AREAS -The primary
and secondary impacts of wastewater facilities on sensitive
areas such as dunes, wetlands and estuarine waters, should
be considered in planning for wastewater facilities.
The EIS process Included several steps. First, an inventory
of existing conditions was prepared. Next, alternative
wastewater management strategies were developed. Third,
the strategies were evaluated, aided by using a case study.
Finally, this entire process was summarized and published
in the draft EIS.
I would now like to summarize the strategies addressed
by the EIS. They include: The proposed EIS strategy, the
201 strategy and the no Federal action strategy.
A special strategy is developed in this EIS. This
approach is intended to provide assistance to local govern-
ments in planning for wastewater management. The approach
encourages communities involved in facilities planning to
update and revise their draft 201 plans, as appropriate,
using special procedures developed by this EIS. The pro-
cedures developed by this EIS refine those normally under-
taken in the preparation of a 201 plan. The procedures
are consistent with 201 construction grants regulations
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and other facilities plan preparation guidance, and are
tailored to address the unique evnironmental and socio-
economic conditions on the North Carolina barrier islands.
The procedures are designed to address the six issues identi
fied earlier. Special attention is given to two areas:
One, a thorough evaluation of potentially reasonable waste-
water technologies, especially on-site and snail community
systems, and two, the financial and institutional impacts
of operating and maintaining wastewater management systems.
The procedures fall into three major groupings:
First, determining need and estimating flows, then developinf
alternative wastewater management systems, and finally,
evaluating these alternative systems.
An overview of these procedures, which is Figure 11.1
in the draft EIS, is included in the handout you received
tonight. The procedures are described in detail in the
draft EIS, and the alternatives development technical
reference document.
The EIS has compiled informatin and developed tools
which will be helpful to those planning for wastewater
management. These tools include a computerized data base
of natural resource information, details on wastewater
management options, on-site wastewater treatment and dis-
posal system siting criteria, a financial planning handbook,
with worksheets, and a predictive groundwater model. These
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procedures and tools are designed to allow identification
Of all viable alternative systems, and to promote considera-
tion of the major potential impacts on both the man-made and
the natural environments.
The EIS compared the proposed strategy to the alterna-
tives of no action or no Federal action strategy, and of
approving the draft 201 plans as sumltted or the 201
strategy. The no Federal action strategy would be a decisior
by EPA not to participate in the further planning or funding
of wastewater management facilities in the study area. The
analysis of this strategy concludes that there would be con-
tinued growth on the barrier islands, regardless of whether
publicly-owned and funded facilities are constructed.
Without additional EPA assistance, existing wastewater
management practices are likely to continue. Localized
state regulations would govern the use of soil absorption
systems. Individual property owners would be responsible
for providing adequate treatment and would bear the cost of
renovating failing systems or installing new facilities.
The 201 strategy would be the approval and implemen-
tation of the draft plans without significant changes. The
plans would have to be updated in certain areas such as
costs. Those plans proposing ocean outfalls, the Dare
County and Carteret County plan, would have to incorporate
the results of site-specific outfall surveys. The Carteret
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County plan for the barrier islands would have to be modi-
fied, since one of the two communities involved elected not
to participate.
One of the six plans, Hatteras Island, proposes no
action, because it was determined that a system is not
economically feasible at this time. The other five plans
exhibit several similarities. Each plan calls for the
replacement of existing on-site wastewater systems with
centralized collection, transmission, treatment, and dis-
posal systems. These plans justified the need for facili-
ties based on the belief that shellfishing harvest area
closings were caused by existing on-site systems. The
plans also projected additional shellfish area closings,
with continued residential and commercial developments, usinj;
on-site systems.
Another similarity is the proposal to provide sewer
lines to most areas of these communities. Pumping stations
and force mains are to be used in all facilities to trans-
port effluent to the treatment plant. Secondary treatment
is proposed for each facility. Ocean disposal is proposed
in Dare and Carteret counties, spray disposal in Topsail/
Surf City and Southwestern Brunswick county, and surface
water discharge to the Cape Fear River in Southeastern
Brunswick County.
The EIS developed strategy is proposed as a means of
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funding, any project must be eligible for funding based on

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its position on the State priority list. Also, any project

3
to be funded must meet the construction grant regulations

4
applicable at the time of funding.

S
I look forward to receiving your comments. Suggestions

6
for improving the methods proposed in this EIS for waste-

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water management planning are most welcome. Mr. Zeller.

8
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MR. ZELLER: Thank you Mr. Crum. How, I would like to move
on with the real purpose of this hearing, to receive comment!

10
from the public, and we will do so immediately. Before we

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do, I would just like to make sure that all of you here have

12
registered at the desk. He would like to have a record of

13
the hearing attendance, and importantly, we can also then

14
provide you with information from our mailing list. So, if
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IS
you have not already registered at the desk, please do so.
H
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Quite a number of people have indicated they wish to speak
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to night, so I'm going to ask them to the extent that you

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can, to be brief in your comments, and if you would like to

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summarize your comments, then provide official comments for

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the record, that will be fine. On the other hand, I am

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very concerned about seeing that everyone gets on the record

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that is interested in having information on the record, so

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I'll «ee that we have enough time to do that. Let me start

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off then by calling our first speaker then, and ask him to

