United States	Region 4	EPA 904/9-83-115

Environmental Protection	345 Courtland Street, NE	August 1983

Agency	Atlanta, GA 30365

SEPA Environmental	Final

Impact Statement

Hilton Head, South Carolina
Wastewater Facilities

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iiiiedaonAgcKy

FINAL

ENVIRONMENTAL IMPACT STATEMENT
for

HILTON HEAD ISLAND, SOUTH CAROLINA
Prepared by
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia 30365

This Final EIS addresses proposed wastewater facilities for
Hilton Head Island, South Carolina. Numerous wastewater
management alternatives have been evaluated with particular
attention to water quality in the area's surface and groundwater
resources and the impacts of projected population growth on
the natural and human resources of Hilton Head Island and the
surrounding area.

Comments and inquiries should be forwarded to:

Robert C. Cooper
Project Officer, NEPA Compliance Section
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
404/881-3776

Approved by

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EXECUTIVE SUMMARY

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EXECUTIVE SUMMARY FOR ENVIRONMENTAL IMPACT STATEMENT

HILTON HEAD ISLAND WASTEWATER FACILITIES

Draft ( )
Final ( x )

Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365

Type of Action:	Administrative Action ( x )

Legislative Action ( )

EXECUTIVE SUMMARY

PART A. PURPOSE OF EIS AND BACKGROUND

This Environmental Impact Statement (EIS) addresses alternatives for and
impacts of the provision of wastewater management facilities on Hilton Head
Island. Wastewater collection and treatment on Hilton Head is principally
provided by designated public services districts, which have been established
by state enabling legislation. Four public service districts comprise the
island as follows:

Sea Pines Public Service District
Forest Beach Public Service District
Broad Creek Public Service District
Hilton Head No. 1 Public Service District

Each public service district (PSD) operates its own wastewater treatment and
disposal facilities, with the exception of the Forest Beach Public Service
District. Wastewater is conveyed from Forest Beach to the Sea Pines Public
Service District for treatment and disposal. Plate ES-1 depicts the location
of the PSD treatment facilities and spray irrigation areas.

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Hilton Head Plantation is served by treatment facilities owned and op-
erated by the Hilton Head Plantation Utilities Corporation. Several small,
privately-owned treatment facilities are located elsewhere on the island
which provide service to isolated residential or resort areas including the
Lout; (love Club, Wexford, Cotton Hope Plantation, Jenkins Island - Windmill
Harbour and the Mariners Cove Club. The remaining rural areas of the island
utilize septic tank-drainfield systems.

Treated wastewater from the wastewater facilities on the island is
disposed of by several methods. To a large extent, treated wastewater is
used to irrigate the golf courses on the island. In a few cases, treated
wastewater is sprayed onto areas of open land as a supplement to golf course
irrigation. However, present wastewater flows from the Sea Pines PSD -
Forest Beach PSD exceed the total irrigation demands of the golf courses
located within Sea Pines and Shipyard Plantations. As a result, up to 1.8
million gallons per day (mgd) of treated wastewater are discharged into
Lawton Canal and thence to Lawton Creek which is classified for shellfishing.

The 201 Facilities Plan, completed in 1975, recommended that the effluent
from all treatment plants be disposed of by spray irrigation on nearby golf
courses so as not to impact area shellfish waters. While conceptually sound,
this scheme was based upon golf course irrigation rates which have proved to
be optimistic, particularly in the case of the Sea Pines PSD and the Forest
Beach PSD. The continued ability of the other PSD's on the island to dispose
of their treated wastewater by golf course irrigation will depend upon the
actual rate of development experienced within each.

In August 1978 the South Carolina Department of Health and Environmental
Control (DHEC) closed shellfish beds in Lawton Canal and Lawton Creek, in
Point Comfort Creek, and in adjacent waters of Broad Creek. These areas were
closed because of high total and fecal coliform counts encountered in surface
water samples. Subsequent water quality studies confirmed that shellfish
standards were being violated; findings indicated that these violations were
attributable to non-point source bacterial contamination.

Because of these environmental complexities and the uniqueness of Hilton
Head as a barrier island, the Environmental Protection Agency decided to pre-
pare an Environmental Impact Statement with respect to wastewater management
facilities to serve the existing and future populations of Hilton Head Island.
Subsequently, a Notice of Intent was issued by the EPA Regional Administrator
in April, 1979. Concurrent with the Hilton Head EIS, the South Carolina
DHEC initiated a study of the Lawton Creek - Broad Creek watershed in order to
better define the extent to which non-point and point sources influence their
bacterial characteristics. These studies confirmed the existence and magnitude
of non-point contamination of Lawton Creek. Only the effluent from the Sea
Pines treatment plant met water quality standards with any consistency.

Additional non-point work has been performed through the 208 program under
the direction of an advisory committee representing local, state, and Federal
governments. The study has recommended effective management practices to abate
non-point pollution from island development. These recommendations are now
before the Beaufort County Council.

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PART B. CHANGES AND NEW INFORMATION
SINCE THE DRAFT

Comments regarding the Draft EIS were received at the June 23, 1982
public hearing held at the Hilton Head Island Elementary School and during
the comment period held afterward. These comments and new information
have been carefully considered in the Final EIS process.

New information incorporated into the Final EIS includes:

a.	The alternative wastewater management program proposed by the Sea
Pines Public Service District has been thoroughly evaluated and
serves as the basis of EPA's final decision.

b.	Comments regarding the population projections for Hilton Head
Island and the associated wastewater flows have been considered.
Updated flow projections have been made for the major service
areas and wastewater management alternatives re-evaluated.

c.	Several commenters indicated the need for a wastewater management
plan for the entire island, regardless of EPA's funding and
permitting constraints. Although the EIS focuses on the Sea
Pines PSD - Forest Beach PSD, EPA recognizes and supports com-
prehensive wastewater management alternatives for the remainder
of Hilton Head. Several alternatives are presented in the Final
EIS, and recommendations made with respect to local implementation
of an island-wide plan.

d.	Several persons and interests commented regarding non-point source
pollution on Hilton Head Island; all were concerned with the
water quality impacts resulting from non-point source pollution.
Some commenters supported EPA's action to condition funding for
additional wastewater facilities upon demonstrated progress
toward solving the non-point source problem. While others con-
curred with the EPA conclusion regarding the magnitude of non-
point source pollution, these commenters believed the Draft EIS

to be lacking because it did not offer any specific solutions.
EPA's final decision addresses these concerns.

e.	The South Carolina Coastal Council has adopted a Special Area
Management Plan for Hilton Head Island which establishes policy
with respect to new projects or the expansion and significant
alteration of existing projects or activities. Among ,other
things, policy is set forth regarding the discharge of treated
sewage into the surface waters of Hilton Head Island. The final
evaluation of wastewater management alternatives is consistent
with Council policy.

f.	The Cubit Engineering dye study performed for the Sea Pines
Public Service District evaluates water quality impacts from a
wastewater discharge into Calibogue Sound. This information
has been considered by EPA during the decision process.

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g. Residents of Hilton Head have recently voted by referendum to
attain city-status through incorporation. Consequently, many of
the actions recommended to be taken at the local government level
as mitigative measures, particularly with respect to land use and
non-point source control, will become the eventual responsibility
of the new City of Hilton Head Island.

PART C. ALTERNATIVES CONSIDERED
AND THEIR EVALUATION

A broad range of wastewater management alternatives were formulated
and evaluated for the Sea Pines PSD - Forest Beach PSD and the remainder
of the island. The alternatives presented in the Final EIS are based upon
updated wastewater flows for the major service areas as noted below.

	Service Area	

Sea Pines PSD - Forest Beach PSD
Broad Creek Public Service District
Hilton Head No. 1 PSD
Gardner-Matthews Plantation
Hilton Head Plantation

Peak
Wastewater Flow
4.5 mgd
2.4 mgd
2.8 mgd
1.1 mgd
2.0 mgd

During the alternative evaluation process, reuse of treated wastewater for
beneficial purposes through golf course, open space, and lawn irrigation was
considered to be a primary objective. However, it is recognized that, during
periods of heavy rainfall, irrigation needs may be insufficient to utilize
all of the treated wastewater on the island. Consequently, a supplemental
backup system is required for each reuse system. Supplemental disposal tech-
niques include discharge to Lawton Canal, discharge to either Calibogue
Sound or the Atlantic Ocean via a subaqueous outfall and diffuser, and treat-
ment and land application either on or off the island.

Alternative management schemes are generally described below.

Sea Pines PSD - Forest Beach PSD

Each wastewater management system for the Sea Pines - Forest Beach ser-
vice area includes expansion of the Sea Pines PSD treatment plant to 5.0 mgd;
irrigation of the five 18-hole and one 9-hole golf courses within the service
area; and possible implementation of the experimental wetlands discharge in
the Sea Pines Forest Preserve. Seven different alternatives have been for-
mulated around these common elements as summarized below.

Lawton Canal Discharge - This alternative involves the discharge of advanced-
treated wastewater to Lawton Canal as a supplement to irrigation of the golf
courses. Sand filters would be constructed at the 5.0 mgd plant proposed by
the Sea Pines PSD in order to achieve the effluent quality required by DHEC.
The experimental wetlands discharge system could be utilized to the extent
possible.

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Calibogue Sound Discharge - This alternative involves the discharge of
secondary-treated wastewater to Calibogue Sound through a subaqueous out-
fall and diffuser as a supplement to irrigation of the golf courses.

Again, the experimental wetlands discharge system could be utilized to
the extent possible.

Atlantic Ocean Discharge - This alternative involves the discharge of
secondary-treated wastewater to the Atlantic Ocean through subaqueous out-
fall and diffuser as a supplement to irrigation of the golf courses. Again,
the experimental wetlands discharge system could be utilized to the extent

possible.

A substantially longer underwater outfall is required to reach a 20-foot
depth in the Atlantic Ocean than required to reach water of greater than
30-foot depth in Calibogue Sound. Figure ES-1 shows relative water depths
in the Sound and in the Ocean.

Wastewater Reuse - Treated wastewater will be reused not only to irrigate
golf courses but also to irrigate open space and lawns. Wastewater will
be treated to an advanced level to achieve a suspended solids concen-
tration of 5 mg/1 prior to reuse. The experimental wetlands discharge
system may continue to be implemented in an effort to reestablish
diminishing wetlands within the Forest Preserve.

A backup system must be constructed for periods of heavy rainfall. This
system can be a discharge to Calibogue Sound, an Ocean outfall, or any
other approved system that will meet Federal, State, and local require-
ments.

Rapid Infiltration - This alternative has been developed to meet the pos-
sible constraint that lands outside of the PSD boundaries could not be
obtained for the land application of wastewater to supplement golf course
irrigation. A combination of rapid infiltration, woodlands irrigation, and
wetlands discharge into the Forest Preserve is required to provide this
supplemental capacity.

The woodlands irrigation scheme involves the application of treated waste-
water onto wooded parcels which lie within the Forest Beach PSD along its
boundary with the Broad Creek PSD and immediately adjacent to the Hilton
Head Golf Club. These parcels have an estimated usable area of approxi-
mately 32 acres. At an application rate of 2 inches per week, approximately
0.25 mgd could be applied.

As indicated in a previous report prepared for the Sea Pines PSD, a site
within the Sea Pines Forest Preserve adjacent to the Sea Pines PSD plant
is the best site available for construction of a rapid infiltration system.
This area is presently wooded and construction of a rapid infiltration
system would require extensive clearing and site alteration. Approximately
80 acres of bed area would be required to dispose of 3.25 mgd.

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Assuming that the woodlands irrigation and rapid infiltration components
can handle 0.25 mgd and 3.25 mgd respectively, the wetlands discharge system
must handle 1.0 mgd to provide a workable alternative. If either wetlands
discharge or rapid infiltration cannot reliably handle the indicated rate
of application, then the other must accommodate the difference. If both
wetlands discharge and rapid infiltration cannot reliably handle their re-
spective rates of application, there is insufficient suitable land within
the PSD's for woodlands irrigation to take up the slack.

Spray Irrigation On-Island - This alternative provides for the disposal of
wastewater quantities which are not used by the golf courses totally by spray
irrigation on a single large tract outside the boundaries of the PSD's. The
experimental wetlands discharge system could be utilized to the extent pos-
sible.

Of the undeveloped land parcels on Hilton Head, the Gardner-Matthews tract
(Parcel 1 on Beaufort County Tax Map 11) has been identified as most suitable
for land application of treated wastewater. This parcel has a total area of
nearly 1,000 acres; almost 40 percent of the parcel is composed of the well-
drained Wando soils which are generally located in the center of the parcel.
The Otter Hole Trailer Park and a 15-acre residential property lie within the
tract. Almost all of the estimated 600 usable acres would be required for the
land application system.

Spray Irrigation Off-Island - This alternative provides for the disposal of
wastewater quantities which are not used by the golf courses totally by spray
irrigation on large tracts of land off the island including the crossing of'
Skull Creek and Mackay Creek either with an underwater pipeline or pipe sus-
pended from the bridges. Again, the experimental wetlands discharge system
could be utilized to the extent possible.

Three general areas on the mainland have been identified as potential spray
sites, based upon soils characteristics. These areas are Union Camp property
in the Bluffton area, contiguous parcels in the Sawmill Creek area, and con-
tiguous parcels south of Route 278 generally across from Moss Creek Plantation.

No-Federal Action Alternative - A requirement of the EIS process developed by
EPA is that a no-action alternative will be considered along with other waste-
water facilities alternatives. The no-action alternative implies that no
Federal funding would be available for wastewater facilities on Hilton Head.
Under this alternative, improvement and/or expansion of the wastewater facili-
ties would be required but there would be no Federal funds provided for design
and construction of the facilities.

The wastewater management alternatives formulated for the Sea Pines PSD -
Forest Beach PSD were evaluated with respect to several factors including
costs, environmental impacts, and implementability. Table ES-1 summarizes the
evaluation of the Sea Pines - Forest Beach alternatives previously described.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUtMAR? OF ALTERNATIVES EVALUATION

Alternative

Discharge to Lawton
Canal with Sand
Filters

Cost

(Total Present Worth)
$1,659,400

<
H-
H*

Environmental Impacts

1.	Increase In size of areas closed to
shellflshlng will be required due to
Increased wastewater flows into SA
waters.

2.	Selection of this alternative could
set a precedent for the approval of
other discharges Into SA waters.

3.	Selection of this alternative would
provide Federal support for popula-
tion growth potentially causing
increased urban runoff into SA
waters.

Implementablllty

1. NPDES permit required from DHEC.

New buffer zone boundary for
discharge to shellfish waters
must be established.

Permit required from Coastal
Council.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUMMARY OF ALTERNATIVES EVALUATION

Cost

Alternative	 (Total Present Worth)

Discharge to Calibogue	$2,696,600

Sound without Sand
Filters

	Environmental Impacts	

1.	The discharge of treated wastewater
Into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however, shellfish closures would
remain unless existing non-point
source problems are abated.

2.	Selection of this alternative would
allow a continuous discharge into
Callbotne Soumd.

J . S«l«ctlo« 9f tills ilunut i»e would
let a precedent for the approval
of other discharges Into coastal
waters.

4. Selection of this alternative would
provide Federal support for popula-
tion growth potentially causing
increased urban runoff Into SA
waters.

	Implementablllty	

1. NPDES Permit required from DHEC.

2.	Permit required from Coastal Council
discharge of secondarily treated
effluent la not consistent with the
Hilton Bead Island Special Area
HaoasoMnt Plan.

3.	Department of the Any permit will
be required for the construction

of a subaqueous outfall and diffuser

A. Detailed studies needed to determine
outfall pipe alignment, diffuser
location and orientation, and port
design.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUtMART OF ALTERNATIVES EVALUATION

Alternative

Discharge to Atlantic
Ocean without Sand
Filters

Cost

(Total Present Worth)
$4,451,800

X

Environmental Impacts

1.	The discharge of treated wastewater
Into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

2.	Selection of this alternative would
allow a continuous discharge into
the Atlantic Ocean.

Implementablllty

NPDES Permit required from
DHEC.

2. Permit required from Coastal

Council; discharge of secondarily
treated effluent is not con-
sistent with the Hilton Head
Island Special Area Management
Plan.

Selection of this alternative would
set a precedent for the approval of
other discharges into coastal waters.

Department of the Army permit
will be required for the con-
struction of a subaqueous
outfall and dlffuser.

4. Selection of this alternative would
provide Federal support for popula-
tion growth potentially causing
increased urban runoff into SA waters.

Detailed studies needed to
determine outfall pipe align-
ment, dlffuser location and
orientation, and port design.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUMMARY OF ALTERNATIVES EVALUATION

Alternative

Wastewater Reuse

Cost

(Total Present Worth)
$5,223,900 *

Environmental Impacts

X

Cost Includes Callbogue Sound
outfall as backup system. Use
of another backup system will
modify that portion of costs.

1.	The discharge of treated wastewater
into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

2.	Provides advanced treatment of waste-
water to maximise reuse potential.

Extends reuse of filtered wastewater
to landscape areas, buffer areas,
md residential lawn Irrigation
heretofore not approved for second-
ary treated effluent; Increased
reuse lessens demand on ground-
water withdrawals from the Ocala
Aquifer.

Under this alternative, a back-up
outfall to Callbogue Sound or the
Ocean may be provided for periods
of heavy rainfall.

Selection of this alternative would
set a precedent for similar manage-
ment concepts elsewhere on the
Island.

Implementablllty

NPDES permit for back-up dis-
charge to Callbogue Sound or
the Ocean required from DHEC.

Permit required from Coastal
Council for back-up discharge
to Callbogue Sound or Ocean.

Department of the Army permit
will be required for the con-
struction of a subaqueous outfall
and dlffuser.

Detailed studies needed to de-
termine outfall pipe alignment,
dlffuser location and orientation,
and port design for back-up
Callbogue Sound or Ocean discharge

Selection of this alternative would
provide Federal support for popula-
tion growth, potentially causing in-
creased urban runoff Into SA waters.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUtMARY OF ALTERNATIVES EVALUATION

Alternative

Rapid Infiltration

Cost

(Total Present Worth)
$9,232,700

Environmental Impacts

1.	The discharge of treated wastewater
into the SA waters of Lavton Canal
and Broad Creek could be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

2.	This system is not technically
feasible due to soil and water table
conditions.

3.	Rapid Infiltration system increases
potential for groundwater con-
tamination.

Implementablllty

1. Sea Pines PSD must exercise
power of eminent domain to
acquire land.

2.	Pilot testing of Rapid Infiltra-
tion system should precede full-
scale implementation.

3.	Extensive holding ponds or back-
up discharge required for periods
of heavy rainfall with attendant
studies and permits.

4.	Rapid Infiltration system would
require extensive clearing and
site alteration of more than 100
acres within the Sea Pines Forest
Preserve.

5.	Spray irrigation within Shipyard
Plantation would utilize 67 acres
of otherwise developable land.

6. Selection of this alternative would
provide Federal support for popula-
tion growth potentially causing
increased runoff into SA waters.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUMMARY OF ALTERNATIVES EVALUATION

Alternative

Land Application at
Gardner-Matthews
site.

Cost

(Total Present Worth)
$13,260,000

X

Environmental Impacts

1.	The discharge of treated wastewater
into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

2.	Construction of extensive spray
irrigation network within the
Gardner-Matthews site will alter
existing habitat.

3.	This alternative would utilize
over 600 acres of otherwise
developable land.

Implementablllty

Beaufort County must exercise
power of eminent domain to ac-
quire land for PSD use. Develop-
ment plans exist for current site.

2.	Site specific studies will be
required to determine actual
allowable application rate for
spray irrigation system.

3.	Extensive holding ponds or back-up
discharge required for periods

of heavy rainfall with attendant
studies and permits.

4. Selection of this alternative
would provide Federal support
for population growth potentially
causing increased runoff into
SA waters.

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TABLE ES-1

SEA PINES PSD - FOREST BEACH PSD
SUMMARY OF ALTERNATIVES EVALUATION

Alternative

Off-Island Land
Application

Cost

(Total Present Worth)
$14,007,200

X
H-
H*

Environmental Impacts

1.	The discharge of treated wastewater
into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

2.	Construction of extensive spray
irrigation network at selected site
will alter existing habitat.

3. Selection of this alternative would
provide Federal support for popula-
tion growth, potentially causing
increased runoff into SA waters.

Implementabillty

1. Beaufort County may be re-
quired to exercise power of
eminent domain to acquire land
for PSD use.

2.	Substantial opposition from
Beaufort County residents re-
garding concept of off-island
spray irrigation.

3.	Department of Army (and Coastal
Council) permit would be required
if subaqueous crossing of Skull
Creek and Mackay Creek utilized.

4.	Extensive holding ponds or back-
up discharge required for periods
of heavy rainfall with attendant
studies and permits.

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TABLE ES-X

SEA PINES PSD - FOREST BEACH PSD
SUMMARY OF ALTERNATIVES EVALUATION

Alternatives

No Federal Action.
Sea Pines Public
Service District
would implement the
Wastewater Reuse
Alternative with
100Z local funding.

Cost

(Total Present Worth)
$5,223,900 *

Environmental Impacts

* Cost Includes Callbogue Sound
outfall as backup system. Use
of another backup systea will
modify that portion of costs.

The discharge of treated wastewater
Into the SA waters of Lawton Canal
and Broad Creek would be eliminated;
however shellfish closures would
remain unless existing non-point
source problems are abated.

Provides advanced treatment of
wastewater to maximize reuse
potential.

Extends reuse of filtered waste-
water to landscape areas, buffer
areas, and residential lawn Ir-
rigation heretofore not approved
for secondary treated effluent;
Increased reuse lessens demand on
groundwater withdrawals from the
Ocala Aquifer.

Under this alternative, a back-up
outfall to Callbogua Sound or the
Ocaan may be provided for periods
of heavy rainfall.

5.	Implementation of this alternative
would set precedent for similar
management concepts elsewhere on
the Island.

6.	Federal participation would not

be provided to any alternative which
would support Increased urban runoff
Into SA waters.

Implementablllty

NPDES permit for back-up discharge
to Callbogue Sound required from
DHEC.

2. Permit required from Coastal

Council for back-up discharge to
Callbogue Sound.

Department of the Army permit will
be required for the construction
of a subaqueous outfall and
dlffuser.

Detailed studies needed to determine
outfall pipe alignment, dlffuser
location and orientation, and port
design for back-up Callbogue Sound
discharge.

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Island-wide Plan

CPA recognizes and supports the need for wastewater management plan-
ning for the remainder of the island. While this liTS proposes no funding
actions or permitting decisions outside of the Sea Pines PSD - Forest
Beach PSD, possible wastewater management alternatives for other areas
of the island are identified and discussed herein.

These investigations have focused on alternative outfall configura-
tions to serve as a back-up to the maximum reuse of treated wastewater
within each service area. The back-up systems evaluated include the fol-
lowing:

(1)	Single outfall into Port Royal Sound for areas outside the Sea
Pines PSD - Forest Beach PSD.

(2)	Single outfall into the Atlantic Ocean for areas outside the
Sea Pines PSD - Forest Beach PSD, or for the entire island
including the Sea Pines PSD - Forest Beach PSD.

(3)	Pumping of treated wastewater from the entire island to the
Savannah River for discharge, either via the mainland or via
Daufuskie Island.

Several basic observations are drawn from these and previous evalua-
tions .

(1)	Costs for a two outfall scheme (Calibogue Sound - Port Royal Sound)
are significantly lower than costs for a single outfall into the
Atlantic Ocean to serve the entire island.

(2)	Under the two oiitfall scheme, total costs are not significantly
affected by whether Broad Creek PSD is pumped north to a Port
Royal backup outfall, or south to a larger Calibogue Sound backup
outfall in conjunction with the Sea Pines PSD - Forest Beach PSD.

(3)	Costs for discharge to the Savannah River via the mainland are
slightly lower than via Daufuskie Island (and more environmental-
ly acceptable). The Savannah River alternative, regardless of
route, is over twice the cost of the next most costly alternative -
a single outfall into the Atlantic Ocean for the entire island.

PART D. AGENCY DECISION

Decision

The Final EIS finds that wastewater reuse with a backup system is the
preferred alternative for wastewater management in the Sea Pines - Forest
Beach PSD service area. The backup system can be a discharge to Calibogue

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Sound, an Ocean outfall, or any other approved system that will meet
Federal, State, and local requirements. The exact location of any surface
water discharge would have to be determined based on further studies and
evaluation of technical criteria applicable to the proposed discharge. If
another method of backup is selected, studies to determine design, discharge
locations, and operability would have to be conducted. Any proposed backup
system would be reviewed and approved by EPA and DHEC prior to initiation
of construction. An appropriate public notification will be given regarding
any approval actions by EPA of any proposed backup system.

The major elements of the preferred system include (1) installation
of advanced treatment at the Sea Pines PSD Treatment Plant sufficient to meet
a 5 mg/1 limit for suspended solids, (2) construction of a treated wastewater
distribution system, (3) construction of a backup system for periods of heavy
rainfall and unusual operating conditions and (4) elimination of the current
direct discharge to Lawton Canal. This alternative promotes wastewater reuse
by means of golf course, open space, and lawn irrigation. DHEC has appropriate
legal authority to insure that the backup system is only used during periods of
heavy rainfall and unusual operating conditions.

Although not preferred, secondary treatment with discharge to Calibogue
Sound has been found to be the most cost-effective alternative. The amount
of Federal funding participation is limited by law to the appropriate share
of this most cost-effective alternative. This alternative has been estimated
to have a net present worth cost of $1.8 million and a capital cost of $2.0
million. The selected alternative for this EIS is the preferred system
described above involving wastewater reuse. This system is an Alternative/
Innovative System.

The EIS identifies non-point source pollution as the most significant
source of surface water degradation on Hilton Head Island. To address this
problem, EPA will undertake a study to evaluate non-point source pollution
within the Sea Pines - Forest Beach PSD service area. In addition, EPA
participation in funding of the selected wastewater reuse alternative is
contingent upon certain actions being taken at the PSD and local government
level. Further details are provided in Chapter II.

The EIS proposes no funding actions or permitting decisions in other
parts of the island. However, there are some measures which if adopted
would encourage reuse, conserve water resources, and promote the implementa-
tion of appropriate wastewater management techniques. Specific recommendations
are presented in Chapter II. Coordination of the selected wastewater reuse
alternative for the Sea Pines - Forest Beach PSD with the implementation of
wastewater management programs elsewhere on the island is also discussed in
Chapter II.

The preceeding recommended actions for Hilton Head encourage the maximum
reuse of treated wastewater throughout the island. The life of potable water
resources would be extended, existing and future surface water quality con-
ditions should be improved, and a long term implementable option for waste-
water management would be in place.

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Grant Conditions

EPA has imposed certain grant conditions which are required prior
to construction of the selected wastewater reuse alternative. These
actions will serve to mitigate direct impacts related to the construc-
tion and operation of the wastewater reuse alternative and will also
address secondary impacts related to non-point pollution. They are
detailed in Chapter II.

Mitjgative Measures

In addition, EPA recommends various measures which should be
implemented to lessen the impacts of future population growth on the
natural and man-made environment of Hilton Head. These measures are
listed in Chapter II, and most are the responsibility of the local
Beaufort County government and/or the new City of Hilton Head Island.
The appropriate government should move to implement these actions as
soon as possible.

PART E. PUBLIC PARTICIPATION

Public participation programs are mandated by Federal regulations
governing the preparation of Environmental Impact Statements. Public
participation is an important and valuable part of the EIS process because
it provides for active public involvement in developing and evaluating
wastewater management alternatives.

At the beginning of the Hilton Head Island EIS, a public partici-
pation program was established to provide opportunities for interested
groups, individuals, and government agencies to participate in the
development of the EIS. The focal point of this program was the estab-
lishment of a Review Committee. This group served in an advisory
capacity to EPA and their consultants. Specific functions and duties
of the group included:

Identifying local planning and environmental objectives

Identifying study area issues and conflicts regarding

wastewater management and environmental conditions

Reviewing all task report submissions

Assisting in the development and evaluation of wastewater

management alternatives

Reviewing Draft and Final Environmental Impact Statements

xvii

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The Review Committee met at regular intervals throughout the development of
the EIS. In addition, EPA and their consultants met upon request with
individual members of the Review Committee or with the groups they repre-
sented. A series of meetings were also held with the NAACP Board throughout
development of the EIS and two public meetings were conducted at various stages
in the process.

A public hearing on the Draft EIS was held on June 23, 1982 and comments
received thereafter. Chapter IV of this Final EIS provides responses to
comments which were raised, and Chapter V presents a complete list of agen-
cies and interest groups who were asked to comment.

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FINAL ENVIRONMENTAL IMPACT STATEMENT
HILTON HEAD ISLAND WASTEWATER FACILITIES

TABLE OF CONTENTS

Page

EXECUTIVE SUMMARY	i
PART A. PURPOSE OF EIS AND BACKGROUND

PART B. CHANGES AND NEW INFORMATION SINCE	iii
THE DRAFT

PART C. ALTERNATIVES CONSIDERED AND THEIR	iv
EVALUATION

1.	SEA PINES PSD - FOREST BEACH PSD	iv

2.	ISLAND-WIDE PLAN	xv

PART D. AGENCY DECISION	xv

1.	DECISION	xv

2.	GRANT CONDITIONS	xvii

3.	MITIGATIVE MEASURES	xvii

PART E. PUBLIC PARTICIPATION	xvii

CHAPTER I. BACKGROUND	!_!

PART A. INTRODUCTION	j.j

PART B. GEOGRAPHICAL SETTING	!_!

PART C. DEVELOPMENT PATTERNS	j_1

PART D. EXISTING WASTEWATER MANAGEMENT	i_2

PART E. LOCAL WATER QUALITY	x_3

PART F. PURPOSE OF AND NEED FOR EIS	i_3

CHAPTER II. AGENCY DECISION	jj.j

PART A. SEA PINES PSD - FOREST BEACH PSD	II-l

PART B. NON-POINT SOURCE	n_2

PART C. REMAINING AREAS OF THE ISLAND	II-2

PART D. BASIS OF DECISION	n-3

PART E, GRANT CONDITIONS	ri_4

PART F. MITIGATIVE MEASURES	H_5

CHAPTER III. CHANGES AND ADDITIONS TO THE DRAFT	III-l

PART A. INTRODUCTION	HI_1

PART B. SOUTH CAROLINA COASTAL COUNCIL	IiI-1

SPECIAL AREA MANAGEMENT PLAN

PART C. CUBIT ENGINEERING LTD. CALIBOGUE	III-2
SOUND DYE STUDY

xix

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TABLE OF CONTENTS (Cont'd.)

Page

PART D. WASTEWATER MANAGEMENT ALTERNATIVES	III-2

1.	SEA PINES PSD - FOREST BEACH PSD	III-3

2.	ISLAND-WIDE WASTEWATER MANAGEMENT	III-4

3.	SUMMARY OF COSTS	II1-5

PART E. EPA NON-POINT SOURCE STUDY	III-5

CHAPTER IV. PUBLIC PARTICIPATION	IV-1

PART A. INTRODUCTION	IV-1

PART B. COMMENTS AND RESPONSES	IV-1

1.	NON-POINT SOURCE POLLUTION	IV-1

2.	POPULATION AND WASTEWATER FLOWS	IV-2

3.	NEW WASTEWATER MANAGEMENT ALTERNATIVES	IV-3

4.	WASTEWATER REUSE AND WATER CONSERVATION	IV-4

5.	CALIBOGUE SOUND DISCHARGE	IV-4

6.	CUBIT ENGINEERING DYE STUDY	IV-5

7.	CORPS OF ENGINEERS COMMENTS	IV-5

8.	BIOLOGICAL ASSESSMENT AND ENDANGERED	IV-6
SPECIES

9.	ISLAND-WIDE WASTEWATER MANAGEMENT	IV-6

10.	CONSOLIDATION OF PSD'S AND TREATMENT	IV-7
PLANTS

11.	CONTINUED USE OF ON-LOT SYSTEMS	IV-8

12.	PROVISION OF SEWERAGE TO UNSEWERED	IV-9
COMMUNITIES

PART C. HEARING TRANSCRIPT AND WRITTEN COMMENTS	IV-9

CHAPTER V. EIS COORDINATION	V-l

PART A. INTRODUCTION	V-l

PART B. AGENCIES AND GROUPS	V-l

CHAPTER VI. LIST OF PREPARERS	VI-1

APPENDIX A. SOUTH CAROLINA COASTAL COUNCIL - HILTON HEAD
ISLAND SPECIAL AREA MANAGEMENT PLAN

APPENDIX B. CUBIT ENGINEERING LTD. CALIBOGUE SOUND DYE
STUDY

APPENDIX C. AUGUST 3, 1982 LETTER AND SEPTEMBER 1, 1982
RESPONSE REGARDING WASTEWATER REUSE

xx

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Table

ES-1

III-l

FINAL ENVIRONMENTAL IMPACT STATEMENT
HILTON HEAD ISLAND WASTEWATER FACILITIES

LIST OF TABLES

Sea Pines PSD - Forest Beach PSD
Summary of Alternatives Evaluation

Cost Summary for Hilton Head Island
Wastewater Management Alternatives

Page

VII

III-6

Plate
ES-1
1-1
III-l

LIST OF PLATES

Wastewater Facilities and Disposal Areas
Wastewater Facilities and Disposal Areas
Existing Irrigated Land

Following
Page

ii

1-2

III-3

Figure
ES-1

LIST OF FIGURES

Water Depths of Calibogue Sound and Atlantic
Ocean

Following
Page

vx

xxi

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CHAPTER I
BACKGROUND

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CHAPTER I - BACKGROUND

PART A. INTRODUCTION

The Hilton Head Island Environmental Impact Statement is being pre-
pared to address the provision of wastewater management facilities to
serve existing and future needs.

PART B. GEOGRAPHICAL SETTING

Hilton Head Island lies off of the southeastern tip of South Carolina
about thirty miles northeast of Savannah, Georgia. Hilton Head is one of
the barrier islands along the Atlantic and Gulf Coasts and is the largest
oceanfront island between New York and Florida. The island is approxi-
mately twelve miles long, up to five miles wide, and covers approximately
forty-two square miles.

The Atlantic Ocean borders Hilton Head to the east, Calibogue Sound
to the south, and Port Royal Sound to the north. Skull Creek, which com-
prises a link of the Intracoastal Waterway, separates Hilton Head from the
mainland. Broad Creek, a seven-mile tidal inlet which opens to Calibogue
Sound, cuts diagonally across the island. Plate 1-1 illustrates these
features.

PART C. DEVELOPMENT PATTERNS

Hilton Head is largely devoted to resort development. Over half of
the island is developed according to the "plantation" concept. These
planned unit developments contain residential, recreational, and occasional
neighborhood commercial land uses. A second type of development is also
resort-oriented but is made up of apartment and condominium complexes.
A third type of development is rural residential, found on lands owned by
persons who lived on the island before resort development was undertaken.
Nodes of commercial and office/institutional development are located
along Highway 278 near Hilton Head Plantation, at Sea Pines Circle, at
Forest Beach, and at Pineland Mall. The Harbour Town shopping district
is located within the gates of Sea Pines Plantation.

Hilton Head was part of unincorporated Beaufort County un'til the recent
passage of an incorporation referendum. The Cities of Beaufort and Port
Royal have adopted zoning ordinances, but the County has not. At present,
there is no zoning on Hilton Head Island.

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Development within the plantations has been orderly ana preuitLa-
ble; approximately 17,500 of the island's 28,000 acres are currently
owned by plantation developers, all of whom have filed masterplans with
the Beaufort County Joint Planning Commission. The rate of development
and ultimate land uses have been much more difficult to predict for areas
outside of the plantations, because there is no master land use plan or
density controls. The pattern, density, and timing of development on
the island has major implications for the type and location of wastewater
facilities as well as other community facilities and services.

PART D. EXISTING WASTEWATER MANAGEMENT

Wastewater collection and treatment for the island is principally
provided by designated public service districts, which have been estab-
lished by State enabling legislation. Four public service districts (PSD's)
are located on the island.

Sea Pines Public Service District
Forest Beach Public Service District
Broad Creek Public Service District
. Hilton Head No. 1 Public Service District

Each public service district (PSD) operates its own wastewater treatment
and disposal facilities, with the exception of the Forest Beach PSD.
Wastewater is conveyed from Forest Beach to the Sea Pines PSD for treat-
ment and disposal.

Hilton Head Plantation is served by treatment facilities owned and
operated by the Hilton Head Plantation Utilities Corporation. The Long
Cove Club and Jenkins Island-Windmill Harbor, both under development,
will be served by their own wastewater facilities. The remaining rural
areas of the island utilize septic tank - drainfield systems.

Treated effluent from the wastewater facilities on the island are
disposed of by several methods. Approximately 60 percent of the treated
wastewater is used to irrigate the golf courses on the island. Treated
wastewater is also sprayed onto areas of open land as a supplement to
golf course irrigation. Present wastewater flows from the Sea Pines PSD -
Forest Beach PSD exceed the total irrigation demands of the golf courses
located within Sea Pines and Shipyard Plantations. As a result, up to
1.8 million gallons per day (mgd) of treated wastewater are discharged
into Lawton Canal and thence to Lawton Creek which is classified for
shellfishing. Existing spray areas for each PSD are displayed on Plate
1-1.

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PAGE NOT
AVAI LAB LE

DIGITALLY

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PART E. LOCAL WATER QUALITY

During the early portion of the 1977-1978 oyster season the Shellfish
and Recreational Waters Division of the South Carolina Department of Health
and Environmental Control (DHEC) found fecal coliform counts which ex-
ceeded standards during routine investigation of oyster meats from the
shell stock (raw unshucked oysters) of the Hilton Head Oyster Company.

These high oyster meat coliform counts were again encountered upon sampling
a second time in May 1978. Subsequent investigations and interviews with
harvesters established that these oysters had been taken from Lawton Creek.
Analyses of surface water samples from Lawton Creek in July 1978 revealed
total and fecal coliform counts which exceeded standards. In August 1978
DHEC closed shellfish beds from "all waters and bottoms of Lawton Creek
and Point Comfort Creek and the adjacent shore of Broad Creek running the
length of Buck Island and Marsh". Prior to this time harvesting of oysters
had only been prohibited by DHEC from "the waters and bottoms within a
1000 ft. radius of Palmetto Bay Marina, Harbour Town Marina and Baynard
Cove Marina". These areas of closures are shown in Plate 1-1.

These closures have since resulted in a number of special water
quality studies by DHEC and one study by the U. S. Public Health Service,
Food and Drug Administration, Shellfish and Sanitation Branch. These
studies concentrated on the bacterial and/or hydrologic characteristics
of the Sea Pines PSD Wastewater Treatment Plant, Lawton Canal, Lawton
Creek, and Broad Creek. From these studies it was determined that (1)
closure of these areas to shellfish harvesting was supported by water
quality data and (2) there were indications that bacterial contamination
arising from non-point sources in the Lawton Creek - Broad Creek drainage
area was significant.

PART F. PURPOSE OF AND NEED FOR EIS

Because of these environmental complexities and the uniqueness of
Hilton Head as a barrier island, the Environmental Protection Agency
decided to prepare an Environmental Impact Statement with respect to waste-
water management facilities to serve the existing and future populations
of Hilton Head Island. Subsequently, a Notice of Intent was issued by
the EPA Regional Administrator in April 1979.

During the EIS process a number of major issue areas were identified.
The following issues were determined to be the most significant:

1. The identification of a method or combination of methods for
disposal of treated wastewater effluent, adequate for year
2000 capacity and compatible with the water quality standards
designated by the South Carolina Department of Health and
Environmental Control (DHEC), and compatible with the Special
Area Management Plan for Hilton Head Island adopted by the
South Carolina Coastal Council,

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2.	The determination of the capacity for spray irrigation of
treated wastewater effluent on the island and the impacts
resulting from this wastewater disposal alternative,

3.	The magnitude and causes of non-point source pollution on the
island and the relationship of this pollution source to the
evaluation of alternatives,

4.	The extent and cause of septic tank failures on the island,

5.	The disparity between OBERS Series E population projections

and indicated trends based on historical growth, platted property
holdings, and developer's plans and the resulting disparity in
future wastewater flow projections as it impacts the need for
wastewater treatment and disposal facilities, and

6.	The impacts from growth supported by the provision of waste-
water facilities and measures to minimize adverse effects from
projected development.

Concurrent with the Hilton Head EIS, the South Carolina DHEC conducted
a study of the Lawton Creek - Broad Creek watershed to better define the
extent to which non-point and point sources influence their bacterial
characteristics. Water quality and bacteria samples were collected during
dry and wet climatic periods in order to evaluate the extent of point and
non-point source contamination. A program of groundwater sampling was
also conducted within Sea Pines in order to obtain additional data. These
studies confirmed the existence and magnitude of non-point contamination
of Lawton Creek. Exact sources of the non-point problem were not identified
as an output of this study.

Additional non-point work was performed under the 208 program by
the firm of Moore Gardner & Associates, under the direction of an advisory
committee representing local, state, and Federal governments. The study
developed effective management practices to abate non-point pollution
resulting from island development. Findings and recommendations from the
208 effort are now before the Beaufort County Council for their considera-
tion.

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CHAPTER II
AGENCY DECISION

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CHAPTER II - AGENCY DECISION

PART A. SEA PINES PSD - FOREST BEACH PSD

The Final EIS finds that wastewater reuse with a backup system is the
preferred alternative for wastewater management in the Sea Pines - Forest
Beach PSD service area. The backup system can be a discharge to Calibogue
Sound, an Ocean outfall, or any other approved system that will meet
Federal, State, and local requirements. The exact location of any sur-
face water discharge would have to be determined based on further studies
and evaluation of technical criteria applicable to the proposed discharge.
If another method of backup is selected, studies to determine design,
discharge locations, and operability would have to be conducted. Any
proposed backup system would be reviewed and approved by EPA and DHEC prior
to initiation of construction. An appropriate public notification will be
given regarding any approval actions by EPA of any proposed backup system.

The major elements of the preferred system include (1) installation
of advanced treatment at the Sea Pines PSD Wastewater Treatment Plant
sufficient to meet a 5 mg/1 limit for suspended solids, (2) construction
of a treated wastewater distribution system, (3) construction of a back-
up system for periods of heavy rainfall and unusual operating conditions
and (4) elimination of the current direct discharge to Lawton Canal.

This alternative promotes wastewater reuse by means of golf course, open
space and lawn irrigation.

Although not preferred, secondary treatment with discharge to Calibogue
Sound has been found to be the most cost-effective alternative. The
amount of Federal funding participation is limited by law to the appro-
priate share of this most cost-effective alternative. This alternative
has been estimated to have a net present worth cost of $1.8 million and
a capital cost of $2.0 million. The selected alternative for this EIS
is the preferred system described above involving wastewater reuse.

This system is an Alternative/Innovative System.

An experimental wastewater disposal system utilizing wetlands is
currently being implemented in the Sea Pines Forest Preserve. This system
may be continued if locally desired. EPA may assist DHEC and the Sea Pines -
Forest Beach PSD in a sampling and analysis program to monitor the wetlands
disposal system if the program is continued. The wetlands analysis would be
designed to monitor biological changes and water quality effects due to the
wastewater discharge. This site specific investigation could be of sig-
nificant value to DHEC and EPA in evaluating the effects of this discharge.

II-l

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PART B. NON-POINT SOURCE

The EIS identifies non-point pollution as the most significant source
of surface water degradation on Hilton Head Island. To address this problem,
EPA will undertake a study to evaluate non-point source pollution within the
Sea Pines - Forest Beach PSD service area. The non-point source study will
be designed to identify the sources of pollution, evaluate means to minimize
the contribution from these sources and to identify the means to implement
appropriate measures. Wetlands will be evaluated as one means for non-point
pollution treatment.

The facilities recommended to be constructed as part of the selected alterna-
tive may support development that adds to the non-point problem. Therefore, EPA
will provide funds only if progress is being made in solving the non-point
source problem. Progress is defined as passage of an ordinance by Beaufort
County or the City of Hilton Head Island addressing on-lot retention for new
construction and a commitment by the Sea Pines - Forest Beach PSD and Beaufort
County to participate in the EPA study to specifically address the existing
non-point source problem.

PART C. REMAINING AREAS OF THE ISLAND

This EIS proposes no funding actions or permitting decisions for other parts
of the island. However, there are some measures which if adopted would
encourage reuse, conserve water resources and promote the implementation of
appropriate wastewater management techniques. The specific recommendations are:

1.	DHEC, the PSD's and local developers should formulate an agreement to
provide wastewater management service for the island. This agreement
should include a specific delineation of service area boundaries.

2.	The number of service areas should be minimized and the existing waste-
water systems should be integrated within each service area.

3.	Facilities capable of meeting a 5 mg/1 suspended solids limit should be
provided at each treatment plant to maximize the reuse potential of the
treated wastewater.

4.	Available spray capacity of each service area should be adequate for the
total expected daily effluent requirements under normal operating
conditions.

5.	Construction of the collection, treatment, and distribution systems
should be coordinated to avoid foreclosing available reuse options

6.	The reuse of advanced treated wastewater should be extended to landscape
areas, buffer areas, and residential lawn irrigation heretofore not
approved for secondary treated effluent.

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7.	A backup system should be provided for use in periods of heavy
rainfall and unusual operating conditions. The backup system
can be a discharge to Port Royal Sound, an Ocean outfall, or
any other approved system that will meet Federal, State, and
local requirements. Discharges from such backup systems should
be limited to periods when these unusual operating conditions
exist.

8.	The total number of outfalls should be minimized, preferably two

or Less. Significant adverse impacts to productive shellfish waters
should be avoided through proper siting and operation of such outfalls.

9.	Water conservation measures should be adopted and incorporated into
new construction.

Based upon the foregoing, the selected wastewater reuse alternative
for the Sea Pines - Forest Beach PSD can easily be coordinated with waste-
water management programs elsewhere on the island.

PART D. BASIS OF DECISION

The preceeding recommended actions for Hilton Head would encourage
the maximum reuse of treated wastewater throughout the island. This action
would provide significant relief to the growing problems associated with
groundwater supply. Allowing EPA funds to be used to resolve the Sea
Pines - Forest Beach wastewater management problems supports this island-
wide reuse concept.

Also the provision that no Federal funds be provided unless Beaufort
County and the Sea Pines - Forest Beach PSD demonstrate a commitment to
address the non-point source problem provides an incentive to help resolve
a pressing water quality problem on the island. The funding by EPA o a
more specific study of the existing non-point source problem in Sea Pines
will further increase the chances of improving existing water quality
in this area.

The experimental wetlands wastewater disposal system to the Forest
Preserve may be implemented and evaluated if locally desired. The wet-
lands will also be evaluated to determine if this area is a viable option
for treatment of non-point source pollution. Careful monitoring of the wet-
lands discharge system will identify any significant adverse impacts suffi-
ciently early to avoid long term loss of the resource.

Most of the major problems affecting the management of water resouces
in the Hilton Head area are addressed by these proposed actions. The lire
of potable water resources would be extended, existing and future sur ace
water quality conditions should be improved, and a long term implementa-
ble option for wastewater management would be in place.

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PART E. GRANT CONDITIONS

The following actions are required prior to construction of the
selected wastewater reuse alternative. These actions will serve to
mitigate direct impacts related to the construction and operation of the
wastewater reuse alternative and will also address secondary impacts re-
lated to non-point pollution.

1.	If a Calibogue Sound outfall or an Ocean outfall is selected as the
backup, detailed studies are required during design to determine the
optimal location and orientation of the backup outfall/diffuser struc-
ture into Calibogue Sound or into the Atlantic Ocean. These studies
should develop outfall and diffuser designs; alignment and depth of
discharge; and effluent plume location, mixing, and dilution. If
another method of backup is selected, studies to determine design,
discharge locations, and operability would have to be conducted. Any
proposed backup system would be reviewed and approved by EPA and DHFC
prior to initiation of construction.

2.	Appropriate monitoring programs must be developed to insure the proper
use of the backup systems. These programs will be approved by DHEC.

3.	An appropriate monitoring program must be developed for the wastewater-
reuse system to deter any adverse impacts.

4.	An acceptable erosion control plan must be developed prior to construc-
tion of the pipeline crossing of South Beach for a Calibogue Sound backup
outfall, or the crossing of Atlantic Ocean beaches for an Ocean outfall.

5.	No construction for a Calibogue Sound or Ocean outfall through the beach
and surf zone shall be accomplished during the period of May 1 through
October 15 to avoid adverse impact to the loggerhead turtle.

6.	A site specific archeological survey is required of areas to be affected
by the selected alternative.

7.	A site specific vegetative survey is required of areas to be affected
by the selected alternative.

8.	Beaufort County or the City of Hilton Head Island must adopt an effective
ordinance which addresses on-lot retention of storm water runoff for new
construction.

9.	The County and the Sea Pines PSD - Forest Beach PSD must agree to par-
ticipate in EPA's Sea Pines - Forest Beach non-point study.

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PART F. MITIGATIVE MEASURES

The following are recommended measures which should be implemented
to lessen the impacts of future population growth on the natural and
man-made environment of Hilton Head. Most of these measures are the
responsibility of the local Beaufort County government and the new
City of Hilton Head Island. The appropriate governing body should move
to implement these actions as soon as possible.

1.	Surface Water Quality

-Development of a more extensive water quality baseline of the
entire island so that data exist against which to measure
future water quality changes and assess the significance of
any changes.

-Consideration of using wetlands for urban runoff treatment.

-Control of discharges from bilges and sanitary facilities of
commercial and pleasure boats, particularly within estuarine
and marine waters. More stringent enforcement of Coast Guard
regulations.

-A policy by local regulatory bodies to discourage the construction
of new marinas that adversely affect productive shellfish waters.

-Implementation of recommendations of the Hilton Head Island 208
Non-Point Study and the Hilton Head Land Use Plan related to
water quality.

2.	Surface Water Quantity

-Relief of localized flooding of unpaved roads at the north end
of the island. Drainage improvements should be made by the
Public Works Department of the responsible local government.

Such activity should be planned very carefully to assure that
additional non-point source pollution does not result.

3.	Groundwater Quality and Quantity

-Implementation of a water conservation program via public
education and changes to the plumbing code so as to decrease
demand on the groundwater resource.

4.	Terrestrial Ecosystems

-Enforce regulations of the U. S. Army Corps of Engineers, the
South Carolina Coastal Council, and the Beaufort County Develop-
ment Standards Ordinance which restrict the development of wetlands,
oceanfront beaches, and primary dunes.

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5.	Aquatic Ecosystems

-Implementation of previously discussed mitigative measures affecting
surface water quality.

6.	Population

-Implementation of local controls to plan population densities on the
island consistent with local community development goals.

7.	Land Use

-Strengthening of the Development Standards Ordinance to control
building densities within a site and ensure provision of desired
open space.

-Adoption of a Land Use Plan to control strip development along
Highway 278, regulate densities, buffer incompatible land uses, and
regulate nuisances.

8.	Recreation

-A more active role by citizens and island representatives in the
preparation of the County and City capital budgets to provide for
public recreation.

-Cooperation between local government and oceanfront developers to
provide public access easements to beaches where possible.

9.	Transportation

-Upgrading of unpaved county roads.

-Provision of bikeway systems and sidewalks.

-Increased and more efficient signalization.

10. Community Services and Facilities

-Coordination of detailed community facilities and capital budgeting
and land use planning.

-Adequate funding of island needs by county government and new city
government.

11-6

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CHAPTER III
CHANGES AND ADDITIONS TO THE DRAFT

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CHAPTER III - CHANGES AND ADDITIONS TO THE DRAFT

PART A. INTRODUCTION

Since the preparation and publication of the Draft EIS, several
changes and additions have been made to reflect new information that
has been received. The following parts describe the new information,
their impacts on wastewater management alternatives, and the revisions
and/or additions made as a result.

PART B. SOUTH CAROLINA COASTAL COUNCIL
SPECIAL AREA MANAGEMENT PLAN

The South Carolina Coastal Council has adopted a Special Area
Management Plan for Hilton Head Island which establishes policy with
respect to new projects or the expansion and significant alteration
of existing projects or activities. Among other things, policy is set
forth regarding the discharge of treated sewage into the surface waters
of Hilton Head Island.

The following policies are established with respect to the discharge
of treated wastewater into the surface waters of Hilton Head Island.

(1)	No discharge of primary or secondarily treated effluent into
the critical areas of Hilton Head Island. This recommendation
does not preclude the evaluation of ocean discharge or any other
innovative technologies found to be acceptable by the South
Carolina Coastal Council. In the event that an ocean discharge
is found to be acceptable, the S. C. Coastal Council will con-
sider the location of the discharge at the most appropriate
location.

(2)	Any method of effluent disposal, other than land application

on the island, will be evaluated on the basis of a comprehensive
island-wide solution to the short and long term requirements of
Hilton Head Island and the surrounding natural systems.

(3)	In view of the critical future potable water requirements for
Hilton Head Island, and the fact that little information is
now available concerning present use, quantity and quality of
the existing ground water, the S. C. Coastal Council recommends
that the appropriate parties undertake comprehensive studies

to determine the quantity and quality of potable water resources
for Hilton Head Island to accommodate future growth predictions.

The final evaluation of wastewater management alternatives, as presented
in this Final EIS, is consistent with Council policy.

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The Special Area Management Plan also addresses other areas of
impact including stormwater runoff, tidal and freshwater wetlands, beaches
and dunes, public access, and cultural resources; and sets forth appro-
priate management policies. Compliance with these policies is largely
a matter for local and state authorities.

A copy of the Special Area Management Plan for Hilton Head Island
is included as Appendix A to this Final EIS.

PART C. CUBIT ENGINEERING LTD.

CALIBOGUE SOUND DYE STUDY

The Cubit Engineering Limited dye study performed for the Sea Pines
Public Service District evaluates water quality impacts from the discharge
of a secondarily-treated effluent into Calibogue Sound.

The study consisted of a numerical model analysis of the Calibogue
Sound system to simulate the tidal hydraulics of the area and the behavior
of the effluent within the Sound and its tributaries if continuously
discharged into the system. A field study was also performed by Cubit
to obtain data for model calibration. Tide stage, current velocity,
and other physical data were obtained to describe the hydrodynamics of
the Sound. Tracer dye was injected at the outfall site and monitored
through a floodtide cycle to provide information on the dispersion and
excursion characteristics of the system.

The investigation concludes that the discharge of 3 million gallons
per day of a secondarily-treated effluent into Calibogue Sound would have
no impact on the dissolved oxygen or fecal coliform of the Sound or its
tributaries. These findings support the conclusions of previous water
quality modeling work performed as part of the Low Country 208 planning
program. EPA has evaluated the Cubit Engineering study and finds it
to be an acceptable basis from which to evaluate water quality impacts.

A copy of the complete report prepared by Cubit Engineering Limited
is included as Appendix B to this Final EIS.

PART D. WASTEWATER MANAGEMENT ALTERNATIVES

Since publication of the Draft EIS, the various wastewater manage-
ment alternatives for the Sea Pines Public Service District - Forest Beach
Public Service District have been recosted to reflect revised wastewater
flow projections and to bring the costs up-to-date^. In addition, several
new alternatives have been formulated for Sea Pines - Forest Beach and
the remainder of the island. These revisions and additions are presented
below. The alternatives presented in the Final EIS are based upon updated
wastewater flows for the major service areas as noted on the following page.

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		Service Area	

Sea Pines PSD - Forest Beach PSD
Broad Creek Public Service District
Hilton Head No. 1 PSD
Gardner-Matthews Plantation
Hilton Head Plantation

Peak
Wastewater Flow
4.5 mgd
2.4 mgd
2.8 mgd
1.1 mgd
2.0 mgd

Sea Pines PSD - Forest Beach PSD

Wastewater Reuse Alternative - This alternative is based upon the alter-
native proposed by the Sea Pines Public Service District at the Draft
EIS public hearing. Additional information on the Sea Pines proposal
was requested by EPA in a letter dated August 3, 1982; this information
was provided by the Public Service District by letter dated September 1,
1982 and carefully considered in the Final EIS decision. Copies of the
August 3 and September 1 letters are included as Appendix C to this
Final EIS.

The wastewater reuse alternative emphasizes the maximum reuse of
advanced treated wastewater for golf course, open space, and lawn
irrigation; advanced treatment will provide a suspended solids concentration
of 5 mg/1 prior to reuse. The increased reuse of wastewater for irriga-
tion purposes will significantly reduce withdrawals from the Ocala Aquifer
and help conserve the island's potable water supply.

Plate III-l indicates the location of approximately 130 acres of
existing irrigated land in Sea Pines and South Forest Beach that is
adjacent to or near the golf course irrigation distribution mains now
in place from the Sea Pines treatment plant to the respective golf
courses. This existing irrigation network would be extended to provide
for the use of treated effluent for irrigation in these and other areas.
No cross connections to the District's potable water system will be allowed.

As part of the reuse alternative, the experimental wetlands discharge
system located within the Forest Preserve may continue to be evaluated
in an effort to reestablish diminishing wetlands. Periods of drought
and diversion of natural recharge have dried up many wetlands areas in the
Preserve thereby drastically altering the natural habitat.

During periods of heavy rainfall, irrigation needs may be insufficient
to utilize all of the treated wastewater from the Sea Pines plant. Conse-
quently, a supplemental back-up system is required for the reuse alterna-
tive. The back-up system can be a discharge to Calibogue Sound, an Ocean
outfall, or any other approved system that will meet Federal, State,

and local requirements.

1II-3

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PAGE NOT

AVAIL ABLE
DIGITALLY

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Summary of Alternatives - A summary of the updated costs of the Sea
Pines - Forest Beach alternatives are presented below, based upon a
wastewater flow of 4.5 mgd.

Lawton Canal w/Sand Filters

Calibogue Sound w/o Sand Filters

Atlantic Ocean Outfall w/o Sand Filters

Wastewater Reuse *

Rapid Infiltration

Gardner Matthews

Union Camp Mainland

Alternatives

Equivalent Annual Cost
$ 192,300

312,600
516,100
605,700

1,070,400
1,537,400
$ 1,624,000

Descriptions of each alternative listed above are provided in the
Executive Summary of this document, and Table ES-1 provides a summary
of the major environmental impacts and implementability considerations
for each.

Island-wide Wastewater Management

While this EIS proposes no funding actions or permitting decisions
outside of the Sea Pines PSD - Forest Beach PSD, possible wastewater management
alternatives for other areas of the island have been evaluated. These investiga-
tions have focused on alternative outfall configurations to serve as a back-up to
the maximum reuse of treated wastewater within each service area. The back-up
systems evaluated include the following!

(1)	Single outfall into Port Royal Sound for areas outside the Sea
Pines PSD - Forest Beach PSD.

(2)	Single outfall into the Atlantic Ocean for areas outside the
Sea Pines PSD - Forest Beach PSD, or for the entire island
including the Sea Pines PSD - Forest Beach PSD.

(3)	Pumping of treated wastewater from the entire Island to the
Savannah River for discharge, either via the mainland or via
Daufuskie Island.

Several basic observations are drawn from these and previous eval-
uations performed for Sea Pines - Forest Beach.

(1)	Costs for a two outfall scheme (Calibogue Sound - Port Royal
Sound) are significantly lower than costs for a single outfall
into the Atlantic Ocean to serve the entire island.

(2)	Under the two outfall scheme, total costs are not significantly
affected by whether Broad Creek PSD is pumped north to a Port
Royal backup outfall, or south to a larger Calibogue Sound
backup outfall in conjunction with the Sea Pines PSD - Forest
Beach PSD.

* Cost includes Calibogue Sound outfall as backup system. Use of another
backup system will modify that portion of cost.

III-4

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(3) Costs for discharge to the Savannah River via the mainland are
slightly lower than via Daufuskie Island (and more environment-
ally acceptable). The Savannah River alternative, regardless of
route, is over twice the cost of the next most costly alterna-
tive - a single outfall into the Atlantic Ocean for the entire
island.

The coordination of the selected alternative for the Sea Pines PSD -
Forest Beach PSD with wastewater management programs elsewhere on the
island is discussed in the Executive Summary and in Chapter II.

Summary of Costs

Table III-l presents a summary of design flows, project costs,
operation and maintenance costs, net present worths, and equivalent
annual costs for the Sea Pines - Forest Beach alternatives and for the
alternative back-up outfall configurations for the remainder of the
island.

PART E. EPA NON-POINT SOURCE STUDY

EPA has initiated a special study of non-point source pollution in
the Sea Pines - Forest Beach area. The study is designed to identify the
sources of pollution which are leading to the continued closure of shell-
fishing waters and to evaluate means to minimize the contributions from
these sources.

The initial phase of the study is focusing on a delineation of drainage
patterns and flows in the area. After this information has been collected,
a sampling and lab analysis program will be developed to better identify the
sources of pollution. Additional phases of the study will be designed based
upon the outputs of this work.

III-5

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TABLE III-l

COST SUW4ARV FOR HILTON HEAD ISLAND
WASTEWATER MANAGEMENT ALTERNATIVES(1)

No.

Description

Design
Flow
(»gd)

Project
Cost

Land
Cost

Salvage
Value

Annual
0 5 M
Cost

Total
Present
Worth

Equivalent
Annual
Cost

A-l

Calibogue Sound Outfall

4.5

$ 2,830,100

—

t 1,356,000

$ 31,270

$ 2,696,600

$ 312,600

2

Calibogue Sound Outfall

4.77

3,465,500

—

1,672,100

36,470

3,282,900

380,600

3

Calibogue Sound Outfall

7.42

5,368,100

—

2,588,300

57,540

5,094,800

590,700

B-l

Lawton Canal w/Sand Filters

4.5

1,331.000

—

450,500

53,500

1,659,400

192,300

C-l

Atlantic Ocean Outfall

4.5

4,922,100

—

2,450,300

29,950

4,451,800

516,100

2

Atlantic Ocean Outfall

4.77

5,185,500

—

2,571,800

35,150

4,723,900

547,700

3

Atlantic Ocean Outfall

7.42

8,728,100

—

4,345,800

56,220

7,920,800

918,329

D-l

Rapid Infiltration/Woodlands Irrigation

4.5

2,687,700

8,725,000

9,998,500

91,940

9,232,700

1,070,400

2

Rapid Infiltration/Noodlands Irrigation/
Calibogue Outfall

4.5

4,893,100

8,725,000

11,159,900

97,400

11,139,800

1,291,500

E-l

Spray Irrigation t Gardner Matthews
w/Calibogue Outfall

4.5

7,511,800

10,350,000

14,155,000

170,540

15,124,000

1,7S3,S00

2

Spray Irrigation w/o Calibogue Outfall

4.5

5,355,300

10,350,000

13,026,900

165,590

13,260,000

1,537,400

F-l

Spray Irrigation at Union Cany w/Calibogue

4.5

13,187,500

3,450,000

10,041,300

257,300

15,871,000

1,840,100

2

Spray Irrigation at Union Camp
w/o Calibogue Outfall

4. S

11,031,000

3,450,000

8,913,300

252,350

14,007,200

1,624,000

G

Wastewater Reuse/Sand Filters/
Calibogue Outfall

4.5

5,133,500

—

2,315,200

90,270

5,223,900

605,700

(1) A11 cost in 1985 Present North based upon 15-year planning period ending in the year 2000, 7.375 percent interest and 1983 price levels.

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TABLE III-l

COST SUMMARY FOR HILTON HEAD ISLAND
WASTEWATER MANAGEMENT ALTERNATIVES(l)
(continued)

No.

Description

Design
Flow '
(¦gd)

Project
Cost

Land
Cost .

Salvage
Value

Annual
0 8 M
Cost

Total
Present
Worth

Equivalent
Annual
Cost

H-l

Port Royal Sound Outfall

6.18

$ 3,7S0,300

—

| 1,785,800

$ 53,060

$ 3,676,900

$ 426,300

2

Port Ro/al Sound Outfall

8.83

5,422,800

—

2,581,600

74,760

5,300,000

614,500

1-1

Atlantic Ocean Outfall (Gannett Fleming Rte)

13.6

14,767,600

—

7,329,100

109,100

13,529,300

1,568,600

2

Atlantic Ocean Outfall (Thomas 4 Button Rte)

13.6

19,350,900

—

9,726,500

111,240

17,418,200

2.019,500

J

Savannah River Via Daufuskie Island

13.6

39,838,700

—

20,443,200

444,410

37,593,000

4,3S8,500

r

Savannah River Via Mainland

13.6

30,332,200

—

15,470,600

438,250

34,112,200

3,421,600

11) Ml cut la IMS Mtwt Worth bnwl upon IS-year planning period ending In the ytir 2000, 7.875 percent interest and 198J price level!.

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CHAPTER IV
PUBLIC PARTICIPATION

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CHAPTER IV - PUBLIC PARTICIPATION

PART A. INTRODUCTION

A public hearing on the Draft EIS was held on June 23, 1982 and
comments received thereafter. Major issues, comments, and responses are
presented in Part B of this chapter. Comments and responses are cross-
referenced to the actual public hearing transcript and written comments
which are reproduced in Part C.

PART B. COMMENTS AND RESPONSES

The following substantive issues have been raised through comments
and new developments since publication of the Draft EIS. Responses are
provided for each in light of EPA's Final Decision.

ISSUE NO. 1 - NON-POINT SOURCE POLLUTION

Several persons and interests commented regarding non-point source pollution
on Hilton Head Island. All were concerned with the water quality impacts
resulting from non-point source pollution; it was agreed that these ex-
isting impacts would only become worse in the future unless effective
action is taken. Some commenters supported EPA's action to condition
funding for additional wastewater facilities upon demonstrated progress
toward solving the non-point source problem. While others concurred with
the EPA conclusion regarding the magnitude of non-point source pollution,
these commenters believed the Draft EIS to be lacking because it did not
offer any specific solutions.

The purpose of the Hilton Head EIS is to select a wastewater management
program for the island and to determine the extent of Federal participation
in the funding of the program. Consequently, wastewater management
alternatives were formulated and evaluated and their environmental impacts
assessed During this process ancillary issues were considered including
the impacts of existing and future non-point source pollution.

Substantial work related to the non-point source problem was performed con-
currently with the EIS process, most notably the special studies conducted
by DHEC and the 208 effort. Data and findings from these investigations
have been recognized and incorporated into the Hilton Head EIS.

The Hilton Head EIS concludes that non-point source pollution is a major
water quality consideration for the study area. While the development of
specific non-point solutions is beyond the scope and purpose of the EIS,

IV-1

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the non-point source problem has been carefully considered throughout,
and lil'A has identified it as the most significant source of surface water
degradation. Recognizing the need for abatement, EPA has conditioned fund-
ing for the Sea Pines PSD - Forest Beach PSD preferred alternative upon
demonstrated progress in solving the non-point source problem.

Progress is defined as passage of an ordinance by Beaufort County re-
quiring on-lot retention for new construction and a commitment by the
Sea Pines PSD - Forest Beach PSD to participate in a study to specifically
address the existing non-point source problem. EPA will direct this study
which will identify the sources of non-point source pollution, evaluate methods
to minimize the contribution from these sources, and identify the means to
implement appropriate control measures.

ISSUE NO. 2 - POPULATION AND WASTEWATER FLOWS

Several commenters questioned the basis for the population projections for
Hilton Head Island, and hence questioned the projected wastewater flows.
The focus of these comments relate to the disparity between the OBERS
Series E population projections used to determine the level of EPA funding
of wastewater facilities and the indicated trends based on historical growth,
platted property holdings, and developer's plans.

Methodology

Population projections were made at two levels: (1) from the OBERS base
and (2) from information gathered from the Beaufort County Joint Planning
Commission (JPC). These projections were then disaggregated among the public
service districts, the Hilton Head Plantation, and areas of the island out-
side of the existing PSD boundaries. Both sets of projections were based
upon historical occupancy rates for rental units and seasonal residents and
therefore, in some cases, are considerably less than 100 percent occupancy.

In order to establish the maximum needs for the treatment and disposal
capacity for existing service areas, it is assumed that the existing PSD
areas and the Hilton Head Plantation will be 100 percent sewered by the year
2000. This assumption is made to assure that planning considers fully adequate
facilities and that worst case environmental impacts can be evaluated. However
it is not intended to preclude the use of existing on-lot systems that are
functioning properly or the use of on-lot systems for new construction where
soils are suitable.

Based upon the population disaggregations for the year 2000, the assumption
of 100 percent sewer service, and per capita wastewater flow rates for various
population components, wastewater flows were projected for each of the PSD's
the Hilton Head Plantation, and the non-PSD areas of the island. They	'

represent the daily flow of the highest monthly average flow to'be expected
in the year 2000 based upon historical occupancy rates for rental units and
seasonal residents.

IV-2

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Wastewater management alternatives were formulated and evaluated princi-
pally for the Sea Pines PSD - Forest Beach PSD. Where on-going waste-
water facility construction met or exceeded projected flows, the "no
action" alternative with respect to EPA funding was judged to be the
only alternative.

Concerns

In general, the commenters indicated that the OBERS wastewater flows
were unrealistic. In many instances, the projections made by the
individual service areas also exceeded the higher JPC-based wastewater
flows presented in the Draft EIS. While the commenters recognized
that EPA funding must be constrained to the OBERS level, they expressed
the legitimate concern that use of lower wastewater flows would preclude
the identification of possible wastewater management plans for the entire
island and could possibly lead to the duplication of wastewater facilities
among the various service areas.

Resolution

These comments and concerns have been carefully considered in the Final
EIS. While this EIS proposes no funding actions or permitting decisions
outside of the Sea Pines PSD - Forest Beach PSD, possible wastewater manage-
ment alternatives for other areas of the island are identified and discussed
herein.

The wastewater management alternatives evaluated in the Final EIS are
based upon updated JPC population projections. These population pro-
jections which were developed in the Hilton Head land use planning effort,
were used to generate updated flow projections for the major service areas
as follows:

___	Service Area	

Sea Pines PSD - Forest Beach PSD
Broad Creek Public Service District
Hilton Head No. 1 PSD
Gardner-Matthews Plantation
Hilton Head Plantation

Peak
Wastewater Flow
4.5 mgd
2.4 mgd
2.8 mgd
1.1 mgd
2.0 mgd

ISSUE NO. 3 - NEW WASTEWATER MANAGEMENT ALTERNATIVES

At the June 23, 1982 public hearing on the Draft EIS the Sea Pines Public
Service District outlined an alternative management program to handle
wastewater from the Sea Pines PSD and Forest Beach PSD service areas.
The alternative emphasized reuse of advanced treated wastewater for golf
course, open space, and lawn irrigation; the Forest Preserve wetlands
discharge system; and discharge of advanced treated wastewater into Lawton
Canal during periods of extreme rainfall.

IV-3

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Additional information on the Sea Pines alternative was requested by EPA
in a letter dated August 3, 1982; this information was provided by letter
dated September 1, 1982 and carefully considered in the Final EIS process.

The Final EIS endorses the Sea Pines proposal to provide for maximum reuse
of treated wastewater; advanced treatment will be provided to achieve a suspended
solids concentration of 5 mg/1 prior to reuse. The experimental wetlands discharge
system may continue to be implemented in an effort to reestablish diminishing wet-
lands within the Forest Preserve. A backup system is required for periods of
heavy rainfall and unusual operating conditions.

Detailed information and discussion of the EPA alternative is provided else-
where in the Final EIS.

ISSUE NO. 4 - WASTEWATER REUSE AND WATER CONSERVATION

There was overwhelming support expressed during the comment period for the
reuse of treated wastewater for irrigation purposes on the island, to re-
lieve demands on the Ocala Aquifer. EPA endorses this concept.

The recommended wastewater management program for the Sea Pines PSD - Forest
Beach PSD service area promotes the reuse of treated wastewater for benefi-
cial purposes through golf course, open space, and lawn irrigation and through
the experimental use of the Forest Preserve wetlands. The use of treated
wastewater for golf course, open space, and lawn irrigation will signifi-
cantly reduce withdrawals from the Ocala Aquifer; it is hoped that the ex-
perimental wetlands system will restore diminishing wetlands within the Sea
Pines Forest Preserve without adversely impacting the ecosystem.

In addition to the reuse of treated wastewater, EPA supports the use of water-
saving and flow-reducing techniques to lessen water supply demand. It is
recommended that Beaufort County implement the use of water-saving devices in
all new construction, and that the Public Service Districts on Hilton Head
encourage water conservation among their customers.

ISSUE NO. 5 - CALIBOGUE SOUND DISCHARGE

Manv comments were received regarding the discharge of treated wastewater to
Calibocue Sound and the assimilative capacity of the receiving waters. Most
of the comments expressed concern oveT the use of chlorine as a disinfectant,
and others suggested that discharge be at ebb tide.

,,p. believes that chlorination is the most effective means of disinfection
for use in the selected wastewater irrigation program. The use of chlorine for
disinfection has been standard practice for years. Significant adverse

IV-4

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impacts are not expected to occur from the periodic discharge of
chlorinated wastewater into Calibogue Sound. Although Calibogue Sound
is a very sensitive resource, the intermittent nature of the discharge
should mitigate any potential problems. In addition, any wastewater
discharge will have been treated to an advanced level in order to pro-
vide a solids-free effluent. Because the chlorine demand of the final
effluent will be lessened, the chlorination process can be more easily
controlled. As a result, the potential for over-chlorination will be
virtually eliminated.

The Cubit Engineering study of a Calibogue Sound discharge, performed for
the Sea Pines Public Service District, supports the EPA position (and
that of previous studies) regarding the negligible effect of such dis-
charge on the water quality of Calibogue Sound. Consequently, EPA does
not believe that an ebb-tide only discharge is required.

ISSUE NO. 6 - CUBIT ENGINEERING DYE STUDY

Several commenters observed that the Cubit dye study was conducted at
the lowest current of the year and hence questioned its validity. Others
questioned the mechanism for vertical mixing of the wastewater with the
overlying water column.

The Cubit Engineering study of Calibogue Sound has been evaluated by
EPA and found to provide an acceptable basis from which to evaluate
water quality impacts.

The conduct of the dye study at the lowest current of the year provides
a worst-case evaluation of water quality impacts (due to lack of dis-
persion) and therefore does not alter the validity o the conclusions.
Vertical mixing of the wastewater with the overlying water column will
be accomplished through the rise of the wastewater to the surface due
to its lesser density than the more saline receiving waters.

While the Cubit study addresses the predicted impacts of a Calibogue
Sound discharge, it does not eliminate the need for additional work.
To further minimize impacts, detailed studies will be required during
design to determine the optimal location and orientation of the backup
outfall/diffuser structure. These studies should develop outfall and
diffuser design; alignment and depth of discharge; and effluent plume
location, mixing, and dispersion. These studies are required prior
to construction.

ISSUE NO. 7 - CORPS OF ENGINEERS COMMENTS

The Corps of Engineers has commented regarding (1) the protection of
significant cultural resources and (2) requirements for a Department of
the Army permit for certain construction activities.

IV-5

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Construction of the selected alternative is not anticipated to impact any
significant cultural resources. An archeological survey of the pipeline to
Calibogue Sound is required to insure avoidance of such impacts. EPA
will comply with current legislation and regulations to avoid or mitigate
any potential impacts.

The Charleston District of the Corps of Engineers has been contacted re-
garding permit requirements for subaqueous pipelines. A permit will be
required for a Calibogue Sound or Ocean backup outfall and diffuser.

ISSUE NO. 8 - BIOLOGICAL ASSESSMENT AND ENDANGERED SPECIES

The United States Department of the Interior has commented regarding the
possible presence of any endangered or threatened species, listed or proposed
to be listed, which may be present in the impact area of the proposed project.

The following is a list of endangered or threatened species which are be-
lieved to possibly be present in the Hilton Head Study Area.

1.	American alligator (Alligator mississippiensis)	- Threatened

2.	Loggerhead turtle (Caretta caretta)	- Threatened

3.	Bald eagle (Haliaeetus leucocephalus)	- Endangered

4.	Brown pelican (Pelecanus occidentalis)	- Endangered

5.	Florida manatee (Trichechus manatus)	- Endangered

In addition there are several marine species, including the endangered short-
nose sturgeon (Acipenser brevirostrum), which may occur in the project area
and for which the National Marine Fisheries Service has responsibility.

The selected alternative has been evaluated with respect to possible impacts
upon these endangered and threatened species. Construction of the pipeline
crossing of South Beach for a Calibogue Sound backup outfall may impact the
nesting period for the loggerhead turtles. As a grant condition, EPA will
require that an acceptable erosion control plan and construction schedule be
developed to avoid this potential impact. All other construction activity
will be in already disturbed areas and should have no impact on any of these
species. The quality of the wastewater that is now being sprayed on the
golf courses will be improved as part of this project.

ISSUE NO. 9 - ISLAND-WIDE WASTEWATER MANAGEMENT

Several commenters indicated the need for a wastewater management plan for
the entire island, regardless of EPA's funding and permitting constraints.

Despite the Draft EIS focus on the Sea Pines PSD - Forest Beach PSD EPA
recognizes and supports the need for wastewater management planning'for the
rest of the island.

IV-6

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The following actions are recommended.

1.	DHEC, the PSD's, and local developers should formulate an agreement
to provide wastewater management service for the island. This
agreement should include a specific delineation of service area
boundaries,

2.	The number of service areas should be minimized and the existing
wastewater systems should be integrated within each service area.

3.	Facilities capable of meeting a 5 mg/1 suspended solids limit
should be provided at each treatment plant to maximize the reuse
potential of the treated wastewater.

4.	Available spray capacity of each service area should be adequate

for the total expected daily effluent requirements under normal opera-
ting conditions.

5.	Construction of the collection, treatment and distribution systems
should be coordinated to avoid foreclosing available reuse options.

6.	The reuse of advanced treated wastewater should be extended to land-
scape areas, buffer areas, and residential lawn irrigation hereto-
fore not approved for secondary treated effluent.

7.	A backup system should be provided for use in periods of heavy rain-
fall and unusual operating conditions. The backup system can be a
discharge to Port Royal Sound, an Ocean outfall, or any other
approved system that will meet Federal, State and local requirements.

8.	The total number of outfalls should be minimized, preferably two or
less. Significant adverse impacts to productive shellfish waters
should be avoided through proper siting and operation of such outfalls.

9.	Water conservation measures should be adopted and incorporated into
new construction.

Alternatives for island-wide wastewater management are presented and dis-
cussed elsewhere within the Final EIS.

ISSUE NO. 10 - CONSOLIDATION OF PSD'S AND
TREATMENT PLANTS

Many comments were received regarding the duplication of wastewater facili-
ties, the coordination of wastewater management programs, and the possible
consolidation of the various Public Service Districts.

The 201 Facilities Plan evaluated various combinations of wastewater treat-
ment facilities for Hilton Head. In addition to the continued treatment
of wastewater by the individual public service districts, several more

IV-7

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regional concepts which would involve a lesser number of treatment facili-
ties were considered. The recommended alternative called for the continued
operation of the existing PSD treatment facilities based upon the high costs
of pumping wastewater long distances to a single location for treatment.

The EIS concurs in this finding, especially in view of the Final EIS objective
to provide for the maximum reuse of advanced treated wastewater throughout
the island. The consolidation of the existing PSD treatment facilities to
a central facility would not only require extensive pumping of raw wastewater
to a central location for treatment, but also the repumping of treated waste-
water back to individual irrigation sites.

However, EPA does not support the proliferation of small package wastewater
treatment plants on the island nor the creation of numerous new service areas
beyond those presently existing. Rather, EPA supports the coordination of
wastewater management programs among the various PSD's on Hilton Head and
has recommended the following actions in its Final Decision.

fl) DHEC, the PSD's, and local developers should formulate an agreement to
provide wastewater management service for the island. This agreement
should include a specific delineation of service area boundaries.

(2)	The number of service areas should be minimized and the existing waste-
water systems should be integrated within each service area.

(3)	The total number of backup outfalls should be minimized, preferably two
or less. Significant adverse impacts to productive shellfish waters
should be avoided through proper siting and operation of such outfalls.

ISSUE NO. 11 - CONTINUED USE OF ON-LOT SYSTEMS

Several persons commented regarding the continued use of septic tanks on the
island and the need for a more comprehensive maintenance program for existing
systems.

EPA believes that the continued use of on-lot systems on Hilton Head Island
is acceptable where soils, groundwater depth, and site conditions are suita-
ble. The EIS has not identified any areas on the island where widespread
septic tank malfunctions are known to occur.

EPA supports the development of appropriate monitoring programs in areas
relying upon septic tanks by the Beaufort County Health Department and the
South Carolina Department of Health and Environmental Control. Regular in-
spection and maintenance guidelines should be established and implemented
as part of this program.

IV-8

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ISSUE NO. 12 - PROVISION OF SEWERAGE TO
UNSEWERED COMMUNITIES

Several comments were received regarding the extension of sewerage service
to areas of the island that are presently unsewered.

As discussed in the answer above, EPA has not identified significant public
health or environmental problems in the non-sewered areas of Hilton Head
that would necessitate the extension of sewer service at this time. Should
such problems occur in the future, an appropriate wastewater management
program can be implemented. Several alternatives were presented in the
Draft EIS and cost estimates given as a function of population and distance
from existing sewers.

In its Final Decision, EPA has recommended that DHEC, the PSD's and local
developers formulate an agreement to provide wastewater management service
to the island. This agreement should include a specific delineation
of service area boundaries.

PART C. HEARING TRANSCRIPT AND
WRITTEN COMMENTS

Copies of the public hearing transcript and of the written comments
received thereafter are provided in this part. They are cross-referenced
to the issues and responses presented in Part B of this chapter.

IV-9

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CONTENTS OF PUBLIC HEARING TRANSCRIPT

A copy of the June 23, 1982 hearing transcript follows. Persons
giving statements at the hearing, their representation, and the pages
of the transcript which their statement encompasses is provided below.

PERSON

REPRESENTING

Robert C. Cooper
Roger E. Davis
Mac Burdette
Steve Hopkins

Arnold Ellison

Grand Moorehouse
Leslie Teal
W. L. Longnecker

Charles Golson
Donald Hook

Bea Cheil
Carroll Dailey
Perry White
Bob Gale

Thomas Barnwell
Emory Campbell

EPA Region IV

South Carolina DHEC

South Carolina Coastal Council

South Carolina Wildlife &
Marine Resources Department

Sea Pines Public Service
District

Hilton Head Island Commission
Citizen

Association of Sea Pines
Plantation Property Owners,
Island Concerns Committee

Citizen

Hilton Head Island
Community Association

League of Women's Voters

May River Committee

N.A.A.C.P., Hilton Head Chapter

Sierra Club, Nancy Cathcart
Group

Citizen

Citizen

TRANSCRIPT PAGES
7-22
23 - 25
26 - 27

28	- 29

29	- 36

37 - 43
44 - 52
54 - 55

56	- 57

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HILTON HEAD ISLAND, SOUTH CAROLINA
DRAFT ENVIRONMENTAL IMPACT STATEMENT
PUBLIC HEARING

Proceedings held in the Hilton Head Elementary School,
Hilton Head Island, South Carolina, on the 23rd day of
June, 1982, at 7:30 P.M., reported by Edmund W. Ruchalski,
Certified Court Reporter, B-538.

and

Certified Court Reporters	p Q Box

Beverly A. Cerbone	Savannah, Georgia 31412

Edmund W. Ruchalski	(912)234-4068

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INDEX

PAGE

I. INTRODUCTION AND PURPOSES OF THE

ENVIRONMENTAL IMPACT STATEMENT 	 3

II. SUMMARY OF THE DRAFT EIS 		7

III. COMMENTS FROM THE FLOOR 		22

IV. ADJOURN				82

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HEARING OFFICER: We're a little past time so I would like to
formally open the Public Hearing, and begin with our
comments. First of all let me tell you that my name is
Howard Zeller. And I'm the assistant regional administrator
of the United States Environmental Protection Agency. My
office is in Atlanta, Georgia. And I will be Hearing Officer
here tonight for this hearing. The purpose of the hearing
is to develop a record and to receive comments on the Draft
Environmental Impact Statement, which was recently issued
relative to the waste treatment facilities here on Hilton
Head Island. I want to welcome all of you to the hearing.
And I want you to understand that it's your hearing and
it's for the purposes of information, and I want you to
feel free to participate. If you have not filled out a
card when you came in and indicated your interest in making
a statement at this hearing, I would ask you to please do
so or let me know otherwise. And even if you do not wish
to make a statement, you should fill out a card because
this becomes part of our official record. And it's our
way of notifying you of the results of this hearing. So
it's very important that you be registered for the hearing
so that we have a complete record of the events.

Now I have a number of things tliat I'm obligated to
get into the record, so if you'll bear with me I'm going to
go through my notes here and make sure that we have a legal

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A

document developed, and we'll add a few things into the

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record before we get into the actual making of statements.
First of all the hearing tonight is to receive public
and agency comments on the Hilton Head Island, South
Carolina 201 Area Environmental Impact Statement. The
Draft EIS addresses the proposed wastewater facilities for
Hilton Head Island.

Now with me tonight at the hearing on my immediate
left is Roger Davis, who is the .Deputy Commissioner of the
Department of Health and Environmental Control for the
State of South Carolina. On my immediate right is Bob
Howard, Mr. Howard is on my staff and he heads up the
National Environmental Policy Compliance Group. In other
words he is in charge of preparation of all Environmental
Impact Statements for the eight states of region four. Mr.
Robert Cooper who is further over on my right is the Project
Officer for this particular EIS. Mr. Cooper has been
intimately involved with this project for several years now,
probably about three years, and has followed its develop-
ment. And he s the person that's largely responsible for
the document that we have tonight. And he'll be making a
statement later on to discuss it.

Let me ask now are there, I always like to do this
at hearings, are there any elected officials that are here
at this hearing? If so I would like to acknowledge

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Yl ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION IV

345 COURTLAND STREET
ATLANTA. GEORGIA 30385

AUG 2 6 1983

TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:

Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for wastewater management in Hilton
Head island, South Carolina.

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 ElS 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 administrative
action on this project 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;

Mr. Robert Cooper, Project Officer
NEPA Compliance Section
Environmental Assessment Branch
U.S. Environmental Protection Agency
34 5 Courtland Street, N.E.

Atlanta, Georgia 3036 5

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your presence. Would you stand?

NOTE: (Spectator acknowledges himself)

HEARING OFFICER: Thank you, sir, we're very happy to have you
here, appreciate your taking the time to be here. Well
let me talk a little bit about the hearing itself. Under
EPA Regulations the type of hearing that we have tonight
is an informational hearing. In other words it's a non-
adversarial meeting type hearing. There will—I will not
permit any cross-examination of anyone. I may ask some
questions of the people that make statements, other panel
members may ask some questions. I will not necessarily
allow anyone from the audience to ask questions of an
individual who makes a statement, unless that would be
agreeable to that person involved. But I do want to develc
information, and to have an accurate record here of what
this project is all about. So whatever that entails, I
want to try to see that that's done.

The authority for the action tonight is found in the
Statutes, if you'd care to pursue it, it's under the
"Cleanwater Act" of the United States Environmental Pro-
tection Agency, and the National^ Environmental Policy Act.
The "Cleanwater Act" says that we should hold a hearings
on the 201 Project, Area Wide Planning Projects of this
nature if there are Federal funds involved. And the
National Environmental Policy Act says that any time there

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is a project that would have a, that involves Federal
dollars that would have a significant impact on the environ-
ment , you shouldhave an Environmental Impact Statement
prepared. So that's the statutory basis for the hearing
tonight.

Now we made our decision on an EIS for the 201
Facilities Plan because we thought there would be an
effect on the environment. In April of 1979 we sent a

I

notice of our intent of the Draft Environmental Impact
Statement, this document here, which I think most of you
have, if you do not have there are copies available back
there on the desk and summaries of it. This Draft Environ-
mental Impact Statement was made available on May 3rd,
1982. It appeared in the Federal Register on Hay 14th, 1982
And as far as purposes and for purposes of comment on this
document I am going to keep the comment period open to
receive written comments in my office until July 9th 1982

Now we followed all of the applicable regulations
as far as this public hearing is concerned. We issued a
public notice on April 30th. We published it in the»

news ¦"

papers, and all of the places that we were supposed to, and

I'm pleased to see that it did have some results beca

we have a good turn-out for the hearing.

Let me just comment again, relative tn o,,*.

u uur reason

for being here, the Environmental Proton-.., *

rocection Agency urges

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you to be Involved in the decision making process for
projects of this nature. We want you to understand what
it is the agency is doing. And we encourage your participa-
tion in the hearing.

Now before we get into receiving comments from the
public, I'm going to ask some of the Federal and State
people to make brief statements about the hearing, so that
we can get those matters into the record. Now the first
person I want to call on now for purposes of the record will
be Robert Cooper, who you remember I said was Project
Officer of this project. And I'm going to ask Mr. Cooper
to make some official comments for the record at this time.
Mr. Cooper?

COMMENTS BY MR. COOPER:

Thank you, Mr. Zeller. Good evening, ladies and gentlemen.
I would like to speak a few minutes tonight about the back-
ground of this EIS and the alternatives which we have been
evaluating.