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come up to the podium, and to identify himself for the
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record. The first speaker is Mr. Craig Cogger, who is
Research Associate at the North Carolina State University
in the Soil Science Department. Mr. Cogger, would you come
forward please. We are pleased to have your comments.
MR. COGGER: I'll summarize some written comments which I
have made. I think, in general, the environmental impact
statement was thorough and informative and well done, and I
think that the recommended strategy, using on-site systems
with small community systems in some of the more sensitive
or high-in-density areas is probably the best overall
strategy. I feel that several of the assumptions and con-
clusions made should be re-examined to make this EIS a better
assessment of the monetary, health and environmental costs
of waste treatment on the barrier islands. I will summarize
a few of the specific comments.
The first deals with the separation of the water table.
Our State rules right now require a one foot separation
from the bottom of the absorption trenches in your septic
drain fields to the seasonally high water table. We've been
involved with some research on the barrier islands, and from
our data, we have concluded that you really get a 1ot
better treatment if you have a two foot separation in those
sandy soils between the bottom of the trenches and sea-
sonally high water table. I think that this additional
separation is important in getting good treatment with
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on-aite systems, and I recommend that this idea be con-
sidered in this EIS for on-site systems. I think the EIS
pointed out that in most of the coastal areas, you do have
a great majority of the land, you are going to be able to
put in systems that will meet that criteria. So this is
not something that is going to take a lot of land out of
development for on-site systems.
I have a few comments about costs that were in the EIS.
I'll just mention a couple of these. Maintenance and manage-
ment were mentioned in there, especially when we start
talking about these alternative systems, like low pressure
pipe and the mound system, which are going to be needed on
some of your marginal soil where you may be using on-site
systems. And the only cost figures I saw was about a
twenty dollar a year for pump maintenance, and I think you're
going to find that the rate of pump or control failure
problems that we have seen, that it is going to take more
than an average of twenty dollars a year to be maintaining
those things. And there is also a whole question about
management of the systems, where you have a lot of these
alternative systems, a lot of little pumps cranking away
and technology which is not perfect yet, we're going to need
a pretty good management program to make sure they are
working properly and to get good water quality. And I think
well, I don't think, I know, it's going to cost money to do
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that. That money is going to have to come from somewhere.
I don't know if it's appropriate to be included in this EIS,
but I think that those are some costs that are going to have
to be considered. Another thing is, EIS assumes in some
areas we are going to degrade the quality of our surface
unconfined water acquifer. It points out that in a lot of
places local people get their water from deeper wells.
A lot of times on a community basis. However, there still
are a number of people who use shallow wells for their
ground water. If they are in an area where it gets degraded,
if that's what happens, who pays the costs, once their wells
are contaminated, for hookups to one of these other, whether
it is deep well or off-island systems. That's another cost _
that would have to be included.
I move now to density of developments. This is a hot
issue in North Carolina. It is mentioned several times in
the EIS. The first thing I'll cover is the effect of
on-site systems on the density of development. The EIS
correctly states that where we have on-site or small com-
munity systems, we're going to have lower density develop-
ments, and fewer problems that come with high density
development than we will if we have some large community
system, but I think people can see, driving up and down
Bogue Banks here, we can have pretty high density develop-
ments with on-site systems. I believe that the current
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density requirements that we have may allow serious pollu-
tion of the shallow acquifer, and I'm not entirely convinced
that our surface waters or estuarine waters are going to be
safe in these situations either. It's difficult, where we
do have some of this high density going on. An approach
that might be taken, is to designate some areas like large
parts of the Bogue Banks, as high density areas even with
the on-site systems, and we say, if the people are willing,
we're going to take our lumps with the shallow ground water,
and we're going to lose it. There's not many people
drinking it anyway, and see what happens to the surface
waters, maybe take our lumps there, but designate other
areas that are going to be at much lower densitiy than what
is currently allowed. One thing that concerned me in this
EIS about the density of development was there was a state-
ment that some of these off-island waste treatment systems,
where we after the secondary treatment, we apply it on
waste land by spray irrigation. It seems to me that it said
you get higher loading rates than you would on on-site
systems on the barrier islands, and there was a greater
possibility of ground water contamination beneath these
spray irrigations fields. Well, the way thing3 are currentlj
done in North Carolina, if you have a spray irrigation
field, you have to take into account haw much nitrogen and
everything else you are adding to that land, and determine
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form really, looking at a couple of finger canal areas in
this county up in Atlantic Beach. One was developed house
trailers, seasonal occupancy.for the most part. The other
was undeveloped, and we found substantially higher levels
of ammonium, nitrogen and fecal coliform bacteria in the
ground water beneath the developed one. It was, I think
about eight parts per million ammonium, on the average. The
fecal coliform levels were running about, on the average,
over all our wells overall time, about a hundred, which
is not really high, but for waters to get directly into
the shellfishing waters, it is above the shellfishing limits
I'll just conclude now, as I stated to begin with, I
think the environmental impact statement is basically well
done, and I think its thrust is heading in the right direc-
tion, but 1 think it may fall short in assessing a cost
of the maintenance and management of the on-site strategy,
and in evaluating the pollution potential of some of the
systems. If the proper management and maintenance are not
carried out, and we don't have the money to do that or the
people here don't realize they are going to have to spend
this money and balk at it, I think the pollution Of the
shallow ground waters and even the surface waters will
become an ever-increasing problem as the density of develop-
ment continues to increase in many areas. Thank you.
MR. ZELLER: Thank you. Very good comments. I appreciate
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your taking your time to be here. I will comment back to
you on a couple of issues. Let me assure you that the
density of development is not just a hot issue in North
Carolina. It is a hot issue everywhere in the United States
as far as I know. It is a very important issue, and one
that we certainly can't over look. I wanted to ask you
relative to the finger canal water quality studies you
mentioned where you found higher fecal coliform levels and
higher ammonium nitrogen levels, was this an area that had
been filled?
MR. COGGER: Right. These were filled areas, right.
MR. ZELLER: This is typical of what we would expect, and
some of the kinds of water quality problems we have iden-
tified with finger-fill canals many years ago, when we were
looking at the development of these dead end canals and
assessing, not only the impact of septic tanks, but also
the water quality many times in dead end canals and low
disolved oxygen . . . (Interrupted by Mr. Cogger).
MR. COGGER: This was a teat of ground water, you know
beneath, I don't know if you want to call it ground water
or not, but whatever it was beneath the fill areas there.
MR. ZELLER: I think a couple of other key points that you
identified, one of which was relative to maintenance and
management of some of these small systems that are in place.
I looked at a number of those, and have been looking at a
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rather brief statement on behalf of the North Carolina
chapter of the Sierra Club. The Sierra Club commends the
United Sta.tes Environmental Protection Agency and the con-
sulting agencies that have prepared a draft environmental
impact statement on North Carolina barrier islands waste-
water management. DEIS is a thorough and balanced exami-
nation of the subject. He believe the EIS strategy is the
preferred one of the three presented, because it allows
for continued study of water quality problems and their
sources, promotes sound and flexible planning for future
needs, and to minimize the cost to local communities.
However, because the EIS strategy is more open ended than
the others, there are several concerns that need to be
studied in depth should the EIS strategy become the adopted
approach.
Number one. The need for intensive study of the
average primary and secondary environmental impact of ocean
outfalls, should they be a component of the revised 201
plan.
Number two. The possible loss of wastewater manage-
ment constraints due to construction of community and/or
regional systems, must not encourage and promote environ-
mentally unwise and high density development that would
aggravate nonpoint source pollution.
Number three. Assuming on-site systems will be the
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preferred option in some locations, the deleterious effects
on ground water, and the absorbative capacity of the soil
must be regularly monitored, to identify and correct problem:
before they have a wide environmental or public health im-
pact. We appreciate the opportunity to review the draft
environmental impact statement, and to express these con-
cerns. Thank you.
MR. ZELLER: Thank you very much. He appreciate your com-
ments. As indicated earlier, we will respond to all of
these issues in the final EIS when it is promulgated, and
you raised some good points, and we appreciate your coming
here tonight. The next speaker I have is Ms. Flora R.
Garrett. Ms. Garrett is from Pine Knoll Shores. It's good
to have you here.
MS. GARRETT: I wasn't sure whether I was going to apeak
tonight or not. I'm a hew resident of two months in this
area of Pine Knoll Shores, but I am past chairman of a water
and sewer authority in Orange County, North Carolina, and a
past county commissioner, so I am concerned about waste
water treatment. What I would like to say i3, having re-
viewed your document, I think your draft EIS approach is
the way to go, and I think the problem that the State and
the counties in North Carolina have had with over-crowded
trailer parks, large developments in rural areas, has been
because there has been no maintenance and management of
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the package plan small septic tanks. The plan and the
approaches that you suggest mean that the communities here
on the barrier Islands need to get together, either with
the County Health Department orwith themselves» and come
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up with a team that could monitor past ordinances, as
necessary, and, of course, this costs money, but It's inova-
tive, and a direct approach, and I hope that's what we do.
MR. ZELLER: Well, I hope so too. Thank you very much, and
we appreciate the benefit of your experience. As 1 Indi-
cated earlier, I totally agree with your approach. I think
that's very proper. Thank you for your statement.
Next, let me ask Mr. David Harris, who is the City
Manager of the town of Morehead City. Mr. Harris.
MR. HARRIS: 1 have no comments.
MR. ZELLER: I see. I had your card placed in the wrong
location. It shows that you did not indicate to speak, and
I indicated that you wanted to speak. Excuse my error.
Mr. Todd Miller, who is President of the North Carolina
Coastal Federation. Mr. Miller.
MR. MILLER: My name is Todd Miller, and I am President of
the North Carolina Coastal Federation. The Federation
serves as a clearing house for twenty-six groups throughout
North Carolina, who are concerned about coastal issues.
I'll be encouraging each of these groups to send written
comments on this draft, and also providng you with more
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addresses, so that a greater number of people can learn
about these meetints. The comments that I have tonight are
my own comments, and are not meant to represent these
different groups. I am a native of Carteret County. I
think it is important, and it has been brought out through
this draft, that the nature of these islands are very
different than other types of communities that traditionally
receive EPA funding for wastwater projects. Most of the
residents are part time. If you drove down tonight, you
would notice that many of these houses are already empty,
and we are still in August. These are investment properties,
and most of the properties are high income, and on top of
that, the dynamic nature of the islands. We have a 3torm
brewing right now, and the fact that these systems are sus-
ceptible to major damage would also increase the amount of
Federal money that through disaster relief, that would go
into maintaining the systems. These are not your typical
communities that are in desperate need of Federal help. One
example of this is a private sewer plant that is going up
on West Onslow Beach, just South of here, without Federal
assistance. I would like to commend the EPA for its draft,
and in addition to continuing to investigate on-site sewage
treatment in small community systems, I think it is impor-
tant for you to consider the equity question of whether tax
dollars should be spent on systems for communities of this
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nature. Also, the problems of non-water pollution should be
clearly spelled out. One of the biggest problems with the
commercial fishing industry in the State is fresh water,
and the peak flows of fresh water as they come off offering
pollution. Nine out of ten of the commercial species in the
State can have their reproductive cycles interrupted by
fresh water. The fact that current pollution problems cannot
be documented, and that EPA funds are not meant to accommo-
date growth with funding wastewater treatment plants, is
another factor that it's good to, you know, document, that
this has come out the way it has. Hy recommendations are
that you improve, or offer recommendations for improving
State regulations for on-site sewage treatment systems, and
that EPA put money into maintaining, monitoring and regu-
lating programs to assure that on-site and community systems
are operated correctly. Thank you.
KR. ZELLER: Thank you very much. We'll be very happy to
receive written comments from the other groups that are
involved in the Federation. I hope you will encourage them
to give us their comments. I think it is important that we
have that kind of information for our records.
MR. MTLLS3: I've been making a number of calls today, and
a majority of your typical citizens was not aware that this
meeting was going on. I don't know how you go about it, but
I think there is a need to Set broader public awareness of
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what you are doing here.
HR. ZELLER: That's always a concern of ours. He're con-
cerned about our public notification process. He try to
get out adequate notice. He try to develop mailing lists
and put things in the paper, but invariably somebody always
misses the information. He need to continue to do every-
thing we can to get the word out. I'll agree with that.
Now, let me ask Mr. Steve Steinbeck, Superintendent of
On-Site Sewage Treatment Program for the North Carolina
Division of Health Services. Mr. Steinbeck, glad to have
you with us tonight.
HR. STEINBECK: Thank you Mr. Zeller. My name Is Steve
Steinbeck. I'm with the North Carolina Division of Health
Services, Environmental Health Section, Sanitation Branch,
and with all those titles, you might recognize that we
probably have several programs which are directly impacted
by the environmental impact statement, and particularly, the
recommended strategy, public water supplies, shellfish sani-
tation and on-site sewage management, which also Includes
the disposal of septeic or sludge.
First of all, 1 would like to say that I appreciate
the opportunity to be here tonight to speak regarding the
EIS. I think it is unfortunate that there are not others
here. Some of us have been at previous meetings, and we
have known the hours of meetings and the uncountable hours
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of the consultants for the EPA and the EPA staff themselves
have put Into it. Our staff has devoted just a small token
amount of time to It, and I think the end product is to be
commended. I know the stress, some of the stress that the
EIS and the volume of publications that were put together,
and I appreciate the decision, the tough decision that was
made by the Region IV EPA, because m have seen this past
winter, the impact of development along our estaurine shore
lines of North Crolina, which was manifested in the closure,
for the first time in history, of all the shellfishing
waters in North Carolina. X predict that it will happen
again and again, until ultimately you will see the shell-
fishing program in North Carolina become something of
history. X think there is also a real possibility of for-
getting the water supply, the very fragile water supply,
which is apparent right now on our barrier islands. Yes,
we have seen communities up and down our barrier islands go
to off-site, if you will, water supplies. We've seen them
go to community wells. We've seen them pump water many,
many miles so that they no longer have to drink tainted
water coming from that shallow, unconfined acquifer present
throughout the barrier island chain. One may say we are on
a tight schedule. Having spent recently a substantial
amount of time along the barrier islands, I can say that
density, and you can underline that a thousand times, densit
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is the issue, regardless of whether you go on-site or off-
site, spray irrigation whatever wastewater management con-
cept is looked at, density is going to be the thing that is
going to degrade our natural resources. We've seen it con-
sistently. Septic tanks are not the whipping boy that
everybody thought they were. X think part of the EIS study
proved that. However, we do recognize that there is a
cenogenestic effect, and it could become—as you drove down
here this evening, you see the condominiums. I can tell you
that every condominium, every cottage you passed, every
business you passed had a sub-surface system. That sewage
was not disappearing. It doesn't go out of sight and out
mind. And we must recognize that we have got to get it out
of sight and out of mind with treatment, and we must follow
that treatment with management! and we must follow that
management with long range planning, because even with the
best management, we are going to have long term problems
related to on-site community, small, wastewater treatment
disposal systems. With that in mind, I would recommend to
the staff of the EPA and their consultant, to review and
hopefully incorporate as a final publication, the Rural Aids
Project Handbook. This particular handbook was published
by EPA Region V in Chicago. EPA, Region V has recently gone
through a very similar process that is taking place right
now. So I would suggest that this handbook be carefully
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reviewed, and to see if it cannot be modified and used as
a general user publication. Having spent several hours
myself, going through the four publications that were sub-
mitted , it would be very nice to look at a little brief
executive summary, and then get some concepts in a publica-
tion such as the Rural Aids Project Handbook, so I recommend
that. We will have formal written comments at a later-date.
And again, I am speaking specifically for the Sanitation
Branch, the Shellfish Sanitation Program and the On-site
Sewage Program. Bob Denton is in New Orleans, and could not
be here this evening.
In conclusion, I must say that North Carolina, the EPA
qualitary associates and their other consultants should be
commended for a thorough, comprehensive environmental impact
statement and recommended strategy. I feel very strongly
that it is the right direction to go, and I'm speaking for
our Division on that. He do support the EIS strategy, and
it's one that becomes—it's a difficult situation for us to
actually say that we do support it. On the other hand, we
look at our shellfish resource, and on the other hand, I, as
a program supervisor, look at our problems related to on-
site sewage. So it would be very easy for me to say put in
the regional sewers and pump it to the mainland or go to the
ocean outfalls, but I think we have to do a careful balance.
He are doing that now, and I think with continued management
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I'm not talking about statement; I'm talking about local and
regional management, will this work. Thank you.
MR. ZELLER: Thank you very much. He appreciate your com-
ments. They are particularly meaningful as far as this
hearing is concerned, because of your extensive experience
in this area. Let me ask you a question for the record here
I recall the closure of shellfish beds that occurred, and
my recollection is that that was primarily due to nonpoint
source. Is that correct? Is that a correct statement?
MR. STEINBECK: Tes. I think, of course, this particular
winter we had an excessive amount, an unusually high rain-
fall, and we had, corollary to that, freshwater intrusion
from runoff, septic tanks systems, an unusually high number
of malfunction of septeic tank systems, and other pollutants
just running off from paved areas and other surfaces. All
this was created and essentially manifested itself from the
excessive rainfall, which was probably a fifty year event
for us in North Carolina.
MR. ZBLLER: Thank you. Let me next ask Mr. John Melvin
from Greenville, North Carolina, to come forward.
MR. JOHN MELVIN: I'll have to ask .you for forgiveness. I
really had no information on time or didn't know I was
supposed to make a kind of formal statement, so what I'm
going to say is just kind of off-the-cuff, and if it's a
little bit incoherent, just bear with me. I'll try to get
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to ay point.
MR. ZELLER: That's perfectly appropriate. We don't require
any formalities. We're here for comments and information.
We're very glad you took the time to be here.
MR. MELVIN: My main point in all of this, and I haven't
read through all the proposed strategies, but I think you
probably noticed that the general tenor is that large cen-
tralized systems maybe are not the best way to do, especially
down here, and that is the point I would like to emphasize.
I really can see no benefit whatsoever. The present systems
that are here provide fair share treatment. They are well-
managed and maintained. The data that comes from them and __
from monitoring wells substantiates' this.They, due to the
design nature of the individual systems, have a limiting
effect upon density, because as each developer will tell you
as he hollers and screams after going to Raleigh or wherever
to find out how many square feet he's got to have. There
are some limits with large centralized collection systems.
I envision almost brick to brick walls, solid up and down.
There has been some comment about the management of the
various facilities, and I was in the middle of talking to
someone. However, I thought I caught the tail end of your
statement when you said you had found that it was generally
good down here. If it is good, th*n it can be made to be
good all the time. There may have to be certain rules and
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regulations that are drafted to insure this, but it's not
only just a possibility, it's a probability that it can be
done. So, in summary, the systems that are here now, and
when I say systems, I talk about the condominium type systems
I won't comment on the individual septeic tank type systems.
There are some potential problems with those, which I re-
cognize. But going the route of small individual package
plans versus the route of one large central collection system
1 do think, to restate what someone else has said, might just
be a waste of taxpayer's money. I think the EPA could very
well spend it's money at some better locations, which would
be better for the environment in general. I do think it
would increase the density. Thank you.
MR. ZELLER: Thank you Mr. Melvin. We appreciate your com-
ments. Very good comments. The next speaker X have is
Mr. Bill Price, who is a developer with the Carolina Coast-
land Corporation. Mr. Price.