The 201 Facilities Plan for Beaufort County, which

(

was completed in 1975, recommended that the effluent from
all treatment plants be disposed of by spray irrigation
on nearby golf courses so as not to impact area shellfish
waters. While conceptually sound, this scheme was based
upon golf course irrigation rates which have not been
realized, particularly in the case of the Sea Pines PSD

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and the Forest Beach PSD. The failure of the golf
courses to accept all of the wastewater has led to the
continuing discharge into the SA or shellfish harvesting
waters of Lawton Canal.

In August of 1978, the South Carolina Department of
Health and Environmental Control closed shellfish beds
in Lawton Canal and Lawton Crefek, in Point Comfort Creek,
and in adjacent waters of Broad Creek. These areas were
closed because of high total and fecal coliform counts,
which were encountered in surface water samples. Subse-
quent water quality studies confirmed that these violations
were attributed to non-point source bacterial contamination
and were not originating from the wastewater treatment
facility.

Because of these environmental complexities and the
uniqueness of the environment on Hilton Head, EPA decided
to prepare an environmental impact statement on waste-
water management facilities to serve existing and future
populations of Hilton Head Island. Subsequently, a notice
of intent, as Mr. Zeller indicated, was issued in April
of 1978. Concurrent with the Hilton Head EIS, South
Carolina DHEC initiated a study of the Lawton Creek and
Broad Creek watershed to better define the extent to which
non-point and point sources influenced their bacterial
characteristics. These studies confirmed the existence and

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magnitude of non-point source contamination of Lawton
Creek. Only the effluent from the Sea Pines Treatment
Plant met water quality standards with any degree of
consistency. Additional non-point work is now underway
in Beaufort County, and is funded through what is called
the 208 Program. The firm of Moore, Gardner & Associates
is performing the work under the direction of an advisory
committee representing Local, State and Federal Governments.

The focus of the study is to develop effective manage-
ment practices which will abate non-point source pollution
from Island developments. Conclusions from this work will
serve as an adjunct to the findings of the EIS regarding
wastewater management.

The focus of the EIS has been to develop and evaluate
wastewater management systems for the Island which would
accommodate projected populations, with emphasis placed
on methcfi of disposal of the treated wastewater. The
methods generally available include golf course irrigation,
discharge to surface waters, land application by either
spray irrigation or rapid infiltration, and discharge
to wetlands.

Projected populations and wastewater flows were
developed for each of the service areas on the Island and
compared with on-going wastewater facility construction.
Wastewater management alternatives were then formulated

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and evaluated with respect to costs, environmental
consequences, operability, and implementability. Where
on-going wastewater facility construction met or exceeded
the State's allocation of allowable wastewater flows, the
"No-Action" alternative with respect to EPA funding was
judged to be the only alternative.

p^Yg wastewater management alternatives have been
formulated for the Sea Pines PSD-Forest Beach PSD. Each
alternative includes treatment at the Sea Pines Plant,
which is now being expanded to 3.25 MGDj '»irrigation of
the five golf courses within the two PSD s and the experi~
mental wetlands discharge system which has' already been
approved in concept by the South Carolina DHEC and
the Coastal Council.

Even with irrigation on all five golf courses, sub-
stantial amounts of wastewater will remain, which must be
handled by supplemental means. The five alternatives
considered for disposal are: (1) Advanced treatment and
discharge to Lawton Canal, (2) Secondary treatment and
discharge to Calibogue Sound via a subaqueous outfall and

diffuser; (3) Land application within the PSD's using a
combination of spray irrigation at parcei3 wlthln Pores(.

Beach PSD immediately adjacent to the Hilton Head Golf
Club, rapid infiltration within the Forest Preserve, and
the experimental wetlands discharge system handling 1 MOD,

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(4) Land application outside the PSD's by woodlands
irrigation on the Gardner-Hatthews Tract; and (5) Land
application on the mainland by spray irrigation. Funding
options for these alternatives were also considered,
including a hundred percent local funding and Federal
funding being contingent upon non-point source control
measures being implemented at the local level.

I will briefly summarize the costs, the environmental
impacts and implementability of each alternative. And
this information here is contained in the hand-out which
is available on the registration table.

Option A is continued discharge to Lawton Canal, the
total present worth cost of $1.8 million. This alternative
would allow continued discharge to shellfishing waters
when other reasonable options are available. This would
foreclose the chance of opening these closed shellfish
waters.

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The Liiilr of the closed buffer zone will increase as
wastewater flows increase. The selection of this alterna-
tive will set a precedent of allowing future surface
water discharges into shellfish waters. Federal support
would promote growth and development which would increase
non-point source runoff. And a precedent of near-shore
wastewater disposal could encourage other developments
to abandon on-property disposal plans potentially result-

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ing in a reduction of open space and higher densities.

The second option is construction of a new subaqueous
outfall for discharge to Calibogue Sound. Total present
worth cost of this alternative is also $1.8 million. This
alternative would remove the unpermitted discharge to the
shellfishing waters of Lawton Canal. No buffer zone
closures of shellfish beds would be required. The South
Carolina Wildlife and Marine Resources Department has
expressed concern regarding surface water discharges to the
area.

The Coastal Council has also expressed concern re-
grading a precedent for surface discharges and greater
long-range non-point source problems based on greater
ultimate population. Federal support would also promote
growth and development with increased non-point runoff.
A precedent of off-island wastewater disposal could
encourage other developments to abandon on-property disposal
plans potentially resulting in a reduction of open space
and higher densities.

Recently completed dye studies and modeling analysis
indicate that the proposed discharge would have a minimal
impact on the environment of Calibogue Sound.

The third option is rapid infiltration within the
Sea Pines Forest Preserve, and spray irrigation w^ihin
Shipyard Plantation. The total present worth of this alter-

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native is gauged at $6.7 million. This system was not
deemed to be technically feasible due to soil and
water table conditions. This system would remove unper-
mitted discharge to shellfishing waters, and would set ou
precedent for surface discharges.

Federal support would promote growth and development,
which could encourage increase non-point source runoff.
Sixty-seven acres of land within Shipyard Plantation would
no longer be available for other forms of development.

The fourth option is spray irrigation on the Gardner-
Matthews site. The total present worth cost of this
alternative is $12.6 million. Removal of unpermitted
discharge to shellfish waters would result. And increases
in the Island's disposal capacity would be limited by the
specific capacity of the spray site.

Selection of this alternative would not provide a
precedent for additional surface water discharges. Federal
support would promote growth and development, and increase
non-point source runoff within the capacity of the
discharge site. Power of eminent domain would have to be
used by the County to take land from the land owner who
currently has other plans for its use.

Site specific studies will be required to determine
specific spray irrigation application rates. This alterna-
tive would give the perception of a solution to the waste-

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water disposal problem that is limited in scope. There-
fore future developments would likely be planned to manage
their disposal on their own property. Lower densities and
greater open space would likely result. Five hundred acres
of land would no longer be available for other forms of
development.

The fifth option was spray irrigation off-island.
The total present worth of this alternative was $12.5
million. This alternative would lead to the removal of
the unpermitted discharge to the shellfish waters of
Lawton Canal. This alternative would not provide a prece-
dent for the approval of the additional surface water dis-
charges of wastewater. The purchase or leasing of land couL
potentially be negotiated without the use of eminent domain,

A precedent of off-is land disposal could encourage
other developments to abandon on-property disposal plans
potentially resulting in a reduction of open space and
higher densities on the island. Federal support would
promote growth and development, which would increase non-
point source runoff. Site specific studies will be re-
quired to determine specific spray irrigation application
rates.

Option six is a No Federal Action alternative. Sea
Pines - Forest Beach PSD's would implement either alterna-

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tive Two, Four or Five, with one hundred percent Local
funding. Again these alternatives are discharge to
Calibogue Sound, spray irrigation on the Gardner-Matthews
site, or spray irrigation off-island. The discharge of
treated wastewater into the SA waters of Lawton Canal would
be eliminated. Federal participation would not be
provided to any alternative which would support increased
urban runoff pollution of SA waters.

Implementation of a discharge to Calibogue Sound
would provide a precedent for other surface water dis-
charges. Site specific studies would be required on the
locally selected alternative to determine the spray
application rates.

The final alternative is Federal funding conditional
on a non-point source solution. This option would be
identical to the previous one except Federal funding would
be made available if an effective implementable non-point
source control program is established.

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This alternative would provide for discharge to
Calibogue Sound or spray irrigation on or off-island. The
discharge of treated wastewater into the SA waters of
Lawton Canal would be eliminated. Federal participation
would notbeprovided to any alternative which would support
increased urban runoff pollution of SA waters. Implementa-
tion of a discharge to Calibogue Sound would provide a

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precedent for other surface water discharges. Site
specific studies would be required on a locally selected
alternative to determine spray application rates if the
spray irrigation alternatives were chosen.

This alternative could provide incentive for the
implementation of an effective non-point source program.
The preferred wastewater management alternative for the
SeaPines-Forest Beach PSD's was judged by EPA to be the
Federal funding conditional on non-point source solution
alternative, that last one which I described. Under this
alternative the Sea Pines PSD would implement the most
cost-effective and implementable of these disposal op-
tions: Discharge to Calibogue Sound, spray irrigation at
the Gardner-Matthews Site, or spray irrigation off-island.

Federal funding for construction would be made avail-
able consistent with State priority listing, if an effective
non-point source control program was developed for the Sea
Pines - Forest Beach area by the Beaufort County Government
by the time the Step II Design Phase was complete.

If Federal funding is made available for Step III,
facilities sized to dispose of the 1.8 MGD presently
going into Lawton Canal would be eligible. Any additional
capacity constructed would have to be funded with one
hundred percent local funding.

Present plans of the Broad Creek pen «« .» ,

LR tbu envision expan-

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sion of the existing 0.6 MGD treatment plant to 1.2 in
1982. A second expansion 1.2 to 1.8 is envisioned by
1984, and a third 2.4 MGD by 1988. These plans will
provide capacity beyond that required for the year 2000
OBERS Population or the Joint Planning Commission Popula-
tion.

Wastewater is presently sprayed on the Fazio Golf
Course and an existing twenty acre spray site. As needs
dictate, the Trent Jones Golf Course will also be irrigated
with treated wastewater. These two courses and the existin
spray site are adequate to handle the OBERS and JPC based
flows projected for the year 2000. However, additional
spray areas or another permissible disposal alternative
may be required to match the designed capacity of the
proposed 1.2 MGD plant. The cost of the Broad Creek ex-
pansion program must be borne entirely at the local PSD
level. Current EPA Policy prevents their participation
in funding of wastewater facilities greater than the
OBERS population.

Consequently the program described above for the Broad
Creek PSD represents the no-action alternative with respect
to Federal funding.

The Hilton Head number one PSD wastewater facilities
primarily serve apartments, condominiums, and commercial
establishments located within the boundaries of the PSD.

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Single-family residences within the Port Royal Plantation
are served by septic tanks. Current flows average about
a hundred and seventy-five thousand gallons per day.
Treatment facilities were constructed in 1971 and consist
of an unlined oxidation pond followed by two unlined holding
ponds. Wastewater from the oxidation pond percolates into
the groundwater, and DHEC has placed a moratorium on
additional connections to the System.

In order to provide additional capacity private
development has constructed an interim four hundred and
forty thousand gallon per day treatment facility adjacent
tothePSD's existing oxidation pond. Treated effluent is
pumped from the plant, under route 278, to Port Royal
Plantation for irrigation on two golf courses. DHEC
has approved the use of these courses for spray irrigation
to at least eight hundred thousand gallons per day of
wastewater.

Construction is now underway for a new eight hundred
thousand gallon per day plant to serve existing and future
needs within this area. A completely new facility is being
built because of the inadequacy of the existing unlined
oxidation pond. As part of the Hilton Head number one
project, the Port Royal Inn Package Plant win be abandoned

and a pumping station and force main constructed to convey

wastewater to the new PSD facilitip* tu

The entire project

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is being funded, in part, by an EPA construction grant.

The Hilton Head number one PSD has recently asked
DHEC to allow the four hundred and forty thousand gallon
per day interim facility to remain in operation after con-
struction of the new plant has been completed. The existing
golf courses cannot accommodate the total capacity of
1.24 MGD which would result. A third golf coursednthe Port
Royal Plantation is planned for construction within the nex:
four years.

Additional EPA funding will not be available for any
future needs of the Hilton Head number one PSD in excess
of the eight hundred thousand gallons per day facility
now under construction. Therefore the cost for future
expansion beyond eight hundred thousand gallons per day,
and for securing additional spray irrigation areas or for
an alternate disposal method must be borne totally by the
PSD.

Hilton Head Plantation is served by treatment
facilities owned and operated by the Hilton Head Plantation
Utilities Corporation. The Hilton Head Plantation plans
to expand the existing activated sludge package plant from
0.5 to 1.0 MGD during 1984, based upon anticipated housing
starts. The resulting capacity will be sufficient to
accommodate the year 2000 population which the plantation
projects. The corporation is not eligible to receive EPA

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grant funds for improvements.

Areas of Hilton Head Island which lie outside the
boundaries of the Hilton Head Plantation or the existing
Public Service Districts are served by septic tank-drain-
field systems, the exception of the Mariner's Cove Club
and the Northside Trailer Park. There are no areas where
widespread septic tank malfunctions are known to occur.

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The septic tank-drainfield system remains the
preferred system for use in the non-PSD areas where soils,
groundwater depth, and site conditions are acceptable.

If an area should experience septic tank failures in the
future, a community-sized on-lot system could be developed
or sewers extended from an adjacent PSD. Where septic
tank failures occur on an individual basis, on-site
improvements would be the only feasible solution.

The Mariner's Cove Plant provides treatment for the
wastewater generated from forty units of the Mariner's
Cove Club Complex, which is located south of Route 278, near
the bridge to Pinckney Island. Effluent from the plant
is spray irrigated. Its continued operation is envisioned
although increased emphasis on operation and maintenance
of the plant and spray system is required.

The Northside Trailer Park is located on the northern
end of Hilton Head, off of Gumtree Road. Residents of
the trailer park have been asked by the Hilton Head Flanta-

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tion Company to vacate the property after which the
existing ten thousand gallons per day package plant will
be abandoned.

A major conclusion of this EIS is that the control
of non-point source pollution is a significant environ-
mental problem on Hilton Head Island. This problem will
grow continually worse throughout the island regardless
of which alternative is selected for the discharge of
wastewater if control measures are not implemented before
development intensifies. The implementation of appropriate
non-point source control such as on-lot retention and
treatment through natural wetland systems could significant!,
mitigate non-point source problems.

The implementation of the recently submitted recommend; i
tions of the 208 study by the Beaufort County Council
would go a long way toward protecting water quality in the
Hilton Head area from further degradation. Another importai.
goal is the passage of land use control legislation. The
control of allowable development densities is an issue of
utmost importance, which must be dealt with by the Beaufort
County Council if water quality is going to be maintained
in the future.

A third issue of major concern in the maintenance
of water quality is the proliferation of marinas in the
Hilton Head area. Each new marina in SA waters requires a

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new buffer zone, requires that a new buffer zone area
be closed to shellfish harvesting. This situation is
especially critical in Broad Creek.

With this hearing tonight we are nearing the end of
the EIS process. During this process, we have achieved
a better understanding of the nature and extent of water
quality problems in the Hilton Head area and have evaluated
a wide range of wastewater disposal alternatives. EPA's
selection of preferred alternatives was principally based
upon the preservation of SA waters at a reasonable cost.

It is now up to the Beaufort County Council and the
South Carolina Coastal Council to implement the necessary
control measures with regard to non-point source runoff
controls, population density controls, and proper siting
of marinas. It is only when all of these issues have
been properly addressed that water quality in the Hilton
Head area can be improved or at a minimum maintained at
its current level.

Thank you for your attention and your attendance here
tonight.

HEARING OFFICER: Thank you, Mr. Cooper, that's a good

summary of the events that were covered in the EIS. Next
I would like to ask Mr. Roger Davis of the South Carolina
Department of Health and Environmental Control to make
a statement. As most of you know the State of South

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Carolina has been delegated the National Pollutant Dis-
charge Elimination System Permit Program. Now any facility
that is ultimately constructed and in operation would be
permitted by the State of South Carolina with EPA's con-
currence. EIS is part of that process, and let ine ask
Mr. Davis to go ahead at this time.

COMMENTS BY MR. DAVIS:

Thank you, Mr. Zeller. I'm going to,, with your indulgence,
read a comparatively brief statement into the record.
"The staff of the department of Health and Environmental
Control has been involved with this EIS since its inception,
having generated some of the information contained therein
and having reviewed the work of others. It has become
obvious through this process that there is no ideal solu-
tion to the problems caused, created by the population
density of this barrier island.

Hilton Head is surrounded by high quality waters,
despite the degree of habitation that currently exists.
However violations of the water quality standards do exist
because the water must be of nearly pristine quality for
the harvesting of shellfish to be allowed. Studies have
shown that rainwater which flows across the island collecte(
in storm drains and discharged to the lagoons and creeks
is sufficiently contaminated to be the major cause of the
elevated bacteria levels in those areas which have been

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closed for shellfishing. Unless this problem which is
M known as non-point source pollution is solved, funds
^ directed at up-grading of waste treatment plants will
1 provide no added beneficial use of the surrounding waters.

n

—	A two-pronged approach to the point and non-point
sources of pollution will require a high degree of local
co-ordination and action. Strong local ordinances must
be developed for the island as a whole for any non-
point source control program to be effective. Strong con-

^ sideration should also be given to water conservation meas-
?§ ures, both as a means of protecting the limited supply of
W ground water and of reducing the magnitude of the waste

N

—	disposal problem.

The installation of water efficient fixtures and new
construction still have a measurable impact given the	|

build-out yet expected to occur. The Department has been
concerned about the impact of the point source discharge
from since the early days of the development of the island
The first indication of this concern was in 1967 when the
proposed facility to discharge to the Lawton Canal area
was judged to be adequate to protect the shellfish beds
at the projected waste flows then projected at five hundred
thousand gallons per day.

In 1970 the Department began encouraging the district
to use spray Irrigation as a means of „aste disposal, and

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received positive responses. If I may at this point,
I'd like to take this opportunity to clear up what I
believe has been a recurring misconception. Reference
has been made on numerous times to the unpermitted dis-
charge of Sea Pines PSD, in the. context of it being an
illegal discharge. This characterization is inappropriate
since the facility was constructed with full DHEC approval.
We chose not to issue a Federal discharge permit for the
facility on the basis of the District's plan to phase out
the discharge. Unfortunately tt>e plan to totally eliminate
the discharge was unsuccessful. DHEC then issued an
administrative order which recognized* and authorized the
continued discharge to Lawton Ditch, and requires the study
of additional alternatives to the discharge.

This study has since been supplanted by this EIS. The
study of the water quality issues on the island has been
a high priority for DHEC. For two straight years the
Hilton Head EIS was identified by DHEC as one of only
a few major issues included in a co-ordination agreement
between the agency and EPA.

After evaluating comments received here tonight, DIIEC
will submit detailed comments on the Draft EIS before the
close of the record. Thank you.

HEARING OFFICER: Thank you, Mr. Davis. Next I'd lik6 to call
on Mr. Mac Burdette with the Coastal Planning Commission,

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excuse me, the South Carolina Coastal Council. The
Council will be involved in any effort as far as issuance
of a permit is concerned, I believe the South Carolina Law
requires that the Council approve any permit before it s
issued. Along those lines we would appreciate your
comments for the record, sir.

COMMENTS BY MR. BURDETTE:

Thank you, Mr. Zeller, my name is Mac Burdette. X tn the

planning co-ordinator for the South Carolina Coastal
Council. Dr. WaStTBeam, the executive director of the
South Carolina Coastal Council asked me on behalf of the
full Coastal Council membership to read the following letter
"June 17, 1982, directed to Mr. Charles Jet*&er, administra-
tive director, Environmental Protection Agency, Atlanta
Georgia, Dear Charles: The South Carolina Coastal Council
has completed its review of the Draft Environmental Impact
Statement for Hilton Head Island, South Carolina Wastewater
Facilities. Pursuant to policies of the South Carolina
Coastal Zone Management Plan, and to 15CFRPart 930 which
reads, "Consistency for Department of Interior Outer Con-
tinental Shelf Pre-Lease Sale Activities and/or other Feder^
Activities directly affecting the Coastal Zone, an alterna-
tive method allowing the discharge of secondarily treated
effluent in the Calibogue Sound is not consistent with
the policies of the South Carolina Coastal Council. The

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Hilton Head Island Special Area Management Plan, Chapter
Two, Section One, Item C states that, "No discharge of
primary or secondarily treated effluent into the critical
areas of Hilton Head Island shall be allowed. This policy
— is based upon concern for the quality of water surrounding
Hilton Head Island, the possible long-term indirect im-
pact associated with rapid development, and upon the poten

to

^ tial establishment of precedents that could affect the

entire coastal area of South Carolina. Whereas we do

recognize that the EIS has issued on April 30th, 1982,

is still in draft form, please be advised of the Coastal

Council's concern and intentions. Should the final EIS

contain this alternative in a design which would not

satisfy our consistency requirements, the Coastal Council

would be obliged to issue a negative determination at that

time. We realize the difficulties associated with providing
(Phonetic)

the necessary input structure to support development.

"However, the Coastal Council's responsibities as
mandated by the South Carolina General Assembly remain
directed toward the preservation and enhancement of a sound
natural environment for future generations. We appreciate
your deliberation, and look forward to working with you to
bring about an acceptable solution. Sincerely, H. Wayne
Beam, Executive Director, South Carolina Coastal Council."
Thank you, sir.

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HEARING OFFICER: Thank you, Mr. Burdette, we appreciate your
comments. You are of course correct in stating that this
is a Draft Environmental,Impact Statement, and the reason
why we're here are to receive comments and to hear of
people's concerns so that we may review the decision, the
preliminary decision that was made. We appreciate your
in-put to be a key party in the ultimate resolution of
this project, I assure you. Next I'd like to ask Mr.

Steve Hopkins, who is a regional marine biologist with
the South Carolina Wildlife and Marine Resources Department.
Please come forward and make a statement, Mr. Hopkins.

COMMENTS BY MR. HOPKINS:

Ladies and gentlemen, comments from the Marine Resources

Division of South Carolina Wildlife will be written out and

sent to you very shortly. Basically though our position

has not changed since the inception of this study three

uo years ago. We are still opposed to the discharge of

§ wastewater into the marine environment, whether it be

S> through the Lawton Canal or Calibogue Sound. This opposi-
te

	tion is based upon potentially adverse effects of various

components of wastewater, such as but not limited to high
concentrations of nutrients, disinfecting agents and trace
metals. And more important that the Sea Pines-Forest Beach
PSD outfall itself is the precedent it will set for waste-
water disposal all along a rapidly developing South Caroling

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coastline. With regard to cost effectiveness of a parti-
cular alternative we ask EPA to heed the advice given to-
night not from the PSD Commissioners or employees or the
Plantation representatives, or building contractors and
so forth, but rather from the people that are going to
bear the burden of these alternatives, whatever it may
be. It is these people who are the ones who can weigh the
cost of their montly sewer bill against property values.
Certainly if you degrade the environment around the island
you're going to make it a less desirable place to live,
and these people are going to pay for it in the long run,
in a very different way. Thank you.

HEARING OFFICER: Mr. Hopkins, that's why we're here, to hear
what the people have to say. Next I'd like to ask Mr.

Arnold Ellison, vrtio is manager of the Sea Pines Public Service
District to please come forward and make a statement,, as
he's indicated he wishes to do.

COMMENTS BY MR. ELLISON:

Mr. Zeller, I'm Arnold Ellison, manager of the Sea Pines
Public Service District. The Draft Environmental Impact
Statement has considered a number of alternatives for
wastewater disposal, and through your review process the
list was narrowed down to five, for which costs ranging from
1.8 million to fifteen million dollars were identified.

These items have already been identified by Mr. Cooper, so 1

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will not go through them agaih. During the three plus
years that the EIS has been in process, the Sea Pines
Public Service District has continued to seek it's own
ways to use and dispose of the treated wastewater. Some
of our efforts include: (1) Continued spray irrigation on
the Club course and Shipyard Golf courses, and to construct
new lines to spray irrigate the Ocean, Sea Marsh, Harbor
Town, and the new nine-hole course in Shipyard. This will
provide spray irrigation on five and a half golf courses.
All that are located within the Sea Pines and Forest Beach
Public Service District.

We have gained approval for pumping treated wastewater
to the forest reserve to re-establish a wetland. A three
year program will be conducted to determine the quantity
of water this wetland can accommodate. We will be pumping
six hundred thousand gallons a day the first year, 1.0
million gallons the second year, and 1.5 million gallons a
day the third year into this vet land. (3) We have con-
ducted a study on the dispersion ard environmental impact
of a secondary effluent introduced to deep water at the
southern tip of Hilton Head Island. We hope that we will
never have to implement or to construct an outfall in
Calibogue Sound, but we have felt the need to evaluate this
alternative to a greater degree than you have in the EIS.

Cubett Engineering from Clemson, South Carolina per-

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formed the study in March of this year, and their report

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has been made available to the EPA staff. The study has
determined that there would be no adverse impact on the
environment from a three MGD or million gallons per day
discharge at the southern tip of Hilton Head Island. In
fact, there would be no change in background concentrations
of any of the perimeters. (A) We have moved ahead with
the treatment plan expansion that includes an environmentall
sound method of sludge disposal. We will be injecting the
sludge into a sand media located at the treatment plant
that has an under-drain collection system. The water removs
from the sludge will be pumped back to the treatement plant
and the sludge mixed with the sand media will provide a

top soil that can be used for landscaping yards and flower
gardens.

(5) We have investigated Actions taken by other
communities in reusing treated wastewater. St. Petersburg,
—Florida has treated their wastewater with tertiary filters

mi

and disinfected to a degree that health officials are

§

satisfied that viruses have been killed. This process

S

t-H allows the city to use treated wastewater for spray irri-
gation of golf courses, parks, road shoulders and medians,
and landscaping of individual yards as well as for fire
protection.

The results of this EIS have significant importance

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to the Sea Pines and Forest Beach Public Service District.

In 1978 the districts received and order from the State
Department of Health and Environmental Control that re-
quired a study of wastewater disposal alternatives. The
EIS became this study that Mr. Davis has already referred
to. Within ninety days of the EIS completion, the district
must submit an engineering report detailing the concept
for implementation of the selected alternative. Within
two hundred and seventy days of approval of the engineering
report, the district must submit plans and specifications
for construction of these facilities. The facility must
then be constructed in accordance with a schedule to be
developed by DHEC.

If the study is finalized as presented, we will have
no choice but to pursue the Calibogue Sound discharge. Ther
are a number of items in the Draft EIS that give concern
to the district. I 11 enumerate them. Number One, the
draft indicates that some of the alternatives for effluent
disposal will allow the unbridled development of the
island. We contend that denial of sewage service will only
cause developers to seek ways to dispose treated wastewater
on the mainland. This is, in fact, already being pursued.
The added cost will then cause a higher number of units to
be built to cover the increased cost of sewage treatement
and disposal. We think this will cause an increase in

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densities, not a decrease.

The limits on development density should be handled
by local ordinance, and are presently being pursued by
the JPC and the Beaufort County Council. (2) The removal
of the present outfall from Lawton Canal will not open any
of the closed shellfish areas. Water in the Lawton Creek,
Point Comfort Creek and portions of Broad Creek do not
presently meet SA standards because of runoff pollution.

We realize there would have to be a buffer zone for
any outfall from a treatment plant. But this buffer zone
that we would have in Lawton Creek falls between two
existing buffer zones, those for Harbor Town Marina and
Palmetto Bay Marina.

(3) Federal funding for any of the selected alterna-
tives, would be limited to that portion of the work re-
quired to eliminate our present 1.8 MGD outfall. This is
an outfall that is presented or created by our present
customers. It has nothing to do with new development. This
funding would be used to assist the present customers and
would not be used for plant expansions for new development.

The EIS, however, prohibits any Federal funding unless
a storm water runoff program is implemented for Sea Pines

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to the program that could be implemented. I say this be-

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cause all work that's been done by the 208 Study and by
the Coastal Council as well as JPC's development standard
ordinance deals with runoff from new developments. None
of these seem to have a solution for runoff pollution for
developed areas, such as Sea Pines and Forest Beach.

We raise the question, does EPA have a suggested
program for controlling or treating runoff from developed
areas? If you were given the responsibility to stop con-
k? tamination of oyster beds, what reasonable action could you
implement?

The Sea Pines and Forest Beach Public Service District;
feel there is considerable study still needed to insure tha
treated wastewater is used, not disposed, to its maximum.
We have a limited amount of good drinking water, and it
is being used in great quantities for non-potable purposes.
We would like to present our plan for moving forward. (1)
Continue the three year program on the wetlands recharge
and work to gain more land in the forest reserve.

Recently there was some land given to the Island
Audubon Society by Mr. Don Schrater. This land and other
tracts may be available for waterN recharge. (2) Monitor

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^ the water used on the present and new golf courses to see
how much water each is using and work with golf course
superintendents to try to maximize use of the treated waste-
water. (3) Pursue the use of a tertiary effluent for

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spray irrigation throughout Sea Pines and Shipyard, not
just use secondary but tertiary for everything.
^"1	The construction of the water mains to the five golf

^ courses provides a delivery system for spraying treated
s wastewater on landscaped areas similar to the system used

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in St. Petersburg, Florida. We1 know that great quantities
of potable water are used for these purposes, but we need
to quantify this use and see how much treated effluent coul<
be used.

(4)	We would like to install tertiary filters as
soon as possible so that the best quality water can be
provided for spray irrigation, and that any continued dis-
charge to Lawton Canal will meet limits of five milligrams
per liter for both BOD and suspended solids. This plan is
in fact one of the alternatives discussed in the EIS but
has been refused.

(5)	By providing a tertiary degree of treatment, we
would then ask to have the limits of discharge removed so
that the districts can proceed with meeting their obligatior
to serve. It is necessary to lift the limit on the amount
discharged to Lawton Canal in order to serve the vacant
lots within the already developed subdivisions and to serve
the areas presently on septic tanks. Currently in Sea
Pines there are nine hundred and six houses on septic tanks,
this is thirty-seven percent of all the houses in Sea Pines

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are still using septic tanks.

(6)	At the end of a reasonable time see if we can
accomplish a zero discharge. This is our desire, to have
a hundred percent reuse of the wastewater. We would also
like to see if County Council and Coastal Council are
able to make any progress in improving the existing water
quality in Lawton Creek and Broad Creek.

(7)	If at the end of the designated period we have
not obtained a zero discharge and if progress has been
made in eliminating the non-point pollution from the
developed areas, we would then pursue the other alternatives
that you have indicated acceptable in the EIS, We ask your
consideration in your writing the final EIS in such a way
that the program I have outlined be classified as an
acceptable alternative to EPA. Thank you.

HEARING OFFICER: Thank you, Mr. Ellison, you brought some

new information to bear as far as, the hearing is concerned.
And as I indicated earlier one of our reasons for being
here is to get all information and all comments relative
to what we have proposed into the record. I will not
comment towards your proposal at this time. That would
not be appropriate. We will comment when the final
Environmental Impact Statement is made. And we'll proceed
at that time. I will just make a side comment. You are
correct in your perception that EPA considers the non-point

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source problem at Hilton Head to be very severe and
very critical, and something it absolutely has to get
under control for the well-being of the island and all of
the people that dwell on the island.( Next let me ask
Mr. Grant Moorehouse, who is with the Hilton Head Island
Commission to please come forward and make a statement.

COMMENTS BY MR. MOOREHOUSE:

Mr. Zeller, members of your staff, ladies and gentlemen,
I'm Grant Moorehouse, member of the Hilton Head Island
Commission. I think it's a bad spot to be in, and I think
I'm the first layman on the speaker. And that's bad.

This commission recognizing that the Envirormental Impact
Statement primarily is a study of the Sea Pines Public
Service District and the Forest Beach Public Service
District, and its present and future disposal of waste-
water accepts the study on it's face value with certain
exceptions.

We feel that the study and its proposals present
environmental problems and observations and it offers
solutions which are not fully and do not fully answer
the total island's future growth and its problems. There-
fore our acceptance is one of acceptance of a study as
a tool, a beginning point to further reconsider t;he problen
presented. For example, (1) and I'm going to repeat, I think,
little bit of what has already been said, but this is our

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observation. (1) It points out the problem and the
importance of storm water runoff as a serious major problenj
but offers no real solution. And it further goes on to
state that the 208 Study which is being done must be made
adjunct to this study, and particularly as it affects the
waste, the storm water runoff and septic tank runoffs, non
point pollution. But this study isn't complete at the
present time. We have a problem putting the two of them
together to approve the whole study.

It establishes good areas for septic tank operations
with slight pollution problems. And I think it's been
brought up that forty percent of Sea Pines alone is on
septic tanks. And that the whole DHEC study of the Lawton
Canal came up with the conclusion that Mr. Ellison's waste-
water treatment plant was the cleanest water in that canal.
So it's non-point pollution, and I guess that's been said.

Its wastewater, it brings up its wastewater management
and disposal problems seemed based more upon economic
factors than upon a long-lasting impact for our future
growth. Basic observations we made of the study is (1)
the non-point pollution problem. And the study points out
that the non-point pollution problem must be controlled
before any Federal funding is available, and yet the 208
Study is not available. And in all nine options for the
Sea Pines Public Service District and the Forest Beach

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District, effluent disposal studies fail to take in that
the problem is non-point pollution problem. That the OBERS
we feel that the OBERS criteria for projected population is
nowhere near reflective of the Island trend of growth
plus tourism. It talks of fifty to sixty thousand people
k? in future years. We know there will be forty to fifty
here next month, thousand people.

It talks of Broad Creek PSD growth to a capacity of
1.2 million gallons per day in 1981 and '83, then to a
figure of 1.8 in '84, and I guess there's a new figure
of two point something in '88. And it doesn't speak to
where that effluent will go.

It talks about discharge to the sound ocean or
Port Royal fundamentally is sound. But that doesn't
resolve the non-point pollution problem at all. Further
conclusions and proposals, we feel that the non-point
pollution problem is so serious and so immediate and such
an environmental threat to the island that if the 208 Study
or not, we propose the following action: We feel that
in the septic tank area at present the only concern that
anyone has concerning septic tanks, and that's pointed out
§ in the study, is that of the owners when this backs up.
And I dare say that there are many of us here tonight who
watched it back up the last four or five days. We need to
develop a monitoring system, and further where the PSD's

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exist develop some sort of program to inspect, evaluate
these operations and then some criteria in time that these
units must go on those sewer lines, whatever those
criteria is, whether it's the years they have been in
operation, whether it's faulty operation causing leakage,
whether it's monitoring of the local lagoons, ponds,
drainage ditches or whatever. Whatever points this out
and whatever criteria can be developed must be studied
and done.

And the storm water runoff, we need to review the
status of the 208 Study now, where are they, when is it
coming, so that some conclusions can be drawn. While we
don't know of any real program of an on-going study in
this area and the United States, there have got to be
some. And we need to evaluate these, find out where they
are.

We do point out that the new DS02 Amendments will
contain requirements for developers to develop runoff syste^
to handle the first inch of water runoff. As stated before
we believe this to be the major problem.

Second problems in the effluent disposal. We finally
are	against those proposals that are submitted that

offer open water discharge in the Calibogue, Port Royal,
or the Atlantic. While the effluent may meet all the
quality standards, we submit that there are both short-

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range and long-range problems with this program. I believe
Mr. Ellison pointed them out distinctly. Open discharge
presents no curb on population growth. It encourages
development of all sorts, and should the Sea Pines Public
District and Forest Beach District receive an approval,
then all PSD's should receive approval on an equal and
fair basis.

It presents no solution to the non-point pollution
—-i problem and doesn't really take in the fact what non-

point pollution problems really are, and what that dis-
g charge is, and how much of that gets into that drainage

CO

pipe that goes into the Calibogue Sound. It has another
name, I can't think what it is. It's a drainage pipe.

It has a negative effect on the potable water usage.
One of our concerns is that the study lacks attention to
water reserves, its use, their^use, and preservation for
the future. With open water discharge as opposed to irri-
gation, spraying, flooding programs as proposed, other
^ programs that have not really been considered in the

te;

§ study, all the good water is going to go out to the sea.

to
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H And we'll continue to pump some seventy percent of the
water out of our aquafer to irrigate. Why not save that
thirty percent that's going to go out to the sea, which
is good water, and that's already been proven, to reduce
the seventy percent that's going to be pumped up.

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We are worried about the water supply, and our
most precious resource. And if you all read the Savannah
Paper on Sunday, there are serious concerns in the low
country, and in the low country of Georgia, between Savannai
and Brunswick concerning these faults.

The real program again is population growth. And our
conclusion is basically that the real population growth
s§ plus tourism far exceeds those projected in the study, and
« far exceeds projected build-out programs. And finally we

	 urge that this study and "whatever proposals are finally

adopted and implemented are not done too hurriedly. Those
who are more expert than we urge at this time, not infinitum
but at least three to five years be given to refine the
techniques that are presently being used, and to explore
the various proposals and alternative techniques that do
exist and are not covered in this study, and be a given
time to use these programs.

On one hand we recommend serious programs to eliminate
septic tank systems which are high non-point pollution
sources, yet forty percent of the Sea Pines are still on
septic. What then is the proposal? If we jump into that
sort of thing on the capacity of the Sea Pines Public
Service District to handle forty percent more waste. Plus
the effect on the flooding proposal, Mr. Ellison talked aboti
that. How fast may it be used as a partial solution. Offi-

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cials urged at least three years to consider and deter-
mine the flooding proposal as to how much or how little
this technique may be used and whether it will be success-
ful or not. What is the total effect on final irrigation
of all golf courses in the Sea Pines Public Service Dis-
trict? What's the effect of adding to that irrigation to
private residential use, medium use on 278, which DHEC
has refused to allow us to do.

Again the answer is unknown until enough time is taker
to analyze the problems and the various variables that
are involved. Therefore let us use the study as a tool and
a resource to further study and resolve the unknowns that
it presents, and to co-ordinate such results in other
phases and plans for development, building ordinances, land
use plans, population projections, Coastal Council
studies and other such as a 208 Study which are to follow.
Let's not jump before we know all of the facts, thank you.

HEARING OFFICER: Thank you, Mr. Moorehouse. We appreciate you
comments and we'll be responding to those at a later date.
This completes the summary of official speakers, as far
as their identity is concerned. And now I'd like to go
in the order of their registration and call on those
people who asked to make a statement at this hearing. The
first person that I would like to call at this time is Mr.
Manuel Holland, who is minister of the Unitarian Church

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here at Hilton Head. Mr. Holland, would you like to make

a statement? It wasn't clear to me whether you did or not,

but as you were one of the first to be registered I wanted

to ask you. The next person I would call on is Mr. M. T.

Lafitte, and please correct me if I pronounce your name

wrong. The next person who has filled out a card and asked

to be heard is Leslie Teel. Mr. Teel, I ask you to come

forward and speak from the podium so we can get your

comments in the record. (Mr. Holland and Mr. Lafitte declinec
at this time)

COMMENTS BY MR. TEEL:

Mr. Chairman, and ladies and gentlemen, before I forget
to say it, I want to say right now that I am now, always
have been and always will be one hundred percent in favor
of one hundred percent of local financing for sewage
disposal. Now I'm at a bit of a disadvantage tonight, be-
cause I have not had the opportunity to read the EIS report.
Everything that I know about what's been going on I read
in the newspaper. Of course, we all know that just once
in awhile they might make a little mistake, so you'll have
to bear with me.

Now one of the speakers this evening made reference,
before I get into that however I'd like to say that in
what I have read I have not seen any article that dealt
with just who it is that performed the EIS. I'd like to
find out, if you don't mind,was this EIS performed by some

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State or Federal Agency, or was it performed by a private
contractor, because, would .you mind enlightening me, please?

HEARING OFFICER: The EIS was done by the Environmental

Protection Agency who utilizes a private contractor for the
development of these statements. We monitor very closely
what the contractor did, and we ask the contractor to do
certain items, which he did, and which we reviewed and
developed into the report.

MR. TEEL: I see, thank you. Now reference has been made to-
night to another study that has been made. And I don't knof
to what,to just what extent this study was made from
Clemson University. I'm trying to find the name of the,

Cubett, Cubett Engineering. I redd an article in yester-
(Phonetic)

day's Island Packett it was June 22nd, an article, what
I read concerning Cubett Engineers really does concern me,
especially in light of the fact that some of the people
on the EIS and the Environmental Protection Agency of cours£
might take this thing real serious. And if y'all are going
to entertain this study, I would certainly hope that along

I

with the other reports you're going to have that maybe you
could let us know that this study is being relied on, be-
cause I'd like to point out for instance, it said that
conclusions jive, that this Cubett*s conclusions jive with
those of the EIS study team, "That the discharge of three
million gallons per day of secondarily treated wastewater



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it could ever get over to Skull Creek and Mackie Creek
to go on over into Port Royal Sound. There's no mention
of that at all, but then I found a little article that
went on to explain that. They go on down to state, there
it is, "Thus any continuously released substance will be
transported into Port Royal Sound," And therefore to
answer to how many cubic feet are going to all of these
other rivers, around where we have our oysters and other
shellfish, and shrimp and so forth, the answer to that is
according to these people that not any of it is going in
there. It's all going over to Calibogue Sound, by some
miracle it's going to get over to Calibogue Sound. When
they assimilated the water quality with and without the
sewage outfall, the results of the two simulations are
nearly identical they concluded.

I find a bit of a conflict there with what they are
saying, because if it's nearly identical, I've already said
before that it would have no effect on it at all, on the
water quality standard. But down here it says, "It's nearly
identical." Well that means it's not identical, and it's a
lead pipe cinch it's not going to be a higher water
standard if you dump this stuff in there. So what they're
saying here is it is going to lower it. That's what
South Carolina Wildlife & Game Department has said, even
though that was disputed, and they've said it time and ngair

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and have never backed down on it, and that s what other
agencies have saxd, the Coastal Council, that the water
quality would be reduced if we did it. And 1 think most
of us really and truely know this.

Only by discharging on the ebb tide could the materiafL
discharge from the outfall be advected, whatever that is,
I've got to look it up, advected predominately to the
Atlantic Ocean. Now I imagine in pointing that out it
must be something bad about dumping it into the Atlantic
Ocean. You can't put it out thereout it's all right to
put it in Calibogue and let it go over to Port Royal Sound.
I don't understand that reasoning. We don't harvest oysters
out in the Atlantic Ocean.

It said, "Still the field study and the mathematical
model simulation together convinced Cubett Engineering
that three million gallons of waste water daily would have
"No Effect" on dissolved oxygen or fecal coliform counts
in the sound and the tributaries. Well we don't have any-
body here tonight from this outfit I imagine to answer a
few questions concerning that. But I find that very diffi-
cult to believe that it wouldn't have any account in that.

Now I want to drop back on this ten thousand cubic
feet per second through Calibogue Sound on spring tide.
Spring tide doesn t come but twice a month. And then they
go on to say that continuous pumping into it because of thifij

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would cause all of it to go in the Port Royal Sound. So
I certainly do hope that if you people are going to enter-
tain any of the data that is offered by this study that
you will look at it mighty hard and mighty long and ask
an awful lot of questions- 1 mean when they put the dye in]
there, they said a little bit of it went in the Cooper
River and on to Bull Creek to the first bend. That's as
far as it's mentioned in this article about the dye. It
doesn't say anything about specific gravity or how did it
go in there. Did it go in there in a powder or was it a
liquid, and if it was what was the specific gravity of that
what was the specific gravity of Calibogue without any of
that, and what was the specific gravity of the secondary
treated sewage that they want to dump into Calibogue Sound.

So there's an awful lot of stuff to be covered with
those fellows if you're going to entertain any idea of goinfc
along with what they have had to say. Now I'd like to--I
wrote down, I just jotted down a little statement right
quick like before I came over here. And I think it's
important to say this. That it should be pointed out that
the subject this evening is of great importance to all of
the people in South Carolina in general, and the people of
Beaufort County in particular.

Now the article in this paper that I've got here said
that they hoped that the people on the Island would come out)



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because they wanted to get their opinion. Well my
gracious, there's a lot of people more on this Island
involved with this thing, because this estuary system
affects all of us. Calibogue Sound is a part of our
pristine estuary, which in turn is an important part of
our heritage. And it must not be defiled.

I've read observations by.others that ours is the onljy
pristine estuary on the East Coast of the United States.
I've sailed in and out of ports in every state from Maine
to Florida, and I believe that that is a true statement.
I'm skipping over a little bit that I've already gotten to.

I would like to deal with the idea of how much it
costs. We've heard a lot about, you know, how this thing
is going to cost if we dump it in the Calibogue Sound at
1.8 million and it might be, if you're going to have to dum^
it over there in Blufton where I live it will be twelve
million, something like that. Now that's, I don't believe
as far as I'm concerned, and I can't understand any logic
whatsoever and what in the heck cost has got to do with it,
whether or not you're going to damage the environment. Be-
cause that's the bottom line. Are we going to damage the
environment? That's what we need to protect irrespective
of what the cost is going to be.

And I notice that, unless I overlooked it, I glanced
at this report a few minutes ago, that one option was left

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out, and that's the option of pumping this stuff out to
sea.I don't know why they didn't cover that. It looks like
that would be a pretty good one to put in there. It would
be a lot more logical to pump it out to sea than it would
be to try to put it over on the mainland somewhere, because
what we've got over there on the mainland is hardpan, and
that's not going anywhere but in the May River if you put
it over there, the May River on one side and Cooper on the
other, you know, we're out on a little peninsula, a good
size peninsula.

So I'd like to, in closing, I'd like to make the
observation that as far as I can see this problem at hand,
that it's not up to the Beaufort County to go over on the
mainland and use the imminent domain and so forth that we'vj
heard. I think frankly some of these things sounded very
much like a veiled threat to me about imminent domain and
how much it's going to cost and how much more people are
going to have to pay for a place over here if they can't
dump it in Calibogue where it's going to be cheaper.

Well frankly I don't give a damn how much it costs,
you know, so long as they don't damage the environment and
damage the people, the public interest. We're really deal-
ing with something here that's very important now. We're
dealing with the public interest. And if they've got to
cut down on the development which I think they should, I wan

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over here one day trying to get to the bank and I almost
had a wreck trying to cross the road. They can't even
handle the traffic. No wonder they can't handle the sewage.
So I think it's time to come to draw the line, say all
right, if we can't handle this doggone sewage, then we're
just going to have stop bringing all of these people in
here and mess up not just Hilton Head, but the whole souther
end of Beaufort County and before long, if it goes over
there where the engineers say it's going, it's going to
be over there in Beaufort. And we're going to have them up
in the air. Thank you very much.

HEARING OFFICER: Thank you, Mr. Teel, for some interesting
comments. Let me respond very generally to some of the
things that you said. First of all, relative to the studies
that involve dyes and mathematical models, these are very,
very complex engineering studies that, and the results will
be interpreted by our engineers and scientist^ and will tel|l
us exactly what's happening to the waste that's discharged
into Calibogue Sound. And if you'd like to wait until aftet:
the hearing, I'll ask one of our staff people here that's
been involved in those studies to talk with you a little
bit more about it so that you'll understand better what wc
are doing, and what kind of results we're looking for. But
we're looking for a way to, by using dyes that are injected
into the sound and tracking it with tidal movements to see

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how an effluent if it was put out into Calibogue Sound,
which way it would go and how it would travel. And using
mathematical models we can project what water quality
might be. And these are valid studies which we have used
for many, many years, and have been very highly perfected
by our engineers to give us information on what, you know,
what may happen. I agree with you totally, the protection
of the environment is our responsibility, and that's our
first responsibility, and that's what we've addressed. But
what we've done, Mr. Teel, in the EIS is said we can protec:
the environment with this many different ways, each one of
which has a different cost attached to it. And the Federal
Law is rather specific in telling us that we must be cost
effective in terms of protecting the environment. And that
is an obligation we have to the tax payers. And I think
you would expect us to, you know, to exercise that respon-
sibility, which we try to do. But you're correct, the
first responsibility has to be, you know, for protection
of the environment and protection of water quality. And
let me say finally that we certainly meant to indicate no
veiled threats. The options that were in the EIS were
simply some things that could be done. And there are
various things that could be done. And we've heard some
other things here tonight that could be done. But I
appreciate your interest. And we're glad to have you here.

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MR. TEEL: I'd like to make a statement. This was not from
your agency. The remarks were made, and I'd like to get
my paper.

HEARING OFFICER: All right, sir, we'll let you get your paper
and I'd like to move on with the next speaker, which is
Mr. W. L. Longnecker, who is Chairman of the Island's
Concern Commission.

COMMENTS BY MR. LONGNECKER:

Thank you, Mr. Zeller. There may be some repetition as I
have heard this evening, but we; feel obliged to make this
statement. We've found that the wastewater facilities
draft very informative, and accept the report as a good
comprehensive study of the problem on the Island. 'We feel
however that a decision on the recommended options may be
premature at this time. First the report emphasizes that
the the'"non-point source problem is the most serious of
the water disposal problems on the Island to the point that
Federal funding for any wastewater project is contingent
upon the correction of non-source runoff.

The Section 208 Study which is currently being pre-
pared is expected to recommend methods to control the
non-point source pollution, and must be integrated with the
wastewater management recommendations before final decisions
should be made. Next, Island wide co-ordination of all the
wastewater management programs is recommended. There is no

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platform yet to accomplish this. It might be possible
that considerable monies could be saved and a better over-
all island management would result.

Third, having heard the proposals of the Sea Pines
Public Service District regarding a feasible program to
upgrade the wastewater to Lawton Creek from secondary to
tertiary water. I think that action justifies a delay
to allow measurement of the positive impact on the system.
The additional spray irrigation and wetland recharge pro-
posals are important options to consider. The questions
are: Which areas can be best benefited by spraying, how
much actual usage can golf courses absorb, and how much
water can selected areas and wetlands take.

If it is feasible to reuse instead of dispose of the
water, that is most desirable and the long-range saving of
the potable water for future generations is commendable.
A delay of action is normally not' an acceptable decision.
However, in this case it might be advisable to delay a
decision for a reasonable period until the related facts
are available, until more questions are answered, and until
important correlation is completed. Thank you.

HEARING OFFICER: We appreciate your statement. As I indicated
we intend to fully evaluate all of the options. The

5

Environmental Impact Statement that we're talking about her|»
tonight is in draft form. And after all of these options

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have been evaluated a final Impact Statement will be
issued. We appreciate your comments. Next I'd like to
ask Mr. Charles T. Colson, Jr. Mr. Colson, are you here?

COMMENTS BY MR. COLSON:

I'm Charles 0. Colson, Jr., I live on Myrtle Island, which
is just outside of Blufton. I live on about two acres of
land that have over three hundred foot frontage on the
May River. I vitally concerned aboiit the water. I don't
care about Hilton Head. These people can have it. I'just
don't want them messing up my environment. And the way I
look at it I could take a pinch of arsenic, put it in a
glass of water and drink it, it would kill me. I could put
a pinch of arsenic in five gallons of water and drink it,
it would probably just make me sick.

Now this is what you people want to do. Dump this
stuff in Calibogue Sound, and just make me sick instead
of killing me. And I don't agree to that. And I think the
Coastal Council and I think the Fish & Game Commission is
light years ahead of y'all in y'alls thinking.

And Mr. Cooper kept talking about government funds
for this. This is the cheapest way we'd get more government
money here. Where were you characters when I put In my
septic tank? You know, this is foolish. I don't want to
pay any money for these people over here to get rid of thef)
sewage. I don't want it in my water. And if lc cost them

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a fortune to get rid of it, that's the price they pay
for living there.

And I think it's a terrible situation. And this whole
thing to me is just full of politics and money. It smells
of sewerage.

HEARING OFFICER: Thank you, Mr. Colson. Mr. Donald Hook.

COMMENTS BY MR. HOOK:

Sir, gentlemen, I would like to report to you tonight the
comments and recommendations of the Hilton Head Island
Community Association. In this paper which you will receivj
there are recountings of history and a bit of data. In eaci
case the reference within the EIS is noted on the paper.
In addition to the people, the environment of Hilton Head
Island is its most important asset. The climate, the
land, the waters and the air all undergird the Island's
economic and social base. The high quality of this environ-
ment attracts people and their investments in homes,
businesses and vacations.

The island will remain a potent attraction so long as
it retains a high environmental policy. Our comments and
recommendations are keyed to the EIS s objective, which is
stated, "To select a wastewater management program for
Hilton Head Island that is compatible with the protections
of the areas sensitive resources, while recognizing the
existing extensive development pressures.

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The topics we will address are in order: Protection
of the areas resources, expensive development pressures,
and a wastewater management program for Hilton Head Island.

Under protection of the areas resources we have chosen
to emphasize the functions of planning and monitoring. The
importance of planning is illustrated by Sea Pines current
problems. Plans for the disposal of the effluent from
the Sea Pines two million gallons per day plant could not
in 1978 be entirely accomplished. The golf courses could
not accept the amount of effluent being produced. To
relieve the golf courses about three-quarters of the efflueri
was discharged into Lawton Canal. Thus the original plan
to use only the golf courses was only about twenty-five
percent effective. And in addition contributed to con-
taminating the waters associated with the Lawton Canal.

Continued population growth will call for continued
expansion of our sewage treatment systems. If planning
for that expansion would be no more effective than the
Sea Pines example just sited, our region will be faced with
a problem of truely an impressive magnitude as the island
and the neighboring mainland approach build-out.

Because planning involves so many complex variables,
and because no current comprehensive plan for the island
exists, and because unanticipated problems have been ex-
perienced here, we suspect that any plan will risk some

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degree of failure. To minimize that risk we recommend
that all governmental agencies charged with protecting
the areas resources approve plans for effluent disposal
before implementation is permitted.

The function of monitoring provides regulating agencies
with information on the state of our island, and indicates
the extent to which plans work out in practice. Several
monitoring programs are already in effect or are being
designed by DHEC, South Carolina Water Resources Commission
the Army Corp of Engineers and the Beaufort Jasper Water
Authority.

The EPA states that additional information is required
for the effective monitoring of our water quality. We
endorse the EPA's recommendation to develop a more exten-
sive water quality base line of the entire island so that
that exists against which to measure future water quality
changes and assess significance in changes.

We also recommend that data gathered by the various
concerned governmental agencies be routinely shared with
each other, and with the Beaufort, County Joint Planning
Commission. In addition to its other uses, the data
should be used to help determine island capacities and
thus rates and limits for construction and land use in our
region.

On the topic of extensive development pressure, much

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of Hilton Head Island's development compliments the
high quality of nature's work. Our man-made environment,
including homes and accommodations for transients and
sports facilities help to make Hilton Head Island a
desirable place to visit and to live. However, largely
because of information presented in the Joint Planning
Commission's State of the Island Report earlier this year,
the community has become acutely aware of the extent to
which development can degrade the quality of living here.
Of the burdens that we people put upon the land and the
waters.

There is deep concern that the Island's capacities
will become irreversibly overburdened. The extensive
development pressures noted in the EIS's Statement of
Purpose must not be allowed to force a decision in the
selecting of a wastewater management systems. Those
very pressures help to generate Sea Pines present dilemma
and created a problem in tine I^awton Waters, the solution
of which will probably require residents of Sea Pines
and Forest Beach to pay increased costs for no increase
in services.

The interest of Hilton Head Island's residents and
visitors will be poorly served indeed if the Island's
capacities for safe disposal are exceeded and if users
must pay for mistakes not of their own making. To help

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protect the interests of the Island's residents, visitors
and tourist industry, one, v?e support the EPA's recommenda-
tions for the development of better controls and the more
astringent enforcement of existing regulations as detailed
in the EIS under Mitigative Measures.

Two, we recommend that any plan for correcting existin;
problems or those which arise in the future, and which will
require additional financing or operating costs be cost
effective for current users. That is either no additional
charge should be made, or the additional costs should beyond
correcting the problem result in some other positive
benefit to the community. This speaks to Mr. Ellison's
re-use.

Our final segment is on a wastewater management plan
for Hilton Head Island. The Hilton Head Island Community
Association supported and continues to support South
Carolina Coastal Council's proposal that no discharge of
effluent to the surface waters around Hilton Head Island
be permitted. One concern about this method of effluent
disposal is that the precedent .thereby established at any
location would make surface watei* discharge a readily
available option for all other locations as noted in the
EIS.

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This could happen even if poor results were obtained
in the initial case on the grounds that water quality would

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not be lowered since it would have been already polluted.
The second concern stems from the mobility of effluent
in tides and currents. Should unexpected pollution or
other undesirable conditions occur, nearby areas could be
very easily affected.

Hilton Head Island itself, could be boomeranged by
its own effluent, or by others effluent similarly discharged
Thirdly, we note the sharp disagreement of other agencies
to the EPA over the acceptability of discharging effluent
to our surface waters.

When different agencies, each charged with pro-
tecting the public interest and the environment reach
such radically different conclusions, we think it prudent
to recommend against implementing a plan.

The next page, which I will not read, details some
quotations from letters in response to the South Carolina
Coastal Sound.

Disposal of effluent on land at a rate and by methods
consistent with the absorbative capacity of a disposal
site is far preferable to discharge the surface waters.
However, we believe that Hilton Head Island's problems
should be solved on Hilton Head Island. It is patently
unfair to pre-empt the use of off-island land from those
who may later require the use of that land. We agree with
the point of view for instance that Blufton should not be-

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come our septic tank.

We recommend that a site or sites on Hilton Head
Island be acquired for effluent disposal, or that other
methods and technologies be explored. Among these could
be, already mentioned this evening, irrigation of roadsides
medians and/or private property, recyling of purified
water through the potable water supply, aquifers and/or
storage tanks, and anaerobic generators.

The summary recommendation speaks to the fact that
we are geographically an entity. Socially we are an entityj
if not politically. We think that all plans for the Island
should recognize that fact. Therefore, we recommend that

Q) I	-

|| an island-wide plan for sewage treatment and disposal shoul
be created and implemented. Such a plan would help avoid
problems arising from piecemeal, unco-ordinated development
of sewage systems on the Island, would facilitate a
maintenance of standards, and would aid the cause of
orderly development.

The plan should include, A, development of an exten-
sive water quality baseline for the entire Island as re-
commended by the EIS. B, the certainment of the capacities
for effluent absorption for all areas of the Island. This
information could help to determine advisable rates in
extensive development.

C, it should include the development of better con-

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how people live and whether the island grows through
development of our environmental program.

I think it's extremely important that we look at and
consider that we're not dealing with one single option
here in terms of resolving the problem on Hilton Head.
There are many options. It depends on how we choose
to react to our people problem of what we want to do. You
can't, you know, we don't want to get ourselves locked
into a vacuum and consider there's one solution to this
problem. That's not true. We have to look at both of
the issues, and that's very, very critical. And that's
why we're here, and why we're listening to comments. The
solution to one is not necessarily the solution to the
other. And it may not turn out that way. Thank you very
much. I think you correctly addressed that problem.

Next let me ask for Bea Cheil, and I know I didn't
pronounce that right. You're going to have to correct me
on that. The secretary of the League of Women Voters,
we're very glad to have you here tonight. The League of
Women Voters is one of my favorite organizations. I'm
looking forward to hearing your comments.

COMMENTS BY MS. CHEIL:

Thank you, my name is Beatrice Cheil. And I am speaking
I am making a statement for the Hilton Head Island Members
at Large Unit of the League of Women Voters. The League

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has studied the final draft of the Environmental Impact
Analysis Statement for Hilton Head Island Wastewater
Facilities, dated February, 1982. It is our valued
judgement that none of the alternatives listed in this

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document is completely satisfactory as a solution to the
problems associated with wastewater management on the
Island. The League commends those agencies involved in
this document for their deligent and comprehensive study
thus far, but urges them to continue to seeking more
satisfactory solutions.

The League fully agrees with DHEC, that effluent
must be treated. Our recommendation is for tertiary
treatment to potable form and recycling. We are against
the discharge of treated sewage into the waters around
Hilton Head Island which may be harmful not only to Island
residents, but also to neighboring communities. There
must be some assurance that any proposal to discharge
wastewater downstream does not result in the Domino Effect
where the last property owner suffers.

No alteration of existing waterways, lagoons, ponds,
rivers, streams, et cetera, should be allowed unless a
change would Increase the filtering of the non-point run-
off, and not adversely affect the natural drainage systems
or existing water flow.

The League urges support for policies to reduce the

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non-essential part of waste streams and the recovery of
the non-reduceable portion so as to insure safe disposal
of the rest. This would preclude dumping in the areas
where shellfish harvesting and recreational fishing would
be severely affected and would result in loss of income
to many native islanders.

The section in the draft on the mitigative measures
makes it clear that there must be co-operation from Beaufort:
County. Such measures as reduction of impervious surfaces
of parking areas, on-site retention or percolation of run-
off, the use of wetlands for purification of storm water
runoff, not overloading wetlands which may harm natural
vegetation, and encouraging erosion and setimentation
control on sites adjacent to bodies of water are the areas
in which local government must act in order to lessen the
impact of population growth on the environment. The
League study of the Environmental Impact Statement raises
the question, which we ask of you respectfully. Has the
EPA ever considered the possibility and the feasibility

^ of consolidation of all public service districts and

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a independent waste and sewage companies on Hilton Head

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3 Island as an alternative. If not, then may we suggest such
a study which may reveal that the financial burden on any
one segment to the Island may be lessened, also that golf
courses which do not have available treated effluent to meet

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their irrigation needs at this time may benefit from
excess treated effluent of other areas. The mechanics
of exercising condemnation authority for land acquisition
may be simplified. Duplication of facilities and services
may be eliminated. And the problems of Hilton Head Island
wastewater disposal could be taken care of on the Island
where it originates.

At this time it appears that even the experts cannot
agree. Therefore the League cannot presume to have the
final solution. We ask only that there be further study
to seek the alternative which would assure waters that are
safe to swim in, habitable for aquatic life, free of
nuisance conditions, and usable for commercial and recrea-
tional fishing.

This we see is imperative for the health, the safety
and the economy of Hilton Head Island. Thank you.

HEARING OFFICER: Thank you very much, we appreciate your.

being here and taking the time to develop those comments.
Next I'd like to ask Carol Daly with the May River Committed
to come forward, please.

COMMENTS BY MR. DALY:



Carol Daly from the May River Committee, which was formed
because we are a group living around the river, and we're
concerned about of course the discharge of sewage into
Calibogue. We have tried to do work to be intelligent so

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that we know what we're talking about, and I'm not--I'm
going to be very brief, because if you will write to the
May River Committee, we will give you our fact sheets and
then on any item on there that you want more knowledge
about, you write to the May River Committee in Blufton,
you don't need to put a box on it, and we will get you
detailed answers for that.

I wish we could support, we're for what EPA is for,
the same as the Coastal Council and all of you, but in

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no way can we support the EIS Statement. It is loosely
reasoned. It is, there are too many woulds and shoulds,
might be and could be. And we're never going to get any-
where with that. We have to say shall, cannot, and use
words like that.

I didn't want to talk about the Cubett Engineering
Study because I haven't seen it. I know that Arnold will
send me one. But I haven't. But there are some great
concerns I have about it of which I've expressed to Arnold
a month or two ago that of all the days to do the tests, and
^ really what they're after is dispersion of the effluent.
They did it on March the 18th with the lowest current
in the whole year, 1.19 (Unintelligible).

Tonight for example, it's 2.7, I just looked it up
in the table just for the heck of it. And on a good
spring tide it's 3.3 knots. The 3.3 knots would have lots


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more dispersion. And why it was made on a flood night I
don't know because the basic way to discharge and disperse
effluent is on an ebb tide with intermittent discharge.
Intermittent discharge is a small word but it means a lot
to holding areas for the effluent and hold it there four
or five days. It's quite expensive and quite involved. I
haven't seen any note that EPA has taken that into
account, and the cost factor. But the cost factor does
not interest me because when I look at Cubbidge on the
May River unloading twenty-eight bushels of crabs in one
day and realize how many others are out there, and when
I think where those crabs are going, this is a little
ridiculous to say, but I don't think it is, they're going
up to Baltimore.

Now Chesapeake Bay is suffering badly. The crabs
are really in, well say bad shape. And maybe most of
the biologists feel that the Susqueharmah River is bringing
down what we're talking about, and which I've heard
described tonight like you could drink it, but it isn't.
There are standards of what the effluent secondarily
treated contains, and I won't go into that.

We know who live up in the marshes that it is a
giant nursery. As a matter of fact the Port Royal Sound
study which really, any of you who are interested should
get it, because it's understandable even for laymen like

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myself in the beginning, in their summaries. They call
it a national treasure, these marshes from Beaufort on
down to where we are. And they truely are. If you ever
cast a shrimp net and saw the little one inch flounders
and stripe bass, why you just can't believe what's there.

We care about it. We're really concerned and we do
not feel the EPA has given us any attention, our marsh,
we do not think so. I have heard, I think, a hundred times
about the Lawton Canal, the effluent coming from the servic£
district being purer than the Lawton Canal. I'll tell you
something, and this is no secret to anyone, any embayment,
which is the May River, there's no fresh water in it, it's
not even an estuary, you can't call it that. It accumu-
lates all the impurities, not all of them, but it accumulate
and builds, and builds and builds, because it doesn't flush
with fresh water. Now this isn't, if you want facts on it,
I'll give you those.

I was hoping that everything would be wrapped up.

(Phonetic)

We've spent so much time with working with the SAMP Plan
which we like to do it. It was great experience, and made
us feel good. So because our committee has started on this
208, now to other people in other areas we're about ten
years behind on treating the surface wasterwater, because
they are now looking to see how much is coming from the sky.
We use to not think about things like that. And this mightb

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trite. We know you need to collect like the first inch
or half inch, and then you can let the rest go, because
you've got the one with all the impurities.

There is so much to be done, but I'll assure you,
we're not going to get any place unless we make positive
statements that this is. And it's just like the best
things that happen for all of us is to forget discharging,
into Calibogue, do you know why? It will make you do some-
thing. Lots of communities, and I could name them, declare
a moratorium. It's terrible, builders and everybody, it's
terrible. But some — I think it has to, I don't, I'm not
telling you what to do on Hilton Head. Our interest really
we're off-islanders, is on the island.

The May River Committee would be so glad to work
positively. We have the facilities available to do it.
But I'm sorry, we cannot support your Environmental Impact
Statement. And we do have the great big one, too. Thank
you.

HEARING OFFICER: We appreciate your comments, Mr. Daly. And
if you will provide us the information you indicated you
have, we would be interested in reviewing it. And we'll
respond to it. Next let roe call on Palmer Simmons. Bob
Bender, who is assistant editor of the Hilton Head News.
Mr. Joel Meeker?

MR. MEEKER: I have nothing to add, sir, thank you.

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HEARING OFFICER: Mr. Robert Albright? Wheatley, Carrie or
Garrie Wheatley. Perry White, president of the Hilton
Head Chapter of the N.A.A.C.P.

COMMENTS BY MR. WHITE: Mr. Zeller, we would like to comment
the team and the study for tying the EIS to the 208 non-
point source study. After all, we feel that the non-point
source is a part of the problem and simply a product of
development that created the wastewater problems in the
first place.

Our concerns about the study are many. However, I
will confine my comments to a few points, and others will
be addressed in a letter directly to EPA.

First, we are diabolically opposedyfco any and all
options and recommendations that call for the dumping of
treated wastewater in the canals, the creeks, sounds, the
ocean, or any other body of salt water on the island, or
surrounding the island.

Our second concern deals with property outside of the
populate, outside of the plantations, and other known
planned developments. Mention is made of these areas as
it relates to the build-out population for the island. We
question how the need for sewage capacity was determined. A
further question is what will happen in the event these
areas were to be developed at a density similar to those of
other sections of the island.

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A third area of concern is the fishing industry. One
section of the study referred to it as part of black
culture. We believe that statement to be an understatement
as well as an incorrect one. The loss of this important
natural resource must have a far greater impact on the
food service industry of this island than on the few people
whoeam their livelihood by harvesting and prossessing of
seafoods.

The allusion to the industry as a black culture furthe}
points to a lack of understanding of the native islanders
by the study group and other new-comers to the island.

Many people have fought diligently to keep polluting in-
dustries from coming into our area. Why then should we
permit the socalled clean industries to pollute the waters.

A fourth concern deals with the treatment of marinas,
and pollution from boats. We consider your treatment to be
too light for the level and the type of pollution generated
from those sources. We have some questions. What effect,
if any will consolidation of all public service districts
have with the discharge of wastewater and associated problenj*
Why did the study only list privately, only list privately
owned sewage treatment plants and avoided their problems.
What do they do with wastewater? There are some observation^

First, it is apparent from the study that the avail-
ability of Federal funds is the only big stick that the EPA

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has. If so, what happens when funding is obtained from
other sources? Is it okay for privately funded sewage
treatment plants to discharge in our waters?

The second observation, the Sea Pines Company cele-
brated its twenty-fifth anniversary this week. It is the
oldest and the premiere developer on this ipland. The
company is known for its high quality development. If a
company of this caliber finds it necessary to dump its
wastewater in our creeks, what is to be expected of
developers with lesser reputations.

If development on this island has caused these
problems in twenty-five short years, what can be expected
in the next twenty-five years? What price will future
generations have to pay for our mistakes and for our grief?
Thank, you.

HEARING OFFICER: Thank you, Mr. White, for a very good state-
ment. You raised some points that we will be responding
to in the final analysis. I would make one comment to
you. We'll respond fully to all of the issues, but you
mentioned that the Federal dollars appeared to be the only
big stick involved in this program. That's not totally
true, because there are, there are other, if you will, big
sticks that can be utilized through permit programs and
other requirements that can be exercised. So dollars are
not the only answer. No matter what.dollars are utilized

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in development of waste treatment facilities, those
facilities must meet water quality requirements and
adequately protect the environment. Thank you for your
comments. Next let me ask Bob Gale, who is chairman

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of the Nancy Cathcart Group of the Siera Club.

COMMENTS BY MR. GALE:

I speak for the South Carolina State Siera Club Chapter,
as well as the local group. The Nandy Cathcart Group of
the South Carolina Siera Club strongly opposes the strategy
that the discharge of treated effluent should be allowed
into the surface waters, such as Calibogue Sound off of
Hilton Head. Our position is that no discharge of
treated effluent to the surface waters around Hilton Head
Island should be permitted.

Treated water is a resource and should be used on
Hilton Head Island, not dumped off the island. Land appli-
cation using natural infiltration techniques in wetlands,
golf courses and sports fields should be employed where
feasible. The surface waters around Hilton Head Island
are generally pristine estuarine environments.

We must not set the precedent that inland waters such
as Calibogue Sound make useful dumps for sewage or any
other material. Dumping chlorinated water in the sound
could have these adverse biological effects, one, useful
algae, the base of the marshland food chain could be killed

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Two, useful bacteria in bottom sediments could be killed.
Three, the larval stage of growth in oysters, crabs and
fin-fish could be adversely affected, thereby pyramiding
a deficit impact throughout the estuarine food web.

Large outfalls of treated wastewater would change
the serenity at the dump site. Five, entire populations
of wildlife at the dump site could be altered. Chlorine, even
at low levels has been found to be toxic to animals. New
treatment technology, such as treatment of effluent with
ultra-violet light should be employed, if possible.

Secondarily treated sewage contains nutrients that
could overload sediments with nitrogen and phosphorus. If
there are low currents at the sub-surface levels of inland
waters, this overloading could impact the aerobic anaerobic
balance of decomposition of bottom matter.

We urge EPA to investigate these effects and how well
inland waters can flush pollutants using long-term re-
search, based on firm biological and hydrological data.
Our estuaries are critical habitats too vital to all living
things here to be impacted by a short sighted easy way out
solution to an effluent problem which may very well have
innovative, useful solutions.

The solution for disposing treated effluent should
include the entire island, not just one public service dis-

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service districts should develop tertiary treatment plants
which further purify wastewater and remove nitrogen and
phosphorus. Drinking water can be produced by tertiary
treatment. This would provide a guaranteed drinking
water supply, and would conserve our dwindling ground water
reserves. Certainly recylcing drinking water from ter-
tiary treatment would be a wiser investment than pumping
water from the Savannah River, which could be further
impacted by future industrial pollution.

Wastewater can be returned to our aquatic marshes and
swamps. Here effluent is filtered by plant life and absorbed
by the spongy soil of the watershed. This process is
called natural infiltration. Other areas which could
benefit the limited irrigation of wastewater are golf
course^ lawns, sports fields, power easements, and highway
median plannings.

The Siera Club urges the EPA to reject dumping effluent
into surface waters of Hilton Head Island, and to focus on
more creative solutions to waste disposal problems, which
would involve sound biological principals and water conser-
vation techniques.

That concludes my statement, but I would like to furthex
add that the Island Community should support the Sea Pines
Public Service District for considering the many alterna-
tives that they have been looking into all along, and parti-

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cularly the tertiary treatment of effluent for reuse. And
we also think that DHEC is to be commended for its, as
I understand it it has considered allowing tertiary effluen:
to be used for irrigating medians and highway shrubbery
plannings. We support any research along those lines.

Thank you.

HEARING OFFICER: Thank you very much, Mr. Gale. I might make
a brief comment. We share your concern with regard to the
use of chlorine. I think there has been a great many well
documented scientific studies that have shown that in cer-
tain areas this can be harmful to the environment. And as
you indicated other methods such as ultra-violet are
available for disinfection and we agree with you very strong
ly on that subject, and any effort made in this regard
would probably include UV. It will certainly be a strong
factor in our consideration. Next let me ask Mr. Thomas
Barnwell. Mr. Barnwell is a shrimp fisherman.

COMMENTS BY MR. BARNWELL:

I'm not sure I can say I appreciate that, because there are
many of us here who feel that this effort of potentially
dumping the water into Port Royal Sound and Calibogue Sound
would definitely be a major detriment to the shrimp-fishing
and the seafood industry, not just of Hilton Head, but
Beaufort County area. And we're very much opposed to that.
I would like to just mention some numbers for your records.

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And these numbers are reflected in the 1979 South Carolina
statistical report that's accumulated by the South Carolina
Commercial Seafood Producers, as well as they're found
within the Statistical Bureau of DHEC. For example we
begin looking at only one year isolation, just whole fish
caught for the entire State in terms of dollar volume for
'79 was $2,643,457.00*, point eightypercent of that fish
harvest came from the Beaufort County Community.

Oysters in terms of dollar volume, 1979 statewide was
$1,279,802.00. Eighty-three percent of those oysters'
dollars was generated in Beaufort County. Crabs, whole, in
terms of dollar volume for the entire State was $1,986^,403.CjO
sixty-eight percent of those were produced in Beaufort
County. Clams, in the shell, total value for the State
;	was 463,882, and of course Beaufort County produced thir-

j	teen percent of that, and the volume is climbing. Shrimp

7	production, $20,059,406.00 worth statewide. Of that thirty-]

g	three percent was produced in Beaufort County.

9	Of the numbers that I have thrown out to you comes up

0	to a total dollar volume, $26,455,690.00. And of course,

1	you isolate the shrimp from that you get thirty-five per-

2	cent in terms of the dollars in the seafood industry you

3	can find in the Beaufort County Community alone.

4	I would like to echo extreme appreciation to Mr.

5	Perry White for his statements, and I'd like for the record

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to echo that very, very plain, it's a concern of ours
as fishermen within the area. I'd like also to make note
of the League of Women Voters comments about saving the
waters clean, not just for us alone, as persons in the
industry providing a safe food for the entire country,
not just Hilton Head Island. And, we certainly hope that
those of you who have a voice in the decision making proces s
posture into this decision that you will allow the seafood
producers of this area to continue to be an economically
viable entity in this community. Thank you.

HEARING OFFICER: Thank you, very much, Mr. Barnwell. You
have certainly demonstrated to us the importance of
Beaufort County in the State's landings and as far as
value is concerned those were some very significant numbers.
Next let me ask Mr. Emory Campbell, N.A.A.C.P.

COMMENTS BY MR. CAMPBELL:

Mr. Chairman, my comment has to do with drainage. We
believe that is was stated much too lightly in the EIS.
At one time on the island the drainage system encompassed
the entire island. In this study you've treated it as a
mitigating measure too lightly, we feel. We feel that the
original ditches that have been allowed to be closed are
now non-functional, and therefore we have many more portions
of wetlands that are really authentic on the island. The
new drainage systems that have been developed over the last

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twenty-five years only deal with those developed areas,
and therefore other areas have been allowed to become
wetlands that are not actually wetlands. Yet we know
drainage is important. And we would not want all of the
ditches opened up to flow into the rivers without any
kind of filtering.

We think that you should address the drainage system
to be designed to drain through or to the swamps and old
historic wetlands. Now we know that the 208 Study is
considering this, but an important study such as this shoulc
also address it much more heavily than it has.

We note that also the draining, I mean ditches draining,
to wetlands now might cause some other problems, but we
think wherever feasible those ditches should be reopened
and drained to those wetlands. And in order to find them
again, we urge you to consult with some old islanders who
know where they all are, so that you might find them and
include them in your study. Thank you.

HEARING OFFICER: Thank you, Mr. Campbell, that brings up an

interesting point, and one that we were talking about tonight
as we left for dinner. As we looked at flilton Head and
talked about many of the things that have happened on the
island in the last twenty-five years, as the island was
developed where certain areas were killed and certain
drainage patterns were changed, and a great many human mani-

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fesCations that are evident right now that it would be
probably very difficult to go back and really determine,
you know, what were the true wetlands on Hilton Head
Island at one time. And we believe, of course, that's
part of the problem, every time man comes in and makes
massive changes and adjustments in the way that nature is
doing things we get impacts when it rains and at other
times. Your point is well taken. I agree, I think there
is a drainage problem. And one that I think it's appro-
priate to go back and take a look at in the EIS. And if
we can address that further, we will, but your observations
are very cogent , and I thank you for it. That completes
statements from all of the people that have indicated they
wish to speak at this hearing. Is there anyone here who
has npt filled out a card to indicate he wishes to speak
or would like to speak now? Or some of the individuals who
passed earlier Chat would like to come up and make a state-
ment? If not, I'll go ahead with a few more comments and
close this hearing out.

Let me say sincerely that this is, .1 believe has been
a very good hearing. You're a very well informed public
and the comments that you have made have indicated that
you have read the Draft EIS, and you are aware of what's
been proposed, and you know what our recommendations cover.
And you've expressed some very clear thoughts and ideas on

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how you like those ideas. I appreciate that. And we
will take all of these comments into consideration. Let
me remind you again that you may submit comments until
July 9th, 1982. Now if for some reason you might need
additional time to prepare comments, you can contact me
directly and I'm generally fairly reasonable about allowing
additional time if for some reason you cannot get all of
the information within the time frame that you asked for.
But let me encourage you to try to get your comments in,
and unless I hear from anyone specifically, that comment
period will close at that time.

Now if you have comments you should send those to Mr.
E. T. Heinan with the Environmental Assessment Branch.
His name and address appears on the bottom of the agenda
that was handed out to you at the meeting. Many of you
indicated that you would be sending in final comments, you
should send those comments to that person at that address,
and all of this information will be pulled together. The

next step in this process is to develop a final environ-
mental impact statement.

I'm not sure how long that will take at this point
in time because we've got a lot of information here tonight,
and we'll simply have to have some time to review that.
Let me just say arbitrarily, Mr. Cooper, that probably in
the neighborhood of six months? HopefuUy fl00ner than chac,

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depending a lot on how things work out.

The final EIS, when it does come out, will have a
summary of the draft, and it will have all of the comments
that were brought out in light at this hearing, and EPA'a
response to those comments. Now we'll have a summary of
the new information, and we'll have a final decision from
EPA. Now there has been some new information that's been

I

brought out at this hearing, and we'll respond to that
information. It will be in the final impact statement. I
want to remind all of you again that I asked you to fill
out a card at the beginning of this hearing so you could
receive EPA's final decision. If you've done so, you will.
If you haven't, you may wish to fill out that card, so that
you'll receive that information.

Again I thank you for your presence, and I saw a hand
in the audience, do you have an additional comment you'd
like to make? If so I'd ask you to come to the podium so
that I can get it on the record.

NOTE: (Mr. Morris Campbell was mentioned as being present.)

HEARING OFFICER: We're happy to have you, Mr. Campbell. We
are pleased that you would come to our hearing. Again, if
there are no other comments to be made at this time I'm
going to declare this hearing closed, and thank you for
your attention.

END OF HEARING.

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CERTIFICATE

I hereby certify that the foregoing eighty-five pages
of typrwritten material were taken down and transcribed under
my supervision, and that the same contain a true and correct
transcript of said proceeding.

I further certify that I am a disinterested party to this
action, and that I am not of kin nor counsel to any of the
parties hereto.

This_	day of			, 1982.

CERBONE & RUCHALSKI

tUMUNU VV. KUonHuj..

Notary Public, Cluiham County,
Commission F>o|ip«	,r<<

EDMUND W. RUCHALSKI—'			

Certified Court Reporter B-538
Notary Public

/

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LISTING OF WRITTEN COMMENTS

Copies of written comments regarding the Hilton Head Draft EIS
which were received relative to the June 23, 1982 public hearing follow.
A listing of all written comments is provided below.

COMMENTER

Roger E. Davis
James H. Lee

Donald P. Schrader
N. A. Lieurance

Christopher W. Billman

Charles Gatch

Charles Golson
Melville Coburn

Colonel Dominy

H. Wayne Beam
A. P. Crouse, Jr.

Capt. J. M. Giarnese
M. T. Laffitte
L. P. Struble, Jr.
Carroll Dailey
E. J. Kusel

REPRESENTING

South Carolina DHEC

U. S. Department of the
Interior - Office of
Environmental Project Review

C and S Investments South

Broad Creek Public Service
District

Sierra Club, South Carolina
Chapter

Beaufort County Joint Planning
Commission

Citizen

Hilton Head No. 1 Public
Service District

Department of the Array
Savannah District Corps of
Engineers

South Carolina Coastal
Council

Department of the Army
Charleston District Corps
of Engineers

Department of the Air Force

Citizen

Citizen

May River Committee

Association of Sea Pines
Plantation Property Owners,

Inc.

DATE

July 9, 1982
June 29, 1982

July 8, 1982
July 8, 1982

July 12, 1982

July 7, 1982

July 7, 1982
July 6, 1982

July 7, 1982

June 17, 1982
May 14, 1982

May 12, 1982
July 6, 1982
July 1, 1982
June 28, 1982
June 28, 1982

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COMMENTER

REPRESENTING

DATE

J. Stephen Hopkins

Dr. F. S. Lisella
Nancy Ciehanski

W. L. Longnecker

W. T. Hunter

South Carolina Wildlife &
Marine Resources Department

U. S. Public Health Service

League of Women Voters,

Hilton Head Island
Members-At-Large Unit

The Hilton Head Island
Community Association, Inc.

Association of Sea Pines
Plantation Property Owners,
Island Concerns Committee

Hilton Head Island Commission

Sea Pines Public Service
District

Broad Creek Public Service
District

June 24, 1982

June 25, 1982
June 23, 1982

June 23, 1982

June 23,	1982

June 14, 1982

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SoiJh Carolina
Department of
Hea^hand
Environmenbl
Cortrol

July 9, 1982

BOARD

J. Lorin Mason, Jr., M.D., Chairman
Gerald A. Kaynard, Vice-Chairman
Leonard W. Douglas, M. D. , Secretary
Oren L. Brady, Jr.
Moses H. Clarkson, Jr.
Barbara P. Nuessle
James A. Sprulii, Jr.

COMMISSIONER
Robert S. Jackson, M.D.
¦ 2600 Bull Street
Columbia, S.C. 29201

Mr. E. T. Heinen

Chief, Environmental Assessment Branch
Environmental Protection Agency—Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365

The S. C. Department of Health and Environmental Control has reviewed

the referenced document and the comments on the enclosure were generated as a re-
sult. As you may know, this agency has been involved with this project from the
outset and has generated a significant amount of information which was utilized in
the effort. Additionally, I have enclosed a copy of the statement I read into the
record at the public hearing.

We appreciate the opportunity to provide this input, and will be avail-
able at your convenience to discuss or clarify our comments.

Re: Draft Environmental Impact Statement
Hilton Head, South Carolina

Dear Mr. Heinen:

Sincerely,

Roger E. Davis, P.E.

Assistant Deputy Commissioner
Environmental Quality Control

Attachments.

vvxm aim

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SC DHEC comments

Draft Environmental Impact Statement
Hilton Head Island

Page iii: SC DHEC established the position in discussions of Sea Pines
Public Service District consent order that priority should be given to al-
ternatives which eliminate any discharge to Lawton Canal. This position is
consistent with recommendations made to the District as early as 1970. There-
fore, we agree that the utilization of treated effluent for irrigation and
wetlands recharge should be included as a part of the selected alternatives.

(zVjPa

'	+-U y.

Issue No.1

Pafce Xlll - Kiv: We agree that Federal funding 'should be conditional upon
the development of an implementable plan to address the non-point source (NPS)
pollution. If this problem is not dealt with, no added beneficial use of the
wafprs, prpspntly closed for shellfishing, will be possible.

2

TTFlile the population projections for funding purposes have
apparently been accepted by all parties, we are convinced that the actual
population will be much higher. Therefore, either the off-island irrigation
alternative or a discharge alternative may ultimately be required unless
growth controls are implemented at the local level of government.

4.	Page II - 10 and II - 11: The use of sand mounds in areas similar to the
island has not been very successful.

5.	Page II - 13: Flow and waste-reduction measures should be more seriously
recommended. EPA should consider funding an educational/retrofit program
for the Sea Pines/Forest Beach areas.

6.	Page II - 39: Hilton Head No. PSD may encounter difficulty in gaining ap-
proval of the Federal Aviation Administration to irrigate the airport property.
The City of Aiken recently had a similar proposal rejected because of the po-
tential for attracting birds.

7« Page III - 21: Long-range planning for water supply should include con-
sideration of an off-island source.

8- Page IV - 6: The mitigative measure for the primary impac't of irrigation
on groundwater quality should be expanded to describe how application rates
could be lessened. If it is necessary to hold land in reserve for this pur-
pose, the cost should be included for the irrigation alternatives.

9. Page IV - 7: The statement that "a more active water quality role by DHEC
is required" is not clear. This should be clarified, or examples listed. (We
assume this refers to more water quality studies.)

10. "Technical Reference Document A, Environmental Inventory Task Report" should
be updated to include Amendment #2 to DHEC Consent Order 78-84-W, which limits
the allowable discharge to Lawton Canal to 1.8 mgd.

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SC DHEC COMMENTS

Draft Environmental Impact Statement
Hilton Head Island

July 16, 1982
Page 2.

Obviously, each of the alternatives for wastewater management in this
document has certain negative impacts. Recognizing that the major responsibility
of DHEC is the protection of the environment and public health, the Agency believes
that Alternative B (Calibogue Sound discharge) is the alternative which best ad-
dresses the overall problems associated with ultimate waste disposal. In addition,
this alternative is cost effective, an important fact in view of the large cost
differential of the two least cost alternatives.

Issue No. 5

Alternative D (island irrigation) could impact groundwater quality and
the non-point source pollution problem. Additionally, this alternative will very
likely not provide for ultimate development. While Alternative E (off-island ir-
rigation) could overcome the limitation on growth imposed by Alternative D, if cost
is not a factor, long-term leases could be difficult to obtain, in view of the lo-
cal opposition.

Alternative B is predicted to have minimal, possibly immeasurable, impact
on Calibogue Sound and surrounding waters, provided a well-designed and well-placed
outfall is constructed. Disinfection of the effluent will, likely be unnecessary,
which will overcome one of the major concerns expressed for this alternative. The
maximum utilization of effluent for irrigation, consistent with site limitations
should continue to be required, as proposed.

I88U& No. 5

In consideration of the environmental impact and cost effectiveness criterl
the Calibogue Sound alternative is strongly favored by DHEC.

RED/cds

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ii11.'(
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United States Department of the Interior

OFFICE OF ENVIRONMENTAL PROJECT REVIEW

Southeast Region / Suite 1384
Richard B. Russell Federal Building
75 Spring Street, S.W. / Atlanta, Ga. 30303

June 29, 1982

ER-82/813

Mr. E. T. Heirien, Chief
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365

Dear Mr. Heinen:

Co

We have reviewed the draft environmental statement, Wastewater Facilities,
Hilton Head, Beaufort County, South Carolina, and have the following
comments.

General Comments

The draft Environmental Impact Statement (EIS) addresses alternatives
for and impacts of wastewater management facilities on Hilton Head
Island, South Carolina. Hilton Head is a large barrier island mostly
devoted to resort development. Wastewater collection and treatment for
the island is principally provided by four public service districts.