MR. PRICE: Thank you sir. I am a developer with Coastland
Corporation. I have been down here for about thirteen years
I've often heard it said, or not often, but a friend of mine
made the comment ;hat environmentalists is one of the last
persons who bought a house on the shore. I don't think
that's necessarily true, because all of us are environmen-
talists in one way or another. We have an enviable part of
the environment. We live in the environment and have to be
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responsible to that environment. The gentleman a feu
minutes ago made the comment that density was a problem.
Well, I think I would carry it a step further and say, well,
it's not density, but it's people. When we stop producing
people, we won't have anymore problems, I suppose, with
development on the barrier islands or anywhere else. But
as you indicated, I believe you are the EPA manager for the
Southeastern Region. . .
MR. ZELLER: Assistant Administrator for the Southeastern
Region.
MR. PRICE: As we know, the Southeastern part of the United
States is probably one of the fastest growing areas in the
country, and with that we bring a lot of people down into
this neck of the woods, especially North Carolina, who work
and live and have children and go to school and etcetera,
and we also like to have a place for vacations. A lot of
people like the mountains, a lot of people want the seashore
And over the past several years, the coasts along the sea-
shore have become booming areas. We seen to have a lot of
folks who like to come to the seashore. Carteret County has
been working on a 201 plan for about thirteen years that I
know of. Is that about right, Walter?
(SOMEONE IN THE AUDIENCE): Almost.
MR. PRICE: I went to some sort of a water development con-
ference down in Wilmington in '75 and '76, Wrightsville
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Beach, I'm sorry, and a gentleman from the University of
North Carolina made some comments there. He said that he
was developing a study for ocean outfalls. I wrote him a
couple of letters, and never was able to get anything. Then
In 1981, I found out that it had been published. It had
been published in 1977 or '78, and was able to get a copy
of it. The summary of that statement, I will say this
one more thing, I understand that the reports that were
made, they go for about a hundred thousand dollars a pound.
It was about "yea" thick, so I don't know	
MR. ZELLER: Maybe this was. . .
(The above two lines were unintelligible due to two parties
talking at once.)
MR. PRICE: Maybe it was a two hundred thousand dollar re-
port. Anyway, the thrust of it boiled down to one page,
and said that insofar as Onslow Bay was concerned, which
is this deal right out here, there was nothing wrong with
ocean outfalls that he could tell or this group of people.
in their report. I wrote a couple of letters to some folks,
and tried to find out if there was nothing wrong with ocean
outfalls, why is nothing happening with 201 plan of Carteret
County. I never got a report or a response so that I under-
stood, but the closest thing I could get was that we were
waiting behind Dare County, who was also doing a summary
or a report or having a report made for ocean outfalls,
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and that when that report was done, then the decision would
be made by EPA or Coastal Regional Commission Group or
whatever, to determine whether ocean outfall was going to be
permitted. During this time, we were also involved in the
septic tank debate. I put in some septic tanks in 1969 and
1970, and a number since then, and have really have not had
any problems with them. They are monitored, they check the
water quality in the area, in the well systems, and don't
seem to find any problems. We suggest that septic tanks be
put some yeast in a couple of times a year, and check their
wells, and it seems to work fine.
At that same water quality meeting that was held down
in Wrightsville Beach, you had people stand up and say
things like—we did a study in a trailer park on a finger
island up here at Atlantic Beach, and we flushed down the
toilet, and it was in the canal in two minutes. I'm not
sure that that is any indication there is anything wrong
with septic tanks. I'm sure it indicates that there is some
thing wrong with the design of the installation, which may
have been an outfall right into the creek, but it certainly
doesn't necessarily indicate there was anything wrong with
the septic tanks. In addition to that, there was a couple
of instances noted on this island, of septic tank systems
that were installed that were constantly giving trouble,
but the amazing thing was that I have been, you know, been
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involved with development and watch these sorts of things,
and you see people come in and put a septic tank system in
and back fill it with clay, and then wonder why It won't
work. But these are the ill-designed or ill-installed. Bad
installations are historically the things that when you
start, you know, people say that septic tanks are bad.
Let's scare the world. They are the ones that they use as
examples, and I think that's very unfortunate. As a matter
of fact, I have here a CRC memorandum dated 1-20-81 that
says multiple septic tanks are growing problems in the
coastal area, and the thrust of this deal is, gee whiz,
septic tanks are going to destroy the coast. Let's not have
any more of them under any circumstances. And so we give
them package treatment plants. I put in a couple of package
treatment plants. As a matter of fact there is a couple of
fellows back up there, a Mr. Dunn and Mr. Boone, have done
real well I think, off of them trying to keep the things
running, because they are absolutely, they are horrible.
You absolutely can't keep them running all the time. Now
you can—when you got all kinds of bells and whistles, and
whistles behind the bells, and whistles behind the whistles,
you got a dozen pumps on every one of them doing half a
dozen different things, and then a pump comes in and that
doesn't work, and if that doesn't work, you have to get one
from up the street, put it in and keep it operating for a
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while, and these guys are running up and down the island
here constantly, trying to keep eight or ten treatment plants
running. There just isn't any way, in my view, that package
treatment plants, without total persistent, consistent
attention, can be made to continue. Now these things have
only been in for what, six years, five or six years. The
wiring has not burnt out of them yetbut it will be pretty
quick, and the pumps is going to be gone, and all control
devices will be gone, and they will have to rebuild every-
one of them, and probably all the metal cabinets will be
gone, so probably about five to eight years, you have to
rebuild everyone of the electrical systems, in all these
things, because of the extregne corrosion we have on this
island. And 1 expect it is the same on just about every
other island that we've come up with. But right now, they
are working alright evidently, based on the monitoring
systems that they have been working on. Of course, the owner
is responsible, you know. One of those motors costs about
seven hundred and fifty dollars. Then we've got a situation
where 1 think I heard a few minutes ago, that about eighty
percent of the treatment plants in the area are not being
operated properly. This is a major, evidently, municipal
treatment. . .
MR. ZELLER: You're talking about treatment plants as a
group of facilities, you know in the United States, you
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know that generate some of the sane things. It applies to
then also.
MR. PRICE: But we are in a situation on the coast of North
Carolina, and I suppose most coastal areas, where we have
en economic interest, those of us who are in development, or
industry or business or whatever it nay be. And we see
that the municipalities and cities all over the State are
in a position where they go to EPA or the Feds or the State
and say, we need some money to build a treatment plant to
treat our sewage, and it may be built and perform properly
or it may not, but whether it is operating at a hundred
percent, it's still taking up its percentage to be a carryinf
capacity or whatever the river might be that they are dumping
into. So they bring all that stuff downstream and it gets
into the estuarine body of our areas, and that results in
a degree of the percentage of the pollution that we are
evidently responsible for, because of the runoff or nonpoint
source or whatever you want to call it. It's going to the
ocean anyway sometime. The question is, do you put it in
directly and now, or do you liet it filter in through the
estuarine bodies like the one down in Calico Creek over here
in Horehead City or over behind Beaufort. I think it is—
these areas are going to grow, and I think we are very
short-sighted to depend on the small package systems, to
depend on poliferation of septic tanks. I think that
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properly designed, properly implemented within limited
densities, I don't see nothing wrong with that, but you
can't go but just so far with them, I know. I can realize
that, but I think that you really are creating an unfor-
tunate situation when you don't permit the development of
the ocean outfall program and the two on one plans, which
is going to limit the growth of Eastern North Carolina.
And maybe we want to. I know that it has been blamed—I
think your crowd has been blamed over the last little while,
for being the main limiter of growth. . .
HR. ZELLER: Our crowd gets blaned for most everything.
MR. PRICE: The environmentalist bunch, yes. I would like
to make a comment here about one of the reasons, it says,
because the development of the barrier islands results in
construction, which then results in Federal flood losses.
Okay. So they put the monkey on your back to control
development of sanitation regulations. I got a notice here
the first of the week. It's from the Federal Flood Insurance
people. It's a rate increase, that tells you how much it's
going to go up, but there is also with it a bulletin that
had a comment that I thought was very Interesting. It
says—they are talking about rate increase and everything—
and they said they are increasing the rates, because they
had such a tremendous loss ratio over the last couple of
years. But then it says, 'however, the insurance data shows
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that only a relatively small number of coast FIRM, which
is Federal Insurance Rate Map program, buildings meeting or
exceeding the. base flood level criteria in these zones have
been severely damaged by flood events with recurring fre-
quencies of less than a hundred years'. I guess what that
is saying is that the insurance losses that the Federal
Flood Insurance Program has been experiencing are in those
dwellings or structures that were built prior to the publi-
cation of the rate maps when people were building about any
way they wanted to. So I don't really think that we could
be blamed for those governmental losses at this point.
Another thing sort of sticks in my craw. We're talking
about closing shellfish waters. I'm sure that it is
necessary and required at times, but if I'm wrong on this,
I'd like for somebody to tell me right now, because I've
talked with a couple of engineers, and I can't get this
maybe perfectly clear in my mind. But as I understand it,
when they test for infiltration or for runoff, they use the
E. Coli as an indicator. Is that, correct?
(SOMEONE IN THE AUDIENCE): That's correct,
MR. PRICE: But there is nothing necessarily wrong with
E. Coli. It comes off of corn fields, comes out of grass,
trees, everything. You know, everything's got E. Coli
in it now. What you're trying to teat for is viral bac-
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ue ijAvneu up xxi snej.j.1 isfi ana tnat sort or thing. Why
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haven't you got a testing system to test for the things
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that are wrong instead of a trace system, which is really
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MR. COGGER: It's extremely difficult. . .
S
will not consume shellfish. Now, many people have advocated
MR. ZELLER: Please identify yourself for the record.
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that we should go directly to the fecal coliform measurement,
MR. COGGER: Excuse me. Craig Cogger, Soil Science Depart-
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ment, N. C. State University. They have been working for
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measure coli coliform or fecal coliform. There is a great
quite a while on testing for viruses, you know the specific
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ones that cause problems, but it's due to the nature of the
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viruses, it is an extremely difficult procedure to do that,
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coliform measurement. Your point is well made. That issue
and it's not very reliable, and if there was a reliable
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method that could be run, reproducably, in a lot of labs,
13
have remained stedfast in their belief that we should stand
I think everyone would rather be testing for the viruses
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by the coli coliform measurement.
than for the coliform bacteria, but right now science isn't
IS
MR. STEINBECK: Steve Steinbeck. I might comment that North
that good, the science isn't good enough to make that
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Carolina is presenting our case again, their argument of
dependable. We feel, or the people who set this up feel,
17
fecal coliform in New Orleans, and we are going under the
that it's better to dependably test for something that
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fecal coliform standard in North Carolina. He also run
isn't the bad guy itself, but it keeps bad company. You'll
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total to satisfy the Federal requirements, but we are
find it where you find some of the pathogenic ones, rather
20
following the fecal coliform standard in North Carolina.
than to unreliably test for the actual culprit.
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MR. ZELLER: I think the State of Alabama and a number of
MR. PRICE: Pathogenic is the word I'm looking for.
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other states have also taken this approach. I think it is
MR. ZELLER: lour point is well made. That issue has been
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discussed and debated many times. In a number of parts
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the responsibility in terms of, you know, of public health
of the country, the shellfish areas are closed because of
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MR. PRICE: Hell, the thing that concerned oe about It was
1
will continue. As a developer, I am concerned with some of
2
that I understand that the fellow that goes out in a skiff
2
the things that have happened as a result of low density,
3
and picks up little bottles and brings it back to test
3
because you get into a lot of wood frame construction that
4
then, that when he goes out, he can just about tell exactly
4
gives you some fire problems. It also gives you some wind
5
what the E. coli, I don't know about the fecal coli, but the
5
storm problems. I think if you use re-enforced concrete,
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E. coli count, he can tell what it is going to be before he
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based on whether the quality of life the community wanted
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goes out, based upon when it rained last, and he ends up
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to designate as being good for the area, and this is the
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being subject to the pressure of the fishermen as to the
8
way we would like it done. I think maybe it would be a
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close of shellfish areas as opposed to public health, and
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little more reasonable say than to try to do it from these
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I know it's a tough deal for him to be in, but it's also a
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extraneous controls. As a last question, are ocean outfalls
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thing that is not testing for something that is accurate and
11
permitted on the coast of North Carolina currently?
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representative, but if you're saying you've gone to the
12
MR. ZELLER: Ocean outfalls are not prohibited on the coast
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fecal coliform, which is the appropriate check for patho-
13
of North Carolina.
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genic, then that is good to know.
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MR. PRICE: Okay. Therefore, then either public or private
IS
MR. ZELLER: Dr. Terry, do you have a comment?
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development is possible along the Federal Environmental
16
MR. TERRY: I wanted to ask MR. Steinbeck, are you using
IS
Protection Agency?
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fecal coliform that shows ratios or just fecal coliform?
17
MR. ZELLER: I think we've talked about this at some extent
18
MR. STEINBECK: Unfortunately, laboratories on the coast
IB
and MR. Crum addressed that in his comments. What we've
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don't have good, efficient capability of fecal strep. He
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said in the draft environmental Impact statement is that
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are doing some work in Raleigh on fecal strep and fecal
20
we should, on a case by case basis, assess the kinds of
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coliform ratio. It is still much debated and much researche<
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problems that we have, and try to respond to those from a
32
It is not yet founded, I think, in scientific fact.
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water quality standpoint, and come up with what is necessary
23
MR. PRICE: Then it goes back a little bit. Anyway, I
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to resolve that particular problem, and we've outlined a
24
guess the result of this is that I feel like there are a
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strategy and approach where that could be done without
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lot of people that like to go to the coast. I think that
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t be a regional system or anything else. He think we should
eep all of our options available to us. There are all
inds of options and I think we have to look at what we are
alking about for the immediate development, the Immediate
roblems and in terms of what kind of development is there
ltioately going to be on these islands. I don't know. I
hink we should always be careful. I've sat through a num-
ler of hearings like this, where we get into these problems
lith people, and I know there are—and I think it is fair
;o say that you should not expect no environmental regulator:
:o control zoning and development of areas involving people,
rhat's not our job. Now, we are here to protect the en-
vironment, and to see if you have people, that those people
are protected with proper systems, but it's not up to us to
try to develop an environmental program to control people.
That's local officials' responsibility, and unfortunately,
local officials don't meet that in all cases. But that is
a problem tljat has to be addressed, and has to be developed.
So don't look at your environmental regulator to solve those
kind of problems. There are other ways to approach that,
and what we're saying is that where we have problems, they
should be addressed. You are correct in some of the com-
ments that you made. There are some very bad functioning
septic tank systems in this area, and they should be resolved
Something should be done about them.
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	56_
HR. PRICE: But there are also some very good ones.
HR. ZELL.ER: Yes. There are also some very good ones. If
they are good Operating systems, It doesn't seem proper,
you know, to penalize those Individuals and those groups of
Individuals, and say you should pay to connect to a regional
treatment system, when you don't need to. How, by numbers,
you may need the numbers to support these systems, but it's
not fair to those individuals. That's why we said in the
strategy, let's look at the problems and come up with the
best water quality management at the least cost, and 1
think it's a very good approach.
HR. PRICE: 1 think it's reasonable and I agree with the
comments you just made. Just as a final comment, I would
like to say that I feel like that as long as we go—the
further we go with the development of coastal North Carolina
that we do need to get into the ocean outfall philosophy,
and that needs to be done in a joint effort, rather than in
individual situations.
MR. ZELLBR: That may be, and that's really not what we
are here to try to resolve tonight. You may be correct,
and that may be the ultimate answer.
MR. PRICE: But you are establishing what will happen with
the promulgation of whatever this might be, because if you
end up with a lot of individual treatment plants or indi-
vidual septic tanks, then you will never get into ocean
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outfalls.
MR. ZELLER: Hell, I think It Is a question that has to be
addressed, and that's the whole purpose of what we've gone
into. I will have some more things to say in the final
environmental impact statement relative to all these com-
ments. Yours is not the first one that has come up with
ocean outfalls, nor will it be the last.
MR. PRICE: One gentleman talked on public notification.
I couldn't find a copy of this deal, and I checked by the
Chamberof Commerce before I came over here, and they didn't
have one either.
MR. ZELLER: Notification of what?
MR. PRICE: I got notification verbally, and this deal right
here, I don't know, has this been passed out before to
other folks?
MR. ZELLER: Yes.
MR. CRUM: I'll be happy to mail you one as soon as I get
back to my office next week.
Mr. PRICE: Hell, I'd like to put the Carteret County Chamber
of Commerce on your mailing list.
MR. CRUM: Okay. He'll be happy to do that.
MR. ZELLER: Thank you very much. These are all the in-
dividuals that indicated they wanted to make formal comments
Yes, would you like to make a statement?
MR. DAVID CLEMENT: I must have checked the wrong box there.
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May I?
MR. ZELLER: Yes, please. Please give your name for the
court reporter, and we are happy to have you.
MR. CLEMENT: Hell, I'm David Clement from Onslow County.
I don't have the technical or professional background or
points of view of many of your other speakers here. I re-
present several conservation groups in Onslow County. As a
matter of fact, my trip up here is about a hundred miles
round trip. So others couldn't come, and asked me to commen
If we make any comment at all, it has to do with the fact
that the barrier islands do not need to have their develop-
ment subsidized by the Federal Government any more than has
been done. Our barrier islands are developing at a tre-
mendous rate right now, and nothing stands in the way of
that development, other than the wishes of the people and
the controls imposed by the local government. It has been
mentioned that in Onslow County, a major sewage system is
under development right now. This has a tremendous impact
on the ability to develop that area down there, and in the
absence of a 201 plan or any Federal assistance in that
direction. The developer was pleased for permission to go
ahead with his sewage plan.
The problems of density and pollution don't all just
come down to E. coll. They come down by oil and beer cans
and chemicals and stuff like that. It's just the way you
Eastern Couzt ^Reporting (Service
798 cRivet Couit
^acf*oaaiffe, cWoitK Carolina 28540
(919) 346-3545
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live. Every day we have a can full of junk that we don't
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and any written coments that we receive prior to that time
know what to do with, and we Just pour it some place. And
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will become a part of the record, and if you wish to make
if more and more and more people are present in fragile
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a further comment, please feel free to do so, and address
areaa, there's just going to be a lot of that pouring around.
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that comment to Mr. E. T. Heinen, whose name and address
Local government has the ability to come to grips with the
S
appears on the agenda that was handed out to you at the
density problem and the pollution problems. There is pro-

6
beginning of the meeting.
bably no better way to solve the problems which may develop

1
Let me thank all of you again for coming here tonight
on the barrier islands than for local governments to, in

8
and being a part of this hearing. I feel like this has
fact, take their stand on that. So the people I represent

been a good hearing, and we have had some meaningful ex-
in these environmental groups are not anxious to see the

10
change of information and some issues that have been raised
Federal government subsidize greater development in those

11
that it is appropriate for the government to respond to.
areas. Thank you, sir.

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We are committed to assisting local governments in resolving
MR. ZELLER: I agree with you. Thank you for the comments.
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public health and water quality problems in a cost effective
He appreciate that. Is there anyone else who would like
14
way, and your comments will help us in meeting that goal.
to make a statement?
IS
The comments received this evening and during the comment
(No response.)
16
period will be considered and responded to in a final en-
MR. ZELLER: Does anybody have a question. Our real purpose
17
vironmental impact statement. The final EIS will consist
for holding these hearings is to try to discuss these issues
IS
of the Agency's final decision, a summary of the draft EIS
and clarify any of these Issues that may have come up.
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and pertinent information or evaluations that have developed
Does anybody have any questions they would like to raise
20
since publication of the draft and comments received and
at this time. We will try to answer it?
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EPA's responses will be In the final EIS. The transcript
(No response.)
n
of this hearing will also be included. Those of you who
MR. ZELLER: Well, it looks like we've pretty well covered
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have commented tonight or will submit written comments
the ground. Let me remind you again that the record of
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will receive a copy of that final environmental impact
this public hearing will be held open until August the 31st,
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statement.
Eastern Court cfieportiag (Service
79M c/hmt Com tt
CnJimm 1K40
'DJtficm, (919) 346 1545

Eaitezn Court cRefmtlny (Service
791 cftmn C
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That constitutes the business of this evening. Let me
thank you again for being here, and we'll be around here
for a while, and be happy to talk to anyone that wants
to remain. I'll close this hearing* Thank you again.
(END OF TRANSCRIPT)
Eaitcxn Coutt cRepozting Service
798 
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UNITED STATES ENVIRONMENTAL AGENCY
PUBLIC HEARING
ON
THE NORTH CAROLINA BARRIER ISLANDS DRAFT EIS
August 25, 1983
8:00 O'clock P.M.
At
North Carolina Marine Resources Center
Manteo, North Carolina
PRESIDING:
Mr. Howard Zeller
Assistant Regional Administrator
Region IV
Atlanta, Georgia
Mr. Bowman Crunm
Project Manager
Region IV
Atlanta, Georgia
Dr. Claud Terry
Consultant
Region IV
Atlanta, Georgia
P.O. Bo,
22
M. S. RAPER &. ASSOCIATES
Owit Reporter*
107 N. McMotrinc Sf.
Eli:*K»
Sli-KM
JM-I7J5
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1

INDEX

2



3
SPEAKERS:
PAGE

4
Mr. Bowman Crumi
5

5
Mayor Donald Bryant
n

6
Mr. Barry Shannon
17

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Mr. Steve Sawin
19

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COMMENTS:


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Mrs. John Reese
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Mr. Steve Sawin
Ik