With minor exceptions, mainly regarding endangered and threatened
species, we find that the statement adequately addresses impacts on fish
and wildlife resources. Several endangered .or threatened species may
occur in or adjacent to the proposed project area. To facilitate
compliance with Section 7(c) of the Endangered Species Act (Act) of
1973, as amended, Federal agencies or designated non-Federal repre-
sentatives are required to obtain from the Fish and Wildlife Service
(FWS) information concerning the possible presence of any species,
listed or proposed to be listed, which may be present in the impact area
of a proposed construction project, defined as a major Federal action
significantly affecting the quality of the human environment. This
information was furnished on request to Claude Terry and Associates,
Inc., by letter of January 7, 1981.

Section 7(c) and related regulations also require the Federal agency or
the designated non-Federal representative proposing a major Federal
action to conduct and submit to the FWS a biological assessment to
determine the effects of the proposal on listed and proposed endangered

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and threatened species. The biological assessment shall be completed
within 180 days after the date on which initiated or within a time frame
mutually agreed upon between the agency and the FWS and before initiating
the proposed action. If the biological assessment has not begun within
90 days, your agency must verify informally (via telephone) to the FWS
that the list of species obtained for the project area is still accurate.
We do not feel that we can adequately assess the effects of the proposed
action on listed and proposed endangered and threatened species or
critical habitat without a complete assessment. To date, FWS has not
received the biological assessment and the EIS does not address impacts
on endangered and threatened species. Therefore. EPA's obligation under
the Act remains unfulfilled. Correspondence regarding endangered and
threatened species should reference log number 4-2-81-054 and be addressed
to Area Manager, Fish and Wildlife Service, Plateau Building, Room A-5,
50 South French Broad Avenue, Ashevilie, North Carolina 28801.

The Bureau of Mines has no objection to the construction of the small
wastewater treatment facilities as proposed. These facilities will have
little impact on the availability of the heavy mineral resources present
on Hilton Head Island.

Extensive drilling programs conducted by the Bureau of Mines in 1954 and
National Lead Company in 1955 delineated heavy mineral deposits on
Hilton Head Island. These are described in Bulletins 26 and 35 of the
South Carolina Division of Geology. Recent aeroradioactivity studies
conducted by the U.S. Geological Survey give additional information
about the location of deposits. The final EIS should mention the
presence of these minerals. If the -construction of the wastewater
treatment facilities is believed to have no impact on heavy mineral
resources. a statement to that effect should be included in the final
EiT	—		

Specific Comments

Chapter II, D3 (pages 11-14) - This section'should be more specific
regarding the applicability of development constraints contained in the
recently passed South Carolina Coastal Council (SCCC) Hilton Head Island
Special Area Management Plan (SAMP) to the project.

Chapter II, D4 (pages 11-15) - Since under the proposed alternative, no
Federal funds would be provided for wastewater disposal unless non-point
source control measures are implemented, the third paragraph of this
jection should be expanded to read: "Recommendations from this program
[208) regarding the control of non-point source pollution must be integrated
\rith the wastewater management programs on the island in order to upgrade
ind preserve the quality of area waters and in order to qualify for
:ederal Wastewater management funding."

Chapter III, B4 (page 111-5) - In discussing impacts to aquatic systems,
;he potential impacts related to the precedent setting nature of the
;ubaqueous outfall to Calibogue Sound should be addressed.

2

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Chapter III, C (page 111-10) and CI, (page 111-16) - FWS has concerns
with the philosophy that wastewater disposal alternatives involving
surface discharges would be the lesser constraint to development. The
text in these sections implies that it would only be a matter of in-
creasing plant capacity, pumping capability and NPDES permit limitations
to expand treatment facilities. Since the assimilative capacity of
waters is finite, public trust dictates that the referenced statements
should be tempered with emphasis on the limitations as shown in Table
11-2. Also, the additional NPDES permits for increased discharges would
need further analysis to prevent excessive waste loadings.

Summary Comments

In light of the recognized adverse impacts of stormwater runoff to the
surface water quality around Hilton Head Island, we are in total concur-
rence with the preferred wastewater management alternative for the Sea
Pines PSD-Forest Beach PSD of Federal funding conditional or an effective
non-point source program being developed and implemented for the Sea
Pines PSD-Forest Beach PSD area and endangered species responsibilities
being fulfilled. Within these constraints, the document has identified
three environmentally acceptable disposal options for the Sea Pines PSD-
Forest Beach PSD. These options are discharge to Calibogue Sound, spray
irrigation on-island and off-island, and selection of the most cost-
effective, implementable alternative.

Cost estimates within the document show the discharge of secondarily
treated effluent into Calibogue Sound as being the least costly of the
three alternatives. However, it is very difficult to assign a dollar
cost to utilization of the finite assimilative capacity of public waters
or the potential long term degradation of water quality arising from the
cumulative impact due to the precedent this alternative would set.

Implementability of the Calibogue Sound alternative is highly ques-
tionable. Since writing of the draft EIS, the SCCC has passed a SAMP
for Hilton Head Island. Due to concerns'regarding the precedent-setting
nature of this discharge, and possible and probable environmental
effects to marine resources, the SAMP has adopted the policy of "No
discharge of primary or secondary treated effluent into the critical
areas of Hilton Head Island . . . Since a permit, or at least certifi-
cation, would be required through the SCCC for this discharge, it is
unlikely that the Calibogue Sound discharge alternative is implementable.
This development should be addressed in the final EIS, and EPA recommenda-
tions adjusted accordingly.

We are extremely interested in the .Sea Pines PSD controlled experimental
program for the Forest Preserve wetland discharge plan referred to ip
the draft EIS. Specific study plans for monitoring the effectiveness,
impacts and practical limits related to use of this proposed wetlands

3

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discharge system would be worthwhile to explore in the final EIS.

Thank you for the opportunity to comment on the draft enviromental
impact statement.

/ James H. Lee

' Regional Environmental Officer

/' *

4

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C and S INVESTMENTS SOUTH

P.O.Box4978 • Hilton Head Island,S.C.29928 ¦ (803)785-7501

July 8, 1982

Mr. Howard Zeller

Assistant Regional Administrator

EPA, Region IV

345 Courtland Street, N.E.

Atlanta, 6A 30365

Mr. Zeller:

I have studied the Draft E.I.S. Study Volume 1 dated December
1981, and the E.I.S. Draft dated May 1982. As a researcher for
30 years, I compliment you on design, organization, methods and
presentation.

My area of residence and property ownership is in the Sea Pines
Public Service District. It is only regarding that area that I
feel qualified to speak. Your presentation combined with the
statement of Arnold Ellison of the Sea Pines Public Service
District seem to offer a clear solution:' Ellison to pursue all
the methods he outlines and finally tertiary treatment to a
Calibogue Sound outfall as a backup position.	~

Issue No. 3

May I submit these thoughts for your consideration:

Stormwater Runoff

This is a serious problem to all of us but it is not a sewage
problem. Every developer should be required to hold at least the
first inch of run-off on site and then provide for adequate elim-
ination of excess. Already developed areas should be asked to
re-examine their situation and be required where possible to
create holding areas if current ones are inadequate.

But again this is not a sewage problem. As I understand, we are
trying to solve the problem of the SPPSD serving the people it
was empowered to serve.

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Restraint of Growth

Frequently throughout your drafts, you refer to steps that would
increase island growth as though that were a negative. We have a
County Council, a Joint Planning Commission and an Island Council
who have responsibility for orderly development of the island.
An attempt to restrict growth through denying sewer seems most
i nappropriate.

Opposi ti on

More than 13,000 people live on Hilton Head Island. Approxi-
mately 100 attended the June 23 public hearing, and maybe a dozen
spoke. Most of the speakers from these special interest groups
were against Calibogue Sound outfall, but I am sure you heard no
substantial scientific reason to support these emotional posi-
tions. It was simply a matter of, "it doesn't sound good to me."

You should not get the impression from those who spoke against
your recommendations that the island population is overwhelmingly
negative. You could just as well conclude that of 13,000 perman-
ent residents, only a dozen question the report.

You are receiving a letter from the Beaufort County Joint Plan-
ning Commission objecting to treated waste water being released
into surface water, but as the Council's dissenting vice-
president said at the meeting, "the county had no basis in fact
for its opposition."

The newly formed Island Commission is also negative to the E.I.S.
recommendations, but being unable to object on scientific basis,
sees sewer restriction as a growth control.

Hardship

It is the responsibility of the Sea Pines Public Service District
to supply water and sewage services so property owners can enjoy
their property. This we are being denied. Since 1978 our
partnership has owned 54 acres of undeveloped land between the
Forest Preserve and Sea Pines Circle. The limited allotment of
sewer in August 1981 permitted us to develop a small shopping
center on nine acres and an office building on four acres. We
also gave four acres to the Audobon Society. We can do nothing
further. Lack of sewer is denying us the use of our 36 acres.
This causes a severe economic hardship.

Summary

After lengthy, exhaustive study you have determined that
non-point source is more severe than point source pollution.

You have determined that proper discharge to Calibogue Sound
is environmentally acceptable.

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Arnold Ellison has plans that would minimize the Sound outfall
and improve the quality of effluent.

There has been no scientific opposition to your recommenda-
tions.

Additional sewage acceptance by the Sea Pines Public Service
District is urgently needed.

Your draft decisions and recommendations should become your
final report.

Si ncere,

Donald P. Schrader

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Broad Ckijek'Puuuc Service. District

POST OI I'ICK BOX G62fJ
HILTON HttAD ISLAND. S. C. 290LW

July 8, 1982

Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
Region IV

345 Courtland Street, N.E.

Atlanta, Georgia 30365

Re: Hilton Head Island, South Carolina Environmental Impact Statement
Your File No.EPA 904/9-81-091

Dear Mr. Heinen:

The purpose of this letter is to provide additional written comments during
the comment period per your notice dated April 30, 1982, open until July 9,
1982. We would like to have this conraent be made a part of the hearing
record.

First of all, we wish to specifically enumerate the past letters and pieces
of correspondence Wnich should be a part of the record in this file. These
are listed as follows,:

1.	Letter from Mr. William T. Hunter dated June 14, 1982,*

2.	Letter from Mr. William T. Hunter dated August 20, 1981;

3.	Letter from Mr. Lonnie E. Dye of Hussey, Gay & Bell on behalf
of the Broad Creek Public Service District dated June 16, 1981
and attachments.

Reference is made to your Plate 1-1 entitled Wastewater Facilities and
Disposal areas. We wish to note for the record that vfaile the location of
the vastewater facility of the Broad Creek Pliblic Service District is
correct, the disposal area is incorrect as it relates to the area immediately
surrounding the wastewater facility. That area is not inside the District's
boundaries pursuant to its enabling legislation adopted in 1972. There is an
approximate 60 acre "out parcel".

Second, reference is made to Table III-4. To the best of our belief, the
appropriate plantation dwellir^g units at build-out for the following tro
areas within the District are:

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Shelter Cove:

C\]

S§
<»

Single-family -0- ; nulti-family 1613hotel 240; coranercial-
300,000 square feet	'

Palmetto Dunes:

Single-family 1328; multi-family 3,500; hotel 1164;

Paragraph Plate III-3 entitled "Plantation Lands and Generalized Heirs
Property we note also possesses the sane potential problem with respect to
the point trentioned above. The out parcel surrounding the sewage treatment
olant approximately 60 acres, is not a part of the District nor is it part of
P&lnetto Dunes Resort. Accordingly, it might be more appropriate to have
that area "shaded" as is not part of the Plantation lands. It would be
considered part of "generalized heirs property .

py-tcthe District wishes to go on record and state that the msximuQ size
of the sewage treatment plant is presently estimated to be 2.4 mpg; however,
this size of the facility will be review^ by the District on an ongoing
basis as development takes place. In addition, the method of disposal of
treated wastewater will also be subject to a continual method of review on
a behalf 0f the District. Our position is that the South Carolina Department
3 of Health and Environmental Control should give consideration and approval to
expansion plans for the wastewater treatment facility irrespective of the
information contained in the Environmental impact Statement.

truljL^u^s,

N. A. tieurance, Chairman

Broad 'Creek Public Service District

Commission

cc: BCPSD Commissioners
Cary Criffin
Gus Bell

    -------
SIERRA CLUB South Carolina Chapter

... To explore, enjoy and preserve the nation's forests, waters. wildJi/eand wilderness .

July 12

E. T. Heinen, Chief
Environmental Assessment Branch
EPA, Region IV
3*»5 Courtland Street, N. E.

Atlanta, Georgia 30365

Dear Sir:

Enclosed please find our statement regarding the Environmental
Impact Study for Hilton Head Island wastewater facilities.

We realize that your deadline for comments was July 9; however,
we hope that our tardiness will not prevent you from reading
and considering our comments.

We thank you for your time and attention.

Sincerely,'

L.—, Uj •

Christopher W. Billman
Chairman, Conservation Committee

enc.

immm tiswm n

fri)BaEEJIL®t

q.j JUL 15 1982

K1V.-RV.G1..
ATLANTA, L...

    -------
July 7, 1982

Mr. E. T. Heinen, Chief
Environmental Assessment Branch
EPA, Region IV
345 Court!and Street, N.E.

Atlanta, GA 30365

Dear Mr. Heinen:

The Beaufort County Joint Planning Commission has reviewed the
Hilton Head Island Draft EIS and has adopted the following
recommendations regarding issues discussed in the study as part
of the Hilton Head Island Land Use Plan.

1. Although the EPA study of 1981 found acceptable
the disposal of treated effluent into surface
waters, no treated effluent should be discharged Into
the surface waters around Hilton Head Island.until an
Island-wide assessment of the environmental impacts and
water quality is made and a monitoring system is designed.





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2. Beaufort County should pursue a comprehensive Island-
wide approach to waste water treatmentand effluent
disposal and consider merging the Public Service
Districts or establishing another public agency that
serves the needs of the entire Island.

strong support for the position taken by the South Carolina Council
in the recently adopted Special Area Management Plan for Hilton Head
Island.

Regarding other matters discussed in the EIS, the following issues
were identified and recommendations made.

Shallow groundwater and surface water quality samples ta1
    -------
COMMENTS ON HILTON HEAD ISLAND E. I. S. BY NANCY CATHCART GROUP OF THE S. C.
SIERRA CLUB CHAPTER



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The Nancy Cathcart Group of the S. C. Sierra Club Chapter strongly
opposes the strategy that the discharge of treated effluent should be allowed
into the surface waters (Calibogue Sound) off Hilton Head. Our position is
that NO discharge of treated effluent to the surface waters around Hilton Head
Island should be permitted.

Treated water is a resource and should be used on Hilton Head Island,
not dumped off island. Land application — using natjural infiltration techniques
in wetlands, golf course and sports fields -- should be employed where feasible.

The surface waters around Hilton Head Island are generally pristine
estuarine environments. We must not set the precedent that inland waters (such
as Calibogue Sound) make useful dumps for sewage or any other material.

Secondarily treated sewage contains nutrients that could overload
sediments with nitrogen and phosphorous. If there are low currents at sub-
surface levels of inland waters, this overloading could impact the aerobic-
anaerobic balance of decomposition of bottom matter.

We urge E. P. A. to investigate these effects and how well inland
waters can flush pollutants using long term research based on firm biological
and hydrological data. Our estuaries are critical habitats too vital to all
living things here to be impacted by a short-sighted, easy-way-out solution
to an effluent problem which may very well have ipnovative, useful solutions.

The solution for disposing treated effluent should include the entire
island, not just one public service district. Wastewater should be recycled
island-wide. Public service districts should develop tertiary treatment plants
which further purify wastewater and remove nitrogen and phosphorous. Drinking
water can be produced by tertiary treatment. This would provide a guaranteed
drinking water supply and would conserve pur "dwindling ground water reserves.
Certainly, recycling drinking water from tertiary treatment would be a wiser
investment than pumping water from the Savannah River, which could be further
impacted by future industrial pollution.

Wastewater can be returned to our aquatic marshes and swamps. Here
effluent is filtered by plantlife and absorbed by the spongy soil of the water-
shed. This process is called "Natural Infiltration". Other areas which could
benefit from limited irrigation of wastewater are golf courses, lawns, sports
fields, power easements and highway median plantings.

The Sierra Club urges E. P. A- to reject dumping effluent into the
surface waters of Hilton Head Island and to focus on more creative solutions
to waste disposal problems which would involve sound biologic principles
and conservation techniques.

    -------
Mr. E. T. Heinen
July 7, 1982
Page 2

3, A long-term program of frequent shallow watertable
monitoring in areas relying upon septic tank systems

H should be undertaken by the Beaufort County Health

Department and Department of Health and Environmental
Control.

4. In areas served by central collection and treatment
csj systems, no new septic tank systems should be allowed or
^	old systems replaced.

^ 5. The long-term goal should be removal pf all septic tank
§ systems from the Island as central treatment systems
£ become available.

H

—With kindest regards,

CG/jl

C&drih--

	/¦* - j. _ l_	w'

Charles Gatch
Executive Director



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M JUL 13 198*

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    -------
Charl'-o P. Gohon, Jr.
P .ft. Rox
Myrtle Island
Blufr'ton, C.C. 29910

July 7, 1382

United States Environmental Protection Agency
3^5 Court land
Atlanta, Ga. 303&5

Re: Hilton Head E15 Statement

Gentlemen:

I hope you took note of the fact that at the public
hearing of the EIS, not the first developer 'from Hilton
Head addressed the meeting. I feel that the developers have
the EPA locked up in their hip pocket and did not wish to
attend the meeting and rock the boat.

It is more than obvious that you people have lost sight
of the word ENVIRONMENT in your name and should make immediate
arrangements to change it to the Developers Protective Associa-
tion of H i1 ton Head.

The marshlands are the bread basket of the food chain of
marine life. Your proposal of dumping into the sound can only
have a detrimental effect. You certainly cannot show a plus.
The South Carolina Coastal understands this much better than

On the subject of federal aid to assist dumping into the
sound, do you know that Sea Pines, as well as the other plantations,
are PRIVATE. There is a guard at every enterance and the public is
turned away. If the sewerage outfall into the sound comes to past,
it could make an interesting court case.

I have never had much cortfidence in any government bureau-
cracy and your EIS certainly bears this' out. This time you put
the money down the sewer instead of the usual rat hole.

It has been about 120 years since the last Yankee invasion
and at that time Sherman laid waste from the mountains to the sea.
V/e now have a Yankee invasion of Hilton Head and the developers
with your aid will lay waste to the ecology of this area.

you people.

CCOjL'i'*.

    -------
HILTON HEAD NO. 1 PUBLIC SERVICE DISTRICT

Industrial Park Road — Post Office Box 1264
Hilton Head Island, South Carolina 29925
Telephone 803 - 785-5525

July 6, 1982

To: E. T. Heinen, Environmental Assessment Branch
From: Hilton Head Number One Public Service District
Re: Draft EIS for Hilton Head Island, South Carolina

1. The Commissioners of the Hilton Head Number One Public Service
District ( District ) offer the following comments on the Draft
EIS for Hilton Head Island, as it relates to future planning and
development within the District:,

A.	General

The draft EIS does not adequately "...address the provision
of wastewater management facilities to serve existing and future
needs", as stated in the purpose of the EIS on page 1-1 , para-
graph 1.

B.	Population Projection

There is a large disparity between the OBERS population projec-
tion and the actual population. This; disparity impinges on the
demand for wastewater flows. In the District's case, actual flows
have already exceeded the OBERS projected flows for the year
20 00. In addition, the criteria used for the OBERS, as well as
the JPC population projection should have been presented in a
separate appendix in order that their differences may be eval-
uated, and that any assumptions uged in the projection could be
compared to the growth actually occuring on the Island, In this
way, the original projection could be updated to a more accurate
figure.

CM

OS

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S

to

N

"No Action" Alternative

The decision to present the "no action' alternative for areas
whose present population and/or wastewater flows have already
exceeded the OBERS projection is not consistant with the stated
purpose of the EIS. While these "no action" areas are no longer
eligible for federal funding, this should not preclude a dis-
cussion of the available alternatives¦for wastewater management
in order that a comprehensive assessment may be established for
the Island and be available to all Districts for their future
planning needs. As the EIS is now written, it is primarily
applicable to the Sea Pines Public Service District and is not
of value to the Island as a whole. It should be noted that in
Title 40? part 1500, (Preparation of Environmental Impact State-
ments: Guidelines, established by the Council on Environmental
Quality), Section 1500.5 (Types of actions covered by the Act),
paragraph 2 states tha't " '.actions' include but are not limited

    -------
Draft EIS for Hilton Head Island
Page Two	

to: new and continuing projects and program activities...
supported in whole or in part through federal contracts, grants,

The District is presently being funded by the EPA for
construction of new wastewater facilities; therefore, while
the District is no longer elibible, it is using federal funds
and should not be included in the "no action" alternative.

2. In conclusion, the District feels that the Draft Environmental
Impact Statement for Hilton Head Island does not adequately
describe the existing environmental conditions, nor does it ful-
fill it's stated purpose. Therefore, the District recommends that
the responsible agency re-evaluate the criteria used to develop
the EIS; re-evaluate their assesment of existing conditions;
and re-evaluate their recommendation based upon it's effect on
the future planning and development of Hilton Head Island as a
total community.

Respectfully submitted,

Melville B. Coburn
Chairman

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REPLY TO
ATTENTION OF:

DEPARTMENT OF THE ARMY

SAVANNAH DISTRICT. CORPS OF ENGINEERS
P. O. BOX 689
SAVANNAH. GEORGIA 31402

SASPD-EI

7 JUL 1982

Mr. E. T. Heinen

Chief, Environmental Assessment Branch
Environmental Protection Agency, Region IV
345 Courtland Street, N.E.

Atlanta, Georgia 30365

Dear Mr. Heinen:

Reference is made to your Notice of Public Hearing dated 30 April 1982
and the Draft EIS on Hilton Head, South Carolina Wastewater Facilities,
which was forwarded to my office by the U. S. Army Corps of Engineers,
Washington, D. C.

My comments are attached as Inclosure 1. I would appreciate the opportunity
to comment on any further actions concerning the project.

1 Incl
As stated

Copy Furnished:

USACE (DAEN-CWP-V) WASH DC 20314

    -------
COMMENTS ON HILTON HEAD WASTEWATER DEIS

Issue No. 7

Cultural Resources. Locating the sites through survey would not be adequate
mitigation. The EPA needs to indicate that they will comply with current
legislation and regulations to avoid or mitigate impacts to significant
cultural resources.

Regulatory Functions. Construction of the alternative treatment facilities
and discharge structures will likely require Department of the Army authoriza
tions. Hilton Head Island lies within the regulatory jurisdiction of the
Charleston District; review for regulatory purposes requires coordination
with SACOP-P. However, the scope and detail of a DEIS for a 201 facilities
plan is not amenable to determination of regulatory requirements.

    -------
RECEIVED JUL 1 5 1982

South Carolina Coastal Council



James M. Waddell, Jr.
Chairman

H. Wayne Beam, Ph.D
Executive Director

June 17, 1982

Mr. Charles Jeter
Environmental Protection Agency
345 Courtland Street, N.E.

Atlanta, Georgia 30365

Re: Environmental Impact Statement for
Hilton Head Island, S.C. Wastewater
Facilities

Dear Charlie:

The South Carolina Coastal Council has completed its review of the
Draft Environmental Impact Statement for Hilton Head Island, S.C. Wastewater
Facilities. Pursuant to the policies of the South Carolina Coastal Zone
Management Plan and 15 CFR Part 930: Consistency for Department of the
Interior Outer Continental Shelf Prelease Sale Activities and for Other
Federal Activities Directly Affecting the Coastal Zone, an alternative
method allowing the discharge of secondarily treated effluent into
Calibogue Sound is not consistent with the policies of the South Carolina
Coastal Council. The Hilton Head Island Special Area Management Plan
(Chapter Two, Section I, Item C) states that "no discharge of primary or
secondarily treated effluent into the critical areas of Hilton Head Island"
shall be allowed.

Whereas we do recognize that the EIS, as issued on April 30, 1982,
is still in draft form, please be advised of the Coastal Council's concern
and intentions. Should the final EIS contain this alternative in a design
which would not satisfy our consistency requirements, the Coastal Council
would be obliged to submit a negative determination at the appropriate time.

We realize the difficulties associated with providing the necessary
infrastructure to support development, however, the Coastal Council's
responsibilities as mandated by the South Carolina General Assembly, remain
directed toward the preservation and enhancement of a sound natural
environment for future generations. We appreciate your deliberations, and
look forward to working with you to bring about an acceptable solution.

Sincerely,

H. Wayne Beam

Executive Director

HWB:jnk

cc: Senator James M. Waddell, Jr.

Mr. Duncan C. Newkirk

«?rat| Center, 19 Hagocd Street. Suite 802 »	Cv-ii«v ~ W* tfe-xant

    -------
DEPARTMENT OF THE ARMY
Charleston district, corps of engineers

P O BOX 9 1 9
CHARLESTON SC 2&402

AT7CNTIOS Of

SACEN-E

14 May 1982

fir. E. T. Heinen, Chief
Environmental Assessment Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365

Dear Mr. Heinen:

Issue No. 7

We have reviewed the draft EIS for waste-water facilities at Hilton Head,
South Carolina and have no comments in connection with environmental
considerations. However, it appears that a Department of the Army permit
will be required for some of the proposed alternatives.

Should you have any questions concerning Department of the Army "permits,
please telephone Mr. A. B. Gould at (803) 724-4610.

Sincerely,

Copy furnished:

Office, Chief of Engineers
ATTN: DAEN-CWP-V
WASH DC 20314

'ARMJPrrr CROUSE
Chief, Engineering Division

Division Engineer, South Atlantic
ATTN: SADPD-R

    -------
DEPARTMENT OF THE AIR FORCE

REGIONAL CIVIL, ENGINEER, EASTERN REGION (HO AFESC)

»2C TITLE BUILDING, »0 PRVOR STREET. S.W.

ATLANTA. GEORGIA 30J03

ATTN or, R0V2

12 May 1982

tuajECT: Draft Environmental Impact Statement (DEIS), Hilton Head, South Carolina
Wastewater Facilities

to. U. S. Environmental Protection Agency
Region IV

Attn: Mr. E. T. Heinen
Chief, Environmental Assessment Branch
3I+5 Courtland Street, N. E.

Atlanta, Georgia 30365

1.	As the Air Force central point of contact for intergovernmental
coordination of environmental planning matters in Federal Regions I - IV,
we have reviewed the subject DEIS and find that development of the proposed
project will have no impact on Air Force operations in South Carolina.

2.	Thank you for the opportunity to review this DEIS. Our point of contact
is Mr. Winfred G. Dodson, FTS: 2^2-6821/6776.

Captain, USAF, Deputy Chief
Environmental Planning Division

bcolosiwl imm

^:A-P3T.''IV
1I I4KU* GA-

    -------
MONTAGUF I UCKKK l.AI l-l'ITK
MYH'fl-f: ISLAND
I'OST OFFICE BOX 161
BI.UFFTON. SOUTH CAROLINA 29910

July 6, 1982

Me. E. T. Heinan

Chief, Environmental Assessment Branch
US Environmental Protection Agency# Region IV
345 Courtland Street
Atlanta, Georgia 30365

Dear Mr. Heinan:	re: Hilton Head Island

Environmental Impact

I urge you to reconsider your Draft and recommend that no
discharge of treated effluent be allowed in Calibogue Sound.

Yours truly,

Montague T. Laffitte

MTL/kcb

    -------
L. P Strudle Jn.

3 KILLDCCR LANE
HILTON HEAD ISLAND. 8. C.
28828

July 1902

L. T. Heinan

Chief - iiiviorninental 'Assessment Branch
U. S. imviorrunental Protection Afrency

Region IV

345 Courtland Street
Atlanta, Georgia 30365

Dear Sir:

T wish to enter this statement in regard to the EIS
discussed at the Hilton Head island Elementary School
on J„ne 23, 1982.

I moved to Hilton Head Island in 1978 and one of the
chief reasons for coming here was to fully en.ioy and
exploit the marine life in the waters around the Island.

In the winter I gather oysters for my own consumption at
the Public Oyster Grounds. During the rest of the year
I fish off-shore, in-shore and in the bays and sounds.
Already these activities have been threatened by pollution.

s

I further ob.iect to discharge in our waters because there can
be no careful control on the quality of the effluent. Kech-
canical breakdown, human carelessness or outright violation
of the laws can go along unnoticed until the area waters
have been seriously polluted.

If any further permits are made for proper sewage treatment,
1 think:'they should be reserved for effluent from ^ewexs
that will replace the septic tanks on the Island. If any
capacity remains, after consideration of normal home growth,
the balance of capacity may be assigned to.multiple housing
or commercial units.

Thank you.

Very truly yours,

Partially treated effluent makes the consumption of shell
fish unhealthy and dangerous. If the effluent is treated
to the extent that it does not cause pollution of shell
fish, it will have so much chlorine and other chemicals
in it that all marine life will be endangered. Food and
breeding grounds for sea life will be ruined and eventually
we will have little or no marine life in our waters.

    -------
May River Committee

Preserve Our Estuary

Box 391, Bluffton, S.C. 29910 757-3470 and 757-3248 „

June 28, 1982

E.T.Heinen, Chief	Re: Hilton Head Island

EPA Region IV	Environmental Impact

Atlanta, Ga	Statement

Dear Mr. Heinen:

Our committee cannot support EPA's recommendation
as to discharging effluent into Calibogue Sound. You have not
provided data to support your conclusion.

Attached is our fact sheet in more detail than the
one we sent you in February. This new fact sheet elaborates on
but does not supercede our previous letter.

Our Committee will be ready by Fall to work with you
on the complex challenge of dealing with the '208' program.

Carroll 0. Dailey
for May River Committee

    -------
May River Committee

Preserve Our Estuary

Box 391, Bluffton, S.C. 29910 757-3470 and 757-3248
DATA SHEET - RE. EFFLUENT DISCHARGE INTO CALIBOGUE SOUND
The May River is merely an arm of the Sound (embayment). As
such no fresh water flushes it and thus it becomes a trap for
accumulating flotsam, DUtrients, viral, pathogens, chlorine
and whatever might be introduced to its waters. Attention
has not been by EPA in its E.I.S. draft to this potential
for pollution.

Issue No. 6

DYE STUDY

We are aware Sea Pines Public Service District has made a
study through a professional engineering firm to determine
dispersion data on effluent discharge. Since we have not
seen the report, our information is incomplete, being based
on newspaper reports. We have misgivings about this study

for reasons stated below.

Dye tests were made on Mar. -18, 1982, when,
according to NOAA current charts, the current was least for

the entire year.

It is generally accepted that discharge must be

intermittant to coordinate with the ebb tide current. The

tests were made on a 1.1 knot flood tide. (Port Royal Sound

Study of 1972 released dye on the ebb tide in the Colleton

River in an amount of 750 lbs with approximately one fifth

the volume.pf Braddock Point where 50 lbs were used.)

    -------
May River Committee

Preserve Our Estuary

Box 391, Bluffton. S.C. 29910 757-3470 and 757-3248
CURRENT INFORMATION

Maximum Currents during 1982 at Braddock Point
32°' 07.1'N 80501 W

Spring Flood 3.2 knots Spring Ebb 3.3 knots
Neap "	1.1 "	Neap " 1.9

Average Flood 2.2 "	Aver. " 2.5 "

Currents for Three Dates in	1982

June 23 Flood 2.7 knots	Ebb	3.3 knots

Mar 18 " 1.1 "	"	1.8 "

April 8 " 2.4 "	"	2.7

Generalized Information on Current Patterns

A spring flood tide entering Calibogue from the south

meets the flood tide coming down from Port Royal at the May

River mouth. The western side of this current from the south

continues without interruption into the May River. On the

easterly side of the Sound there is great turmoil where the

two flood tides meet at May River entrance. With its much

larger volume the tide from south rides over the small current

and continues to Port Royal Sound where it turns immediately

along the north shore of thg Island eastward and then southerly

along the coast.

Other Miscellaneous Data

References have been made about releasing the effluent
in deep water as a means of dispersion. There is no water
deep enough in Calibogue for such dispersion (50'-60') since
the effluent immediately rises to the surface when released
into saltwater.

    -------
ASPPPO

Association of Sea Pines Plantation Property Owners, Inc.

Post Office Box 5704
Hilton Head Island, S.C. 2993S
Telephone 785-7721

TFKMS EXPIRE

Tt l'i ujry

DjvuI M, BiKlu'ltirf
ElL>* rt G. Bellows
W. [\jLhard Cafhcarl
Ben {. Grant
Mark L. Sluppy

June 28, 1982

BOARD OF DIRECTORS

February I9S-5
Paul Freeman. Jr.

Willard ). Harm>;. Vice President
Helen C. Scott
Edward J. Kuscl. President
John |. Min^ay

ADMINISTRATOR
Woodlord Montgomery

February
Richard T. Clark
Walter L. lor\4ru\ mv
James H. Simpson. Se>.ty. Trea-
Alfred \V Wolff
John H. Wyss

Mr. E. T. Heinan

Chief, Environmental Assessment Branch
U.S. Environmental Protection Agency, Region IV
345 Courtland St.

Atlanta, GA 30365

Subject: Environmental Impact Statement
covering Hilton Head Island

Good morning, Mr. Heinan:

Issue No. 3

The Board of Directors of the Association of Sea Pines Plantation
Property Owners Association, Inc. urges the granting of an extension
to the Sea Pines Public Service District for discharge of excess treat-
ed effluent into the Lawton Canal. This extension should be for a
reasonable period of time not to exceed five (5) years. Furthermore,
the effluent must be given tertiary treatment and the Sea Pines PSD
must seek out additional on island land areas for spray irrigation in-
cluding privately owned landscaped areas, road medians, etc.

This extension will give the various agencies involved the necessary
time to determine the most cost effective method of disposing of this
excess discharge in the future. As of this date, these agencies are
not in agreement indicating there are still many questions to be an-
swered. Certainly they must await the completion of the 208 study
since storm water run off is the major pollutant to be dealt with in
a total plan for Hilton Head Island.

If the tertiary treated effluent can be used for other purposes
such as spray irrigation of privately owned landscaped areas and road
medians which now use our drinking water, we will conserve significant
founts of potable water for use by future generations.

Thank you for your consideration.

Cordially

Suite ]0, Elguin Building — 41 Bow Circle — Palmetto Bay Center

    -------
South Can illiid
Hi It/life kH Marine
Resources Department

James A. Timmerman, Jr.. Pn 0
Executive Director
Pat Ryan
Director of
Law Enforcement and Boating

J. Stephen Hopkins
Marine Resources Division
SCWMRD

P.O. Box 478

Port Royal", S.C. 29935

24 June 1982

Mr. E.T. Heinan

Chief, Environmental Assessment Branch
US Environmental Protection Agency, Region IV
345 Courtland St.

Atlanta, GA 30365

Dear Mr. Heinan,

Issue No. S

The Marine Resources Division of the S.C. Wildlife and Marine
Resources Dept. would like to issue a few comments concerning the
Draft Environmental Impact Statement for Hilton Head Island Waste-
water Facilities, Our position, with regards to the'disposal of
wastewater, has not changed since the inception of this study in
May 1979. However, the preferred alternative outlined in the draft
does not meet with our approval so we find it necessary to reiterate
our objection to the disposal of wastewater in the marine environ-
ment. This objection is based upon the adverse impacts of a number
of pollutants which one would expect to find associated with the
Sea Pines - Forest Beach PSD effluent as well as the deleterious
precedent it would set for other coastal developments. These poll-
utants include, but are not limited to, excessive levels of nutrients,
disinfecting agents, viruses, heavy metals, pesticides, BOD and fresh
water.

As mentioned in previous letters to EPA concerning this same
situation, it is feared that the nutrient load in the effluent from
the Sea Pines waste treatment facility, as well as future outfalls
from new developments, could have adverse impacts on the marine food
chain. It has been established that the species composition of the
phytoplankton community is sensitive to changes in the level of various
nutrients as well as the ratio of nitrogen:phosphate. For instance,
nutrient overloading and low N:P ratios tend to favor such species as
Nanochloris sp. and Stichoccus sp. These algae are consumed by the
American Oyster but are an inferior nutrient source. Thus, oyster
production is decreased. A decrease in oyster production will impact
upon the recreational and commercial oyster fisheries as well as the
physical characteristics of the estuary. Oyster reefs play an essen-
tial role in the formation of tide pools which are highly utilized by
a variety of organisms. In addition, oysters influence the water tur-
bidity by depositing suspended particulate matter (100 lbs. of sediment

P. O. Box 167 ~ Dutch Plaza ~ Building D ~ Columbia, South Carolina 29202 ~ Telephone: 803-758-6736

    -------
per year per square yard of reef).

Dense blooms of algae, resulting from nutrient overloading, will
also affect the biological oxygen demand. In some instances, the BOD
is intense enough to result in an oxygen depletion, killing a variety
of marine organisms and lowering total production.

The changes in the ecosystem mentioned above, while serious in
themselves, are overshadowed by a yet more damaging agent. Research
conducted.over the past few years has shown that the addition of large
quantities of chlorine to the marine environment is extremely damaging.
The best example is the Chesapeake Bay where-/the cumulative effect of
a large number of treated sewage outfalls is believed by some to be
the primary agent responsible for the declining fishery resources in
what has historically been the largest seafood producing area in the
country. The problem in that area is perceived to be so serious that
the Tidewater Administration of the state of Maryland may back a bill
in that legislature to ban all chlorinated discharges to surface waters.
The toxic affects of chlorine has been demonstrated for a large number
of marine organisms, many of which exist in Calibogue Sound and it's
tributaries. A few examples of.organisms to which chlorine is toxic
are the Rockfish or striped bass (Morone saxatilis), Spotted Seatrout
(Cynoscion nebulosus), Spot (Leiostomus xanthurus), Atlantic Siversides
(Menidia mendia), Blue Crabs (Callinectes sapidus), Mud Crabs (Panopeus
herbstii), Hermit Crabs (Pagurus longicarpus), Hard Clams (Mercenaria
mercenaria), American Oysters (Crassostrea virginica), and lower down
the food chain, a copepod (Acartia tonsa).

Several fish kills in Maryland have been attributed to chlorine
toxicity. In addition, a 1977 report to the U.S. Congress by the Comp-
troller General encouraged EPA to stop unnecessary and harmful levels
of domestic sewage chlorination. The idea of chlorinating a marine
outfall to prevent bacterial contamination of shellfish is self-defeat-
ing. As the volume of the discharge increases in response to continued
development you approach a situation where the shellfish are safe to
eat, if you can find any that are still alive. In addition, disinfect-
ing agents are not completely effective in destroying certain viruses
which may become concentrated in filter feeders.

Another adverse impact of wastewater discharges is the toxic
affects of trace metals and their geochemical deriviatives. Trace
metal contamination is often thought of as being associated with
industrial discharges. However, it has been found that trace metals
are present in fairly high concentrations in municipal wastewater
discharges as well. When freshwater polluted with "dissolved" trace
metals enter the marine system, the metals and their derivatives
are rapidly deposited in the sediment through floculation and pre-
cipitation of colloids. The toxicity of these compounds varies from
species to species. Some organisms are killed outright through ab-
sorption or ingestion. Other benthic animals and algae accumulate
the pollutants and pass them on to organisms higher up the food chain.
In this way, the trace metals may be distributed throughout the estuarine
system and later passed on to man at locations far removed from the
actual discharge pipe.

    -------
Inevitably, pesticides also make their way into municipal waste-
water discharges. The adverse effects of pesticides upon marine life
is well documented and its pathways are often similar to that of cer-
tain trace metals as discussed above.

Even the fresh water which is released via a marine discharge can
have an adverse effect on the systems total productivity. The salinity
gradients around Hilton Head are already being impacted by the increase
in runoff as a result of land use changes. An additional five million
gallons per day just stresses the system that much more. As salinities
change, stenohaline species are displaced and the species diversity
dwindles. It is just one more way in which man disrupts an ecosystem
which has evolved to make the best use of the' natural conditions. Even
if the toxic effects of many components of the discharge are overlooked,
the abrupt (in an evolutionary sense) changes resulting from water qual-
ity manipulation will result in long term productivity reductions while
the system is shifting towards a new equilibrium.

We agree with statements in the draft EIS which note that non-
point source pollution is of a greater magnitude than the point source
discharge. However, we do not agree with assertions made 'by the PSD
representatives that the Lawton Canal 'discharge is of "better" quality
than the surrounding creek water. It is "better" only in the sense
that it contains fewer col-iform bacteria as a result of heavy chlorina-
tion. Of course, the bacteria are in no way harmful to the marine life
while the discharge has a variety of components which are either toxic
or disruptive to the food chain as discussed above. While non-point
source pollutants do contain compounds which are hazardous to both
humans and marine life, their presence should not preclude efforts to
abate further degradation of the water quality through a point source
discharge.

While the Marine Resources Division is concerned only with the
protection of the marine environment, some comments relative to EPA's
apparent commitment to "cost-effective" solutions seem in order. First,
the cost projections presented in the draft EIS are too simplistic in
nature. Data has been presented on the present net worth and projected
annual user costs for the various disposal alternatives. However, no
attempt has been made to evaluate the effect of these various alterna-
tives on such things as property values, the tourist trade, commer-
cial fisheries, etcs.., Since the island's clean environment is of
paramount importance in determining the success of fisheries, tourism
and real estate investments, hedging on the costs of wastewater dis-
posal at the expense of the surrounding environment would be false
economy. In addition, your "cost-effective" solutions would result in
minor savings on the Sea Pines - Forest Beach PSD sewer bills at the
expense of all the citizens of Beaufort and Jasper Counties who util-
ize the marine resources of the area for recreation or a livelihood.
In a yet larger sense, marine resource user groups along the entire
South Carolina Coast would be forced to endure a hardship, in the form
of environmental degradation, as a result of the precedent set on
Hilton Head for marine wastewater disposal from new development.

    -------
-'1-

We strongly urge EPA to recommend that marine disposal of waste-
water be prohibited and that the present outfall in Lawton Creek be
eliminated, by whatever means, immediately. With the elimination of
the buffer zone around Lawton Creek we can begin to work on methods
of controling the non-point source pollution and, hopefully, return
all the waters around the island to the pristine state in which Sea
Pines found them, twenty-five years ago.

J. Stephen Hopkins
Regional Marine Biologist
Office of Conservation, Management
& Marketing

    -------
[jI.I'AC I Ml.N T Ol III. AL III HUMAN SI KVIC.l.S

Centors for Disease Cc".
Atlanta, Georgia 30333

(404) 262-6649

June 25, 1982

Mr. John E. Hagan, III, P.E.

Acting Chief, Environmental.Assessment Branch
Environmental Protection Agency, Region IV
345 Courtland Street, N.E.

Atlanta, Georgia 30365

Dear Mr. Hagan:

We have completed our review of the Draft Environmental Impact Statement (EIS)
for Hilton Head, South Carolina, Wastewater facilities. We are responding on
behalf of the U.S. Public Health Service.

Since water quality data have indicated that non-point source pollution from
stormwater run-off is a severe problem and may worsen, we agree that EPA
funding should be dependent upon the development of a non-point source control
program within the public service district (PSD). We note, however that
at present there is no existing authority or legislation for implementing
such a program (page IV-4). We suggest that the final statement elaborate
on steps being taken by the PSD to ensure that an appropriate agency receives
the authority necessary to implement the recommendations provided by EPA.

We have reviewed the subject EIS for potential vector-borne disease impacts
No serious vector problems are expected as a result of this project.

We appreciate the opportunity to review this draft document. Please send us
a copy of the final statement when it becomes available.

Sincerely yours,

Frank S. Lisella, Ph.D.

Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health

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6 Hummingbird Court
Hilton Head Island
South Carolina 29928
June 23, 1982



!§
8

E. T. Heinen, Chief
Environmental Assessment Branch
EPA, Region IV
3kS Cnurtland Street, N.E.

Atlanta, Georgia 30365

Dear Sir:

The Hilton Head Island members-at-large unit of the
of Women Voters has studied the final draft of the "Environmental
Impact Analysis Statement for Hilton Head Island Wastewater
Facilities", dated February 1982. It.is our value judgement
that none of the alternatives listed in this document is com-
pletely satisfactory as a solution to the problems associated
with wastewater management on the island. The League commends
those agencies involved in this document for their diligent and
comrehensive study thus far, but urges them to oontinue seeking
other, more satisfactory solutions.

The League fully agrees with DHEC that effluent must be
treated. Our recommendation is for tertiary treatment to do
lorm and reeling. ar® against the discharge of treated
.sewage into the waters around Hilton Head Island which mav k.
[harmful not only to island residents, but also to neighboring
communities. There must be assurance that any proposal to dis-
charge wastewater downstream does not result in the domino
leffect where the last property owner suffers.