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Mr. Allan Walsh
27

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******

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1* O Box
2*
M. S. RAPER & ASSOCIATES
Owrt Rrpifim
107 K. McM.^riar **«.
fcbrahcth (.itT. N.C. 'i*'1
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'	MR. ZELLER: It's a little past eight o'clock and
*	although we may have some other people coming in, I would like to
® convene the hearing at this time. First of all, let me welcome
all of you to this public hearing which is being held on the EIS
5 Statement which addresses wastewater management for the North
4 Carolina Barrier Islands.
'	Let me begin by introducing myself and the rest of
•	the panel that is with me. My name is Howard Zeller, and I am
9 the Assistant Regional Administrator of the IV Region of the
" South United States, the IV Region or Region IV, and my office is
" in Atlanta, Georgia. With me from the Environmental Agency is
Mr. Bowman Crumm who is the Project Manager of the Environmental
13 Impact Statement for which we are holding this hearing tonight. And
I would like to introduce Doctor Claud Terry who is standing in
the rear. Doctor Terry is our consultant who is primarily
responsible for developing the data and writing the report for
which we are holding the hearing.
The purpose of the hearing is to receive public
comment and other agencies' comments on the Draft of the Impact
Statement. The Impact Statement for the Barrier Islands
Wastewater Management provides guidance for the local governments
and their contractors, assistance in the planning for wastewater
management, and the preparation of the facilities. This plan is the first
24 step in the EPA's three-step construction grant program for the
M. S. RAPER & ASSOCIATES
Court Repmtcrs
P.O.	107 N. McMorrlnc S..	J3S-I6M
22	Elizabeth City. N.C. 27909	J35-I735
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wastewater managements. Now, to be eligible for federal funding,
proposed facilities must be part of an approved facilities plan.
To identify these costly means of resolving public health and
water quality problems resulting from improperly treated sanitary
wastewater, Steps 2 and 3 of the construction grants program are
for design and construction, respectively.
These steps follow completion and approval of
the facilities plan. Now, all but one of the Draft 201 facilities
plan for the North Carolina Barrier Islands h.ive proposed the
construction cf extensive wastewater collection, transportation and
treatment facilities to serve the larger portions of these
islands. After we made an environmental review of the proposed
facilities the Environmental Protection Agency had serious
concerns about the costs of these facilities relative to the
people that would be served.
The National Environmental Policy Act requires
federal agencies to prepare an environmental impact for the
major federal actions that may significantly effect the quality
of the human environment. Because of the environmental complexities
and water issues that were involved in these projects, EPA mnde a
decision to prepare an Environmental Impact Statement. Then in
September of 1980 we published our notice of the intent prepared
on the islands.
And this public hearing tonight is being held to
M. S. RAPER & ASSOCIATES
Court Reporters
I'. O. Ilm	107 N. McMorrinr Si	HS-1664
22	Eli;ahctli C'ity, N.C.	135-1735
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receive comments on the Draft Environmental Impact Statement.
EPA wishes to encourage public participation in the federal
decision making process and the development and improve public
understanding of the federally funded project.
Now, the craft which was made available to the
public and to the EPA after the federal activities on July 9,
1983, as was listed in the federal register on July 15, 1983. The
Draft EIS comment period will extend until August 3, 1983. Conmen
received this evening and during the comment period will become
a part of the record.
This is the third public hearing that the Environmental
Protection Agency has held this week. The first was in Brunswick
County and then in Moorehead City and this is the third public
hearing on the docket. We have received numerous conments from
the public and from those interested in the proceeding, and we
will respond to all of those issues as well as the issues raised
here tonight in the final publication which will be three to
four months from now.
Now, before I go into accepting testimony from
the floor from those individuals that wish to make a statement,
I would like to have Mr. Crumm, who is the Project Officer,
give us a very brief sunmary of what's included in the EIS and
what the EPA proposes in the document. Mr. Cruras.
MR. CRUMM: Thank you, Mr. Zeller. Good evening.
' o. Bo.
22
M. S. RAPER Sl ASSOCIATES
C«tt Reporters
107 N. McMucrinc S>.
EKishcth C-itY. NX. !7W
Ili-KM
H5-I733
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This Environmental Impact Statement or EIS has been prepared in
response to issues raised during the review of the five Draft 201
Facilities Plans. These plans proposed the construction of
wastewater collection, transportation ,-ind treatment facilities to
serve large portions of North Carolina's Barrier Islands. Through
the EIS process, wastewater management alternatives for the
Barrier Islands were developed and evaluated and a strategy is
proposed.
The review of these Draft 201 Plans and the scoping
process for the EIS identified six basic issues to be addresses.
The issues and the major conclusions of the EIS are as follows:
Number 1: Water Quality - It is important to
identify existing water quality problems in order to determine
the need for additional wastewater facilities. The Draft 201
Plans pointed to septic tanks on Barrier Islands as the
reason for closed shellfishing waters. The data reviewed
through the EIS process do not confirm this conclusion. The
surface runoff from the mainland appears to be the cause of
the closing except in a few isolated cases.
Number 2: Alternative Wastewater Techniques - The
Draft 201 Plans do not fully evaluate on-site and community system
technologies for wastewater management on Barrier Islands.
The EIS has found that these systems may provide more cost
effective solutions to solve existing water quality and public
O. Rm
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M. S. RAPER & ASSOCIATES
Grant Reporter*
107 N. McXkwvtae St.
Eteafcnh Ckv. NXX 27W*
115-173 J
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health problems while providing for desired development. The EIS
1
table response to soil absorption disposal of wastewater. The
2
proposes additional site specific analyses of these alternatives.
2
EIS also recommends collection of data in certain instances. EPA
3
Issue Number 3: Financial Impact on Local Government
3
has initiated a study which will demonstrate this water table
4
Providing wastewater treatment is a major financial undertaking for
4
response method and will collect groundwater quality data for
5
a community and its residents. The financial and management
S
three locations on the North Carolina Barrier Islands. The
6
implications to the local governments and the system users can
«
information from this study along with the meLhod developed by
7
be significant. The Draft 201 Plans do not demonstrate the
7
the EIS should significantly improve the ability to predict the
•
financial and institutional capability of these communities to
t
impacts on groundwater from soil absorption disposal. Results
»
support the proposed system. The EIS provides guidance for
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from this study should be available by the end of next year.
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local governments to evaluate and resolve these potentially
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And Issue Number 6: Sensitive Natural Areas -
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severe impacts.
11
The primary and secondary impacts of wastewater facilities on
12
Number 4; Nonpoint Source Pollution - The
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sensitive areas such as dunes, wetlands and esruarine waters
13
shell fishing waters have been closed where sewer systems exist
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should be considered in planning for wastewater facilities.
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in coastal areas of the southeast. Studies have shown many of thes
B M
The EIS process included several steps. First,
15
closures to result from nonpoint runoff. New wastewater facilities
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an inventory of existing conditions was prepared. Next,
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may promote higher density development thus increasing the
l«
alternative wastewater management strategies were developed.
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potential for nonpoint source pollution of estuarine waters.
17
Third, the strategies were evaluated, aided by using a case
IS
Issue Number 5: Groundwater - The potential impact
18
study. Finally, this entire process was summarized and
19
on groundwater hydrology and groundwater quality Is a major
19
published in the Draft EIS.
20
issue when considering soil absorption wastewater systems.
20
I would now like to summarize the strategies
21
Although few of the Barrier Island comminities use the surficial
21
addressed by the EIS. They include the proposed EIS strategy,
22
acquifer for water supply, the effects of any proposed system
22
the 201 strategy and the no federal action strategy.
¦a
on groundwater should be carefully considered.
23
A special strategy is developed in this EIS. This

The EIS proposes a method for determining the water
24
approach is intended to provide assistance to local governments

M. S. RAPER & ASSOCIATES
Onirt Reporters
P. O. Bon 107 N. McMorrfnc St. J35-166*
22 Eliabcth Chr. N.C. 1JW 315-1735

M. S. RAPER & ASSOCIATES
G«trt Reporters
I'. O. Ho> 107 N. McMurrinc St. DS-1664
22 Elisabeth Cltv. N.C. 279>-9 JJ5-I735
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in planning for wastewater management. The approach encourages
conmunities involved in facilities planning Co update and revise
their Draft 201 Plans as appropriate using special procedures
developed by this EIS.
The procedures developed by this EIS refine those
normally undertaken in the preparation of a 201 Plan. The
procedures are consistent with 201 construction grants regulations
and other facilities plan preparation guidance and are tailored
to address the unique environmental and socioeconomic conditions
on the North Carolina Barrier Islands. The procedures are
designed to address the six issue areas identified earlier.
Special attention is given to two areas: 1) A thorough
evaluation of potentially reasonable wastewater technologies,
especially on-site and small comnunity systems, and 2) The
financial and institutional impacts of operating and maintaining
wastewater management systems.
The procedures fall into ^^fi^a^jor groupings;
One, determining need and estimating flows; two, developing
alternative wastewater management systems, and three, evaluating
these alternative systems.
An overview of these procedures, Figure 11.1 in the
Draft EIS, is part of the handout you received. The procedures
are described in detail in the Draft EIS and the Alternatives
Development Technical Reference Guide.
I' O. Ro.
22
M. S. RAPER & ASSOCIATES
Gnat Reporters
107 N. McMocrtnc St.
Elfeahrfh City.	27909
335-1664
333-1735
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The EIS has compiled information and developed tools
which will be helpful to those planning for wastewater management.
These tools include a computerized data base of natural resource
information, details on wastewater management options, on-site
wastewater treatment and disposal system siting criteria, a
financial planning handbook with worksheets and a predictive
groundwater model. These procedures and tools are designed to
allow identification of all viable alternative systems and
to promote consideration of the major potential impacts on
both the man-made and natural environments.
The EIS compared the proposed strategy to the
alternatives of no action -- what we call no federal action
strategy -- and of approving the Draft 201 Plans as submitted
or the 201 strategy.
The no federal action strategy would be a decision
by EPA not to participate in the further planning or funding of
wastewater management facilities in the study area. rhe k
analysis of this strategy concludes that there would be continued
growth on the Barrier Islands regardless of whether publicly-owned
and funded facilities are constructed. Without additional
EPA assistance, existing wastewater management practices are
likely to continue. Localized state regulations would govern
the use of soil absorption systems. Individual property owners
would be responsible for providing adequate treatment and would
i- o. Iln.
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M. S. RAPER &. ASSOCIATES
Omrt Riprwtcr*
107 N. McMuvrinr Sr.
EliraKth Citv. N.C.
135-1664
335-1735
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bear the cost of renovating failing systems or installing new
systems.
The 201 strategy would be the approval and
implementation of the Draft Flans without significant changes.
The plans would have to be updated in certain areas such as
costs. Those plans proposing ocean outfalls, here in Dare
County and in Carteret County, would have to incorporate the
results of site-speciflc outfall surveys. The one in Dare County
has been completed in the past year. The Carteret County plan
for the Barrier Islands would have to be modified since one of
the two comnunities involved elected not to participate.
One of the six plans, Hatteras Island, proposes no
action because it was determined that a system is not economically
feasible at this time. The other five plans exhibit several
similarities. Each plan calls for the replacement of existing
on-site wastewater systems, mostly septic systems, with
centralized collection, transmission, treatment and disposal
systems. These plans justified the need for facilities based
on the belief that shellfishing harvest area closings were
caused by existing on-site systems. The plans also projected
additional shellfish area closings with continued residential
and comnercial developments using on-site systems.
Another similarity is the proposal to provide sewer
lines to most areas of these comnunities. Pumping stations and
I'. O. Box
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M. S. RAPER & ASSOCIATES
Gait Reporters
107 N. McMufrinc Si.
ElbaKih Cto». MX1 27Kt
1)3-1664
335-1735
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force mains are to be used in all facilities ro transport
effluent to the treatment plant. Secondary treatment is
proposed for each facility. Ocean disposal in proposed in
Dare and Carteret Counties, spray disposal in topsoi1/surf city
and southwestern Brunswick County and surface water discharge' to
the Cape Fear River in southeastern Brunswick County.
The EIS developed strategy is proposed as a means
of assisting local communities in finding a cost effective
affordable means of providing wastewater management. The
approach is designed to allow maximum flexibility for local
governments to accomodate desired growth.
The EiS concludes that the 201 strategy would
result in costly systems which could produce adverse secondary
impacts to local governments. The no federal action strategy
would leave certain water quality problems unresolved and could
increase the probability of future problems. Mo federal action
would likely eliminate the continuation of facilities planning.
The EIS strategy incorporates the following
beneficial features: 1) The procedures promote documenting and
then resolving water quality problems; 2) The procedures provide
flexibility for meeting existing and future wastewater management
needs; 3) The procedures promote maximum local decision making and
provide for disclosure of financial and institutional impacts, and
The procedures minimize costs to cotraminlties by promoting
M. S. RAPER & ASSOCIATES
Gmrt Rcpiirte™
I*. O Iku	107 N. McMufrinc Si.	<15-1664
22	Elfeahcili Cliv. N.C. :T*-i	UJ-1735
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consideration of less expensive alternatives.
The construction grants program has been delegated
to the State of North Carolina. Any future wastewater management
projects will have to meet state requirements. To receive federal
funding, any project must be eligible for funding based on its
position on the sbte priority list. Also, any project to be
funded must meet the construction grant regulations applicable
at the time of fiinding.
I look forward to receiving your comments tonight
and the suggestions for improving the methods proposed in this
EIS for wastewater management planning are most welcome.
Mr. Zeller.
MR. ZELLER: Thank you, Mr. Crutnm. Now I'm ready
to go .ahead and ask the speakers who have indicated they wish to
speak to come forward. Before I do that, let me remind all of
you again that it's important that you register and fill out a
registration card as an attendee at this hearing so that we can
keep you up on the progress and what the final decision is as
it's developed. So if you haven't filled out a registration
card, before you leave please do so.
I would like at this time to recognize Mr. James
Murphy who is a conmissioner from Kill Devil Hills present at
this meeting. Mr. Murphy, if you would identify yourself for me.
MR. MURPHY: I didn't want to speak.
M. S. RAPER & ASSOCIATES
Owt Rtfmtcn
I' O. Bo.	107 K. McMorrinc Si.	11MCM
H	Btalwrfi Chi. N.C. Z7K9	135-17JI
MR. ZELLER: Sir?
MR. MURPHY: I said I dicin't enre to speak.
MR. ZELLER: No, but 1 just wanted to identify you
as being present at the hearing and acknowledge you here. Thank
you for coming.
Another public official I would like to identify
who has indicated that he does wish to speak is Mr. Donald
Bryant who is Mayor of the town of Nags Head. Mr. Bryant.
We ask that you to state your name fur the recoid
so that we can identify you, and we are pleased to have you here
at this meeting.
MAYOR BRYANT: Thank you. I'm Donald Bryant, Mayor
of Nags Head, North Carolina. I won't say much this evening.
X do not intend to attempt to refute the EIS Ornft that 1 have
read as I'm not an engineer, and I'm not qualified to take
exception to the details that are outlined in the EIS. I merely
want to state from a local government standpoint it seems to me
that we are faced with, if you will, a f.-ite complete. in other
words the answer to the problem may have been predetermined by
the EIS process. Since the delays that have occurred have placed
us in a position of being forced into a time frame that would
result in a significant loss of federal funding for whatever
alternative is selected by the local government::. Host of the
24 j people here know that I'm not a strong proponent of uncontrol1ed
M. S. RAPER & ASSOCIATES
Q«trt ffrfKNtrrs
I* O ftm	l»7 N. McMorrinc St	U5US64
22	Eh:al*«t» i:*v. RC.	U5-I7JJ
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growth. But reading the EIS leads me to the conclusion that it
may address more the density question than the wastewater
treatment question.
We believe the problem of the wastewater disposal
is one of the most, if not the most, critical and important
issue facing us, and we are distressed that the options available
to us seem to have been significantly narrowed by the EPA process.
Thank you very much for the opportunity to 3peak to you.
MR. ZELLER: Thank you very much Mr. Bryant. Some
of the issues that you raised have been brought out at other
hearings, particularly this question on — you referred to delays
and federal funding. He intend to address that whole issue of
the priority list and how, you know, how this is a factor in
terms of federal grants. And 1 think we can satisfactorily
resolve that issue.
There have been a number of problems relative to
getting some of these facilities on the priority list where they
would be eligible for grants. The situation in this country is
simply that there are not enough dollars to do all of the
things that need to be done. And we have developed these priority
lists which have certain criteria involved in getting to the top
of the list. And there's a need to have a further explanation,
and we will address that issue in the final EIS.
Secondly, a point I would respond to, X believe we
M. S. MPER Sl ASSOCIATES
Cmnt RepaHers
I'. O. Dm 107 N. McMonfec Sr.	1)3-1664
22 Eltahcih City. NJC. tTKt	335-17}J
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did -- I feel like and we'll certainly have another look at it,
but I feel like that the document does address the wastewater
treatment. Now, [ don't know how you can avoid people and
density problems when you address wastewater treatment. Am!
that's tied into every wastewater treatment that's ever been
built in this country, and ever will ho buill" in this country,
as people dependent as is nearly everything else. Ro I don't
know how to avoid that. So the issue is addressed, hut I think
it's secondarily addressed.
And I also feel like, I might point out at this
time, that the document does develop a strn'egy. Ami instead
of saying let's simply go ahead with just pup approach to
resolving this problem, let's look at each one of those
problems and let's make a site-specific analysis of each one
of these problems. And the problem might very well he different
in this community than some other community. So we have said
let's not adopt a common approach to try to solve all of these
problems. Let's look at these problems indi vl'dunl ly and comr
up with a site-specific analysis. And there area lot of things
that are going to have to be analyzed.
First of all, you know when you put systems in
place, the people that use those systems have to pay for them.
And depending on the number of people involved and the cost of
putting it in place would depend on how much those people would
M. S. RAPER &. ASSOC IATES
Gtift Rrpprtcrj
I' O. llo»	107 N. McMnrrtnc 5,	l);.|664
22	Elbafccih Ciu. N£. :1V	135-1735
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have to pay to get the job done. There are a great many factors

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that come into this that we feel like need to be evaluated so that

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we get the best possible utilization out of these grant dollars

4
that accomplish what we need to accomplish in terms of water

5
quality and to provide the kind of development that North

t
Carolina wants on the Barrier Islands. Thank you.

7
Let me ask then the next speaker to come forward

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which is Mr. Barry Shannon from the Southern Shores Civic

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Association. Mr. Shannon.

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MR. SHANNON: My name is Barry Shannon, and I'm

11
representing Southern Shores Civic Association. The Association

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has approximately 12 hundred members, and in our opinion its
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views on the EIS relating to the sewage disposal systems are
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representative of those of the majority of the people on the
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Outer Banks. We consider the EIS to be an excellent study and

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conniend the EPA on its development and the positions taken.

17
The 201 strategy is clearly out of line with,the Deeds and

IS
desires of the people in the area. It cannot be supported

19
cost-wise and would encourage high density development. The

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carrying capacity of the Outer Banks simply cannot stand such

21
development. The operational costs, repair costs due to storm

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damage and costs of sewage lines and et cetera were not considered

23
in the initial 201 proposals, and would be beyond the capabilities

24
of the local jurisdictions to finance.
M. S. RAPER & ASSOCIATES
CfittTt Reporters
O. Box	107 N. McMuntar St.	H5-1M4
21	ElimK.h cjkr. NX. '7W9	U5-I7J5
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The federal government should nut finance such
marginal projects. In summary, we harmonily agree that the
201 strategy be abandoned.
The no action federal -- excuse me. The no federal
action would continue current wastewater practices with the
local, state regulations governing. There would he no federal
support and costs would be borneby the users. This strategy
has merit, and would facilitate the control of the government.
We can support this strategy.
The EIS strategy would supplement the no federal
action strategy by supplying assistance to the local government
in the completion of the planning for the wastewater management
programs. This does have merit and the acceptable guidelines
would be provided and financial assistance given to the local
jurisdictions to assist in the planning. Tn no way, however,
if the EIS strategy is approved should such funds be used to
continue or to resurrect the 201 strategy and planning. With
that reservation we can support the EIS strategy providing
the community facilities are not promoted aggressively. Where
they are used, they should be of high quality and meet high
standards.
Too often community facilities falter and fail
because of poor quality and management.
In summary, we oppose the 201 strategy and support
M. S. RAPER & ASStH IA FES
Gun Rfptirtcr<
r O. H««\	107 N. McMorrin? Sr.	IH-lfM
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the EPA position on this matter. We support the no federal action
strategy, but consider minimum federal support to complete
planning under this strategy would be worthwhile. This, in
effect, is the EIS strategy which we support and recommend be
adopted, taking into account the previous comments. Thank you.
MR. ZELLER: Thank you, Mr. Shannon. We appreciate
your being here and giving us that statement. I certainly agree
in the comments that you made relative to maintenance and proper
operation of small on-site and community systems. It's been my
experience over many years that these systems work well, but
they will not work well if they are not properly operated and
properly maintained. They can do the job. And that has to be
a very important key for this stage of strategy that has been
proposed. You simply have to have proper maintenance and
operation or this will'not bfe successful and your statement
points that out. And I wanted to share with you my agreement
along those lines, because a number of these systems are in
place and I think they are doing the job.
Next, let me ask Mr. Steve Sawin. He indicated that
he probably wanted to make a statement, and it looks like you have
decided that you do want to make a statement.
MR. SAWIN: Steve Sawin. I indicated that I
probably because I've never come to a public hearing where I didn't.
I am on the advisory committee for the EIS and have followed this
M. S. RAPER & ASSOCIATES
Court Reporters
I' O. Box	107 N. McMorrlnc St.	U5-MW
22	ElluK-th Cliv. N.C 27*."l	JJ5-I73J
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' development from its inception, although I must say having about
J six hundred pages dumped on me in July and being told that we
were having this public hearing at this time caught me quite off
4 guard, and I haven't read all of the latest materinl.
®	My comments will be based on mv relatively unique
6	perspective in that I have just bought n community system that
7	floundered and went bankrupt. And I find that the EIS strategy
® makes comments about the advisibility of smal1 community systems
which do not properly take into account what you just were
talking about. It is easy to say that of course all of thi.u
hinges on proper and good management, but the costs to the
state and to the communities and the counties in ensuring that
a large number of small community systems are properly managed
can be considerably greater than the costs in managing the
central system that they own.
Recently, and I'm not sure of all of the facts, but
recently the State Department of Health tried to make a change
in the regulations regarding sewage treatment operators and
license.es to lower the number of plants, small community systems
that they could manage on a given license. And I heard rumors,
and I have not checked the reliability of them, that this was
instigated by finding that out in western North Carolina there was
one licensee who was managing fifty snulL community systems, one
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person. If this is in fact true, then then is no w.iy that those j
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fifty systems could be well managed.
So as we go through the EIS strategy, which I would
support, I think much greater detail than has been given should
be given to how does the Dare County Board of Health, Department
of Health, manage the small community systems. Or if DEM is
going to watch them, how do they? Because the one that I have
just acquired has created enough headaches for the whole county
and the DEM over in Greenville in the last two years, and is
a case study on how it shouldn't be done. I thank you.
MR. ZELLER: Thank you. We will have to address
that issue. That issue will be addressed in the final impact
statement. It's something that has come up in all of these
hearings relative to these type systems. Again, it's consistent
with my experience and I think anyone who's had experience with
wastewater treatment that these small community systems simply
have to be operated properly. And let me point out that that's
not -- that proper maintenance and operation is not restricted to
small community systems by any means. A recent study, and I
pointed this out in one of the other hearings, a recent study that
was conducted by the Environmental Protection Agency on the
operation and effectiveness of the municipal waste treatment
facilities in this country showed that about eighty percent of
the plants were not operating nearly as well as they should be.
And you know that's — that's a real tradegy and one that we have
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tog£t to the heart of, because this year alone in this country
we are spending 2.4 billion dollars for construction grants for
constructing publicly owned, you know, owned and operated waste
treatment works. And if eighty percent of these thai we're
spending that kind of money for aren't operating right, we've got
to get off our — you know, off our cans and see that something
is done. So the problem, you know, when I speak of that problem,
I am not saying that it is universally addressed towards small
systems on Barrier Islands. It's a general statement, but it's
important -- particularly important to the ''-rale that we have
been looking at and the subject of these h« M ings that* we have
that kind of operation.
Thank you very much. We'll want to address that in
the final EIS, and I'm sure the state is aware of that. And I
thiik the state is intending and will take proper fiction. I might
also add this. The State of North Carolina lias been a real leader
in this area and has a lot of recognition is being one- of the
states that does a good job in this area. So I think we can
expect the state to come through with what we need to have done,
and I feel sure that's going to happen. This is also something tha
we will be talking with the state officials about further as we
begin to implement this. Thank you very much.
Next 1 have an indication from Mr. and Mrs. John
Reese that they may wish to make a statement? You changed your
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M. S. RAPER ASSOCIATES
Gwrt Reporters
107 N. McMuctfne St.
EteaKth C*r. N-C- 279T9
DM664
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minds? Well, did we answer your question? Did you have a
question you wanted to ask?
MRS. REESE: No. I think the main thing I was
concerned about down here was the fact that water seems to be
such a tight conmodity and wondering -- I agree with the choice
that I think they have made, but just hoping that the demands
of the systems wouldn't decrease the water supply that is
available.
MR. ZELLER: Thank you very much, Mrs. Reese. We
share your concern. And a very important part of this study
is addressed to groundwater and what impacts would be on ground-
water as a result of any of these kinds of systems. We don't
have all of the data on that, but there is a very thorough study
that will be made putting down test wells and measuring ground-
water quality and movement of groundwater and all of these
issues that are important to have assurance that this precious
commodity as you pointed out will be protected by any system
that is put in place. That goes without saying. That
absolutely has to be done.
These are all of the individuals that 1 have who
have indicated that they wish to speak or make a statement. I
think it's important when we have meetings like this that
everybody have an understanding of what we are proposing. And
if you have any questions or if anybody else wants to n.ake a
l\ O. Box
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Court Reporters
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Elisabeth City. NjC J7V9
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statement or ask a question, I'll be hnppy to respond to that at
this time. Is there anybody in the audience who wants to raise an
issue or talk about any of the points in the KIS? This is a
good opportunity to do that.
MR. SAWIN: I have a question.
MR. ZELLER: Please give your name again for the
record, please.
MR. SAWIN: I'm Steve Snwin. T have a question
which may not have anything to do with the EIS, but I heard about
a week ago that the EPA is beginning to do studies on the waste
treatment -- or not the waste treatment effect*, but effects on
high water marshes or estuarine marshes by what effect it has if
you put wastewater into them. Is -- do you know where I can p,et
more information on that?
MR. ZELLER: Yes. We presently have a study
underway along the lines that you mentioned, sir. Basically
we're looking at what the impact would be of discharging waste
into saltwater and freshwater wetland areas recognizing the
importance of these wetland areas and how effective they can be
in terms of natural purification. You know, nature is the best
waste treatment system that's ever been devised. And we feel
like there may be some benefits to these wetlands in terms of
the natural enrichment that would be involved as well as their
ability to serve as waste treatment systems. We also realize that
I* O. Km
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M. S. RAPER ASSOCIATES
Quirt Rx-porters
107 N. McMorrine Si.
hh-.Kil. (.itv. N.C.
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that this dollar business on construction grants, four billion,
on waste treatment plants is limited and we need to get all of
the help we'can wherever we can find it. So this is the study
that's underway. And it's not completed at this time. And maybe,
Bo, you can add a little more to that about some of the detaALs
of the study, when it will be completed. But it is, I think,
a very good study and is going to give us some very meaningful
information and I think will be helpful in a lot of areas. And
we are looking at a lot of different things such as discharge
of certain waste from commercial fishing operations, freeze
water from shrimp boats and wash water that has a very high
organic or biochemical oxygen demand and loads down the waste
treatment systems when it has to be treated. But we think put
into these wetlands that it can be naturally treated because
we are talking about natural constituents there. We're not talking
about anything toxic or harmful. And we have a lot of good feelinj
about that study.
Let me ask Bo Cruma to talk a little bit more about
it. Bo.
MR. CRUMM: Well, that study has recently gotten
underway, and I am honestly not sure about the time table. But
is is one of my fellow project officers that is in charge of that
study, and 1 would be delighted for anyone that would like to
indicate that would be interested in following that, participating
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M. S. RAPER & ASSOCIATES
Ourt Rsrpotters
107 N. McMomnc Si.
Elrrafcvth City. N.C. 27V
H 5-1664
535-1735
in it possibly, and receive all of the mailings, just let me
know after the hearing and I'll be happv to do that. Doctor Terry,
could you
DOCTOR TERRY: Yes, Bo. Them is a phase one
document out of the freshwater wetland? --
MR. CRUMM: Right.
DOCTOR TERRY: So if you are interested in that,
I believe that phase one document is DEIS --
MR. CRUMM: That's available, yes.
DOCTOR TERRY: It's not DC1S --
MR. CRUMM: It's at the draft stage. Yes. The
freshwater wetland study is in two phases and the first phase is
ready. The saltwater wetlands is just begun and there hasn't
been any publication on that yet, but like you said, that document
is available, in limited numbers, but there are a fcv left. And
please let me know and I'll be happy to see that anyone who wishes
is put on the mailing list and is kept in touch with the progress
of either one of those studies.
MR. ZELLER: That was Doctor Terry, by the way,
who made that corarient a little while back. I ihink those are very
interesting studies and I feel like they may have an application
in communities like this where we have a lot nf commercial
fishermen and some wastewater problems that are associated with
this. So we are looking forward to getting that kind of data base
r o Hm
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IC7 N. McMt>rrinr S».
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in place to help us in the process.
Anyone else?
MR. WALSH: I'm Allan Halsh from Colington. Does
the peat-mining operation fit into this story -- this study?
MR. ZELLER: Well, the peat-mining operation doesn't
fit into this story here, but it certainly is a story.
MR. WALSH: Is the EPA maintaining some control
over it?
MR. ZELLER: Yes. We have some controls. Frankly
speaking, we have limited controls in most of the peat-mining
operations. We are talking with the State of North Carolina.
They have agreed with us. We have some concerns about what some
of the overall environmental impacts maybe on the peat-mining
in the Albemarle Peninsula. I've been familiar with what has
been going on there in the past ten years and have made a number of
site visits there. And of course there is an energy facility
there that is going to involve the production of methyl using
peat as fuel that is a. pilot experimental study being done by
the Department of Energy. A number of agriculture operations are
looking at the possibility of marketing peat as an energy fuel
and what can be done and of course, they are interested in using
those lands for agricultural purposes. There are a number of
environmental concerns that we have on this kind of an operation,
the least of which is what happens to those wetlands when the peat
M. S. RAPER & ASSOCIATES
Gmrt Reporter*
I'. O. Box	107 N. McMorHnc Sr.	135-16(54
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is mined and all of those general farming activities when those
wetlands are impacted. The balance of nature, of course, if
very important in any system, and we're taking a big chunk of
wetlands out of a system converting it to other uses. And we
feel like we need to develop some information.. We're doing a
study at Cooley Farms (sic) right now on what kind of effect is
going to be involved. So yes, we do have an involvement in that
and do have some concerns. It's not part of this study, but is
part of something t.hat EPA is doing.
MR. WALSH: Is that going to be published?
MR. ZELLER: Yes.
MR. WALSH: Is this operation considered point
source?
MR. ZELLER: Talking about the --
MR. WALSH: The discharge --
MR. ZELLER: -- peat mining?
MR. WALSH: The runoff from that? Is that
considered --
MR. ZELLER: No, no. Most of it is not. There
will not be any point source discharge. And of course, therein,
some of the more serious problems associated with it will be,
of course, from the nonpoint source discharge. We know when that
land is cleared we have processes that take place when we remove
the cover and take the water out and certain elements like mercury
M. S. RAPER & ASSOCIATES
Omrt Rcfxtrters
I* O H»x 107 N. McMorrlnc Sf	HM664
2? EtisaKth City. N.C. 27V	*35-1735
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become much, higher and show up as runoff in the rivers and streams
And we know we have a flow of nutrients, pesticides as nonpoint
source into the waterways that create some problems. And we're
concerned about all of these things.
MR. WALSH: It's not actually wastewater, is it?
MR. ZELLER: No. It's when -- normally when we
say wastewater we think of that pipe or that point source, and --
MR. WALSH: But that has a pronounced effect on the-
MR. ZELLER: Yes. Hopoint pollution, just as a
general term, is oile of the more serious problems we have in this
country. As we pointed out earlier here in this study, you know,
that type of nonpoint source or natural runoff is the major
problem in closing shellfish beds in the Barrier Islands area.
And in this case it's bacteria, but nonpoint source runoff as
bacteria, nutrients which cause excessive algea growth and
sometimes problems, pesticides. All of those things.
MR. WALSH: Do you categorize that as industrial?
MR. ZELLER: No. Most of the nonpoint source are
probably
MR. WALSH: No, l*m sorry. I mean the peat-mining
problem. Is that considered an industrial problem?
MR. ZELLER: I think it's probably kind of in-
between. It's not really an industrial activity because it's
associated with changing the use of the land and converting wetlands
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Ottrt Rtffxrters
107 K. McMorrtnc St.
EKalvth Ckv. N.C. 27909
m-1664
335-1735
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towards other
uses. Now this comes under a different permit system
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type permit through the Corps of Engineer.
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MR. ZELLER: The state and EPA are both very active
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in this area.

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MR. WALSH: Pulling your technical know-how?
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MR. ZELLER: Yes. We are both very active. I
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think there is someone here from the state, Ip thnt right? Yes.
10

(Unidentified:) I'm here from the state.
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MR. ZELLER: Would you want to make a corwnent?
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(Unidentified-.) No, nc^t really. 1 don't have any
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comment.

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(Unidentified:) No.
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Does anyone else have a question or comment?
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the track.

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MR. ZELLER: No. We're in the area, and --
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MR. ZELLER: -- I'm pleased to see an awareness
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and concern
and some interest in this, because I've got some