No alteration of existing waterways, lagoons, ponds, rivers
streams, etc. should be allowed unless a change would inceease '
the filtering of non-point run-off and not adversely affect the
natural drainage systems or existing waterflow.

The League urges support for policies to reduce the non«
essential part of waste streams and the* recovery of the non-
reducable portion so as to ensure safe disposal of the rest.

This would preclude dumping in areas where shellfish harvesting
tthd recreational fishing would be severely affected and would

    -------
E.T. Heinen, continued

result in loss of income to many native islanders.

The section on Mitigative Measures makes it clear that
there must be cooperation by Beaufort County. Such measures
as reduction of impervious surfaces of parking areas, etc.,
on-site retention or percolation of run-off, the use of wet-
lands for purification of storm water run-off, not overloading
wetlands which may harm natural vegetation, and encouraging
erosion and sedementation controls on sites adjacent to bodies
of water, are the areas in which local government must act in
order to lessen the impact of population growth on the envi-
ronment.

<2>

s

to

i?

The League study of the Environmental Impact Statement
raises a question which we ask respectfully. Has the EPA
ever considered the possibility and feasibility of consolidation
of all the Public Service Districts and the independent Waste
And Sewage Companies on Hilton Head Island as an alternative?
If not, then may we suggest such a study which may reveal that
the financial burden on any one segment of the island may be
lessened. Also, that golf courses which do not have available
treated effluent to meet their irrigation needs at this time
may benefit from the excess treated effluent of other areas
on the island. The mechanics of exercising condemnation au-
thority for land acquisition may be simplified. Duplication
of facilities and services may be eliminated and the problems
of Hilton Head Island wastewater disposal could be taken oare
of on the island where it originates.

At this point in time it appears that even the experts
cannot agree. Therefore, the League cannot presume to have a
final solution. We ask only that there be further study to
seek the alternative which would assure waters that are safe
to swim in, habitable for acquatic life, free of nuisance
conditions, and usable for commercial and recreational fishing.
This is imperative for the health, safety, and economy of this
island.

Yours truly,

'Wancy Ann Ciehanski, President
Hilton Island MAL Unit,

League of Women Voters

Above presented before a Public Hearing on June 23, 1982
at the Hilton Head Elementary School by
Beatrice P. Chait, Hilton Head Island Unit - Secretary

    -------
COMMENTS AND RECOMMENDATIONS
for

U.S. ENVIRONMENTAL PROTECTION AGENCY'S

DRAFT ENVIRONMENTAL IMPACT STATEMENT
FOR HILTON HEAD ISLANDSOUTH CAROLINA
As presented for Public Hearing on June 23, 1982.

Submitted by

THE HILTON HEAD ISLAND COMMUNITY ASSOCIATION, INC.

June 23, 1982

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u!;conni:i;DATiot;s

Any plan for disposing of effluent generated on Hilton
Head Island should be approved by all governmental
agencies charged with protecting the area's environment.

Approval should be based on evidence from preliminary
on-site tests, and/or implementation of the plan at
other similar locations, demonstrating that the plan
will have negligible, adverse effects^ on the environ-
ment .

Such approval should be required for plans to correct
existing problems, or to increase the capacity of an
existing system, or to install a new system.

Any plan for disposing of.effluent should be cost-

effective for current users in the area to be served.

a.	The plan should not risk creating a problem the
solution of which would require additional '
capital investment or increased operating costs.

b.	The plan should not risk creating problems which
would affect other areas.

c.	If the plan is to correct a problem resulting
from system design or installation, either no
cost should be imposed on current users, or the
plan should return to the area a benefit other
than the problem's correction.

An island-wide plan for sewage treatment and disposal
should be created and implemented. Such a plan would
help avoid problems arising from piecemeal, uncoor-
dinated development of sewage systems on the island
would facilitate the maintenance of standards and '
would aid the cause of orderly development. '

The plan should include:

a.	Development of an extensive water quality baseline
for the entire island, as recommended by the EIS

b.	Ascertainment of the capacities for effluent
absorption for all areas of the island This
information could help to determine advisable
rates and extents of developments.

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KirO.'iMEHUATlOHS (conI. )

Island-wide plan, (cont.)

c.	Study, or restudy of disposal sites and methods
other than presented in the EIS. These might
include:

(1)	Irrigation of roadsides, medians and/or
private property.

(2)	Recycling of purified water through the
potable water supply via aquifers and/or
storage tanks.

(3)	Anaerobic generators.

d.	The development of better controls and/or more
stringent enforcement of existing regulations,
as recommended by the EIS. (111-20, IV-6)

e.	Encouragement, to the extent possible, of water
conservation techniques by public and private
water users, as recommended by the EIS. (II-6)

Vigorous pursuit of regulation and correction of non
point source pollution. This would include the
continued development of techniques as well as
development of regulation and enforcement procedures

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COMMENTS

In addition to the people, the environment oi Hilton Head
Island is its most important asset. The climate, the land,
the waters and the air all undergird the island's economic
and social base.

The high quality of this environment attracts people and
their investments in homes, businesses and vacations. The
island will remain a potent attraction so long as it retains
a high environmental quality.

Our comments and recommendations are keyed to the EIS's
objective, which is "to select a wastewater management pro-
gram of Hilton Head Island that is compatible with the
protection of the area's sensitive resources, particularly
water quality, while recognizing the existing extensive
development pressures." (xiv, D)

The topics we address are, in order.

1.	Protection of the area's resources.

2.	Extensive development pressures.

3.	A wastewater management program for HHI,

-3-

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rkovi.e'i'j o;j of the area • s hkhoui.cls
Planning and Monitor a ncj

The importance of planning is illustrated by Sea Pines'
current problems.

Plans for the disposal of effluent from the Sea Pines 2.0
MGD plan could not, in 1978, be entirely accomplished; the
golf courses could not accept the amount of effluent being
produced. To relieve the golf courses, about 3/4 of the
effluent was discharged into Lawton Canal. (III-J-12) Thus
the original plan, to use only the 'golf courses, was only
about 25% effective and, in addition contributed to contami-
nating the waters associated with the Lawton Canal. (II-7)

Continued population growth will call for continued expan-
sion of our sewage treatment systems. If planning for that
expansion is no more effective than the Sea Pines example
just cited, our region will be faced with a problem of truly
impressive magnitude as the island and the neighboring main-
land approach buildout.

Because planning involves so many complex variables, because
no comprehensive plan exists, and because unanticipated
problems have been experienced here, we suspect that any
plan will risk some degree of failure. To minimize that
risk, we recommend that all governmental agencies charged
with protecting the area's resources approve plans for
effluent dinposa] before implementation is permitted.

- 4-

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Monitor i ihj provides regulating cicjoncios w.i Lh information
on thn i;tate of our island, and indicates tho extent to
which plans work out in practice. Several monitoring
programs are already in effect or are being designed by
DHEC, S.C. Water Resources Commission, the Army Corps of
Engineers, and the Beaufort-Jasper Water'.Authority.

The EPA states that additional information is required for
the effective monitoring of our water quality. We endorse
the EPA's recommendation to develop a more extensive
water quality baseline of the entire island so that data
exist against which to measure future water quality changes
and assess significance of changes. (IV-7)

We also recommend that data gathered by DHEC, SCCC, EPA,
Rural Water Authority, S.C. Water Resources Commission,
the Army Corps of Engineers and similar agencies be
routinely shared with each other, and with the Beaufort
County Joint Planning Commission.

In addition to its other uses, the data should be used to
help determine island capacities, and thus rates and limits
for construction and land use in our region.

-5-

    -------
LXTK.ns]vl; ;;EV»:i.oi»Mj:r:'r puF.sistiKK.j;

Much of Hilton Head Island's development complements the
high quality of nature's work. Our man-made environment,
including homes, accommodations for transients, and
sports facilities, help to make Hilton Head Island a
desirable place to visit and to live-

However, particularly because of information presented
in the Joint Planning Commission's State of the Island
Report, the community has become mpre acutely aware of
the extent to which development can degrade the quality
of living here, of the burdens that people put upon the
land and the waters. There is deep concern that.the
island's capacities will become irreversibly overburdened.

The "existing extensive development pressures" noted in
the EIS's statement of purpose must not be allowed to
force a decision in the selecting of a wastewater manage-
ment system. Those very pressures helped to generate
Sea Pines' present dilemma, and created a problem, the
solution of which will probably require residents of Sea
Pines and Forest Beach districts to pay increased costs
for no increase in services, (viii)

-6-

    -------
The interests of Hilton Head Inland's residents and
visitors will be poorly served if the island's capacities
for safe disposal are exceeded, and if users must pay for
mistakes not of their own making.

To help protect the interests of the islana s residents,

visitors, and tourist industry:

1.	We support the EPA's recommendations for the
development of better controls, and the more
stringent enforcement of existing regulations

as detailed in the EIS under "Mitigative Measures".

(111-20 et seq, IV-5 et seq)

2.	We. recommend that any plan for correcting existing
problems or those which arise in the future, and
which will require additional financing or
operating costs, be cost-effective for current
users. That is, either no additional charge should
be made, or the additional cost should, beyond
correcting the problem(s), result in positive
benefits to the community.

-7-

    -------
a wASvn-w.TKK	pi,an koh miltoi! iikau isla:::j

The Hilton Head Island Community /association supported,
and continues to support South Carolina Coastal Council's
proposal that no discharge of effluent to the surface waters
around Hilton Head Island be permitted.

One concern about this method of effluent disposal is that
the precedent thereby established at any location would
make surface water discharge a readily—available option
for all other locations. This could happen even if poor
results occurred in the initial case, on the grounds that
water quality would not be lowered since it would have
been already polluted.

A second concern stems from the mobility in tides and
currents. Should unexpected pollution or other undesirable
conditions occur, nearby areas would be very easily
affected. Hilton Head Island itself could be "boomeranged"
by its own, or by others' effluent similarly discharged.

Thirdly, we note the sharp disagreement of other agencies
with EPA over the acceptability of discharging effluent
to our surface waters. When different agencies, each
charged with protecting public interests in the environment
reach such radically different conclusions, we think it
prudent to recommend against implementing a plan.

-8-

    -------
The follov/inq quotations illustrate opposition to surface
water discharge of effluent. The statements are from
responses to the draft of South Carolina Coastal Council'
Special Area Management Plan for Hilton Head Island, datei
February 8, 1982. With regard to effluent, the Plan

recommended that:

"No discharge of treated effluent to the
surface waters around Hilton Head Island
should be permitted."

"Any solution for the disposal of treated
effluent should be comprehensive and should
include the entire island.

Responses to those recommendations included the following;

"The recommendations offered by the Coastal
Council in reference to both the discharge
of treated effluent and non-point source
runoff should be accepted and put into
effect as soon as possible.

Charles M. Bearden
S.C. Wildlife &. Marine
Resources Department
(letter of 3/12/82)

"The National Marine Fisheries^vice fully
supports the concepts put forth in this plan
for the protection of the resources on and

around Hiiton Head	™e" J™/™,,

extremely important to fishery resource^, ana
are quite fragile due to development pressures.

D. R. Ekberg

ii <5 Department of Commerce
(letter of 2/22/82)

-9-

    -------
o: c •' f 1 ucnt o r. land, at a rate and by riot hods
consistent with the: absorptive capacity of the disposal
site, is far preferable to discharge to surface waters.

However, we believe that Hilton Head Island's problems
should be solved on Hilton Head Island. It is patently
unfair to pre-empt the use of off-island land from those
who may later require the use of that land. We agree with
the point of view, for instance, that Bluffton should not
become our septic tank.

We recommend that a site, or sites on Hilton Head Island
be acquired for effluent disposal, or that other methods
and technologies be explored. Among these could be:

1.	Irrigation of roadsides, medians and/or
private property.

2.	Recycling of purified water through the
potable water supply via aquifers and/or
storage tanks.

3.	Anaerobic generators.

-10-

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June V.S,

Public Hearing on Environmental Impact Statement
regarding Wastewater Facilities for Hilton Head Island

W.L. Longnecker - Chairman, Island Concerns Committee;
Association of Sea Pines Plantation Property Owners

We found the wastewater facilities draft very informative and
accept the report as a good, comprehensive study of the problem on the
Island. We feel, however, that a decision on the recommended options
may be premature at this time.

Tnnue No. 1

First, the report emphasizes that the non-point source problem is the
most serious of the water disposal problems on this Island, to the point
that Federal Funding for any wastewater project is contingent upon the
correction of non-source runoff. The Section 208 study which is currently
being prepared is expected to recommend methods to control the non-point
source pollution and must be.integrated with the wastewater management re-
commendations before final decisions should be made.

Next, Island-wide coordination of all the wastewater management
programs is recommended. There is no platform yet to accomplish this. It

might be possible that considerable monies could be saved, and a better

u +. Issue No. 9
overall Island management would resuxc. u—	

Third, having heard the proposals of the Sea Pines Public Service
District regarding the feasible program to upgrade the wastewater to
Lawton creek from secondary to tertiary water, I think that action justifi
a delay to allow measurement of the positive impact on,the system.

The additional spray irrigation and wetland recharge proposals are
important options to consider. The questions are which areas can be best

    -------
-2-

benefited by spraying; how much actual usage can golf courses absorb;
and how much water can selected areas and wetlands take? If it is
feasible to reuse instead of dispose of the water, that is most
desirable and the long range saving of the potable water for future
generations is commendable.

Issue No. 4

A delay of action is normally not an acceptable decision. However,
in this case it might be advisable to delay a decision for a reasonable
period until the related facts are available; until more questions are
answered; and until important correlation is completed.

    -------
HILTON HEAD ISLAND COMMISSION

POSITION PAPER - ENVIRONMENTAL IMPACT STUDY

This Commission, recognising that the EIS primarily is
a study of the Sea Pines Public Service District and its pre-
sent and future disposal of waste water, accepts the study
on its "face value" with certain exceptions. We feel that
the study and its proposals present environmental problems
and observations and offer solutions which do not fully answer
the total Island's future growth. Therefore, our acceptance
is one of acceptance of the study as a tool, a beginning point,
to further reconsider the problems presented. For example:

1.	It points out the problem and importance of storm
water-run off as serious, but offers no real solutions.

2.	The same concerning septic tank operations with re-
spect to non-point pollution.

3.	Establishes "good areas" for septic tank operation...
..-."Slight" pollutant problems.

4.	States that the 208 Studymust be adjunct to this
study, particularily the septic tank operations - but
this study is not completed at the present time.

5.	Its waste water management and disposal proposals
seemed based more upon economic factors, than upon long
lasting impact.

6.	It lacks serious treatment of the effect of waste
water disposal proposals on present potable water supply.

Basic observations of Study:

The non point pollution problem.

-	Study points out that non point problem sources must be
controlled before Federal funding is available.

All nine (9) options for SPPSD effluent disposal fail
to take on the problem of non-point pollution.

-	That the 208 Study concerning effective management practices
to abate non point pollution, is to be an adjunct to the EIS.

-	That the OBERS criteria for projected population is, not
reflective of the Island trend-plus tourism.

Issue No. 2

-	Broad Creek PSD growth to a capacity of~TTTTIjg^~~nT~l981 -
1983, then to a figure of 1.8 mpd in 1984. Where will this
effluent go?

-	Discharge to the Sound, Ocean or Port Royal - fundamentally
sound, but does not resolve non-point pollution problem.

The septic tank operations and failures given minor/cursorv
rH snussion. A main NPP problem?	"

Issue No. 11

- 1 -

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CONCLUSION - .'KOi'OiJALS:

1. The I-.'on point pollution problem is the most serious,
immediate environmental threat to the Island. 208 study
or not we propose the following:

a)	Septic tanks -

At present, the only concern is that of Owners
when system backs up. Need to develope a monitoring
system and further, where PSD exists, develope program
to inspect, evaluate operations, then criteria for
time these units must go on line, (i.e. - years in
operation, faulty operation causing leakage or non
point pollution of adjoining/adjacent waters, etc.).

b)	Storm Water Runoff -

Need to review status of 208 study. While we
know of no real program on-going in the U.S., there
must be some. Evaluate these. We point out that
the DSO amendments will contain requirements -for de-
velopers to develope run-off systems to handle the
first inch of water run off. As stated, we believe
this to be the major problem.

2. Effluent Disposal. Finally we are against those pro-
posals submitted, that offer open waters discharge into
Calibogue, Port Royal or the Atlantic. While the effluent
may meet all quality standards, we submit there are both
short-range and long-range problems.

a)	Open discharge presents no curb on population
growth. Encourages development and should SPPSP receive
such approval, then PSD's all can.

b)	Presents again no solution to NPP.

c)	Has a negative effect on potable water usage.

One of our concerns, the study lacks attention to
our water reserves, their use and preservation. With
open water discharge, as opposed to irrigation, spraying,
flooding programs as proposed, all the good water
goes out to Sea and we will continue to pump some
70% for irrigation purposes as presently. Waste water
totals up to be 30% of water pumped. Why not save
30% of the 70% now being used for irrigation purposes.
Use for spray, golf irrigation, residential, farm,
business, industrial use, etc. -

*31

The real problem is again - population growth. Our conclu-
sion is basically that the rea1 population, growth, plus tourism,
far exceeds those projected in the study and far exceeds projected
build out programs.

- 2 -

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Finally, we urge that this study and whatever proposals
adopted, not be implemented too hurriedly. Those who are more
expert than we urge that time, not adinfinitum but 3-5 years
be given to refine the various proposals and explore alternative
techniques that exists and are not considered in the study.
On one hand we recommend serious programs to eliminate septic
systems which are high non point pollution sources. Forty
(40%) percent of Sea Pines is still on. septic. What then,
is the effect on the SPPSD capacity should we dash into this
proposal without further thought? What is the effect of the
"flooding" proposal? How fast may it be used as a partial
solution? SPPSD officials urge at least three years to determim
how much, or how little this technique may be used. What is
the total effect on final irrigation of all golf courses in
the SPPSD? Again, the answer is unknown until enough time
is taken to analyse the variables.

Therefore, let us use this Study as a tool, a resource,
to further study and resolve the unknowns it presents and
to coordinate such results in all phases for development -
building ordinances, land use plans, population projections,
Coastal Council studies, and others to follow.

- 3 -

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COMMENTS ON HILTON HEAD ISLAND ENVIRONMENTAL
IMPACT STATEMENT PRESENTED AT PUBLIC HEARING
ON JUNE 23, 1982

The Draft Environmental Impact Statement has considered a number
of alternatives for wastewater disposal. Through your review process
the list was narrowed down to five for which costs ranging from
$1.8 million to about $15 million were identified. These were:

Capital Cost

1.	Lawton Canal Discharge w/Tertiary Effluent	$ 1.77 million

2.	Calibogue Sound Discharge w/Secondary Effluent $ 2.03 million

*

3.	Rapid Infiltration w/Secondary Effluent	$ 7.86 million

4.	Spray Irrigation on HHI w/Secondary Effluent $14.93 million

5.	spray Irrigation off HHI w/Secondary Effluent $13.83 million
During the three £lus years that the EIS has been in process,

the sea Pines Public Service District has continued to seek its
own ways to use and dispose of the treated wastewater. Some of

our efforts include:

1.	continued spray irrigation on the Club Course and Shipyard Golf
Courses, and to construct new lines to spray irrigate the Ocean,
Sea Marsh, Harbour Town and the new nine hole course in Shipyard.
This will provide spray irrigation on Sh golf courses—all that
are located within the Sea Pines and Forest Beach Public Service

Districts.

2.	Gained approval for pumping treated wastewater to the Forest
Preserve to re-establish a wetland. A three-year program will
be conducted to determine the quantity of water this wetland

    -------
can accommodate. We will be pumping 600,000 GPD the first year,
1.0 MGD the second year and 1.5 MGD the third year.

We have conducted a study on the dispersion and environmental
impact of a secondary effluent introduced to deep water at the
southern tip of Hilton Head Island. We hope that we will never
have to construct an outfall in Calibogue Sound, but we have
felt the need to evaluate this alternative to a greater degree

than you have in the EIS.

Cubit Engineering from Clemson, South Carolina, performed
the study in March of this year and their report has been made
available to the EPA staff. The etudy has determined that there
would be no adverse impact on the environment from a 3 MGD dis~
charge at the southern tip of Hilton Head Island. In fact there
would be no change in background concentrations of any of the
parameters.

We have moved ahead with a treatment plant expansion that include
an environmentally sound method of sludge disposal. We will
be injecting the sludge into a sand media located at the treatmer
plant that has an underdrain collection system. The water remove
from the sludge will be pumped back to the treatment plant and
the sludge mixed with the sand will provide a top soil that
can be used for landscaping yards and flower gardens.

We have investigated actions taken by other communities in reusi'
treated wastewater. St. Petersburg, Florida, has treated their
wastewater with tertiary filters and disinfected to a degree
that health officials are satisfied that viruses have been kiHe<

    -------
- 3 -

This process allows the City to use treated wastewater for
spray irrigation of golf courses/ parks/ road shoulders and
medians, and landscaping of individual yards as well as for

fire protection.

results of this EIS have significant importance to the Sea
Pines and Forest Beach Public Service Districts. In 1978 the Districts
received an order from the State Department of Health and Environmental
Control (DHEC) that required a study of wastewater disposal alterna-
tives. The EIS became that study. Within 90 days of the EIS com-
pletion, the District must submit an engineering report detailing
the concept for implementation of the. selected alternative. Within
270 days of approval of the engineering report, the District must
submit plans and specifications for construction of the facilities.
The facilities must then be constructed in accordance with a schedule
developed by DHEC. If the study is finalized as presented, we will
have no choice but to pursue the Sound discharge alternative.

There are a number of items in the draft EIS that give concern

to the District:

1. The draft indicates that some of the alternatives for effluent

disposal will allow the unbridled development of the Island.

• i pout an? service will only cause developers
We contend that denial of sewage service	jr	r

,. _ fro3<"pd wastewater on the Mainland*
to seek ways to dispose treatea

r3/-*n<=>. The added costs will then
This is in fact already being done. *»«	

_ r ¦hn hp built to cover the increased
cause a higher number of units	—		

cost of sewage t~..™nt and disposal. The limits on development
densities should be handled by local ordinance and are presently
being pursued by the JPC and Beaufort County Council.

    -------
The removal of the present outfall from Lawton Canal will not
open any of the closed shellfish areas. Water in the Lawton
Creek, Point Comfort Creek and portions of Broad Creek do not
presently meet SA standards because of runoff pollution. We
realize there would have to be a buffer zone for any outfall
from a treatment plant, but this buffer .zone falls between two
other buffer zones—those for Harbour Town and Palmetto Bay
Marina.

Federal funding for -any of the selected alternatives would be
limited to that portion of the work required to eliminate the
present outfall. This funding wotald be used to assist present
customers and would not be used for plant expansions for new
development.

The EIS, however, prohibits any Federal funding unless a
storm water runoff program is implemented for Sea Pines and
Forest Beach. Neither Public Service District has authority
to work in this area and it is questionable as to the program
that could be implemented. I say this because all work done
by the 208 study and by the Coastal Council, as well as the
JPC's development standard ordinance, deals with runoff for
new development. None of these seem to have a solution for
runoff pollution for developed areas such as Sea Pines and Forest
Beach.

We raise the question: Does EPA have a suggested program
for controlling or treating runoff from developed areas? If
you were given the responsibility to stop contamination of oyster
beds, what reasonable action would be taken?

    -------
- 5 -
Issue No. 4

The Sea Pines and Forest Beach Public Service Districts feel
there is considerable study still needed to insure that treated
wastewater is used to its maximum. We have a limited amount of
good drinking water and it is being used in great quantities for

non-potable purposes.

Our plan is to do the following:

1.	Continue the three-year program on the wetlands recharge and
work to gain more land in the Forest Preserve. Recently there
was some land given to the Island Audubon Society by Mr. Don
Schrader. This land and other tracts may be available for water

recharge.

2.	Monitor the water used on the present and new golf courses to
see how much water each is using and work with golf course super-
intendents to try to maximize use of the treated wastewater.

3.	Pursue the use of tertiary effluent for spray irrigation through-
	out Sea Pines and Shipyard. The construction of water mains

to the five golf courses provides a delivery system for spraying

5§

treated wastewater on landscaped areas similar to the system

3

^ used in St. Petersburg, Florida. We know "that great quantities
of potable water are used for these purposes, but we need to
quantify this use and see how much treated effluent could be used.

4.	We would like to install tertiary filters as soon as possible
so that the best quality water can be provided for spray irri-
gation, and that any continued discharge to Lawton Canal will
meet limits of 5 mg/1 for both BOD and suspended, solids. This
plan is in fact one of the alternatives discussed in the EIS.

    -------
- (> -

5. By providing a tertiary degree of treatment, we would then ask
to have the limits of discharge removed so that the Districts
can proceed with meeting their obligations to serve.

It is necessary to lift the limit on the amount discharged
to Lawton Canal in order to serve the vacant lots within the
developed subdivisions and to serve the areas presently on septic
tanks. (Currently there are 906 houses in Sea Pines still on
septic tanks or 37% of all houses in Sea Pines.)

6.	At the end of a reasonable time, see if we can accomplish a
zero discharge. This is our desire—to have a 100% reuse of
the wastewater. We would also like to see if County Council

and the Coastal Council are able to make any progress in improvin
the existing water quality in Lawton Creek and Broad Creek.

7.	If at the end of the designated period we have not obtained

a zero discharge and if progress has been made in eliminating
the non-point pollution from the developed areas, we would then
pursue the other alternatives allowed in the EIS.

We ask your consideration in writing the final EIS in such a
way that the program I have outlined be classed as an acceptable
alternative to EPA.

    -------
Commissioners

Newton A. Lieurance, Sr.
Chairmen
Leslie M. Bernick
Robert E. Huber

Carl H. Lind
James L. Rowe

Broad Creek
Public Service District

P.O. Box 5628
Hilton Head Island, South Carolina 29938

June 14, 1982

803-785-1104
William T. Hunt«r
Manager

Mr. E. T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
Region IV

345 Courtland Street, N.E.
Atlanta, Georgia 30365

RE: HILTON HEAD ISLAND, SOUTH CAROLINA
ENVIRONMENTAL IMPACT STATEMENT

Dear Mr. Heinen:







Issue No. 2



Issue No. 9



We have previously expressed deep concern with the population
and flow projections contained in the Draft Environmental Impact
Statement (EIS) and we herewith reiterate that concern. We
fully realize that the OBERS-based population projections must
be used to evaluate alternatives. However, by so doing, considera-
tion of alternatives for the majority of the Island has been
almost totally disregarded. In essence, the EIS presents an in-
depth study of alternatives for the two public service districts
which provide service for approximately thirty percent of the Island
But these two districts presently have about fifty percent of the
Island's population and also have the most critical wastewater
treatment and disposal problems. However, it seems incomprehensible
that potential problems and solutions for the remaining seventy per-
cent of the Island would be so blatantly disregarded by using popula>
tion data that is obviously erroenous. If, as purported, the EIS
is applicable to the entire Island, alternatives available to all
PSD1s and Non-PSD areas should be evaluated and the preferred alter-
native (s) described.

Attached hereto are copies of previous correspondence, none of which
has been acknowledged by EPA but all of which express our concerns
about the EIS.

Very truly yours,

B^OAD CRE13K PUBLIC SERVICE DISTRICT

William T. Hunter

Manager

WTH:eh
Enclosures

    -------
Commissioners
Zack J. Van Landlngham
Chairman
Carl H. Und
Newton A. Lieurance. Sr.

Broad Creek
Public Service District

P.O. Box 5628
Hilton Head Island, South Carolina 29938

MX

803-785-1104
William T. Hunter
Managar

August 20, 1981

Mr. Charles Jeter, Regional Administrator
Environmental Protection Agency
Department of Natural Resources
Region IV

345 Courtland Street, N.E.

Atlanta, Georgia 30308

RE: HILTON HEAD ISLAND

ENVIRONMENTAL IMPACT STATEMENT

Dear Mr. Jeter:

Issue No. 2

On several occasions within the past nine months, Broad Creek
Public Service District has expressed its deep concern with
the population and flow projections contained in the Environ-
mental Impact Statement. The question was asked of Mr. Robert
Cooper on December 9, 1980, if the projections shown in the
EIS would be interpreted as being limitations. Mr. Cooper con-
firmed that the OBERS population projections are utilized in
allocating EPA funds and funds will not be granted to any project
if the actual populations is in excess of the OBERS population.

The EIS indicates that the peak monthly average flows for the
year 2000 for Broad Creek Public Service District based on
OBERS is 0.64 MGD.

This value is extremely low inasmuch as the actual peak monthly
flows at the Broad Creek Public Service District Plant are
approaching 0.6 MGD at this time. As a matter of record the
South Carolina Department.of Health of Environmental Control has
issued a conditional construction permit to the District to double
the capacity of the treatment plant to 1.2 MGD. This contract has
been awarded, construction has started and will be completed by
April 1, 1982.

Undoubtedly some of the other public service district of Hilton
Head will also be experiencing this same situation. This places
everyone at the distinct economic disadvantage because it precludes
the potential of receiving EPA Grant Funds to offset part of the
construction costs. Inasmuch as the OBERS population is obviously
incorrect because the actual population and flows will in 1983 exceed
the PBERS population projection for the year 2000, it is respectfully
requested that EPA review this information and take whatever steps as

    -------
Mr. Charles Jeter
Page two
August 20, 1981

The District is also very disturbed by the connotation of "no
action" in the Draft EIS. Broad Creek Public Service District
has a history of providing wastewater treatment facilities IN
anvanrF nf the need thereby precluding the discharge of effluent
not^in accordance with. ^Department of Health and Environmental
fontrol standards. Unlike others, we take pride in providing
adequate capacity before it is needed rather than waiting until
plant capacity is SSSiided before starting «e therefore object
to any inference that no action is being taken and respectfully
request that this terminology be corrected.

Very truly yours,

BROAD CREEK PUBLIC SERVICE DISTRICT

\ V

'~\ \YJU

„/Vw \

William T. Hunter
Manager'

WTH:eh

cc: BCPSD Commissioners
Hussey, Gay & Bell
Cary Griffin

    -------
June 16, 1981



i§

Q)
3
CO

H

Mr. Robert Cooper
Environmental Protection Agency
EIS Project

345 Courtland Street, N.E.
Atlanta, Georgia 30308	

RE: BROAD CREEK PUBLIC SERVICE DISTRICT
HILTON HEAD ISLAND, SOUTH CAROLINA

Dear Mr. Cooper:

Enclosed is a copy of the 10-year plan as adopted by the
Commissioners of the Broad Creek Public Service District.
This plan indicates the projected population and capital
improvement projects necessary to provide services to the
area within the public service district.

As have mentioned to you on several occasions, the
District is particularly concerned about the population
and flow projections contained in the EIS. In addition,
we are concerned about the various effluent disposal
alternatives which are being evaluated for Broad Creek
Public Service District and for other districts on the
island.

In a recent article in the "Island Packet" we noticed that
the .draft EIS has been submitted to the EPA and is under
review. We would appreciate very much the opportunity to
discuss this draft with you and will be happy to arrange
to meet you in your Atlanta office. We would also re-
quest that Ms. Louise B. Franklin and Mr. D. Randolph
Grubbs be requested to attend this meeting in order that
we could have the benefit of their input.

    -------
Mr. Robert Cooper
June 16/ 1981
Page 2

Please let us know when it would be convenient to meet
with you.

Sincerely,

LONNIE E. DYE, P.E.

LED/jdt

cc: Mr. Bill Hunter
Mr. Mike Jordan
Ms. Louise B. Franklin
Mr. D. Randolph Grubbs

Enclosure

    -------
Commissioners
Zack J. Van Landlngham
Chairman
Carl H. Llnd
Ntwion A. Uavranca, Sr.

Broad Creek
Public Service District

P.O. Box 5628
Hilton Head Island, South Carolina 29938

803-785-110
William T. Hunt
Managar

TO:

FROM:
DATE:
SUBJECT:

Distribution
William T, Hunter
May 5, 1981
TEN YEAR PLAN

Enclosed is the final plan which has been modified to include
some capital imput from Hussey, Gay & Bell.

The important points to consider while digesting this are:

Units. The master plan for the Zone II property has not been
developed; therefore, the number of units included (1,560) was
an "off the wall" guess.

Timing. The timing of developing property for sale or for
improvements on existing lots is pure conjecture at this time.

We followed a consistant ten year plan which resulted in 100%
developed and improved property by 1991.

This is a sliding scale control and by slowing down or speeding
up will affect expansion and income accordingly.

Dollars. All income and expenses are shown in today's dollars
with no consideration given for inflation. At best we would hope
that they (income and expense) would offset each other.

Debt. No provision was given for additional debt but the amount
to be funded is evidenced by the accumulative negative cash positic
in years 1982 thru 1988.

Replacement. $75,000 per year has been set aside for replacing
existing facilities. This is an arbitrary amount and could easily
be double this.

    -------
Operating Expenses. We show a nominal increase each year of
-50,000. Over the ten year period this would result in dmihi,™
the 1981 operating costs.	doubling

WTHseh

Distribution: Zack J. VanLandingham

Newton A. Lieurance, Sr.

Carl H. Lind

Gus Bell

Lonnie Dye

Cary Griffin

William T. Hunter

    -------
BROAD CREEK PUBLIC SERVICE DISTRICT
USAGE/REVENUE
April 30, 1931

Single Family

Fixed - 95 units @ $20 per month

Metered - 149 units @ $25 (average) per month

$ 22,800 Annual
$ 44,760 Annual

New homes are being processed at ten per month. For this
projection we will use 100 units per year tapping into the
system.

Availability - 767 units @ $108
Total Single Family

As of November 1, 1981 everyone will be metered and
the user income will increase in most instances.

At 12/31/81 we should have the following inventory:

295 Metered hours @ $25 per month

30 Under construction

686 Unimproved

1,011 Total

$ 82,836
$ 150,336

$ 88,500 Annual

lulti-Family

Fixed - 589 units @ $20 per month
Metered - 380 units @ $25 per month

Under construction - 128 units

At 12/31/81 we will have 1,097 metered condominiums
1,097 @ $25 per month

Commercial

$ 141,360 Annua!

114 ,000
$ 255,360

$ 329,100 Annua

Present billings average $150,000 per year but next year we
have deleted the PDR irrigation of Queen's Folly -- about $6,000
The fixed charge to Outdoor Resorts has been deleted also.

    -------
SUMMARY

The annual billing as of January	1, 1981:
Single Family

Metered	$ 88,500

Availability	74,100

$ 162,600

Multi-Family

Metered	$ 329,100

Commercial	§ 150,000

Millage	$ 38,000

Total	$ 679*,700

User revenue includes 1,392 units 8 $5 (excess) x 12 months » $ 83,520

    -------
NEW CUSTOMERS

Single Family

One-third of the applications have been for the Inverness
Section. Based upon 75 completed houses per year, we would
experience the following:

Units	Amount	Cost Per Tap

*

Mariner	50	$750	$1,000

Inverness	25	$750	$ 100

75

Summary:

Revenue - 75 @	$750 $ 56,250
Costs

50 8 $1,000	50,000

25 0 $100	2,500

$ 52,500

Net Income	$ 3,750

Actually with the build-up starting to happen in Mariner,
we are now experiencing houses being constructed next to
existing homes; herefore, tapping into'existing tanks
with only about $100 costs.

Multi-Family

The master plan is not complete for the Zone II property
and we cannot determine the yearly or ultimate building
rate.

Zone III- Marina property along the west side of Highway 278
will probably experience the following:

1400 multi-family units over a 7-10 year period.
Construction will start in 1981 and should result in
at least 140 units connecting each year.

Following the density/available property thesis in Zone III,
we could realize the following:

Total acres	430

Golf course	150

Other	20

Net acres	260

    -------
Density - sixty an acre =1,560 units

Over a ten—year period will result in 156 units per year.

Summary 296 units per year

Commercial

There should be no commercial in Zone II, but there are
plans for 300,000 square feet of commerciai/retail/office
in the Marina property.

Developed over a five-year period will result in 60,000
square feet being completed each year.

Other

No consideration has been given to expansion of District
boundries to the north or south.

It is assumed that the present Long Cove customers will be
transferred to Sea Pines PSD before the next fiscal year.

However, there are some out parcels which are completely
surrounded by BCPSD and we should include them in our
contingency plans.

EGR Property - 3h acres - 26,000 square feet retail
Mr. Mack	- 1*5 acres - unknown

Washington Tract - 50 acres - ^ppJyin;LaQn»ablf_acres
*	factor of 90% - 45 acres

and a density of six to the

acr6 would result in 270 units,

Summary of ultimate build-out.

Present property owners	amily

^	1,097 multi-family

„ TT	1,560 multi-family

Zone III	1-/400 multi-family

Total	5,06 8 units

Commercial

Present - one 360 room hotel

40,000 square feet commercial

Addition - one 324 room hotel
300,000 square feet

Other

"26,000 square feet

rTA	*

    -------
i-iay ^ / , x 3 O X

PALMETTO DUNES RESORT
ZONE II
Undeveloped

Tract

AC

Type

Density
Per Acre

Total
Units

GPD
Unit

Total
Flow

1

4.7

Villas

12

56

300

16,800

2

6.7

Villas

12

81

300

24,300

3

4.0

Beach Club

—

—

—

10,000

4

6.5

Villas

12

78

300

23,400

5

6.4

Villas

12

77

300

23,100

6

7.8

Villas

12

94

300

28,200

7

9.6

Villas

12

115

300

34,500

8

12.2

Restaurant
Hotel

600

34 0 Room

34 0 Room

50
100

30,000
34,400

9

11.6

Villas

8

93

300

27,900

10

6.15

Villas

8

49

300

14,700

11

5.2

Villas

8

42

300

12,600

12

4.4

Villas

8

35

300

10,500

13

1.6

Residential

—

8

300

2,400

14

3.35

Lots

—

17

400

6,800

15

16.9

Lots

—

45

400

18,800

16

4.6

Lots

—

12

400

4,800

17

3.35

Lots

—

8

400

3,200

18

10.4

Lots

—

24

400

9,600

19

7.2

Lots

—

19

400

7,600

20

5.0

Lots

i—

24

400

9,600

21

8.9

Office/Park

w —



400

20,000

875

372,000

    -------
USAGE

(1) Present Demands

1,392 units 0 350
Hotel/Commercial

487,200 gallons daily
100,000

Total Present

587,200

Reserve

716 unimproved lots 8 350
Total Committed

250,600

837,800 gallons

Proposed Construction

(2) G.E. Parcel
Mariner Inn

{3) Marina Site (Zone III)
1,614 units
300,000 Square Feet
Total Zone II
Total known committment

(4) Zone II

877 units

100,000
100.000
200,000

454,500
157,100
611,600
1,627,800

372,000

(5) Non-District

Commercial
270 units 0 350

10,000
94,500
104,500

Total potential capacity required - 2,125,900 gallons per 4ay.

    -------
Pod

1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

May 27, l&bl

PALMETTO DUNES RESORT
ZONE III

Description

Residential

Residential

Yacht Club

Residential

Residential

Residential

Residential/Commercial

Residential/Commercial

Residential/Commercial

Racquet Club

Bank

Transportation Hub
Post Office.

Tour Bus Depot
Island Villa Rentals
Chamber of Commerce
Commercial
Restaurant

Residential/Commercial

Residential

Residential

Mall-Commercial

Bandshell

Church

Church

Residential

Commercial

Commercial

Commercial

Racquet Club

Bazaar

Residential

Residential

Maintenance

Marina Spoil Area

Residential

Service Center

Commercial

Restaurant

P.D.R. Signage

1 BR. 2 BR. 3 BR.
units units units
no. no. no.

28

240
16
20
15

8
28

38

64
58

21

112
52

68
38'

20
24
20

16
125
59

79

123
58

45

12
10

100
11

13

35
50

TOTAL FLOW

536 839 239
107,200 251,700 95,600

Commercial

4 ,800

2,500
2,840
1,900
22,500
200
500
500
150
500
250
4,600
21,500
1,640

16,000
0

1,050
1,200

4,000
6, 600
3,200
25,000
1,000

1,500
0

3,600
4,600
25,000
0

157,130
157,130

Total 611,630 gallons
Total	1.614 «*¦*•?+• a

    -------
.• ' i«r»' y" I *. -»• •; •,|H'

Ct•• t i.\v.i i ¦ M.r a.>

May 18, 1981

Mr. Robert Cooper
Environmental Protection Agency
E1S Project
345 Courtland Street
Atlanta, Georgia 30365

BROAD CREEK PUBLIC SERVICE DISTRICT
Hilton Head Island, S.C.

CVJ

!§
a

CO

i®

H

Dear Mr. Cooper:

Ias we discussed on May 4th, the Broad Creek Public Service
[District is very much interested in the E1S for Hilton Head
Island. The District is particularly concerned about the
(population and flow projections contained in the E1S. In
{additionwe are concerned about the various effluent dis-
posal alternatives which are being evaluated for BCPSD and
cor other districts on the Island.

On behalf of the District, we respectfully request an
opportunity to discuss the draft E1S at the earliest possible
date in your office. Please let us know when we can meet.

Yours/Jvery truly,

LONNIE E. DYE
gdg

cc: Bill Hunter - BCPSD
Mike Jordan
Claude Terry & Assoc.

Gannett, Fleming, Corddry & 'Carpenter

    -------
Commissioners

Zack J. Van Landingham
Chairman
Carl H, Lind
Newton A. Lieurance, Sr.

Broad Creek
Public Service District

P.O. Box 5628
Hilton Head Island, South Carolina 29938

June 11, 1981

803-785-1104

William T. Hunter
Manager

Mr. Lonnie Dye
Hussey, Gay & Bell
P. 0. Box 14247
Savannah, Georgia 31406

Dear Lonnie:

Regarding the next set of documents 2nd meetings to be set
up by ESI/EPA, we still feel that it is imperative to present
them with correct and current data.

Mike Jordan and I feel that a face to face meeting with the
people involved would be necessary and important but at least
you should submit to them the Ten Year Plan as adopted by the
District.

This would verify our dispute with their low estimate of users
and required flows. In addition, we want to go on record as
stating our position concerning the ability to dispose of
effluent with the same options they are recording for the other
Districts on the Island.

Thank you.

Very truly yours,

BROAD CREEK PUBLIC SERVICE DISTRICT

( v \\

'..V :vv\

William T. Hunter
Manager

WTHreh

cc: R. C. Onorato
Gus Bell
Cary Griffin
Mike Jordan

    -------
CHAPTER V
EIS COORDINATION

    -------
CHAPTER V - EIS COORDINATION

PART A. INTRODUCTION

Public participation programs are mandated by Federal Regulations
governing the preparation of Environmental Impact Statements. Public
participation is an important and valuable part of the EIS process
because it provides for active public involvement in developing and
evaluating wastewater management programs.

At the beginning of the Hilton Head Island EIS, a public partici-
pation program was established to provide opportunities for interested
groups/individuals, and government agencies to participate in the
development of the EIS. A Review Committee was established to serve
in an advisory capacity to EPA and their consultants through a series
of committee meetings held during the EIS preparation. In addition,
two public meetings and a public hearing were held at various stages
in the process, a£d interested agencies and groups were asked to comment
on the Draft EIS.

A complete list of the agencies and interest groups who were
involved in the public participation program is presented below.

PART B. AGENCIES AND GROUPS

Public Agency

Beaufort County Council

Beaufort County Joint Planning Commission

Department of the Air Force

Department of the Army Charleston District Corps of Engineers
Department of the Army Savannah District Corps of Engineers
Hilton Head Island Commission
Low Country COG
S. C. Coastal Council

S. C. Dept. of Health S Environmental Control

S. C. DHEC, Shellfish Division

S. C. Wildlife § Marine Resources Department

U. S. Department of the Interior - Office of Environmental Project Reviev
U. S. Public Health Service

Public Service Districts

Broad Creek PSD
Forest Beach PSD
Hilton Head No. 1 PSD
Sea Pines PSD

    -------
Homeowners Associations

Association of Land Owners of Port Royal Plantation
Association of Sea Pines Plantation Property Owners, Island Concerns
Committee

Association of Sea Pines Plantation Property Owners, Inc.

Forest Beach Community Association

Palmetto Dunes Property Owners Association

Shipyard Plantation Property Owners Association

Spanish Wells Property Association

The Hilton Head Island Community Association, Inc.

Private Groups
Audubon Society

Beaufort/Jasper County Comprehensive Health Program

League of Women Voters, Hilton Head Island Members-At-Large Unit

May River Committee

N.A.A.C.P., Hilton Head Chapter

Hilton Head Fishing Cooperative

Shellfish Interests

Sierra Club, Nancy Cathcart Group

Sierra Club, South Carolina Chapter

Developers

C and S Investments South
Heritage Properties
Hilton Head Company
Hilton Head Plantation
Palmetto Dunes Resort
Sea Pines Plantation Company

Trade Associations and Business Groups

Chamber of Commerce

Council of Architects

Hilton Head Hospitality Association

Home Builders Association

Private Citizens

Thomas Barnwell
Emory Campbell
Charles Go1son
M. T. Laffitte
L. P. Struble, Jr.
Leslie Teal

V-2

    -------
CHAPTER VI
LIST OF PREPARERS

    -------
CHAPTER VI - LIST OF PREPARERS

Project Personnel

U. S. Environmental Protection Agency
Robert B. Howard
Robert C. Cooper
William J. Patton

Chief, EIS Preparation Section
EIS Project Officer

Chief, S.C./Tenn. Facilities Planning Section

Consultants

Gannett Fleming Corddry and Carpenter, Inc.

Thomas M. Rachford	Senior Project Manager

D. Randolph Grubbs	Project Manager

L. Edward Stom	Project Engineer

Kenneth E. Vinson	Assistant Project Engineer
Paul Andre DeGeorges
John W. Jacobs

Environmental Scientist
Environmental Scientist

Claude Terry & Associates, Inc.
Claude E. Terry
Louise B. Franklin

Robert J. Hunter
Thomas C. Mather

Project Executive

Project Manager,
Environmental Planner

Environmental Scientist

Environmental Scientist

VI-1

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APPENDIX A. SOUTH CAROLINA COASTAL COUNCIL - HILTON HEAD
ISLAND SPECIAL AREA MANAGEMENT PLAN

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Special Area Management Plan

for

Hilton Head Island

South Carolina Coastal Council

1982

ENVIRONMENTAL IMPACT STATEMENT
BRANCH

ar?nn nr? -

MAY 12 1982

iiD\snns

REGION IV • EPA

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HILTON HEAD ISLAND SPECIAL AREA MANAGEMENT PLAN

April 23, 1982

South Carolina Coastal Council

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Table of Contents

Page

Chapter One - Introduction . 				 1

Chapter Two - Water Quality 	 ......	2

I. Treated Effluent Disposal		 .	2

A.	Issues				2

B.	Existing Policies, Rules and Regulations 	 .	3

C.	Management Policies 	 ...	4

II. Storm Water Runoff 		4

A.	Issues ........ 	 .....	4

B.	Existing Policies, Rules and Regulations 		5

C.	Management Policies 			6

Chapter Three - Tidal Wetlands				7

A.	Issues 	 ........ 		7

B.	Existing Policies, Rules and Regulations . 			8

C.	Management Policies			14

Chapter Four - Freshwater Wetlands 			16

A.	Issues				16

B.	Existing Policies, Rules and Regulations 		19

C.	Management Policies 			20

Chapter Five - Beaches and Dunes 		21

A.	Issues				21

B.	Existing Policies, Rules and Regulations 	 ...	22

C.	Management Policies		25

Chapter Six - Public Access				26

A.	Issues		Z6

B.	Existing Policies, Rules and Regulations 	 ...	26

C.	Management Policies				27

Chapter Seven - Cultural Resources					28

A.	Issues					28

B.	Existing Policies, Rules and Regulations ........	28

C.	Management Policies					30

Appendix A - Recommended Strategies for Storm Water Management
Appendix B - Maps (to be printed at a later date)

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CHAPTER ONE

Introduction

Hilton Head Island is recognized internationally for its unique barrier
island environment that provides the atmosphere for a variety of recreational
activities. That Hilton Head Island plays a major economic role in the state's
tourism industry, is of important significance. Its importance to the local
economy is also obvious. However, in recent years the predictable rush to
maximize the development potential of the island has caused concern over long
term implications for the natural environment, public resources, and the
stability of its economy.

The current year round average population is approximately 14,000.

Current peak population counts, however, surpass 40,000. According to local
and regional estimates, those figures will increase to 35,000 and 100,000
respectively as parcels that are already master planned develop. Considering
the large tracts of land that are not currently master planned, the development
potential of those areas, predictions for a "buildout" scenario are 70,000 and
150,000 respectively. Certainly a number of unknowns could affect these
estimates, but based upon the best available information and current economic
trends, they are not unrealistic.

Current population and development has created an assortment and varying
degrees of environmental problems. It should follow that multiplication of
these figures buy two or three times will compound any existing problems unless
some mitigating measures are implemented. It is on the basis of these
assumptions that the following policies are established by the South Carolina
Coastal Council in the form of a Special Area Management Plan for Hilton Head
Island. These Policies pertain only to new projects or the expansion and
significant alteration of existing projects and activities.

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CHAPTER TWO

Water Quality

I. The discharge of treated savage into the surface waters of Hilton Head
Island.

A. ISSUE: The discharge of treated sewage is currently, and will

continue to be, an issue for developers and residents on Hilton Head
Island. A preliminary draft of the Hilton Head Island, S. C.
Environmental Impact Statement has approved three alternatives for
discharge: 1) land application on Hi Leon Head Island, 2) land
application off the island, and 3) discharge into Calibogue Sound.
The EIS addresses only the needs of the Sea Pines PSD.

Discharge into Calibogue Sound has four primary points for
discussion.

1.	Where (depth, tidal flushing, etc.)

2.	Method (discharge $ treatment)

3.	How much (gallons per day, limited, unlimited or none)

4.	How long (temporary solution or permanent)

While all of the above points are important, determining hew
much, if any, discharge is probably the critical point. First, it is
the consensus of the staff that limiting the amount of discharge may
be possible for a short-term period; however, the demand by other
PSD's may be too difficult to withstand once the precedent for the
island is set. This precedent could certainly involve Port Royal
Sound in subsequent years. The EIS does not investigate a solution
for an island-wide problem, but does pose serious implications for
inevitable demand.

Second, the disposal of treated effluent into Class SA waters
may set a dangerous precedent. The pressure to discharge sewage
effluent along the coast continues to grow. It should be noted that
surface-water discharge is, in most cases, the least expensive method
and thus attractive to most large-scale developments.

Third, there are existing and accepted practices, philosophies,
ana guidelines that should be considered when reviewing this problem.
References to the Clean Water Act and its objectives should be
considered. Existing South Carolina Coastal Management Program
policies should be considered (.see existing policies section :or a
detailed discussion). Past Coastal Council actions should be
considered (e.g., Carolina Water Service application to discharge
into the Stcno *iver). Finally, consideration should be given to the
possible, and probable, environmental effects to marine resources
"(e.g., shellfish, etc.), to include assessment of cumulative impacts.

2

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3. feriatin* Policies. ^uleg. Regulations, and "Stata of the Arcs"
M-namgs:

m-tnt* 1 TMft-nt Plan (III-35, 1 d) Wastewater discharges
shoula be locate* waere uiey pose che least ecological threat - in
areas where disruption or wetlands can be avoided, in areas with good
tidal flushing, and along water courses with relatively low water
quality classification.

rn«ra7 \fena«s«nt Plan (III-30) Other than actual location of
facilities m sensitive tueas, the major negative impact associated
vith sewage treataent systems is the potential water quality
degradation from effluent discharge.

Mmuemt Plan CIXI-SX, 1 a) Swage treataent
fadliaea ana crausmsiiui "systsoa «ust meet applicaole federal,
stats and local wear quality standards.


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Secondarily treated effluent also contains nutrients such as
nitrogen and phosphorus that serve as limiting factors for primary
producers. Subtle changes in concentrations of these nutrients cam
result in changes of types of primary producers, causing shifts in the
species composition and abundance of the entire estuarine community.

C. Policies

1.	No discharge of primary or secondarily treated effluent into the
critical areas of Hilton Head Island. This recommendation does not
preclude the evaluation of ocean discharge or any other innovative
technologies found to be acceptable by the South Carolina Coastal
Council. In the event that an ocean discharge is found to be
acceptable, the S. C. Coastal Council will consider the location of
the discharge at the most appropriate location.

2.	Any method of effluent disposal, other than land application on the
island, will be evaluated on the basis of a comprehensive island-wide
solution to the short and long term requirements of Hilton Head Island
and the surrounding natural systems.

3.	In view of the critical future potable water requirements for Hilton
Head Island, and the fact that little information is now available
concerning present use, quantity and quality of the existing ground
water, the S. C. Coastal Council recommends that the appropriate
parties undertake comprehensive studies to determine the quantity and
quality of potable water resources for Hilton Head Island to
accommodate future growth predictions.

II. The discharge of storm water runoff into the surface waters of Hilton
Head Island.

A. ISSUE: The most serious existing threat to the surface water quality
around Hilton Head Island is from storm water runoff or, as it is
often referred to, nonpoint-source pollution. Without exception, the
volume and substance of this discharge is a function of development,
especially in a rapidly urbanizing area like Hilton Head Island.

While general water quality on the island is not a major problem at
this time, there are significant "trouble spots" on the Island.
Assuming a continued growth pattern, these "spots" can be expected to
broaden significantly ana to begin a transition from short-term
occurances to long-term or even permanent problems. Areas expected to
receive the greatest impacts are Lawton Canal, Baynard Creek, the
Folly, Fish Haul Creek and, most importantly, Broad Creek.

Given existing development guidelines these waters will likely
face a reduced capacity to assimilate increased amounts of runoff and
will likely meet only SB or, in some cases, SC water quality
standards.

This situation would have serious implications for the shell-
fishing industry, the recreational use of wetland areas, and the
natural environment which is an essential part of the atmosphere and
ambience of Hilton Head Island. Certainly when the expected volumes
of storm water runoff occur in combination with possible discharges
of treated effluents, serious water quality issues will occur that may
effect the public health, marine resources, public uses, and the
economy of the area.

4

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3. Existing Policies, Rules. Regulations, and "State of the Arcs"
findings:

Coastal Management Plan (III-17, 1 d) Drainage plans and
constructm«*!'<"ras gor residential development shall be designed so
as to control erosion and sedimentation, water quality degradation,
etc. Example techniques include buffering and filtering runoff, use
of permeable paving surfaces, detention ponds, etc. Best management
practices designed co control nonpoint-source runoff that are
developed as part of 208 Water Quality Planning also apply to new
housing projects.

fo»«rai Managqnent Plat (111-22, I d) Oca should b. taken in
pv-U m mnimi~dlrecT drainage of roadway runoff into

adjacent water bodies.

Plan OII-27,lb)
facilities must oemunstracewmpliance with applicable Federal and
state water quality standards, specifically those addressing drainage
and discharge of storm water runoff.

Management Plan (III-40, 1 d) Drainage plans and
consi^^T^Tor^Se«iaI~developiiMtstoi^d bedesiged to leMen
„	---cinn water quality degradation and other negative

filtering runoff, use of
woiutad buffers, etc. Best Management Practices developed
STpart Sf t£e irea-vri.de 208 Water Quality Plan should be implemented
through the management of major new eomaercial developments.

r—1 s*ma
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C. Policies

1.	The direct discharge of untreated storm water runoff into the critical
area (as defined by the S.C. Coastal Zone Management Act) shall not be
allowed.

2.	The South Carolina Coastal Council shall utilize "Best Management
Practices", such as those identified in the Hilton Head Island 208
Water Quality Study, in the review and issuance of permits and
certifications. The "Best Management Practices" will be applied on a
project by project basis as warranted by specific requirements.

(See Appendix A.)

3.	Optimum utilization of marshes and freshwater wetlands for filtering
storm water runoff should be required.

4.	Drainage projects shall be designed so that the final elevation of a
storm water discharge outlet is at or above the elevation of the
receiving critical area, unless no feasible alternatives exist.

5.	An SA, or better, water quality classification shall be maintained or
achieved in surface waters surrounding Hilton Head Island.

6.	It is recommended that the South Carolina Department of Health and
Environmental Control (DHEC) consider regulating specific point source
discharges of storm water via the National Pollutant Discharge
Elimination System (NPDES).

6

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CHAPTER THREE

Tidal Wetlands

marinas);and the discharge of treated effluent and non-point source
pollutants.

a TCC7TP• rw,« rn the raoid and continuous development taking place on

mfe Head IslSd.TrMSwe exists for filling, dredging, spoil

"?iMn ,	water access facilities and the discharge or

treated eflluent^nd non-point source pollutants. While protection

^ S mn.1- A1T9CT adverse impacts is afforded tidal wetlands through

of the^astal Council and the U.S. Any Corps

rfPnriMers significant pressures to alter these areas will continue
of B^ineers, signi „Lsa o£ development and through projected
auring the teowi plmned pnase o	^	fae	^

^ ^ **3* »¦**« ««

J _?Tjn?n? lH 71 hm areas such as isolated marsh hammocks to which
SSicSTL^s SnlHaiS only by filling or bridging. Kater
'I-.,. r0 these sites will also cause increased applications for
Sarins activities and their accompanying spoil disposal sites. The

c-eeks through dredging will, in many cases, result in
^ilStiOT problems and the need lor periodic rainwnance dredging.
Develoners are finding it difficult to provide highland spoil disposal
sUwfSd 1?i "certain that pressure to use non-vegetated wetlands
(mudflats and non-vegetated creek edges) as disposal sit« will occur
during future phases o£ development.

1 f-MMdna oressure is beginning and will continue to be felt
for the^SSrSetion of marinas. A trend toward lock system/basin type
. . .	-0 flTjrjear. The results o£ this phenomenon will be

SU2? «cSf ™??e 2a«r1or boaters and home owners accompanied by

V	"cMn *» ^ »d

adjacent natural creeks into which they empty.

4. mUAm rh»v* swears to be no overriding justification for
the b^if rme mriS inl^S^ i»P"ving the functions associated
•1.1^ .i?l,™ staff assumptions are that the scarcity of large
S£,fSf SSfrint property and the desire for additional waterfront
devel ocment sites are the prim ^iv.srorttus shift from the more
traditional approaches to manna developments.

» 4irs-r iaoact of marina develoanent is the closure of shellfish
grounds within iMO feet of the site asa pr gramr

5 - j	i... .mnT rrsnds sufgest a demand tor approximately lu

^^r?S TSlton Head Island. That situation combined -with water

, ,T,	associated with storm water runoff, and wastewater

dilcharses cauld eliminate shellfish grounds as a resource for public

a road Old House, Jarvis and Skull Creeks are the most
fiSiv^reas of imcact. What kind of balance can be obtained between
Lhe d«an?for marinas and the shellfish resource? It is predictable
that ^e resource will be eliminated as a direct result of competing
uses that carry acre economic weight.

7

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The discharge of created effluent into surface waters is and will -
continue to be a major issue on Hilton Head Island. It is difficult at
best to reach a scientifically determined limit at or below which the
wetlands will not experience adverse effects. A preliminary draft EES
addressing this problem suggests three alternatives for disposal of
treated effluent, two being land application and the third being
discharge into Calibogue Sound. However, this study is not addressed
to the island-wide problem but to the needs of the Sea Pines PSD only.
The inevitable increasing demands for discharge from other sections of
the island could lead to tremendous water quality problems which will
leave their effects on living marine resources.

The most serious threat to tidal wetlands from present and pending
development has been identified as that of water quality degradation
due to storm water runoff (i.e., storm water which cannot seep
naturally into the ground during rainfall due to the land surface being
covered by buildings, roads, highways, parking lots and other
impermeable surfaces). This runoff picics up many types of bacteria,
chemicals, heavy metals and other toxic materials which are then
carried by the water into the tidal creeks and estuaries. With each
new development the amount of storm water runoff increases and
exacerbates the problem of water quality degradation in the surface
waters around the island. (See Water Quality for further discussion.)

B. Existing Policies, Rules, Regulations, and "State of the Arts"
bindings:

General

Coastal Management Program (111-14,15) These "Guidelines for
Evaluation or all Projects" should be used, without exception, in each
permit application decision. They are most valuable in helping
decision-makers view projects from a broad and comprehensive
perspective.

Discharge of Treated Effluent

Coastal Management Program (III-37, 1 e) Discharge of water used
to pump out holds of fishing vessels must comply with DHEC and Coast
Guard regulations.

Coastal Management Program (111-41, 1 e) Adeauate sewage disposal
systems must oe proviaea oy new commercial development.

Coastal Management Program (III-46, 1 e) Proper handling of
sewage must be maae m new marinas.

Coastal Management Program (111-61, 1 d) "Sewage treatment
facilities snail oe constructed to limit effluent discharge as much as
possible into areas containing productive shellfish beds. Construction
of facilities shall in no case degrade the existing water quality
classification of the receiving water body and if the current
classification is not the highest achievable, the plans shall show a
consideration for the water body ultimately achieving the highest
classification."

8

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Coastal Management Pro Tram ( III -61, 1 e) "Outfall locations
should consider water depth, circulation and mixing in order to protect
water quality. Effluent should not be discharged into poorly confined
or poorly flushed estuarine areas."

r\ia«rfai Management Plan (111-71, 4) Extension of public services
(e.g., sewer cacihtiesj co barrier islands should only be proposed in
a comprehensive approach considering natural "carrying capacity" of che
island.

Rule 30-12 CE") (4) (hi p. 34 Marina proposals shall include
facilities cor cne proper nanaiang of sewage.

vui? fLl (I) Cd) o. 4* To extent feasible, quantity and
quality ot any waters discharged from drainage canals or ditches shall
not extensively alter wetlands or the quality of coastal waters.

Mon-point Source Pollutants

Management Plan (111-17, 1 d) Drainage plans and
construction measures tor Residential development shall be designed co
control erosion, sedimentation, and water quality degradation on
adjacent water and wetlands. ^Techniques to prevent direct storm water
discharge are suggested.)

Coastal Management Plan CIIX-22, I d) "Care should be taken in
design of roads co minimi redirect drainage of roadway runorf into
adjacent water bodies."

Management Plan CIII-22, 1 f) In construction of private
roadways tor private access permeable surfaces should be used rather

than pavement.

Coastal Management Plan (111-27, 1 b) Proposed parking facilities
most demonstrate compliance with water quality standards concerning
drainage and discharge of storm water runoff.

Vfatia^ment Plan CIII-37, 1 a) Drainage from any proposed
seafood processing operations must meet applicable water quality

standards.

*m„,«,ent Plan CIII-43, 1 e ii) Park plans must
incorporate^ximum use or peraeable surfaces where appropriate.

i	Plan UII-
    -------
Water Access Facilities
(marinas, boat ramps, accxs"and piers)

Coastal Management Plan (III-4-6, 1) (Marinas)

"a) To tne extent reasiole carinas shall locate only in areas that
will have the least adverse impact on salt, brackish or freshwater
wetlands and water quality.

b)	To the extent feasible marinas shall be located in areas

where maximum physical advantage exists and where the least initial and
maintenance dredging will be required.

c)	Marinas should avoid or minimise the disruption o£ currents.
Dead-end or deep canals without adequate circulation or tidal flushing
will not be permitted unless it can be determined that water quality
will not be adversely affected.

d)	Marina designs should minimize the need for excavation and filling
of shoreline areas.

e)	Provision of facilities for the proper handling of petroleum
products, sewage, litter, waste and other refuse oust be made in new
marinas, with regard to South Carolina Department of Health and
Environmental Control (OHEC) specifications.

f)	In review and certification of marina permit applications outside
the critical areas, the Coucil will consider th extent of public demand
for the facilities, as demonstrated by the applicant."

Rule 30-12 (E) p. 32-53 (Marinas)

"(2) Commercial docks are also considered a marina type facility. The
standards that apply to marinas will also be used as criteria in the
evaluation of permit applications for commercial docks.

(3)	All marinas affect aquatic habitats to some degree, but adverse
effects can be minimized by utilizing proper location and design
features. Application for marinas shall include a comprehensive site
plan showing location and number of all water-dependent and upland
facilities such as parking and storage facilities.

(4)	In addition to standards for bulkheads and seawalls, docks and
piers, dredging and filling, and navigation channels and access canals,
the following standards are applicable:

a)	Marinas should be located in areas that will have minimal
adverse impact on wetlands, water quality, wildlife and marine
resources, or other critical habitats;

b)	Wiere marina construction would affect shellfish areas, the
Council must consider the rights of the lessee, if applicable, and
the public, and any possible detrimental impacts on "shellfish
resources;

c)	Marinas should be located in areas where maximum physical
advantages exist and where the least initial and maintenance
dredging will be required;

d)	Marinas max, avoid or minimize the disruption of currents.
Dead-end or deep canals without adequate circulation or

tidal flushing '-rill not be permitted unless it can be demonstrated
that water qua1 icy will not be adversely affected;

e)	Marina design must minimize the need for the excavation and
filling of shoreline areas;

f)	Open dockage extending to deep water is usually preferable to
excavation for boat basins, and it must be considered as an
alternative to dredging and bulkheading for marinas;

10

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g) Turning basins and navigation channels shall be designed to
prevent long-term degradation of water quality. In areas where
there is poor water circulation, the depth of boat basins and
access canals should not exceed that of the receiving body of
water to protect water quality.

Where feasible, boat maintenance areas oust be designed so that
all bottom scraping and painting be accomplished over dry land allowing
for proper contra 1 and deposition of residues, spills and storm water
runoff;

i) Dry storage type marinas are preferred, wherever feasible;
j) Applications for construction of marina and commercial dock
facilities will be considered by the Council only after adequate
demonstration by the applicant of demand for the facilities;
k) Applications for marinas must include maintenance dredging
schedules and dredged material disposal sites when applicable,"

Coastal Management Plan (111-48, 1) (Boat Ramps)

1) in the coastal zone usuncil review and certification of
applications for boat ramps will be based on the following policies:

a)	Filling of productive salt, brackish, or freshwater wetlands
for boat ramp construction is prohibited unless no feasible
alternatives'exist in adjacent non-wetland areas. In addition,
the aneunt of fill required must be minimized.

b)	The following privities are considered when justifying boat
ramp location in sensitive areas:

i) public use - open to all citizens,
ii) restricted use - open only to citizens of a particular
area or organization,
iii) private use.

c)	Boat rase locations requiring dredging of productive salt,
brackish or freshwater wetlands to provide channel access to
deep-water will be discouraged.

d)	Boat ramps must be constructed of environmentally acceptable
materials.

Rule 30-12 (B) pp. 29-30 (Boat Ramps)

1)	aoat ramps provide access to the water for those who do not have
water access by means of docks, piers, or marinas. However, boat ramp
construction may require filling or, in some cases, dredging of wetland

•

2)	Specific standards which shall apply are as follows:

a) Filling of vegetated wetlands for boat ramp construction is
prohibited unless no feasible alternatives exist in non-vegetated
wetland areas. In addition, the area to be filled must be limited
to that which is reasonable for the intended use;
c) Justification for'boat ramp construction in environmentally
sensitive areas shall be considered using the following

orioricies:

i) public use - open to-all citizens;
ii) restricted use - open to citizens of a particular area
or organization only;
iii) orivate use - use for one citizen or family;

i'l

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d)	In cases where private use is necessary, siting of ramps" must,
wherever feasible, be located in areas where the least
environmental impact will accrue to the area;

e)	3oat ramp location requiring dredging or filling of wetlands
to orovide deepwater access to the ramp, parking areas for the
ramp, or other associated facilities are prohibited unless no
feasible alternatives exist and environmental impacts can be
minimized;

f)	The siting of "public use" boat ramps is encouraged in easily
accessible areas such as bridges and exisitng, abandoned
causeways, provided that these sites comply with other applicable
regulations.

Rule 30-12 (A) pp. 23-29 (Docks and Piers)

g)	Dry storage in uplands will be encouraged in preference to
moorage in crowded areas;

h)	Developers of- subdivisions, motels, and multiple family
dwellings will be encouraged to develop joint-use moorage
facilities while their plans are in the development stage;

j) Where docks and piers are to be constructed over tidelands
utilised for shellfish culture or other atari culture activity, the
Council will consider the rights of the lessee and the public
prior to approval or denial.

Dredging, Filling and Sooil Disposal

Coastal Management Plan CIII-S5, 1) (Dredging)

TrZ] To the extent ceasible dredging should be performed only
during closed shellfishing season if proposed in a productive
shellfish area.

b)	Suspended sediments must be kept to a minimum. The use of
structures such as weirs and silt curtains to minimize water
quality degradation is encouraged. Where highly toxic sediments
are encountered, dredging will be prohibited unless the activity
is consistent with other dredging policies, as well as those for
manufacturing or other industrial activities.

c)	Dredging should not reduce water circulation, water currents,
mixing, flushing or salinity in the immediate area.

d)	Dredging for establishment of new canals which involves
permanent alteration of valuable wetland habitats will be
prohibited unless no feasible alternative exists or an
overwhelming public interest can be demonstrated. Establishment
of canals for purposes of creating waterfront lots from inland
property, especially where dead-end canals would result, will be
prohibited unless it can be demonstrated that there will be no
significant environmental impacts."

Rule 50-12 (G) p. 37-38 (Dredging and Filling)

**3" tne creation of commercial and residential lots strictly for
private gain is not a legitimate justification for the filling of
wetlands. Permit applications for the filling of wetlands and
submerged lands for these purposes shall be denied, except for
erosion control, see R.30-l2(C), or boat ramps, see R.30-12(3).
All other dredge and fill activities not in the public interest
will be discouraged;

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b)	Dredging and filling in wetland areas shall be undertaken only
if the proposed activity is water-dependent and there are no
feasible alternatives;

c)	To the maximum extent feasible, dredging and filling
activities should be restricted in nursery areas and shellfish
grounds and during periods of migration, spawning, and early
development of important sport and commercial species'

d)	Dredging and excavation shall not create stagnant'water
conditions, lethal fish entrapments, or deposit sunns or others*
contribute to water quality degradation;	*

e)	Designs for dredging and excavation projects shall, where
feasible, include protective measures such as silt curtains
diapers, and weirs to protect water quality to adjacent areas

during construction by preventing the dispersal of silt material-

f)	Dredged materials shall be deposited and contained in such a
manner so as to prevent dispersal into adjacent wetland'areas*

g)	Applications for dredging in submerged and wetland areas for
purposes other than access, navigation, mining, or drainaae shall
be denied, unless an overriding public interest can be
demonstrated. Dredaing permits for mining will be issued only as
specified in (2) (hj below. Drainage permits must be consistent
with the provisions in R.jO-12(U;

i) Wetlands shall not be utilized as depositories for waste
materials except as discussed in R.30-12(1);
jj In all cases, dredging activities shall not be approved until
satisfactory disposal sites have been acquired."

Coastal Management Plan
Urilling)

. . Coastal Management Plan £1X1-16, 1 b) Residential development
which wouia require ruling of wetlands will be prohibited, unless nc
teasible alternatives exist or an overriding public interest can be
demonstrated, and any substantial environmental damage can be
minimized.

Coastal Management Plan (III-22, l a) Where wetlands cannot be
avoictec, orxaging ratner cnan filling will be required wherever
feasible.

Coastal Management Plan
upon Disposal J

Coastal Management Plan (111-57, 1) (Dredged Material Disposal 1
"a} ro ene maximum extent teasible, dredged material aust no- )*»
placed on high value .natural habitats such as salt, brackish or
freshwater wetlands; sucmerged vegetaion; oyster reefs or tidal
guts. Where upland disposal is not possible, areas of relativ-?v
low productivity should be utilized, or ocean disposal should be
employed.

b)' Ob land dredge material disposal sites must be stabilized and
maintained where necessary to prevent erosion and direct Cat-r
run-off.

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c)	Where water disposal is necessary, natural channels must not
be blocked with dredged material and impact on existing water
circulation should be minimized. Depostion in water areas of
higher flushing rate will decrease damage from suspended sediment
and ox/gen depletion.

d)	Consideration must be given to the temporal aspects of spoil
deposition such as impacts on spawning seasons, fish migrations,
waterfowl nesting and wintering areas, and mosquito control.

e)	The selection of upland dredge disposal sites should include
consideration for minimizing negative impact on valuable
terrestrial wildlife or vegetative habitats."

Rule 30-12 (F)(2)(b) p. 35: The location and design of public and
private transportation projects must avoid the critical areas to
the maximum extent feasible. Where coastal waters and cidelands
cannot be avoided, bridging rather Chan filling of these areas
will be required Co che maximum extant feasible.

R?ile 50-12 (I) pp. 40-41 (Deposicion of Dredged Material)
77rT Upland disposal of dredged material shall always be sought in
pv. Jference Co disposal in wetlands. Vegetated wetlands and
mudflats shall not be utilized for disposal of dredged materials
unless there are no feasible alternatives. Any other wetlands
should not be utilized for disposal of dredged materials when
other alternatives exist;

b) Open water and deep water disposal should be considered as an
alcernative if highland alcernacives are not feasible. However,
open and deep water disposal sites should be seriously considered
only after careful consultation with Che Council and other
relevant state and federal agencies;

g)	Consideration must be given to the temporal aspects of spoil
deposition — for example, impacts on spawning, fish migrations,
shellfish harvesting, waterfowl nesting and wintering areas, and
mosquito control. Attention must be given Co possible adverse
impacts of various alternative sites on che puolic health and
welfare as well as on critical fish and wildlife areas;

h)	In all cases, dredging activicies shall not be approved until
satisfactory disposal sites have been acquired."

C. Policies

1.	The South Carolina Coastal Council will continue to strictly enforce
its existing policies, rules and regulations affecting the critical
areas of Hilton Head Island and their use. The Council will also
review the cumulative impacts of proposed projects more closely.

2.	The S. C. Coastal Council discourages the development of marsh
hummocks around Hilton Head Island, as identified in the Hilton Head
Island Marsh Hummock Inventory. The Coastal Council will continue
to strictly enforce policies, rules and regulations governing access
to these areas.

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The S. C. Coastal Council discourages the closure of any productive
shellfish areas around Hilton Head Island, The following
recommendations will be implemented on Hilton Head Island.

A.	Applications for marinas and other activities which would
cause the closure of productive shellfish areas are encouragec
to locate those activities in areas presently closed.

B.	No project which will cause the closure of shellfish grounds
designated as being the most productive by the Hilton Head
Island Shellfish Inventory should be approved.

C.	Applicants for permitted projects which would cause the
closure of shellfish grounds in less significant areas as
identified by the Hilton Head Island Shellfish Inventory shall
be required to submit a mitigation plan for the loss of
resources to the S. C. Coastal Council, the South Carolina
Wildlife and Marine Resources Department and the South
Carolina Department of Health and Environmental Control.

Excavated, basin-type marinas should not be
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CHAPTER FOUR

Freshwater Wetlands

I. The development and building on Hilton Head Island has resulted in a
number of changes to the natural systems present on the island. These
have included the alteration and reshaping of historic drainage
patterns and land forms, the creation of artificial lagoons and
reservoirs, and the indiscriminate dredging and filling of the
Island's freshwater wetlands.

A. ISSUES: These activities have contributed to the elimination of
approximately 33% of all freshwater wetlands on the island,
toreover, an additional 20% have been significantly changed by
developmental activities occurring on their periphery, which have
resulted in an alteration of the natural patterns which initially
created the wetlands.

The consequences of this continuing trend will be:

1. A loss of wildlife habitat diversity. The loss of wildlife habitat
could result in the elimination of many types of animals on the
island. As natural habitat is lost, the diversity of the animal
peculation will decline resulting in the elimination of the natural
wildlife population.

Z. The loss of areas which have historically been the receiving
point for the collection of storm water runoff and flood events.
As more and more of the island is developed, and undeveloped lands
are replaced by impermeable surfaces, the volume and substance of
runoff water increases. Freshwater wetlands typically are
physical depressions or low spots which collect and hold most
runoff. Retained water is gradually absorbed or filtered back
into the ground or surface waters. Until recently these
wetlands have been set aside from development because of the
availability of other land and the increased costs associated
with, dredging and filling them to make the property acceptable
for building. Competition for space on the island has
changed that. Present trends indicate that these wetlands are
being rapidly developed and removed from the system. Runoff
storm water is instead moved through a system of ditches and
drainage pipes as rapidly as possible to its discharge point.

These systems are designed and "sized" to accommodate a specific
storm event. Any storm larger than the designed storm will result
in water coning out of the ditch and flooding the adjacent area
Prior to development the wetlands were the point where these storm
events were absorbed.

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3.

Reduced natural capacity to treat anA Mi*.

storm west, to important function MsSiLfiS'Sf fron

collection of storm water runoff in watianri. ; f

capacity of these areas. Storm wate^ii^J^ ?eat=»nc

as being pure clean rain wat^	gf^1)r t5°u«ht <*

pollutants are usually found in any urban lJ?^er

with rain as a vehicle of movSeST S^STS"!!1??' *5

transported downstream. Pollutants SJ£ LJS	and

street litter; seepage and spm^! SSliS	M

stagnant water; cachings; fuei and

fertilizers and pesticide from yards and ®piAjase»

drippings - gas, oils, brake ™Sd£ S^fafSd8?^8"?18

contaminants; dirt and debris washing from cnn«r^S-,-^^r

mosquito control chemicals from aerial spraw£?S£S2!«?Kaa:

seepap from improperly functioning seDticianks^^??w.«.

animal droppings, and dead animals. The aoSmiU?rj!^ *?,¦

of these different pollutants in a single^Ti"i™ 411

ditch, pipe, or low area can result inVoflto^SL^L,

to raw untreated domestic sewage. Surveys of sa?Jl j

taw sewage in localities throughout the^ou^tr^

constituent levels, such as conform bacteria JiJZ? ^

chlorides and miscellaneous substances to be ccSSbl^in

each case. The sampling information conducted^2« J rH

208 water quality program on Hilton Head Island^a.?m.2£» ®

shown high levels of pollutants at several of thesa^t?^3*
stations.	sampling

The management of storm water runoff requires that »
coordinated approach be used to address the nroblL a „ _v
of different measures must be used if a successful --- numfer
to be implemented. Best Management Practices u«n--rfT??aa 19
involve holding water on site for periods of time with a
gradual release downstream, a reduction in the amount
pavement and impermeable surfaces, maintenance of
open spaces and natural absorption areas, and good
housekeeping to reduce the introduction of pollutant* *».
systems. Because freshwater wetlands perform a cleaning
function in the natural environment, their abiliti«si« h-u
and filter limited amounts of storm water increase the
importance of their preservation. The amount of water whi^n
can be accommodated by each wetland must, of course be
addressed in the engineering and design phases of each or« im~
proposed for construction.	project

4. Loss of aquifer recharge areas. It is highly orobabls
some of the freshwater wetlands on Hilton Head Island are
recharge points for the shallow water aquifer and possibly for
the deepwater aquifer as well. A sue survey is required to
identify these points and verify that an aquifer rscharie i«
in fact occuring. The South Carolina tfater Resources
Commission, during the next year, will be making survevs of
JBny of these wetlands to identify where these points are
located. The elimination of aquifer recharge doints can ha,,,
serious consequents for the island. A fai?^:!} re5£r«
the shallow water aquifer can result in a freshwater draw-down
and contamination or the aquifer by salt water intrusion.

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This could affect Che limited number of people who use shallow
wells for drinking water as well as the number of shallow
wells used for irrigation purposes. Contamination of
the deep water aquifer would affect the total population of
Che island.

The freshwater wetlands of the island can be broadly
classified into four categories. These are: forested (with a
closed canopy), forested (with an open canopy), nonforested,
and the open water community.

The forested (closed canopy) category is made up of a number
of tree comuunities generally containing swamp tupelo,' sweet-
gum, red maple, palmetto, and pond cypress trees.

The forested (with an open canopy) group contains a mixture
of trees and plants dominated by pond cypress, pond pine,
palmetto, tallow trees, marsh, saw grass, foxtail and
cattails.

The nonforested category contains freshwater marsh groups.
Prevalent plants found in this category are marsh,
fern marsh, Virginia chain fern, saw grass, and cattails.

Open water freshwater wetland communities are the floating
aquatic community found in standing water dominated by water
lilies and mosquito ferns, and the pickeral weed community.

The most commonly found forested wetland on the island is the
swamp-tupelo community which predominates the deep wetlands
characteristic of the northern end of the island. The
swamp**tupelo, sweet gum, red maple communites although not as
dominant as the swamp-tupelo group occupy more total area than
any other community." These types of wetlands are found in the
broad, linear wetland northwest of Broad Creek. They often
ran for more than half a mile in length.

Fernmarsh and maidencane marshes are the most common of the
freshwater marshes. The greatest total single area is the
Virginia chain fern, mixed marsh (Wooping Crane Conserancy and
others).

Preliminary investigations provide evidence that most of the
remaining wetlands on Hilton Head Island are 404 Wetlands as
defined by the U.S. Corps of Engineers. However, due to land
development, few 404 wetlands larger than 10 acres still exist
on the island. It is left Co the discretion of the District
Engineer of the U.S. Corps of Engineers whether or not co
allow certain alterations co 404 wetlands less Chan 10 acres in
size.

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B- ^in«-P°UCie5' RUl'S' Reg0lati°"S- mi	of tf» lrr«"

"Resiaenciai'^eveiopment'mil^would r eaili re° the*?"Hng'o^othe?1
petroneK alteration of sale, brackish or frsshwter wetlands will

,faa1iMe 3lte"tiv« «i« «¦ an ov«^di^U

public interest can be demonstrated."	s

Coastal Management Plan (111-22, 1 a,b,f) Transportation
Road ana aignway routes snould be designed to avoid salt
brackish, or freshwater wetlands. Mo substantial chang-s in water
circulation. Private access ways should be designed to avoid
salt, brackish, or freshwater wetlands.

Coastal Management Plan (111-25, 1 a)

Railways snouia oe aesignea to avoid salt, brackish or freshwater
wetlands.

Coastal Management Plan (111-27, 1 a) Parking facilities
The tilling or otner permanent alteration of productive salt
brackish, or freshwater wetlands will be prohibited unless no'
feasible alternative exists, the facility is directly related to a.
water-dependent activity, any substantial environmental impacts
will be minimized, and an overriding public interest can be
demonstrated.

Coastal Management Plan C111-40. 1 a) Commercial Development
Commercial ueveiopment that requires the filling or other
permanent alteration of salt, brackish, or freshwater v«rTw«
will be denied unless no feasible alternatives^sfa£
facility is water-dependant.

Coastal Management Plan C111-73) Wetlands (outside of
critical areas;

"Project proposals which would require fill or other significant
permanent alteration of a productive freshwater marsh will not JL
approved unless no feasible alternative exist or an overridina
public interest can be demonstrated, and any substantial
environmental impact can be minimised."

TTT Other Management Plan Policies (111-31, Forestry, l-b, l-c
111-32, Mining, l-b, l-c; III-34, Manufacturing, l-b, l-c- tttSa
Fish and Seafood Processing,, l-c; 111-38, Aauaculture 1-i-

***	W*' ni-W, Marinas.'l-a-

111-48, Docks $ Piers; III-S3, Impoundments, l-a, l-b' ITT-?? '
Dredging, l-d; 111-57, Dredged Material Disposal, l-a!) '

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C. Policies

1.	The staff of the South Carolina Coastal Council, with the assistance
of other state and federal agencies, will complete comprehensive
site visits to those wetlands identified by the Freshwater Wetlands
Inventory for Hilton Head Island. Designation as a 404 Wetland by the
U.S. Armv Corps of Engineers will provide the primary basis for
investigation and designation as valuable natural resource areas.

Those areas designated as being valuable to the natural systems of
Hilton Head Island should be protected from detrimental alteration.

2.	Storm water runoff should be directed into natural drainage routes and
freshwater wetlands, but should not exceed the assimilative capacities
of those areas.

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CHAPTER FIVE

Beaches and Dunes

I Many broad areas of the beachfront of Hilton Head Island are experiencing
erosion. The areas most prone to erosion are North Forest Beach, Palmetto
Dunes, the Folly Inlet and the extreme tips of the island.

A ISSUE* With the excretion of the tips of the islands, where erosion is
IKSniht to result from the currents moving in and out of the two
sounds, most of the erosion is taking place on the orotruding "bump".
Itis thought that this burro could be the sand supply source for the
island ana consequently could account for the increased erosion rate.

Most development which has occurred over the last few years was
set back well beyond the mean high water mark and primary oceanfront
sand dunes. C In some instances houses have been set back beyond the
third line of dunes, and over 22S feet in the case of North Forest
bSS.) More recently, a trend of increased density and maximization
of the oceanfront lots has resulted in building to the edge of the
setback line. These types of projects have typically shown little
reaard for erosion trends and have proceeded to remove existing
sSondary dunes and the maritime forests that provide sand to the beach
system and afford some degree of storm protection.

The erosion protection measures on Hilton Head Island have been
extensive. Presently, most of the area from the Folly Inlet to North
Forest Beach, except for Palmetto Dunes, has to be continuously
renourished and much of it is either protected by a seawall, reyetment,
aroiiTfield, or, in many instances, with both armouring and groin
Ss.ij, A^kHtionallY. two renourishment projects have occurred in the
§5tt« y£5 taoni area- It is not known whether the erosion will
rnnr-ini» The oattem could reverse, and the beachfront could begin
SS tSErww.Forecasting the .rosion rate is vary similar to
forecasting the weather years in advance; too many factors come into
olaywhich can affect the accuracy of these predictions. However, at
i-flic three studies dealing specifically with the beachfront erosion of
Hilwn Head Island have been conducted in the last ten
m„ —j - iot of information has been collected and analyzed.

'It is susoected that the armouring of the shoreline during the last 20
v.ar<. ha-" rBaulted in an increase in size or spread of the area subject
to erosion Permit applications for erosion control structures granted
over the last few years support this belief. Based upon the
information available it was assumed that the erosion rates similar to
those experienced in past years will continue. It is upon this
assumption that these policy issues and recommendations have been
prepared.

Thm «ih«rantial issues involved in the question of protection of
oceanfront.property on the island are:

1 The Council's present policy in approving erosion control
structures is to review each on a case-by-case basis and to
approve each application on its own merits.

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Based upon this existing policy, should the present system of
permitting individual structures be continued or should a
standard design approach - whether it be renourishment,
seawall or revetment - be selected and all future projects
designed to conform to those specifications?

2.	The Council '"s present policy is to allow no backfilling in
areas where land has been lost to erosion. Should the Council
allow backfilling behind bulkheads, (in areas where adjoining
bulkheads have been constructed), in order to maintain a
continuous line, which studies have indicated is usually more
effective in reflecting water? If this is allowed should the
use of the area be restricted with a setback line?

3.	The Council presently does not enforce any type of setback
requirement behind the primary oceanfront sand dune or point
of highest wave uprush. Development of property which is
presently not subject to erosion has, in many instances,
removed the secondary dunes and maritime forests which
could provide some type of protection in the event' of unusual
weather. Should a setback line and buffer requirement to
protect secondary dunes and maritime forest areas be adopted
by the Council?

4.	There is a documented need for increased information on
erosion patterns and the natural systems of the beachfront all
along the coast. A program to take periodic measurements
along the island's coast could be beneficial to the Council
staff, and to scientists, engineers, and developers. The
anticipated program could be conducted with existing staff and
photography. Increased costs could be expected to be minimal.

5.	The inlets of tidal creeks are known to be highly unstable
areas. Development pressures will inevitably result in
requests to develop the land around these inlets. The Council
could allow development to occur even though the present
regulations will not be effective in protecting the property
from erosion, sudden flooding, or other events. Should an
increased setback be required?

6.	A program to better manage primary and secondary dune systems
remaining after development would be helpful to the
beachfront. It has been recommended chat seme sort of dune
enhancement program be prepared and implemented.

3. Existing Policies, Rules, Regulations, and "State of the Arts"
rintnngs:

Coastal Management Plan Residential Development 2(c), Parking
Facilities *Loj, Manuracturing 2(b), Commercial Development 2(b),

Public Buildings 2(b) . . . The siting of nonwater-depencent structures
on the primary dunes or beaches will be discouraged where other
feasible alternatives exist. Design and construction options which
minimize destruction of the dunes and dune vegetation will be
encouraged.

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„ , vfas-cai wanageawnx r tan ureagea material disposal
2 (a) Upland disposal or oredged material should always be souaht in
preference to disposal in wetlands.	^

,n) SgBl^2|SSSy^ Dune Areas (other than critical areas)
1) flec^p^rnwarpromty to and strong physical and ecological
relationship with beach and primary sand dune critical areas
project proposals in secondary sand dunes oust demonstrate reasoi^bi®
precautions to prevent or limit any direct negative impacts on the
adjacent critical areas.

2)	Special attention must be given in new construction activities in
cceanfront areas to prevent or mitigate negative impacts on adjacent
property owners, specifically, increased erosion or loss of protective
dune formations on adjacent lots due to unnecessary destruction 3 or
encroachment onto stable dunes."