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W1 K. McMorrinr St. )35-tf64
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concern and interest in this, and I'm glad to see the issue raised.
It's one that needs to be addressed.
Well, is there anybody else that wants to raise
an issue or question? Well, all right. Let me make a few
statements and I'll go ahead and close this hearing out and we'll
be around here for awhile and will be glad to talk to any of you
who may want to come up afterwards.
Let me remind you again that the hearing record will
remain open until August 31st, and any written comment that anybody
wishes to make can be received up to that time and considered
part of the official record of this hearing. The place to send
it is the address that appears at the bottom of that handout
that was given to you when you came in. It's to our office
at EPA in Atlanta. The address is listed on that handout.
I want to thank you all for being here. I
appreciate your coining, and we appreciate your comments. We
are committed to working with local governments in resolving
public health and water quality problems in a cost-effective way.
Your comments tonight have helped us to significantly meet that
goal. The conments that have been received this evening and
during the comment period will be carefully considered and they
will all be responded to in the final environmental impact
statement. The final EIS will be the agency's final decision.
It will also have a summary of the draft and will have any
P. O. Box
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M. S. RAPER &. ASSOCIATES
G«rt Reporters
107 N. McMorrine St.
Elisabeth City. N.C. 279
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pertinent additional information or evaluations that have
developed since the publication of the draft and the comments
received and EPA's responses.
I think one of the more significant things, Mr.
Crumm, will probably be that groundwater study that will be
included in the final, and that will be a very important piece
of information. In the final Environmental Impact Statement
there will also be a transcript of this hearing. Those of you
commented tonight or submitted written comments will receive a
copy of the final EIS and I think everyone who is here who his
registered also will receive a final copy of the EIS.
Again, I want to thank you for your appearance here
tonight and for your participation in the hearing. And if there
are no further comments I am going to close the hearing right
now.
IV O. Hox
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107 N. McMorrine *»i.
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CERTIFICATE
STATE OF NORTH CAROLINA,
COUNTY OF DARE, to-wit:
I, Darlene G. Chambers, Notary Public in and for the
State of North Carolina, do hereby certify that the foregoing is
a correct transcription of the hearing taken by me in machine
shorthand and reduced to typewriting by me personally, at the
August 25, 1983 publia .hearing held by the Environmental Protection
Agency of the United States in the North Carolina Marine Resources
Center, Manteo, North Carolina.
Given under my hand this 3^ day of September, 1983.
Notary Public
My Commission Expires:
February 15, 1987.
(SEAL)
I' O lira
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Crnat Reporters
107 N. McMunfar S.
Elizahrth Crtv. NJC. 2?9C*f
S35-I6M
335-1735
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D. EPA Responses to Public Hearing Comments
T-l. EPA realizes that countywide population projections nay vary among
parties calculating these totals. However, difficulties are
encountered in disaggregating these figures to the 201 planning area
level and, below that, to specific barrier islands comuities which
are the focus of this EIS. Furthermore, EPA is required to base its
funding decisions on OBERS population projections alone.
1-2. EPA understands that the countywide housing inventory and numbers of
permanent residents are growing, but again, these figures are not
specific to barrier island communities.
T-3. Many lots measuring 50' x 100' can be developed using on-site
systems when certain conditions are met. See Draft EIS Appendix E,
page E-3, for a lot diagram. Other typical lot configurations are
also shown in this Appendix.
T-4. "Related mainlands" are those portions of each 201 study area which
are not on barrier islands.
T-5. It is possible that when the draft 201 Plans are updated, a central
or regional system will prove to be the most cost effective and
environmentally sound solution for the island and/or mainland commun-
ities. EPA cannot predict the outcome at this time. See T-3
regarding small lots.
T-6. EPA is aware of this aspect of seasonal housing usage.
T-7. This EIS does not dictate the type of wastewater management system
that an individual community must have. It does provide assistance
in planning for the most cost-effective and environmentally sound
system.
T-8. See W-27.
T-9. See W-42.
T-10. See W-29 through W-32.
T-ll. Wastewater management and density of development are interdependent
issues. The EIS is suggesting procedures to evaluate the appro-
priateness of various technologies to serve various densities of
development. The imposition of development densities via zoning and
other forms of land use planning is, however, solely the responsi-
bility of local elected officials.
T-12. The draft 201 Plans were assigned low positions on the state prior-
ity list when they were originally submitted.
The reason EPA decided to prepare an EIS for the five draft 201
Plans was that the agency believed that the communities were not
"getting a handle on the problem" and that significant issues and
considerations had not been properly evaluated. As was stated by
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T-13
EPA at the public hearings, the topics not adequately analyzed
included 1) identification of water quality problems, 2) adequate
evaluation of on-site and snail community wastewater management
technologies, 3) financial burden and management capabilities, 4)
nonpoint source runoff, 5) groundwater impacts, and 6) impacts to
environmentally sensitive areas. The purpose of the EIS is to
provide 201 grant applicants with a series of tools to update their
plans and assure the selection of an alternative which the state can
certify and place on the priority list.
The EIS states that nonpoint, not point, source pollution from the
mainland is the problem. See W-24,
T-14. The N.C. Shellfish Sanitation Office has an ongoing monitoring
program. The coastline is divided into segments. Every fourth year
a segment is subject to a comprehensive survey, and spot checks are
undertaken every second year.
T-15. See W-7. Most states require 2.0 to 4.0 feet of unsaturated soil.
Also see EPA On-Site Design Manual's similar criteria.
T-16. See W-9. Operation and maintenance costs for good quality sewage
effluent pumps have been low to date. Proper placement and use of
corrosion resistant materials have minimized repairs. Correct
selection and location of pump switches can greatly minimize poten-
tial pump burnout. Short and infrequent pumping cycles have minimal
electrical requirements, costing the homeowner pennies per day.
T-17. 0&M of individual sewage disposal systems should remain with the
homeowner. Technical assistance could be made available through the
existing county health department structure regarding 0&M practices
and repairs to malfunctioning systems.
There could easily have been an increase in manpower requirements
for services such as construction inspection and subsequent mainte-
nance surveys of existing systems. Costs for this additional ser-
vice could be borne by the individual obtaining the permit or bene-
fitting from the services. Thus, permit fees can be adjusted
accordingly to raise the necessary operating capital.
T-18. Proper siting, design, construction and maintenance of soil absorp-
tion systems should result in a system capable of producing a pro-
perly renovated effluent which, along with natural dilution, should
not pose a threat to local groundwater resources and individual
wells.
T-19. See W-13.
T-20. See W-15.
T-21. See W-16.
T-22. Should an ocean outfall be a component of a revised 201 Plan, a
site-specific survey will likely be required by the North Carolina
111-124
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Department of Environmental Management. This survey will consist of
detailed engineering and environmental considerations. The purpose
of such a survey will be to determine if an ocean outfall is
cost-effective and environmentally sound for the specific location.
Such a study has been completed for the Dare Beaches 201 Plan.
T-23. EPA agrees with this statement. Furthermore, the purpose of the EIS
is to provide a series of tools for assessing appropriate technol-
ogies and management structures so that this situation is not
allowed to occur.
T-24. Comment noted. See also W-43.
T-25. EPA agrees that adequate management is critical to the satisfactory
installation, operation and maintenance of on-site and small
community systems.
T-26. See W-27.
T-27. Comment rioted.
T-28. EPA believes that the North Carolina soil absorption system regula-
tions provide a sound basis for the regulation of these systems and
need very little improvement. EPA will continue to work with state
and local governments in improving the performance of these systems,
however.
T-29. EPA recognizes that water supply on barrier islands is an important
issue. EPA believes that the tools and procedures developed by the
EIS will, when implemented, serve to decrease impacts to the quality
and quantity of groundwater resources. The groundwater model
described in Appendix D of the Draft EIS is an especially important
tool. See also W-43.
T-30. The density issue has been raised many times in the three public
hearings on the Draft EIS. See W-49, W-67, and T-23.
T-31. See T-25.
T-32. EPA has taken this suggestion under consideration. No decision has
been made at the time of publication of this document.
T-33. Comment noted.
T-34. Comment noted.
T-35. See T-25.
T-36. An ocean outfall site-specific survey for the Dare County 201 Plan
was required by the N.C. Department of Environmental Management.
Subsequently, the Carteret County 201 Plan proposed the use of an
ocean outfall. The DEM and EPA decided that a decision on a survey
for the Carteret plan should await the outcome of the Dare County
survey. That survey is now complete; however, Pine Knoll Shores has
III-125
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elected not to participate in the Carteret County 201 Plan. Should
a revised Carteret 201 Plan again recommend an ocean outfall, it is
likely that a site-specific survey will be required to determine if
it is cost-effective and environmentally acceptable for the Carteret
County location.
T-37. EPA agrees that on-site systems are sound and proven technologies.
However, they can fail when installed in unsuitable locations.
T-38. See T-25.
T-39. The EIS Strategy allows for the consideration of all viable waste-
water management alternatives, including ocean outfalls.
T-40. Ocean outfalls are not prohibited on the coast of North Carolina.
Any proposed ocean outfall must undergo a feasibility study such as
that completed for the Dare Beaches 201 Plan.
T-41. Comment noted.
T-42. Comment noted.
T-43. See W-27 and W-42.
T-44. See T-ll.
T-45. On the contrary; the purpose of the EIS is to broaden communities1
options by requiring, among other things, an in-depth assessment of
the suitability of local conditions for the selection of on-site and
small community systems as an alternative to the proposed large,
costly regional plants.
T-46. The implementation of the EIS Strategy would support the carrying
out of the proposed draft 201 Plans only in those instances where
the use of the EIS procedures demonstrated that the central or
regional approach was justified environmentally and financially.
T-47. See T-25.
T-48. It is not possible to generalize. Cost studies must be undertaken
on a case-by-case basis and be based on life cycle costing tech-
niques.
T-49. The issue of limiting the number of wastewater treatment plants that
an operator could supervise was brought to the Certification Commis-
sion, and a public hearing was held to address that issue and
several other alterations to the rules. In May 1983, the Commission
decided not to impose a limit since it felt that the problem was not
sufficiently widespread to justify action. This was the first time
the issue has been raised, and it is not expected to be raised again
in the near future (Campbell 1983).
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T-50. According to current North Carolina regulations, the Division of
Environmental Management regulates all systems with surface
discharges plus public systems with subsurface discharges. The
Division of Health Services regulates private systems with
subsurface discharges. This information is found in Article 13E of
Chapter 130 of the General Statutes of North Carolina.
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CHAPTER IV. COORDINATION LIST (continued)
N. C. Department of Agriculture
Office of Statistics
N, C. Department of Commerce
Bureau of Statistics
Division of Commercial Sports Fisheries
N. C. Department of Administration
Marine Resources Centers
Office of State Management and Budget
State Clearinghouse
State Historic Preservation Officer
State Archeologlst
State Geologist
North Carolina State University Agricultural Extension Service
Duke Marine Laboratory, Beaufort
East Carolina University Institute for Coastal and Marine Resources
Brunswick County Health Department
Brunswick County Planning Department
Onslow County Planning Department
Carteret County Planning Department
Dare County Health Department
Municipal Governments:
Sunset Beach	Ocean Isle Beach
Regional and Local
Hoi den Beach
Vaupon Beach
Surf City
Long Beach
Southport
Pine Knoll Shores
Manteo
Kill Devil Hills
Atlantic Beach
Nags Head
Topsail Beach
IV-2
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CHAPTER V. LIST OF PREPARERS
U. S. Environmental Protection Agency
Robert B. Howard
W. Bowman Crum
Peter T. McGarry
Chief, NEPA Compliance Section
EIS Project Officer
Chief, NC/KY Facilities
Planning Section
Consultants
Claude Terry & Associates, Inc.
Claude E.
Louise B.
Terry
Frank!in
Gordon C. Carruth
Robert J. Hunter
Michael Brewer
Craig H. Wolfgang
James Hodges
Thomas C. Mather
R. Gregory Bourne
R. B. Coulter
Project Executive
Project Manager (after 8/81),
Environmental Planner
Project Manager (prior to 8/81),
Environmental Planner
Environmental Scientist
Scientist
Scientist
Scientist
Scientist
Engineer
Engineer
Envi ronmental
Envi ronmental
Envi ronmental
Envi ronmental
Envi ronmental
Envi ronmental
Gannett Fleming Corddry and Carpenter, Inc.
Thomas M. Ratchford
Albert T. Bain
Jeffrey Wendle
P. Andre DeGeorges
Sarah Frailey
John W, Jacobs
Senior Project Manager
Project Manager (after 3/81)
Project Manager (prior to 3/81)
Environmental Scientist
Project Engineer
Environmental Scientist
Briscoe, Maphis, Murray & Lamont, Inc.
James Murray
Suzanne Cohen Zoda
ERDAS, Inc.
Lawrie E. Jordan III
Jefferson K. Dooley
Institutional Analyst
Institutional Analyst
Project Manager
Data Base Management
V-l
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REFERENCES
Barbaro, R. D., B. J. Carroll, L. B. Tebo and L. C. Walters. 1969. Bacter-
iological water quality of several recreational areas in the Ross Barnett
Reservoir. J. Water Pollut. Control Fed. 41(2):1330-1339.
Batten, Coy. September 1983. Personal communication. N. C. Department of
Natural Resources and Community Development, Division of Environmental Manage-
ment, Construction Grants Program.
Benton, R. September 1983. Personal communication. N. C. Department of
Human Resources, Division of Health Services, Shellfish Sanitation Office,
Morehead City, NC.
Bowerman, F. R. and K. Y. Chen. 1971. Marina Del Fay: a study of envir-
onmental variables in a semi-enclosed coastal water. University of Southern
California, Sea Grant Program, Los Angeles, CA.
Campbell, J. September 1983. Personal communication. N. C. Department of
Natural Resources and Community Development, Division of Environmental
Management, Water Quality Section, Operations Branch, Training and
Certification Unit.
Carlisle, B. L., C. G. Cogger, M. D. Sobsey, J. Sandura and S. J. Steinbeck.
October 1981. Movement and fate of septic tank effluent in soils of the N.
C. coastal plain. N.C. Dept. Health and Human Resources, Div. of Health
Services.
Cossin, J., K. Smith and K. Frenke. 1971. Sanitary implication of small
boat pollution in an Atlantic estuary. Environmental Letters 2(2):59-63.
Faust, M. A. 1982. Contribution of pleasure boats to fecal bacteria concen-
trations in the Rhode River estuary, Maryland, U.S.A. _In: The science of
the total environment, Vol. 25.
Furfari, S. A. 1968. A problem paper on boat wastes and the National Shell-
fish Sanitation Program. Northeast Marine Health Services Laboratory, U.S.
Public Health Service, Davisville, RI.
Furfari, S. A. and J. L. Verber. 1969. Boat waste survey, Potter Cove,
Rhode Island, summer 1968. Northeast Marine Health Services Laboratory, U.S.
Public Health Service, Davisville, RI.
Kidd, D. E. 1975. Bacterial contamination of Lake Powell waters: an
assessment of the problem. NTIS publication No. PB 261-682.
Mack, W. N. 1971. Pollution of a marina area by watercraft use as indicated
by coliform and chemical concentrations. NTIS publication No. PB 200-622.
Mack, W. N. and F. D'ltri. 1973. Pollution of a marina area by watercraft
use. J. Water Pollut. Control Fed. 45(1):97-104.
R-l
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Mouberry, Arthur. September 1983. Personal communication. N. C. Department
of Natural Resources and Community Development, Division of Environmental
Management, Groundwater Branch.
North Carolina Administrative Code. July 1, 1982. Title 10 Chapter 10
Subchapter 10A, Section .1900: "Laws and rules for qround absorption sewage
treatment and disposal systems."
Seabloom, R. W. 1969. Bacteriological effect of small boat wastes on small
harbors. College of Engineering, University of Washington, Seattle, WA.
Taylor, C. (ed.). 1983a. Waterway guide, Mid-Atlantic edition '83. 36(2).
Published by Boating Industry Magazine.
Taylor, C. (ed.). 1983b. Waterway guide, Southern edition '83. 36(1).
Published by Boating Industry Magazine.
Udell, H. F. 1956. Pollution problem created by waste from cabin cruisers
and other shipping. National Shellfish Sanitation Workshop.
Udell, H. F. 1957-1963. Pollution effect on marine waters from wastes dis-
charges by small boats. New York State Department of Health.
U.S. Department of Health, Education and Welfare, Division of Environmental
Engineering and Food Protection, Shellfish Sanitation Branch. 1965.
National Shellfish Sanitation Program manual of operations: Part I,
sanitation of shellfish growing areas. Washington, DC.
Environmental Protection Agency. 1979. Program requirements memorandum
79-8: small wastewater systems. Issued by John T. Rhett, Deputy Assistant
Administrator for Water Program Operators.
U.S. Environmental Protection Agency. July 1982. Construction grants 1982.
430/9-81-020.
U.S. Environmental Protection Agency. June 1983. Draft Environmental Impact
Statement, North Carolina barrier island wastewater management.
U.S. Food and Drug Administration. 1972. Classification of areas subject to
sanitary waste discharges from boats. U.S. Public Health Service Northeast
Technical Services Unit, Davisville, RI. (Also USDHEW 1965).
U.S. Public Health Service. 1967. Marina, watercraft problems of sanitation
studies. U.S. Department of Health, Education and Welfare. Public Health
Reports 82(3).
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APPENDIX
Work Plan for North Carolina Barrier Islands Ground-Water Study
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WORK PLAN
FOR
NORTH CAROLINA BARRIER ISLANDS
GROUND-WATER STUDY
U.S. ENVIRONMENTAL PROTECTION AGENCY, REGION IV
NEPA COMPLIANCE SECTION
345 COURTLAND STREET, N.E.
ATLANTA, GEORGIA 30365
NOVEMBER 1983
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TABLE OF CONTENTS
introduction 	
OBJECTIVES OF STUDY 	
HYDROLOGIC DESCRIPTION OF STUDY AREAS 	
approach	-	
TASK 1. FINALIZE TRANSECT AND WELL LOCATIONS 	
Subtask 1.1 Transect and Well Locations for
Kill Devil Hills Area 	
Subtask 1.2 Transect and Well Locations for
Atlantic Beach Area 	
Subtask 1.3 Transect and Well Locations for
Surf City Area 	
TASK 2. INSTALLATION OF MONITORING WELLS AND OTHER
MONITORING EQUIPMENT	-	
Subtask 2.1 Obtain Drilling Subcontractors 	
Subtask 2.2 Install Monitoring Wells 	
Subtask 2.3 Install Tidal Gages 	
Subtask 2.4 Install Precipitation Gages 	
Subtask 2.5 Elevation Survey 	
Subtask 2.6 Install Water-Level Recorders 	
TASK 3. DATA COLLECTION 	
Subtask 3.1 Measure Ground-Water Levels 	
Subtask 3.2 Measure Ground-Water Quality 	
Subtask 3.3 Determine Water-Table Aquifer
Properties 	
Subtask 3.4 Measure Ocean and Bay Water Levels 	
TASK 4. LAND AND WATER USE INVENTORY 	
TASK 5. GEOLOGIC CHARACTERIZATION OF STUDY AREAS 	
TASK 6. HYDROLOGIC CHARACTERIZATION OF STUDY AREAS 	
Subtask 6.1 Describe General Hydrogeology
Along Transects 	
Subtask 6.2 Describe Influence of Tides and
Evapotranspiration on Water
Level s
Subtask 6.3 Determine Percolation to the
Water Table 			
Subtask 6.4 Describe Ground-Water Flow Directions
and Flow Rates — 	
TASK 7. GROUND-WATER QUALITY CHARAv.. .-ATION OF
STUDY AREAS	 	 -	
Subtask 7.1 Describe General Ground-water Quality
Along Transects 	
Subtask 7.2 Evaluate Seasonal Meteorological
Effects on Ground-Water Quality 	
Subtask 7.3 Evaluate Impact on Ground-Water
Quality of Various Types of Residences —
TASK 8. EVALUATE GROUND-WATER MODELS 	
TASK 9. REPORT PREPARATION 	
TASK 10. REMOVE EQUIPMENT AND ABANDON WELLS 	
1
4
5
7
7
8
8
10
10
10
13
15
16
16
16
17
17
18
19
21
21
22
22
22
23
23
24
25
25
25
26
26
28
29
ii
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INTRODUCTION
The barrier islands are a narrow chain of islands along the coast of
North Carolina (Figure 1). The islands have a total length of approxi-
mately 260 miles with about 130 miles composed of the Cape Hatteras and
Cape Lookout National Seashores. Island widths are typically 2,000 feet,
but vary from less than 500 feet to more than 2 miles. Altitudes range
from sea level to about 30 feet and are generally less than 10 feet.
Three study areas have been selected for this study. The first
study area is Kill Devil Hills on Hatteras Island. The second study area
is Pine Knoll Shores-Atlantic Beach on Bogue Banks. The third study area
is Surf City on Topsail Island. The location of these study areas is
shown on Figure 1.
Residents in the study areas generally receive their water supply
from the mainland or from deep wells on the islands. Water is distri-
buted to individual homes using a water supply distribution network.
Some residents obtain their water supply from shallow wells. These
wells withdraw water from the water-table aquifer that directly underlies
the islands.
All residents on the islands use on-site septic systems to dispose
of their wastewater. These septic systems are generally composed of a
septic tank, a distribution box and a drain field. The septic tank is
A-l
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Virginia
Beach
VIRGINIA	
NORTH CAROLINA
Elizabeth City
Kill Devil
\ Hills
Greenville*
•Washington
Kinston
New Bern <
ATLANTIC OCEAN
Morehead City
Jacksonville •
Atlantic Beach
LEGEND:
PROPOSED STUDY AREA
New Topsail Beach
10 20 30 miles
Wilmington
Figure 1. Location map.
A-2
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used to settle solids from the wastewater. The distribution box is used
to distribute water to drainage pipes in the drain field. The drain
field is used to dispose of the wastewater by infiltration of the water
into the ground.
A critical factor to the continued development of on-site waste
disposal systems is the response of the water table to the infiltrating
wastewater. This disposal practice creates a net addition of water to
the water-table aquifer wherever a mainland or deep well source is used
for water supply. Water-table levels will rise in response to this
recharge. Water levels could rise to contact drain field trenches and
possibly cause surfacing of effluent in areas where the added wastewater
recharge becomes excessive.
Wastewater management planning requires that those involved in the
management process have simple and reliable procedures for estimating
water level and water quality changes that would be caused by increased
development on the Islands.
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TABLE OF CONTENTS
INTRODUCTION	-	
OBJECTIVES OF STUDY	-	
HYDROLOGIC DESCRIPTION OF STUDY AREAS 	
APPROACH			—			—	
TASK 1. FINALIZE TRANSECT AND WELL LOCATIONS 	
Subtask 1.1 Transect and Well Locations for
Kill Devil Hills Area 	
Subtask 1.2 Transect and Well Locations for
Atlantic Beach Area 	
Subtask 1.3 Transect and Well Locations for
Surf City Area 	
TASK 2. INSTALLATION OF MONITORING WELLS AND OTHER
MONITORING EQUIPMENT 	
Subtask 2.1 Obtain Drilling Subcontractors 		—-
Subtask 2.2 Install Monitoring Wells 	
Subtask 2.3 Install Tidal Gages —	—
Subtask 2.4 Install Precipitation Gages 	
Subtask 2.5 Elevation Survey	--
Subtask 2.6 Install Water-Level Recorders 	
TASK 3. DATA COLLECTION 	
Subtask 3.1 Measure Ground-Water Levels 	
Subtask 3.2 Measure Ground-Water Quality 	
Subtask 3.3 Determine Water-Table Aquifer
Properties 	
Subtask 3.4 Measure Ocean and Bay Water Levels 	
TASK 4. LAND AND WATER USE INVENTORY 	
TASK 5. GEOLOGIC CHARACTERIZATION OF STUDY AREAS 	
TASK 6. HYDROLOGIC CHARACTERIZATION OF STUDY AREAS 	
Subtask 6.1 Describe General Hydrogeology
Along Transects 	
Subtask 6.2 Describe Influence of Tides and
Fvapotranspiration on Water
Levels			
Subtask 6.3 Determine Percolation to the
Water Table 	
Subtask 6.4 Describe Ground-Water Flow Directions
and Flow Rates 	
TASK 7. GROUND-WATER QUALITY CHARACTERIZATION OF
STUDY AREAS 	
Subtask 7.1 Describe General Ground-water Quality
Along Transects 	
Subtask 7.2 Evaluate Seasonal Meteorological
Effects on Ground-Water Quality 	
Subtask 7.3 Evaluate Impact on Ground-Water
Quality of Various Types of Residences —
TASK 8. EVALUATE GROUND-WATER MODELS	-	
TASK 9. REPORT PREPARATION 	
TASK 10. REMOVE EQUIPMENT AND ABANDON WELLS 	-	-
1
4
t;
w
7
7
8
8
10
10
10
13
15
16
16
16
17
17
18
19
21
21
22
22
22
23
23
24
25
25
25
26
26
28
29
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HYDROLOGIC DESCRIPTION OF STUDY AREAS
The ground-water reservoir under the barrier islands generally con-
sists of a sandy water-table aquifer underlain by semi-confined and con-
fined aquifers. The semi-confined and confined aquifers are separated
from the water-table aquifer by confining beds of silt and clay. These
beds can occur at depths between 10 and 50 feet below land surface
(Winner, 1975).
Fresh ground water beneath the barrier islands occurs as a lens-
shaped mass floating on top of denser salt water. The shape and extent
of this freshwater lens is governed by the height of the water table
above mean sea level, the presence of silt and clay confining beds, the
effects of tides and periodic storm wash (Winner, 1978). A mixing zone
occurs at the boundary between the fresh and salty water due to fresh
water circulation and tides.
The water-table aquifer in the Kill Devil Hills area is approxi-
mately 50 feet thick (Peek et al. 1972). This aquifer consists of sand
with some shells and some thin interbedded clays and silty sands. The
base of the water-table aquifer is a layer of clay and interbedded clay
and sand that ranges in thickness from about 35 feet to more than 100
feet.
The water-table aquifer in the Atlantic Beach area is probably not
more than 100 feet thick. Winner (1978) describes the water-table
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aquifer in the area of Cape Lookout to have a maximum thickness of 100
feet with locally occurring confining beds of silt and clay. Cape
Lookout is located on Harpers Island approximately 12 miles east of
Atlantic Beach. Also, Winner (1978) reports that semi-consolidated sandy
limestone occurs at a depth less than 100 feet in the vicinity of
Moorehead City located about one mile north of Atlantic Beach.
Deeper freshwater aquifers underlie the water-table aquifer at both
Kill Devil Hills and Atlantic Beach. Peek et al. (1972) reports the pre-
sence of a Principal Aquifer and a Lower Aquifer at Kill Devil Hills.
The Principal Aquifer underlies the water-table aquifer and is separated
from it by clayey confining beds. The Lower Aquifer underlies the
Principal Aquifer. These aquifers are also separated by clayey confining
beds. Wells in the Atlantic Beach area are generally completed in
Tertiary age limestone at a depth of about 200 feet (LaGrand, 1960).
Some of these wells flowed in 1960.
The water-table aquifer at Surf City is 50 to 85 feet thick
(LaGrand, 1960; Layman, 1965). This aquifer consists of sand with some
clay lenses. The base of this aquifer is the Castle Hayne limstone.
The water-table aquifer at Surf City is underlain by a limestone
aquifer and a deep sandstone aquifer (Layman, 1965). The limestone
aquifer consists of highly porous limestone and has a thickness of
approximately 70 feet. Water in the limestone is under artesian
pressure. The deep sand aquifer consists of interbedded sands and clays
and has a thickness that probably exceeds 190 feet.
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APPROACH
The work to be performed is divided into ten tasks. Task 1 is fina-
lizing the transect and well locations for each study area. Task 2 is
installation of monitoring wells and monitoring equipment. Task 3 is
data collection. Task 4 is determining land and water use in the study
areas. Task 5 is geologic characterization of the study areas. Task 6
is hydrologic characterization of the study areas. Task 7 is charac-
terization of ground-water quality in the study areas. Task 8 is
demonstrating the use of a simple ground-water model. Task 9 is report
preparation. Task 10 is removal of equipment and abandonment of wells.
Each of these tasks is described in the following pages.
TASK 1. FINALIZE TRANSECT AND WELL LOCATIONS
Hydrologic data will be collected along transect lines to be located
in each of the study areas. A minimum of three transects will be
selected in each study area. One transect will be selected in an area of
low population density. A second transect will be selected in an area of
medium population density. A third transect will be selected in an area
of high population density.
Tentative transect and well locations were selected in each of the
study areas during a reconnaissance visit to the areas in October. Each
transect line was located with the idea that well locations could be
placed within road right-of-way lines where practical. In this manner,
obtaining permission to drill at sites along a transect will be
simplified.
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Transect lines and well locations will be finalized when the project
begins. Recent areal photographs which will be supplied to the project
by the EPA will aid in determining the final locations. Permission to
drill wells and install monitoring equipment will then be obtained from
the appropriate authorities or individuals, including the North Carolina
Department of Water Resources.
Subtask 1.1 Transect and Well Locations for Kill Devil Hills Arp*
Three transect lines are located in the Kill Devil Hills area. A
transect line in an area of low density development is located adjacent
to the south end of the Kitty Hawk Memorial along Collington Road. Eight
well location sites are identified along this transect. A medium popula-
tion density transect is located along Chowan Avenue. Five well location
sites are identified along this transect. A high population density
transect is located along 5th Avenue. Six well location sites are iden-
tified along this transect. The locations of transect lines and well
sites 1n the Kill Devil Hills area are shown on Figure 2.
Subtask 1.2 Transect and Well Locations for Atlantic B^arh Arp»
Four transect lines are located in the Pine Knoll Shores-Atlantic
Beach area. A transect line in an area of low population density is
located along Pine Knoll Boulevard in Pine Knoll Shores. Three well
location sites are identified along this transect. A medium population
density transect is located along Willow Road in Pine Knoll Shores. Five
well location sites are identified along this transect. A high popula-
tion density transect that is representative of single family residences
A-8
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Match lino A-A'
Kitty Hawk
¦ Memorial •
MEDIUM
DENSITY
LOW DENSITY
HIGH DENSITY
4000 feet
Match line A-A'
LEGEND:
	Transect line
•' Monitoring well site
9 Monitoring well site with multiple wells
(§) Monitoring well site that includes well with
automatic water-level recorder.
Figure 2. Transect and well locations in Kill Devil Kills.
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is located between Greenville Avenue and Wilson Avenue in Atlantic Beach.
A high population density transect that includes a large multiple family
residence is located along Dunes Avenue in Atlantic Beach. Three well
location sites are identified along each of the high density transects.
The locations of transect lines and well sites in the Pine Knoll
Shores-Atlantic Beach area are shown on Figure 3.
Subtask 1.3 Transect and Well Locations for Surf City Area
Four transect lines are located in the Surf City area. A transect
line in an area of low population density is located between Mecklenburg
Avenue and Carven Avenue. Three well location sites are identified along
this transect. A medium population density transect is located between
Neptune Avenue and Pender Avenue. Three well location sites are iden-
tified along this transect. A high population density transect that is
representative of trailer park development is located between Stevens
Street and Mecklenburg Street. A high population density area that
represented a mix of homes and commercial businesses is located along
Goldsboro Avenue. Three well location sites are identified along each of
the high density transects. The locations of the transect lines and well
sites in the Surf City area are shown on Figure 4.
TASK 2. INSTALLATION OF MONITORING WELLS AND OTHER MONITORING EQUIPMENT
Subtask 2.1 Obtain Drilling Subcontractors
Drilling subcontractors for installing the monitoring wells will be
chosen by competitive bidding. It is anticipated that a separate contact
will be awarded for each study area. A bid package for the drilling work
will be prepared during the first week of the project.
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LOW DENSITY
MEDIUM DENSITY
ATLANTIC OCEAN
"f
<
©
c
o
OJ
2
HIGH DENSITY
single family
HIGH DENSITY
multiple family
4000 feet
LEGEND:
	 Transect line
•	Monitoring well site
•	Monitoring well site with multiple wells
® Monitoring well site that includes well
with automatic water-level recorder
Figure 3. Transect and well locations in Pine Knoll Shores-Atlantic Beach.
A-11
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MEDIUM
.DENSITY
'LOW DENSITY
HIGH DENSITY
trailer
HIGH DENSITY
residential
and commercial
3000 feet
LEGEND:
	Transect line
•	Monitoring well site
•	Monitoring well site with multiple wells
<§) Monitoring well site that includes well with
automatic water-level recorder.
Figure 4. Transect and well locations in Surf City area.
A-12
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Subtask 2.2 Install Monitoring Wells
Monitoring well clusters will be installed at all monitoring well
sites along transects located in high density population areas. Three or
four monitoring wells will be completed at each cluster. One monitoring
well will be completed near the water-table surface. A second monitoring
well will be completed midway between the water-table surface and the top
of clayey confining beds underlying the water-table aquifer. A third
monitoring well will be completed immediately above the top of the con-
fining beds. In the absence of clayey confining beds, one monitoring
well will be completed immediately above the limestone bedrock surface
and an additional monitoring well will be completed approximately 25 feet
into the limestone bedrock.
Three monitoring well clusters will be installed at monitoring well
sites along transects located in medium and low density population areas.
One cluster will be located close to the ocean. Another cluster will be
located close to the bay. The third cluster will be located near the
mid-point of the transect. The proposed locations for monitoring wqll
clusters are shown on Figures 2, 3 and 4.
The monitoring well clusters will serve multiple purposes. Water-
quality data collected from these monitoring wells will aid in iden-
tifying vertical variations in water quality along a transect. These
data will also aid in identifying the quality of water discharging to the
ocean and to the bay. Water-level data collected from these wells will
aid in identifying ground-water flow paths and in monitoring the position
of the water table.
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Single monitoring wells will be located at monitoring well sites
that do not have a cluster of monitoring wells. The monitoring well at a
single well site will consist of a shallow well to monitor the position
of the water table.
One deep monitoring well may be drilled in each study area. This
well will be drilled to determine the depth to the fresh water-salt water
interface and aid in defining the hydrogeology in the area. The well
will be drilled if near-surface confining beds are not identified in the
water-table aquifer in the study area. The well will be terminated
before reaching the fresh water-salt water interface if it becomes
apparent during drilling that confined fresh-water aquifers that receive
water from sources on the mainland are being encounter.
Borings for monitoring wells will be advanced using a hollow stem
auger or other approved method. A geologic log of each borehole will be
recorded by an ABI*geologist who will monitor the drilling. Split-spoon
samples will be taken approximately every five feet during augering .of
the deepest boring. This sampling will be done in accordance with proce-
dures outlined in ASTM D 1586-74. The samples will be used to aid in
defining the lithology at the site. Undisturbed samples may be collected
for laboratory analyses of permeability and grain size to aid in defining
the hydrogeology at the site. These samples will be collected in accor-
dance with procedures outlined in ASTM D 1587-74. Coring may be done to
advance borings that encounter refusal. Coring will be performed in
accordance with ASTM D 2113-70.
*EPA contractor
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Most borings will be completed as two-inch diameter monitoring
wells. PVC pipe and screen will be used for constructing these wells.
The annulus between the well screen and the borehole will have a minimum
1.5-inch thick gravel pack. The remainder of the annulus will be filled
with a cement or bentonite grout mixture. A protective cap and cover
will be placed over the well at the surface.
One shallow boring in each study area will be completed as either a
four-or-six-inch diameter monitoring well. An automatic recorder for
measuring ground-water levels will be installed on each of these wells.
These wells will probably be located in the center of the low population
density transect (Figures 2,3 and 4). The wells will be constructed
using PVC pipe and screen.
Each monitoring well will be developed by pumping or bailing. Water
will be removed from a well until the well produces sediment-free water.
Subtask 2.3 Install Tidal Gages
One tidal gage will be established in the bay and one tidal gage
will be established in the ocean for each study area. These gages will
consist of a reference point with a known elevation from which the
distance to water can be measured. The tidal gage for the bay will be
established on a bridge or a pier. The tidal gage for the ocean will be
established on the nearest fishing pier. A stilling well consisting of
two-inch diameter PVC pipe may be installed on the fishing pier to aid in
more accurately measuring ocean water levels.
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Subtask 2.4 Install Precipitation Gages
A precipitation gage will be established in each study area. The
precipitation gages will be non-recording and will need to be read daily.
An observer will be hired in each study area to read and record daily
precipitation.
Subtask 2.5 Elevation Survey
A professional surveyor will determine the land surface profile
along each transect, elevations of the top of casing for each well and
the elevation for each tidal gage reference point. This data will be
needed in order to reference water levels and land surface to a common
datum. The land surface profile will be determined to the nearest foot
of elevation. The casing elevations and tidal gage elevations will be
determined to an accuracy of 0.02 feet.
The surveyor will be required to establish bench marks in the vici-
nity of each well monitoring site and each tidal gage. These bench marks
will have a known elevation to within 0.02 feet. The bench marks will
provide a reference elevation for replacing well casings that may become
damaged and tidal gages that may become damaged or destroyed.
Subtask 2.6 Install Water-Level Recorders
An automatic water-level recorder will be installed one shallow
monitoring well in each study area. This monitoring well will have been
finished as either a four- or six-inch well in order to accommodate a
recorder float. The recorder will be capable of recording water levels
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for up to 30 days. It will also be capable of recording water levels "to
within 0.01 foot. The recorder will be protected by a metal box which
will be placed over the recorder and anchored to the well casing.
TASK 3. DATA COLLECTION
Data collection efforts include the collection of ground-water level
data, ground-water quality data, aquifer-test data, and ocean and bay
water-level data. Ground-water level data and ocean and bay water-level
data will be collected quarterly. Ground-water quality data will also be
collected quarterly. Additional water-level and water-quality data will
be collected during short-intensive data collection periods. Aquifer-
test data will be collected once at selected monitoring wells.
Subtask 3.1 Measure Ground-Water Levels
Water-level elevations in monitoring wells will be determined from
depth to water measurements. The water-level elevation in a well is
equal to the elevation of the reference point on the top of the casing
from which the depth to water measurement is made minus the measured
depth to water. Depth to water measurements will be made using a steel
tape. Water levels will be measured in all wells coincidentally with the
collection of ground-water quality data.
Water levels will be measured in each of the wells in each high
population density transect over a 24-hour period. This will be done
twice during the course of the study. One set of measurements will be
made during the winter when the effects of ground-water evapotranspira-
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tion are minimal. The second set of measurements will be made during the
summer when the effects of ground-water evapotranspiration are greatest.
Additionally, water levels will be measured along one of the high popula-
tion density transect during and following a major storm event if prac-
tical. Water-level data will be collected after such a storm event until
a recession trend in water levels is well defined.
Subtask 3.2 Measure Ground-water Quality
Water quality will be monitored quarterly along the high population
density transect in each area. The field parameters that will be moni-
tored include pH, temperature and specific conductance. Water samples
will be taken for laboratory determination of fecal coliform bacteria,
nitrate/nitrite, ammonia, chloride, sodium, total dissolved solids,
orthophosphate, MBAS, alkalinity and hardness. Water sampling will be
done in accordance with procedures outlined in ABI's quality assurance
manual (Appendix
Styrofoam ice chests will be used for shipping samples. Sample
bottles will be inventoried, then packed upright in the chests and
covered with ice. The chests will be sealed with filament tape. One
copy of an inventory sheet for each chest will be retained by the field
personnel, one copy will be sent to the quality control manager at ABI
and one copy will be sent with the samples.
Maximum holding times recommended by Standard Methods, 15th Edition
for preserved samples will be followed. This will be done by taking
*Not included here.
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samples at the end of each day to either Norfolk, Virginia, New Bern,
North Carolina or Wilmington, North Carolina, for air transport to
Atlanta, Georgia. The scheduled service to Atlanta from each of the
three airports in the project area is adequate to meet the required time
constraints.
Sample analyses for all parameters except fecal coliform bacteria
will be performed in ABI's Atlanta office. Analysis for fecal coliform
bacteria will be done by ABI in the field using the membrane filtration
technique. Laboratory analysis procedures that will be followed are
outlined in Table 1.
Water quality will be sampled along one of the high population den-
sity transects immediately following a major storm event if practical.
It is envisioned that one set of water quality samples will be collected.
This data collection effort will proceed coincidentally with the collec-
tion of water-level data for a storm event.
Subtask 3.3 Determine Water-Table Aquifer Properties
The hydraulic conductivity for the water-table aquifer will be com-
puted by simple tests performed in the field. Slug tests or bailer tests
will be performed in selected monitoring wells. Generally, a known
volume of water is suddenly removed from the well in a slug test and
recovery of the water level in the well is measured at repeated, closely
spaced intervals. The bailer method requires a single measurement of
residual drawdown in the well after the well has been bailed a given
number of times at closely spaced intervals.
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TABLE 1
WATER QUALITY ANALYSIS METHODS
Analysis
Method
Reference
N-NH„
N-
no3/no2
Chloride
p-P°.
(ortfiophosphate)
MBAS
Sodium (total)
Total Dissolved
Solids
Alkalinity
Hardness, Total
(mg/1 as CaC03)
1)	Dionex Ion Chromatograph
2)	(350.1) Colorimetric,
Automated phenate
Storet No. 00610
1)	Dionex Ion Chromatograph
2)	(353.2) Colorimetric,
Automated,
Cadmium Reduction
Storet No. 00630
1)	Dionex Ion Chromatograph
2)	(325.2) Colorimetric,
Automated Ferricyanide
Storet No. 00940
1)	Dionex Ion Chromatograph
2)	(365.1) Colorimetric,
Automated,
Block Digester
Storet No. 70507
(425.1) Colorimetric
Storet No. 38260
1) (273.1) Atomic Absorption
Storet No. 00929
1) (160.1) Gravimetric,
Dried at 180°C
Storet No. 70300
1) (310.2) Colorimetric,
Automated, Methyl Orange
Storet No. 00410
1) (130.1) Colorimetric,
Automated EDTA
Storet No. 00900
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
EPA-600/4-79-020
*The Dionex ionic chromatograph will be the primary method used for those
analyses where listed.
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Both methods require that the static water level in the well be
measured prior to testing. These tests will be run as soon as practical
after the monitoring well installation program is completed.
Subtask 3.4 Measure Ocean and Bay Water Levels
Water-level elevations in the ocean and bay will be determined from
depth to water measurements. The water level is equal to the elevation
of the reference point from which the measurement is made minus the
measured distance to water. Distance to water measurements will be made
using a steel tape. This data will be collected coincidentally with
ground-water level and ground-water quality data.
Additional tidal data will be collected during intensive ground-
water level and ground-water quality data collection to support these
efforts.
TASK 4. LAND AND WATER USE INVENTORY
A land use inventory will be conducted at the time of well place-
ment. This inventory will identify all types of land use within approxi-
mately 200 feet to either side of the transects. Particular emphasis
will be placed upon identifying areas which may add to or detract from
localized aquifer recharge. These areas will include water bodies such
as ponds or drainage ditches and covered areas such as building foun-
dations, parking lots and other paved or cemented areas.
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Following the inventory, the information obtained will be plotted on
topographical maps of the transect areas. This will enable more accurate
determination of ground-water recharge from precipitation within the
immediate vicinity of the transects.
Wastewater discharge will be determined within 200 feet to either
side of all transects. Usage will be determined on a monthly basis from
utility records or by an on'Site survey where needed.
TASK 5* GEOLOGIC CHARACTERIZATION OF STUDY AREA
The geology at each transect will be characaterized based on
interpretation of geologic logs for the borings along the transects.
Geologic cross~sections will be drawn along each transect that depicts
the lithology at the transect. Variations in lithology will aid in
understanding the hydrogeology along the transect.
TASK 6. HYDROLOGIC CHARACTERIZATION OF STUDY AREAS
Subtask 6.1 Describe General Hydrogeology Along Transects
The hydrogeology along each transect will be characterized based on
the results of the geologic characterization and water-level measurements
made in monitoring wells along the transects. Cross sections will be
drawn along transects for selected time periods that shows the position
of the water table, vertical variations in water levels and vertical
variations in chloride content of the water. Variations in water levels
and chloride content of the water will be examined relative to variations
in lithology. Variations in water levels through time and the general
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relationship between precipitation and water levels will be described
using hydrographs for selected wells.
Subtask 6.2 Describe the Influence of Tides and Evapotranspiration on
Mater Levels
The influence of tidal fluctuations and evapotranspiration on the
position of the water table will be examined through in-depth studies of
water-level fluctuations. Water-level data collected from monitoring
wells with recording gages will provide the basis of information for this
study. The effects of tidal flucuations will be estimated from water-
level records for the winter months when evapotranspiration losses are
minimal. The effects of evapotranspiration will be estimated from water-
level records for the summer months when evapotranspiration is greatest.
Water-level data collected during the intensive studies will aid in eva-
luating the effects of evapotranspiration on the water table.
Subtask 6.3 Determine Percolation to the Water Table
Monthly percolation to. the water table will be determined from the
equation:
PERC = I + R - S - ET
where: PERC = percolation to the water table, in inches;
I = infiltration from precipitation, in inches;
R = recharge from wastewater, in inches;
S = change in soil moisture storage, in inches; and
ET = evapotranspiration.
Monthly infiltration will be assumed to be equal to monthly precipita-
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tion. Monthly precipitation will be measured as described in Task *2.
Monthly recharge from wastewater will be measured as described in Task 4.
Monthly soil moisture changes and monthly evapotranspiration will be com-
puted using methods outlined in Appendix B* Soil moisture changes in
this method are based on monthly changes 1n Infiltration and potential
evapotranspiration. Monthly evapotranspiration is based on monthly
Infiltration rates, monthly potential evapotranspiration and computed
changes 1n monthly soil moisture.
The accuracy of the method used to compute soil moisture changes and
evapotranspiration will be checked during the course of the study.
Water-level data collected during the field studies will be used to esti-
mate evapotranspiration losses for comparison with computed losses.
Subtask 6.4 Describe Ground-water Flow Directions and Flow Rates
Ground-water flow directions will be described from geologic cross-
sections along transects showing the water table configuration and ver-
tical variations in hydraulic heads. Equal potential lines and flow
lines will be constructed along these cross-sections to define flow nets
and directions of ground-water flow.
Ground-water flow times and flow raf~~ wi"P be computed for the
water-table aquifer based on the results of aquif r testi ?.nd analyses
of ground-water flow directions. Flow velocities along cross sections
will be computed based on the hydraulic characteristics of the aquifer
and hydraulic gradients in the aquifer. Flow times along cross-sections
*Not included here.
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will be estimated based on flow velocities and the length of flow lines.
Flow rates along cross-sections will be estimated based on the hydraulic
characteristics of the aquifer and the results of flow-net analyses.
TASK 7. GROUND-WATER QUALITY CHARACTERIZATION OF STUDY AREAS
Water quality sampling will be used to determine variations in
ground-water quality. The results from quarterly sampling will be used
to describe seasonal variations in water quality caused by variations in
domestic wastewater disposal. The results from sampling along one of the
high density transects after a major storm will be used to describe the
impact of natural percolation on water quality.
Subtask 7.1 Describe General Ground-Water Quality Along Transects
The water quality along each high density transect will be charac-
terized based on the results of water sampling and analysis. Cross sec-
tions will be drawn along transects that shows the position of the water
table and variations in the water-quality parameters that are being
measured. Variations in water quality will be examined relative to
variations in land use, specific sources of wastewater discharge and
1ithology.
Subtask 7.2 Evaluate Seasonal and Meteorological Effects on Ground-Water
Quality
Temporal variations in water quality along transects will be
investigated. Changes in water quality along transects will be compared
with changes in recharge from wastewater disposal and infiltration from
precipitation.
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Subtask 7.3 Evaluate Impact on Ground-Mater Quality for Various Types of
Residences
High density population transects were chosen to represent single
family housing, trailers, and multiple family housing. The impacts of
wastewater disposal from each of these types of residences on ground'
water quality will be evaluated by comparing wastewater discharge quan-
tities and water quality along transects.
TASK 8. EVALUATE GROUND-WATER MODELS
The simplified ground-water model developed by Fetter (1972) will be
evaluated for its applicability to estimate changes in water-table eleva-
tions on the barrier islands that result from changes in percolation.
The equation used for these computations is:
W(a2.x2)
h = 4TK—
where: W = percolation to the water table, in feet per day;
h = elevation of water-table, in feet mean sea
level;
a = half-width of the island, in feet;
x 3 distance from center of island to point at which
it is required, in feet;
K = hydraulic conductivity, in feet per day.
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The model will be evaluated by comparing measured water levels along
transects for selected periods with computed water levels for the same
periods. Water-table elevations along transects will be known at regular
intervals from water-level measurements. These elevations will be com-
pared with those computed using the model and average percolation along
the transects for the interval between measurements. Also, changes in
average percolation between intervals will be used to compute water-table
elevations at the end of the intervals.
The principle of superposition will be used for computing water
levels based on changes in percolation. This principle allows solutions
to an equation to be added and subtracted so long as a linear rela-
tionship exists between the independent and dependent variables in the
equation. In Fetter's equation, the independent variable is percolation
(W) and the dependent variable is water-table elevation (h). A linear
relationship exists between W and h2 in the equation. Therefore, solu-
tions for h2 must be added or subtracted before solving for h over the
time intervals.
The influence of tidal fluctuations on water-table elevations will
be identified during the study. These effects will be removed from
measured water-table elevations prior to using these elevations in the
model evaluation process.
An alternate ground-water model that will be evaluated is derived
from data reported by Winner (1975). Winner observed a relationship bet-
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ween change in water-table elevation and change in depth to the fresh
water-salt water interface that departed from an ideal constant rela-
tionship. This relationship, when put in an equation format similar to
the format of Fetters' equation is:
W(a2.x2)
h2 = K(l+12.3h-«)
The fresh water-salt water interface in Winner's relationship is defined
as the point where the chloride content of the water is 250 milligrams
per liter.
This alternate model will be evaluated in a manner similar to the
approach used to evaluate Fetters' model where applicable. Measured
water levels along transects for selected periods will be compared with
computed water levels for the same periods. Water levels cannot be com-
puted based on changes in percolation because there is not a linear rela-
tionship between water-table elevation and percolation.
TASK 9. REPORT PREPARATION
A report will be prepared that describes the work that has been done
and the conclusions that were reached. The report will include:
An introductory section that gives bac1" -ound i-^-nation about
the study, discusses the objectives and scope ot the investiga-
tion and describes the location and physical setting for the
study;
A description of field data collection activities performed
during the study;
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ofdtherstudy"areas;6 9eol°9ica1 and hydrologlcal characteristics
modelsTfor^estimati'nn apJ11cability of simplified ground-water
models tor estimating water,level changes caused by percolation;
An analysis of the imnartc	^
systems on ground-water quality; 0n~site wastewater disposal
. A summary of findings;
Recommendations; and
. Appendices that contain supporting data.
TASK 10. REMOVE EQUIPMENT AND ABANDON WELLS
Monitoring equipment will hp
e ra,noved and monitoring wells will be
abandoned at the completion of t-hp	„ .
OT tne Project. Monitoring wells will be
abandoned in conformance with ororeHi i*.*.. -.c- .
n Procedures specified by the North Carolina
Department of Water Resources fnr	j ^
the abandonment of temporary wells.
Generally, this procedure 1 net urine
finishing the well below grade level
and backfilling the well with a cement grout.
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