Coastal Management Plan Erosion Control Policies (IV-57)
"1) seawalls, ouiJOieaas ana revetments will be considered only as oar-
of a comprehensive erosion control program to insure that these
structures do not cause adverse effects to adjoining propertyowners or
appreciably accelerate erosion in the general beach area*.

23. ... structures must not interfere with existing or planned public
access. . .

3)	. . . structures shall not impede public use of beaches below th»
mean high water line. . .	w

5)	Applications for construction of a seawall in the beach or dim*
critical areas for the purpose of filling behind these jtru^SrefL
create land for private development shall be denied unless the
applicant can clearly demonstrate to the Council that no feasible
alternatives exist ...

6)	Except under special circumstances, such as critically eroding
shorelines chat have a direct measureable effect on the economic wall
being of an applicant or are a threat to the public safety, the Council
will promote the use of natural features of tne dune and beach sys-am
rather than artificial protection ..."	w

Groins

"*) The positive affect and applicability of a groin system in a
comprehensive shore protection program must be demonstrated."

Artificial Beach Nourishment

1) A thorough stud^/- aust be prepared oerore renourishaent is
attempted.

I) Fill ;naterial should not come from dune fields, adioiniM
beaches or nearshore bars.	8

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Sand Dune Management

"1) Private and public projects to restore and stabilise dunes through
non-structural means are encouraged.

2)	To the extent possible, the secondary dunes should be kept in tact
to insure protection of adjoining areas against flooding during storms.

3)	Buffer areas should be established, where feasible, to allow for
fnmtal dune growth and movement.

6) Walkover structures are encouraged over all frontal dunes.

However, these walkover structures should not interfere with public
access or extend below the mean high water line.

9) In all cases, the primary fTont-row sand dune, as defined in
R.30-10(B), should not be permanently altered."

Rules and Regulations

Rule 30-13 Specific Project Standards for Beaches and Dunes.

"51 The Council will promote the use of natural features of the beach

and dune system rather than artificial protection,

c)	The Council will consider the extent to which the project is
consistent with a comprehensive shore protection program for that
particular stretch of beach,

d)	Erosion control structures must not interfere with existing or
planned public access unless other adequate access can be provided,

f)	All erosion control projects must consist of environmentally
acceptable materials, demonstrate sound design and construction so that
they could reasonably be expected to be safe and effective, and
minimize adverse effects to the beach . . .

g)	Erosion control strucures should not normally be approved except
when erosion imminently threatens permanent improvements, including but
not limited to buildings, paved parking lots, swimming pools, etc.,
which existed on the subject property 90 days after adoption of this
regulation; or, in the case of protecting property adjacent to existing
erosion control structures; or, in the case of structures specifically
called for in an approved erosion control plan."

2)	Specific standards for seawalls, bulkheads and revetments.

3)	Standards for groins and jetties.

¦t) Requirements for artificial beach nourishment.

Sand Dune Management

1.	Requi rsnents for walkways over dunes.

2.	Projects to restore or build new dunes.

Ncnwatar-dependent structures ...

The siting of nonwater dependent structures on or over the primary
sand dunes and beaches will be prohibited where other feasible
alternaties exist.

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C. Policies

1.	The S. C. Coastal Council will coordinate with development interests
to establish a beach monitoring program for the purpose of
understanding erosion rates and trends on Hilton Head Island.

2.	The South Carolina Coastal Council shall emphasize the use of
non-structural solutions to erosion on Hilton Head Island.

3.	Erosion control structures should not normally be approved except when
erosion imminently threatens permanent improvements including but not
limited to buildings, paved parking lots, etc.

4.	Developers are urged to assess the erosional history of project areas
and to setback their development beyond the jurisdiction of the
Coastal Council where appropriate.

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CHAPTER SIX

Public Access

I. Public Access to the Coastal Resources on Hilton Head Island.

A. ISSUE: The natural resources of Hilton Head Island provide a variety of
recreational activities for the entire public- The more obvious include
swimming, fishing, shellfish harvesting, boating, hiking, and observation
of wildlife.

Several issues have developed in recent years concerning the
appropriate use of these resource areas. Predicted urbanization will only
compound these pro'oIons.

First, while there is an abundance of recreational areas,
access to these areas is usually controlled by private ownership," thus
limiting the use of primary areas to a select public. This is a
particular problem for access to beach areas. Currently there are only
two public beach access points, with approximately two hundred parking
spaces, on Hilton Head Island. It poses a significant problem ffor the
existing population. Second, like beach access, private ownership and a
lack of funds has limited public access opportunities to boat landings.
With the growing trend toward the small tTailerable boat, the.single
public landing on Hilton Head Island will hot meet the public's demand in
future years. In fact, facilities that allow a user fee will likely
became totally private in order to accommodate membership demand. Third,
the construction and location of marinas are already indicating an adverse
impact on many inland fishing drops on Hilton Head Island. This trend will
likely continue should a prediction of ten additional marinas prove
accurate. Fourth, and most important, is the rapid growth factor. Simply,
there is a much greater current demand for access to recreational areas'
than supply. As the interior portion of the island, which possess no
natural access to water courses, develops a tremendous burden will be
placed upon existing supply. Development interests should note that even
the more affluent island residents will find themselves disenfranchised
of the privilege to utilize public recreational resources.

3. Existing Policies. Rules, Regulations, and "State of the Arts" Findings:

Coastal Management Plan CIII-14, Guidelines for Evaluation) 13)
"To protect and, where possible, to restore or enhance the resources of the
State's coastal :cne for this and succeeding generations."

Coastal Management Plan (III-14, 7) "The possible long-range,
cumulative efzects or che project, when reviewed in the context of other
possible development and the general character of the area."

Coastal Management Plan (III-14, 9ii) "Public recreational lands -
conversion or cnese lanas co other uses without adequate replacement or
compensation, interruption of existing public access, or degradation of
environmental quality in these areas,"

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(V««ra1 Management Plan (III-17, 3 B) Developers axe encouraged to
incorporate cannon use recreational areas in proposals for large-scale
residential developments.

Crtjurai Management Plan (IV-44, t) The Coastal Council fully endorses
and will support, turther,md encourage the protection of and the
expansion o£ public access to shoreline areas in South Carolina.

Management Plan (IY-^4, 8) The provision o£ additional parking
space in upland areas adjacent to beaches should be a priority for
recreational planning by both local and state agencies.

9) Lff-al governments in the coastal zone are urged to incorporate
considerations for provision of public access into their local ordinances
and comprehensive plans, especially j*

influence the 1 oca.ten and design of the new developnent that sight affect

"""lo! Prfviti developers in beach areas are encouraged to include
provision of reasonable public beach areas and access ways in their plans.

12)	The Council advocates the provision of joint use docks, boat ramps,

dtc

13)	The Council recognises the overriding importance of good water
quality as a recreational resource, and will strive to maintain, and

improve, existing standards.

Policies

1 rh#» Smith Carolina Coastal Council should not approve any project or
ihidi wild £u« the net loss of any existing public beach

access.

2- a	as^rassr-

dCTelop a™oordinatS plan'o	^

access to the wetland and beach areas of Hilton Head Island.

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CHAPTER SEVEN

Cultural Resources

I. Because of the potential threat to historic and archeological resources
from continued development, it is extremely important that efforts are made
to identify and preserve these surviving reminders of a rich and colorful
past.

A. ISSUE: Hilton Head Island contains a significant number of both
prehistoric and historic sites. Prehistoric archeological sites
consist chiefly of Indian shell-rings and shell middens or mounds which
date back to prehistoric times. Middens and shell rings offer a
glimpse into the little-known life style and customs of prehistoric
native Americans of the Southeast Atlantic coastal plain. In addition
to this cultural information, these sites may yield biological
information which could help to assess the changing conditions of the
tidelands and evaluate present-day management and conservation
practices.

Historic sites on Hilton Head Island are numerous and range from
the former location of fresh water springs, where sailing vessels
renewed their water supplies, to civil war earthwork fortifications,
ruins of antebellum plantation houses and chapels as well as a slave
cabin and numerous cemeteries. They represent an important part of our
state's as well as our nation's heritage and deserve protection as a
tangible link with and an irreplaceable record of past events and
former ways of life.

As development continues on Hilton Head Island, historic and
archeological sites may be threatened by construction of homes,
commercial establishments, roads, highways, marinas and public
facilities. The island's tangible heritage nay be removed or damaged;
historic and cultural information, as yet undiscovered, may never be
brought to light; and the flavor of the island's history may be lost to
future generations. Because of this potential threat, it is extremely
important that efforts are made to preser/e the surviving reminders of
a rich and colorful past.

3. Existing Policies, Rules, Regulations, and "State of the Arts"
rmcnngs:

The S. C. Coastal Council is mandated by Section 2(B) of the
State's Coastal Zone Management Act (Act 123 of 1977):

(2) To protect and, where possible, to restore or enhance the
resources ct the Scare's coastal tone for this and succeeding
generations;

(5) To encourage and assist state agencies, counties,
municipalities and regional agencies to exercise their responsibilities
and powers in the coastal rone through the development and
implementation of comprehensive programs to achieve wise use of coastal
resources giving full consideration to ecological, cultural and
historic '/alues....

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Thus, the Council, through its direct permitting authority
activities in the critical areas as well as its reviL and
certification of other state agency permits, federal aomw-v n,.-,..r,
project proposals subject to A-9S review and Environment^ l£S5 '
Statements, must include, as part of its review, the orot*cti'arTnf
resources of cultural and historic significance.

As a part of this review the Council relies on the Off if* -u.
State Archeologist, S. C. Institute of Archeology and Anthroro W
the S.C. Department of Archives and History for assessments^? any
impacts on cultural and historic resources. (Created in 1967 th«
S.C. Institute of Archeology and Anthropology <« responsible foT
locating, recording, ana excavating prenistoric and historic
archeological sites and publishing interpretive reports on its
findings. In addition to a number of other duties, the S C
Department of Archives and History is responsible for de"7SIo5ina and
carrying out a plan tor tne preservation of the state's wehlSSr??
historic and cultural sites.)	one,

Chapter IV of the State of South Carolina CM«r,i u.	m T

Program developed by the Coastal council and approved bv tnesSr*
Legislature and the National Oceanic and Atmospheric Administration it
S. Department of Cannerce, contains a section entitled Ceoarachic
of Particular Concern (GAPC's). One of the three cateaor i rh i „
this section is entitled "Areas of Special Historic, Archeoloidcal or
Cultural Significance" and is composed of sites which have beS nL2
to the National Register of Historic Places** as well as sitea^ naned
determined eligible to be named to the National Register Th»«-
classified as GAPC's receive the protection provided by the Coast!?
Council's direct and indirect permitting and review authorities?

The goals of the South Carolina Coastal Zone Management or^
preservation and development of GAPC's of historic, archeolotri ef i"i.
cultural significance are:	«™«uog:tcai or

•To give highest priority to the identified primary
value of a 6APC when considering the preservation *r
development of that area.	*

To ensure that management of GAPC's is consistent
other policies of the South Carolina coastli ne
management program" (CMP, p. IV-3)

In its review of proposed activities which will impact areas of

special historic, archeological or cultural significance listad

management program, the Council uses the following priority-use
criteria cor these areas, beginning with the use of highest priority:

" 1) Uses which preserve the historical or cultural
values for which che site was placed on the National
Register;	'

2) Educational opportunities for the public regarding
the historical, archeological or cultural signified- of

COP p* " If)® M 51" '» ™* disturb*?" 01

29

    -------
Upon Council adoption o£ a Special Area Management Plan for Hilton
Head island, sites listed in the plan will be given the same protection
accorded GAPC sites.

**The National Register of Historic Places was created in 1966 with
the passage in that year of the National Historic Preservation Act
(P.L. 89-465). This act authorized the Secretary of the Interior "to
expand and maintain a national register of districts, sites, buildings,
structures and objects significant in American history, architecture,

archeology, and culture	" The significance of properties nominated

to the National Register is evaluated in accordance with an established
set of criteria. Benefits of listing in the National Register are:

1)	makes private property owners eligible to be considered for
federal grants-in-aid for historic preservation through state programs;

2)	provides protection by requiring comment from the Advisory
Council on Historic Preservation on the effect of federally assisted
projects on these resources;

3)	makes owners who rehabilitate certified historic properties
eligible for federal tax benefits.

C. Policies

1.	Sites, including those listed in the Hilton Head Island Special
Area Management Plan (SAMP), should either be left untouched (except
for investigation carried out or authorized by the S. C. Department of
Archives and History and/or the South Carolina Institute of Archeology
and Anthropology) or preserved and/or restored as a tangible record of
past events and former wavs of life.

2.	Should it be determined that any site, including those listed in the
Hilton Head Island SAMP, may be adversely impacted by proposed
development, the S. C. Coastal Council will contact the S. C.
Department of Archives and History and the S. C. Institute of
Archeology and Anthropology for coirments and recommendations.

3.	Protection of structures and sites shall include one or more of the
following requirements by the S. C. Coastal Council:

A.	An appropriate set back line from the site or structure shall
be maintained behind which development may take place.

B.	Appropriate vegetative buffers may be required to shield the
site or structure from adverse impacts of uses incompatible to
its special historic, archeological or cultural significance.

C.	A reasonable opportunity for professional investigation of the
site or structure may be required at the request of the S. C.
Department of Archives and History and/or the S. C. Institute
of Archeology and Anthropology.

30

    -------
following policies, while not enforceable, are recommended.)

1.	Developers are strongly urged to communicate earty-on with the
South Carolina Coastal Council to discuss plans for development in
order to work out potential problems and avoid unnecessary delays and
expense with regard to the review of their projects.

2.	Developers are encouraged to seek the assistance and advice of the
Hilton Head Island Historical Society, the S. C. Department of
Archives and Historv and the S. C. Institute of Archeology and
Anthropology in efforts to preserve historic and archeological sites
found on their properties.

3.	Because the above list of historic and archeological sites represents
the best information available at^Tesent and is not a totally
complete and up-to-date listing, it is recommended that a
comprehensive cultural resources survey of the area be conducted by
the appropriate agency or agencies as soon as fundine is availahl*'

31

    -------
APPENDIX A

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    -------
APPENDIX B. CUBIT ENGINEERING LTD.

CALIBOGUE SOUND DYE STUDY

    -------
EVALUATION OF PROPOSED SEWAGE OUTFALL
ON WATER QUALITY OF CALIBOGUE SOUND

JUNE 1902

submitted to

SEA PINES PUBLIC SERVICE DISTRICT

CUBIT ENGINEERING LIMITED
CLEMSON, SOUTH CAROLINA

    -------
TABLE OF CONTENTS

1.0 Executive Summary	1

2.0 Introduction	2

3.0 Field Program	3

3.1	Methodology	3

3.2	Results	6
4.0 Numerical Analysis	7

4.1	Numerical Model	8

4.2	Model Parameters	12

4.3	Model Calibration	13

4.4	Results o-f Outfall Analysis	15
5.0 Conclusions	16

References	18

    -------
1.0. EXECUTIVE SUMMARY

A water quality assessment of the proposed Sea Pines sewage
outfall in Calibogus Sound was conducted to estimate its impact
on the area's receiving waters. The scope of services consisted
of a field measurement survey to collect data for the subsequent
numerical model analysis that was performed.

The field study defined hydraulic parameters of the system.
In addition, Rhodamine-WT dye was injected and monitored for a
flood tide cycle to provide information on mixing and upstream
excursion of a pollutant. Dye did not advance beyond Middle Marsh
Island in Calibogue Sound during the period of the study;
furthermore no appreciable, amounts were found in Broad Creek or
the Cooper River past the mouth of Bull Creek.

Some dye entered Bull Creek but advanced no further
than about 6,000 feet upstream from the Cooper River. The
estuary is well mixed as evidenced from	measured

temperature/conductivity depth profiles. As a result injected
dye rapidly dispersed to concentrations ranging from an initial
value of about	to final readings of	at the end of

flood tide flow.

A version o-f the Dynamic Estuary Model was selected to
numerically simulate the estuarine condition*? the model
reproduced tidal flow in the system and calculated several water
quality parameters in response to the advection, dispersion, and
nixing phenomena of the estuary. The calibrated model was used
to simulate the effects on Calibogue Sound of adding a J^boyr <*9<*
discharge of secondary-treatment wastewater. The model showed

1

    -------
that the discharge located near Braddock Cov* would have no
effect on the water quality of the Sound or its tributaries.

2.0 INTRODUCTION

This report presents the results o-f an assessment :jf

effluent discharge in Calibogue Sound resulting from the proposed
Sea Pines sewage outfall. Approximately three million gallons
per day of secondary treated domestic sewage is being considered
for disposal in Calibogue Sound from the Sea Pines Plantation.
Figure 1 shows the general vicinity of the area and the location
of the proposed outfall. In order to assess the environmental
impact of waste disposal in Calibogue Sound and adjacent areas,
the Sea Pines Public Service District contracted with Cubit
Engineering Limited to investigate the outfall concept in terms
of its effect on water quality of the receiving waters.

The study was conducted primarily via a numerical model
analysis of the Calibogue Sound system to simulate the tidal
hydraulics of the area and the behavior of the effluent within
the Sound and its tributaries if continuously discharged into the
system. A field study was also performed to obtain data for
calibrating the model. Tide stage, current velocity and other
physical data were collected to describe the hydrodynamics of the
Sound. In addition, tracer dye was injected at the outfall site
and monitored through a flood-tide cycle to provide information
on dispersion and excursion characteristics within the system;
this was also done for model verification purposes.

2

    -------
his report describes the -field study and numerical model
is in greater detail in the following two sections. An
retation of the results is given in the last section in
of the impact of the outfall on local water quality.
ELD PROGRAM
ethodology

ata was collected in Calibogue Sound for purposes of
ating a numerical model. This section of the report
aes the field work performed and summarises the recorded
In general, the work consisted of injecting a large dose of
scent dye at the proposed outfall location and monitoring
ate of movement, spread, and extent of excursion in
jue Sound and tributary channels on a flood tide. The
«as conducted during March 16-18, 1982, at a time of Spring

>• dye was monitored using three small boats. Two were

s ^	_ .	10 fluorometers to measure the

with Turner Designs Mod©!

surface. Water was pumped

•ration of dye near the

,	via a small bilge pump and

'ously through the instrument

. ,. r,4.ed to tracing the movement of
;sembly. One boat was dedicated to

¦ . „i.hor	dispatched to various

ncioal dve cloud while the other was ax p

		 monitor dye movement into

nd tributaries of the estuary to monitor y

i.— 4 normation for the main boat,
channels and provide backup mormauon

:	., j injection at lQW"water, slack

ird boat performed the dye inJBtfclu

d collected numerous surface water samples in Broad

areas and provided logistical support to th o
t.. In addition, th. third boat w« r..p=n,ibl. for

3

    -------
measuring current velocity in the main channel near the out-fall
site.

Horizontal positioning was achieved on the main boat using a
Motorola Mini-Ranger III electronic distance measurer. A series
of -four transponder stations were erected onshore at known chart
positions (Figure 2). By measuring electronically the distance
between any two stations, the position o-f a boat could be
triangulated to an accuracy of + or - 3 meters. The second and
third boats used navigation markers and landmarks to
visually estimate location.

Fifty pounds of Rhodamine-WT dye was injected with the
assistance of a small pump mounted in the boat. Dye was pumped
in a continuous stream at a rate of 0.25 liters per minute while
the boat traversed the throat of the Sound. Approximately 43
minutes was required to deploy the entire quantity of dye in a
back and forth pattern at the surface of Calibogue Sound near the
proposed outfall site. Dye was injected during low^water
under calm wind conditions. In this manner, the dye remained
relatively concentrated prior to the initial stages of flood
tide.

Drogues were deployed in the dye cloud as a means to monitor
its relative movement up the Sound. Their use was principally
qualitative in nature serving as visual tracers to queue times
and locations of flourmeter measurement and maximum excursion of
the flood tide water mass.

Tidal stillwater elevations were measured at two locations
visually using tide staffs. Continuous measurements were made at
Braddock Cove and the Highway 278 bridge. Figure 2 shows the dye

4

    -------
SUBJECT

PIGGCS 2—

SHEET	OF

    -------
injection point and the tide measurement locations.

Measurements of dye concentration and tidal elevation

Mere made throughout the flood tide cycle until high water slack.

Data were recorded to map dye movement and dilution of the

principal dye mass in Calibogue Sound and in the tributary

Channels. Tidal current was measured at approximate Hal,-hour

¦ „	«„,h rtr-Pf	y .lectromaqnetlc current meter

intervals using a Warsn 			

sidecasted from an anchored position.

J,w a Martek instrument was used to
On the following day, a IZL	

^3i...ra depth and salinity in the
determine the pro-file of temperature, dp

. The Durpose O-f this task was to
water column of Calibogue Sound. The P

well mixed or exhibited any

determine if the estuary

tion. The individual water .ample.

characteristies of strar

„,ior dve concentration in the
collected during the day were read for

evening using the fluorometer*

'4 the various measurements made
Table I gives a summary o

The locations indicated are given in

during the field survey-

figure 2.	^

Location of Eieia Qsasuc-aants

table U MS Wssas

		Location

Measurement	^

Velocity	^^ c2> c3f C4f c3

SalinitY	ci, C2, C3, C4, CS

Temperature	various

Dye	various

Drogues	stations for

Location	bMt

    -------
3.2 ' Results

Results o-f the field study are summarisesd in Figures 3
through 7. Stage and current velocity data are reduced in
Figures 3 and 4. Measured dye concentration and characteristics
o-f the dye cloud shape and movement are given in Figures & and 7.
An indication of the degree of mixing experienced in Calibogue
Sound can be seen in Figure 5 by the almost vertical lines of
temperature and conductivity with depth; this is indicative of a
well mixed estuary as would be expected since there is no
substantial freshwater flow to the Sound.

Dispersion and dilution of the injected dye may be inferred
¦from Figures 6 and 7. Figure 6 shows the profile of the dye
cloud at successive time intervals as it progressed upstream in
Calibogue Sound toward Port Royal Sound. Each pro-file
represents the concentration of dye measured by the main boat
while it was anchored on station. In this manner a relative
measure of dye dispersion was obtained by measuring dye
concentration versus time as the cloud flowed past several
stations. The decrease in peak concentration and the lateral
spreading of the dye may be inferred by comparing the successive
measurements. Figure 7 summarizes peak dye concentrations
measured at each of the four monitoring stations. The
concentrations are presented with reference to the Initial
concentration of Rhodamine dye injected. This figure illustrates
the relative dispersion arTtf-mixing which cumulatively reduces the
concentration of dye as it mixes laterally and vertically with
the ambient waters of Calibogue Sound and the tidal prism.

Virtually no dye was observed in Broad Creek; this

6

    -------
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    -------
phenomenon probably occurred because of hydrodynamic momentum of
water flow northward in Calibogue Sound which hinders transport
across the relatively shallow entrance to the creek.

Dye entered the Cooper River at Haig Point but did not
continue past t-he mouth of Bull Creek at any appreciable
concentration. Instead, the main slug of tracer entered Bull
Creek but progressed no further than the first major bend in the
creek during this study.

Figure 8 summarizes the maximum excursion of the dye within
the study site as well as intermediate peak concentrations that
were measured.

4.0 NUMERICAL ANALYSIS

The second major component of the study consisted of the
development and calibration of a numerical model of the Calibogue
Sound area. The primary purpose of the model was to provide a
capability for predicting the effects of a potential effluent
discharge from the southern end of Hilton Head into Calibogue
Sound and its tributaries. The numerical analysis of water
quality in the system is based upon two primary processes: a
transportation process and a reaction process. The transport
process is hydrodynamic and includes advection, diffusion and
dispersion as welL as the forcing function of the tides and water
inflows from tributaries and waste sources. The reaction process
includes the sources and sinks of a constituent which affects
water quality in Calibogue Sound and that reaction which the
Constituent may experience including physical, chemical, and
biological processes. The reaction process can consist of

7

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sedimentation and f 1 occul ati on of organics, uptake of oxygen by
bacteria, the oxidation of waste and the decay rate of coliform

bacteri a.

4-1 Numerical Model

Several numerical models are currently available which could
be adapted to this problem. However, it was felt at the outset
that because the Calibogue Sound system is not extremely
wide, a one-dimensional model could be employed. The model
chosen for this study is essentially the Dyn^mi r	Model

which was presented by Orlob, et al. (1967), Feigner and Harris
(1970), and Callaway, Byram and Ditsworth (1971. This model does
have some minor modifications from the EPA version. This model
is quite similar to the receiving water part o-f the Storm Uater
Management Model with the exception of the addition of
dispersion. The. Dynamic Estuary Model has been used extensively
in estuarine situations to successfully model the hydrodynamics
and water quality.

The one-dimensional representation of flow in an estuary is
given in the Dynamic Estuary Model as:

3h m JL 9uA

at * ~ B 3 x 	(1)

3u

+	- kufuf + ef-cos a	(2)

— 1- U — - » 3x	-d

where: A	««	channel area

B	=»	channel width

d	®	channel depth

h	-	tidal stags

u	m	water velocity

_	m	friction coefficient from wind over the water
surface

f	»	angle between wind and channel alignment

w	*	wind velocity.

8

    -------
The hydraulic friction coef f i ci ent is:

n2

k 		j-rp	. „

(1.49) R ' 	U)

where:	n » Manning's roughness coef f i ci ent

R = hydraulic radius

No Coriolis effect is included in this representation due to
the dimensions of Calibogue Sound. After suitable changes are
made in the above equations, they can be written in finite
difference form. The solution of this set of equations proceeds
independently of the constitutive transport since the density of
the water is assumed constant throughout the system.
Discretisation of the equations of motion for the finite
difference scheme results in a system of channels and junctions.

explicit integration scheme, employing a two-step Runge-Kutta
3rocedure, is used to solve the equations.

The model simulates the tidal flow throughout the estuary as
:*used by fixed tributary inflows and a repetitious tidal forcing
»ction. The calculations produce at even intervals of A t a time
history of head, flow and velocity throughout the system,
"^se parameters are then used as input to the constitutive
!clUati ons.

The quality parameters that are considered in this study are
'^chemical oxygen demand  and temperature. These are modeled according to the
*neral transport equations

    -------
where:	c = concentration of constituent

E = a dispersion coefficient

E s = summation of sources and sinks of the
consti tuent

A source or sink could consist of a reaction with another
constituent. Consider first the relationship for biochemical
oxygen demand (BOD). The equation describing the distribution of
BOD throughout the system is:

ii+		<5>

at 3x ax* i

where L is BOD and K is the deoxyganation rate coefficient.
Likewise the equation for dissolved oxygen, DO is given bys

i£ + U i£ , E 1^7 - K L f K (C -C) -sb

3t 3x 3xz i 2 s	e	(6)

in which C is dissolved oxygen, K ^ is the reaeration rate,' C

the saturation level of dissolved oxygen, and S is th«

b

benthic oxygon demand. There are numerous other sources and
sinks that could be included in the equations. Although their in-
clusion would more closely approximate nature, these terms would
only add unnecessary complexity to this presentation without
enhancing the accuracy of the results.

The equation describing the transport of fecal coliform in
the system is given by:

3P . 3P _ 3*P „ „

3? + U			

10

    -------
in which is the conform concentration and K is the die-
away rate of the organisms. Equations (5), (6), and (7) describe
the transportation o-f L, C, and P in the estuarine system and
the interrelationships that exist among these three parameters.
These equations are not completely general but are adequate to
describe the system within reasonable limits. The assumptions
upon which this formulation is based are that:

1.	the properties o-f water do not vary;

2.	the longitudinal dispersion coefficient is constant

3.	the entire system is pseudo-one-dimensional;

4.	E is the same for all constituents; and

5.	there are no gradients in the vertical or transverse
horizontal direction.

The dependency of Equations (5) and (6) on temperature is through

, l<2 j and Cg . All three of these terms are temperature-

dependent. The saturation concentration of DO varies as:

C - 14.652 - 0.41022T2* 0.007991T2 - 0.000077774T3..(8)

s

for temperature T , given in °C . The deoxyg en at ion rate
:oefficient, Kj , is -functional ly related to temperature as:

ICj (T) ¦ Kj (20°C) [1.047] (T~20)	(9)

he reaeration rate coefficient, «2 , is a function of
^mperature as well as channel and flaw conditions. The
emperature dependency is given bys

K2(T) - K2(20bC) [1.024] CT~20)	(10)

11

    -------
SUBJECT

SHEET	OF.

• JOMCTIOM
CHAK)K)SL_

MODEL

SCH EM AT 12 ATI ON

CAU BOGUS. SOOMI>2 VICINITY
CUBIT gfMG»\igER>lVit3 L.MVHTBO y

    -------
Values of the equilibrium temperature are merely assumed as
input informati on for this particular estuarine system, since
adequate values of solar radiation, atmospheric radiation, long-
wave back radiation, evaporative heat -flux, and convective heat
flux are unavailable.

An explicit integration technique is used in the model to
solve the constitutive Equations (5), <6) , and (7). To minimize
the numerical errors associated with the convective transport
computation, the quartei—point difference solution technique is
used. This technique effectively minimises the pseudo-dispersion
transport and results in reasonably accurate and stable solutions
for adequate time steps in accord with the Curant conditions.

A schematic description of the Calibogue Sound estuarine-
system is shown in Figure 9. To adequately represent
the Calibogue Sound estuarine system a total of 63 channels and
60 junctions were used. The specific characteristics of the
tidal junction and channel data are given in Appendix A. That
cdata includes channel friction, velocities, and tidal elevations
for the initial conditions of the model. The data also include
the geometry of the con-figuration of the model, that is, the
channel—junction relationships.

*•2 Model Parameters

Operation of the model of Calibogue Sound requires the
dentification of several variables and adjustable parameters
lhat re-flect the mechanics, microbiology and chemistry of the
iystem. The hydrodynamics of the model are based on the tidal

12

    -------
variation at the ocean and at Port Royal Sound, the channel
geometry as presented in Appendix A, flow -from rivers and
outfalls,	channel	roughness coefficients and exchange

coefficient- A single value ;for the roughness coefficient
(Manning's n) of 0.025 was chosen to be representative throughout
the system. Obviously the value will vary throughout the real
system but based on the amount of available hydraulic data, it
was felt that a constant value throughout the system would be
most prudent. There was no significant external flow or
tributaries coming into the system therefore no additional inflow
was input to the model except for that coming from the proposed
outfall at Sea Pines.

In- the water quality model it is necessary to input the BOO
deoxygenation rate, DO reaera^ion coefficient, exchange
coefficient, equilibrium temperature, dispersion coefficient, and.'
decay coefficient for coliform. Additionally, it was necessary
to begin the model at some point, therefore initial condition*
had to be assumed. The model also requires boundary values for
the quality constituents—temperature, DO, BOD and fecal
coliform—at junction 1, the ocean, and junction 2, Port Royal
Sound. Values for the initial conditions are given in Table A.
Likewise values for the rate kinetics ari^ given in Table II.
Although the model has capabilities to incorporate benthic oxygen
uptake, it was decided not to include that factor at this time.

S Model Calibration

The hydrodynamic model was calibrated using the hydraulic
information that was measured in the field study of 16-18, 1982.

13

    -------
The model was compared with the field measured velocities
and water levels. A comparison of the measured tidal heights at
the Highway 278 bridge and at Braddock Cove are given in Figure
3. The measured tidal data are discussed in detail in the

TABLE II-. Rate Kinetics Used i_n Model

Parameter	Value

l/day

Reoxygenation	0.23

BOD Decay	0.23

Coliform Die-away	0.3

previous chapter of this report. A comparison of the velocities
obtained at Braddock Point from the model with the field survey
are shown in Figure 4. It is pointed out that the field result#
represent the highest velocities of the section across Calibogue
Sound and when adjusted to give a representative cross-sectional
average agree well with the model results. It is felt that
these results indicate very good agreement between the
hydrodynamics, the model and the* actual measuerements of the
system. Thus it is felt that the predictions that can be made
with the hydrodynamics of the system are adequate for the
evaluation of the effect o-f the proposed waste water discharge.
An interesting result of the hydrodynamics is that there is a net
flow of approximately 10,000 cfs through Calibogue Sound into
sort Royal Sound. Thus any continuously released substance will
3e transported into Port Royal Sound.

To calibrate the water quality aspects of the model it mas

14

    -------
necessary to simulate the instantaneous dye injection which is
discussed previously in this report. Comparisons of the field
and simulated data show good agreement (e.g. Figure 10).
Un-fortunately there are no data available to calibrate the
dissolved biochemical oxygen demand or coliform. In essence the
model is calibrated for the transport of the material with the
addition of some "acceptable rare kinetics.

4.4 Results o-f Outfall Analysis

To investigate the effects of the proposed wastewater
discharge attention was focussed on BOD, DO and fecal coliform.
It was assumed that the outfall discharged continuously at three
mgd (eight cfs) with the following concentrations
dissolved oxygen = 3 mg/1
BOD	* 30 mg/1

coliform	* 70 MPN/100 ml

Additionally summer conditions were assumed to prevail with ocean
waters at 26 °C rising to 28 *C inside the Sound and its
tributaries.

Simulations o-f water quality were made without the proposed
discharge for background or base conditions. Next, a simulation
was made including the wastewater discharge with the
characteristics presented above. The results of the two
simulations are nearly identical. There is less than one per
cent change in biochemical oxygen demand and no preceptable
change in dissolved osygen. The results are summarized in Table
III. The dissolved oxygen ranged from 6.0 ppm at the ocean
' boundary to as low as 3.03 ppm in the interior locations

13

    -------
c;, |R, IPPT	IQ	RHFFT	QF.

A

4

XT
s

k

—5

>
03



i

u.

h
<
~

w

w

2

S

2
o
P

uj

-7

2

UJ

S2

X

I

UJ

£

<£
A

30 -

%0

PELt>

OBSS ? VATIOM:

i ic?

|	2-	3

-TIME IM HOURS

I
8

I
J

0

CD

WAY IM UAA WE CONCEPT* ATI ONI
TIME OF TRAVE.L

Ik) CAU&OG.OE SOUN t? .
comp&sisoio o~ Mas^est> pisu> P4rA wm4

tSBUUTS OF MU/VlffEiCAC vptsBL, CAUSATION}

CUBIT ¦MOIIMMailvte LIIVIITBD r

    -------
IABLE I Hi. Summary of D1.s5gl.ved Oxyggn Dl_str l_but j.on irng/l_>
Location	Base Condition	With Outfall

Atlantic Ocean

6.0

syg®n in the Sound.

Similarly it was noted that the concentration of fecal
coliform did not change when the discharge was added to the
natural system. This can be readily verified by considering the
nixtura of 8.0 cfs containing 70 MPN/100 ml with a net flow over
1 tidal cycle of 10,000 cfs containing a concentration of 20
1PN/100 ml.

;.o CONCLUSIONS

The field study' together with the mathematical model
imulation have shown the hydrodynamie characteristics of
alibogue Sound and its tributaries. In particular the model
hows for the observed tide that there is a net flow of 10,000

16

    -------
;ubic feet per second (averaged over a diurnal tidal cycle)
through Calibogue Sound into Port Royal Sound. Most importantly
bhe study has shown that the discharge o-f three mgd o-f secondary—
wastewater would have no e-ffect on the dissolved oxygen
coli-form a-f Calibogue Sound and its tributaries.

:reated
3r -fecal

17

    -------
REFERENCES

Callaway, R. J., K. V. Byram, and G. R. Ditsworth,
"Mathematical Model o-f the Columbia River -from the
Paci-fic Ocean to Bonneville Dam," Paci-fic Northwest
Water Laboratory, Environmental Protection Agency,

Part 1, 156 p. (1969), Part 2, 130 p. (1971).

Feigner, K. D., and H. S. Harris, "Documentation Report
Federal Water Quality Administrati on Dynamic Estuary
Model," 0-f-fice o-f Water Quality, Federal Mater Quality
Administration, 248 p. (1970).

Orlob, 0. T., R. P. Schubinski, and K. D. Feigner,
"Mathematical Modeling of Water Quality in Estuarial
Systems, " Proceedings o-f the National Symposium on
Estuarine Pollution, pp. 646-673 (1967).

18

    -------
APPENDIX A

    -------
«»•«••••••«»••• •••••««•««««« CHANNEL DATA •»•««*••«•»*#« ««

IAN.

LCHCrtl

HI 01II

AREA

MANN 1NC

NET CLOW

ItYD. HAD I US

1

2950.

J 750.

106203.

0.025

9727.12

28. 3

2

3(100.

2'4i»0.

91819.

0.025

9726.09

30.3

3

2850.

1900.

82100.

0.025

9725.15

13.2

1

2100.

1550.

39103.

0.025

10183.23

25.'l

5

23JMI.

1100.

15381.

0.025

10183.23

32. i|

6

1200.

1600.

12271.

0.025

10183.19

26.1

7

1300.

1850.

52580.

0.025

10182.99

28.1

a

1300.

1550.

50217.

0.025

6117.29

32.1

9

1200.

850.

29239.

0.025

6117.30

31.1

10

1300.

150.

11565.

0.025

6117.27

32.1

11

I2U0.

't50.

>1113.

0.025

6117.2/

31.1

12

1300.

550.

16705.

0.025

6117.20

30.1

11

1200.

650.

21295.

0.025

6117.19

37.1

11

13H0.

650.

21015.

0.025

6117. 16

32.1

15

2700.

750.

17535.

0.025

6117.20

23.1

16

3800.

7oO.

17060.

0.025

6117.09

21.1

17

3100.

900.

21038.

0.025

6117.05

23.1

16

5100.

800.

13095.

0.025

2831. 10

16.1

19

1300.

700.

22650.

0.025

-6116.81

32.1

20

2700.

850.

16165.

0.025

3283.13

19.1

21

3800.

700.

11952.

0.025

-3263.10

21.1

22

1200.

1550.

59512.

0.025

1067.35

38.1

23

2100.

1050.

29828.

0.025

1067.32

28.1

21

3500.

1000.

20105.

0.025

1067.25

20.1

25

3100.

700.

15673.

0.025

1067.19

22.1

26

3300.

500.

10181.

0.025

1067.17

20.1

27

1000.

650.

13892.

0.025

1067.12

21.1

28

2200.

750.

12281.

0.025

1067.08

16.1

29

1500.

650.

18386.

0.025

1067.05

28.3

30

3000.

150.

10952.

0.025

-1067.00

21.3

31

6200.

1900.

55910.

0.025

-159.73

29.1

32

6000.

1900.-

52112.

0.025

-159.90

27.1

33

11359.

517.

6923.

0.025

-161.56

13.1

3*1

8159.

1718.

10217.

0.025

1.17

23.1

35

5022.

1312.

30729.

0.025

-116.58

23.1

36

1230.

1057.

21750.

0.025

117.81

23.1

37

6080.

1057.

22636.

0.025

-117.67

21.1

38

7U0O.

1057.

19167.

0.025

0.71

18.1

39

21911.

1057.

11185.

0.025

0.11

13.1

<10

3000.

1657.

192191.

0.025

10191.19

11.3

Ml

2816.

5950.

257970.

0.025

10193.83

13.1

12

5171.

1269.

99629.

0.025

162.66

23.3

13

3231.

1910.

55119.

0.025

162.13

28.1

11

9000.

617.

11903.

0.025

-161.78

18.1

'•5

7503.

1552.

28591.

0.025

0.75

18.1

16

7632.

1291.

23836.

0.025

0.56

18.1

17

13712.

906.

16680.

0.025

0.18

18.1

IB

6168.

3622.

59120.

0.025

1.23

16.1

19

6080.

t035.

23198.

0.025

0.91

22.1

50

5119.

1O50.

11088.

0.025

0.73

13.1

51

2261.

7111.

180507.

0.025

9728.15

25.1

52

3000.

1657.

192195.

0.025

10187.08

11.3

53

3000.

1657.

192193.

0.025

-10186.85

11.3

51

3000.

1657.

192197.

0.025

-10191.21

11.3

55

2816.

5950.

257976.

0.025

-10193.51

13.1

56

2261.

5950.

176507.

0.025

-9727.56

29.7

57

2950.

3750.

106209.

0.025

-9726.72

28.3

5ft

3000.

2100.

91821.

0.025

-9725.61

38. 3

59

2850.

\9Q0.

82099.

0.025

-9725.13

13.2

«««*•«*«•««»*	««*»«««»«*««•« JUNCTION DATA »*#•*¦•»#»#•»

JUNC.

AT ENDS

JUNC.

HEAD

CHANNELS ENTER 1NC

JUNCTION

51

39

1

3.Ml

52

0

0

0

0

20

55

2

3.10

19

30

0

0

0

3

56

1

3.11

58

3

0

0

0

1

5

1

3.11

59

1

31

0

0

5

6

5

3.1U

(t

5

0

0

0

6

7

6

3 .11

5

6

0

0

0

7

8

7

3.11

6

7

0

0

0

a

9

8

3.11

7

8

22

0

0

9

10

9

3.11

8

9

0

0

0

10

11

10

3.11

9

10

0

0

0

it

12

11

3.13

10

11

0

0

0

12

13

12

3.13

11

12

0

0

0

13

11

13

3.13

12

13

0

0

0

11

15

11

3.13

13

11

0

0

0

15

16

15

3.13

11

15

0

0

0

16

17

16

3.12

15

16

0

0

0

17

18

17

3.11

16

17

0

0

0

18

19

18

3.11

17

18

20

0

0

2

19

19

3.11

18

19

21

0

0

18

21

20

3.11

57

2

0

0

0

19

21

21

3.11

20

21

0

0

0

8

22

22

3.11

22

23

0

0

0

22

23

23

3.11

23

21

0

0

0

23

21

21

3.11

21

25

0

0

0

21

25

25

3.13

25

26

0

0

0

25

26

26

3.12

26

27

0

0

0

26

27

27

3.12

27

28

0

0

0

27

28

28

3.11

28

29

0

0

0

28

29

29

3.11

29

30

0

0

0

2

29

30

3.15

63

0

0

0

0

1

31

31

3.11

31

32

0

0

0

31

32

32

3.11

32

33

31

0

0

32

33

33

J. 15

33

11

0

0

0

32

31

31

3.15

31

35

36

0

0

31

35

35

3.15

35

37

38

0

0

31

36

36

3.15

36

37

0

0

0

35

36

37

3.15

3S

39

0

0

0

35

37

38

3.15

39

0

0

0

0

37

38

39

3.11

1

56

0

0

0

51

19

10

3.11

51

11

0

0

0

10

52

11

3.11

55

12

18

51

0

11

12

12

3.11

12

13

0

0

0

12

13

13

3.11

13

11

15

0

0

13

33

11

3.15

15

16

0

0

0

13

11

15

3.15

16

17

0

0

0

11

15

16

3.15

17

0

0

0

0

15

16

17

3.11

18

19

0

0

0

11

17

18

3.15

60

50

0

0

0

17

57

19

3.11

10

53

0

0

0

58

18

50

3.11

52

53

0

0

0

53

11

51

3.11

10

51

0

0

0

1

50

52

3.11

11

55

0

0

0

50

19

53

3.11

51

56

0

0

0

51

10

51

3.11

1

57

0

0

0

52

11

55

3.11

2

58

0

0

0

53

39

56

3.11

3

59

0

0

0

51

20

57

3.15

19

60

0

0

0

55

3

58

3.15

50

61

0

0

0

56

1

59

3.15

61

62

0

0

0 :

    -------
60

60B0.

1035.

23 199.

0.025

-0.83

22.'1

'ifl

57

6)

!>'i 19.

man.

I'KI9U.

0.025

O. 63

13.1

5fl

59

62

5'l 19.

2 nn.

2fl'i01.

0.025

0.57

1 3. '1

59

60

63

5*419.

2111.

20101.

0.025

-0.22

13.1

30

60

    -------
DATE: July 1, 1982

subject Hilton Head 201 EIS/W.Q. Assessment

from: Qiief, Facilities Performance Branch

to: Robert Cooper, Project Officer
NEPA Conpliance Section

I have reviewed the subject report and find it an acceptable basis to
reinforce our earlier recarmendaticn that a sound out fail 1 is environmental ly
acceptable. However the effluent assumptions regarding dissolved oxygen and
fecal coliform of 5 mg/1 and 70/100 ml do not appear to have any basis.
SCDHEC should be consulted regarding these. Secondary treatment does not
contain a dissolved oxygen requirement. Also, the flow considered is 3 M3D.
Yet this was changed to 8 cts. The inconsistency should be clarified.

John T. Marlar

EPA Form U20-6 (R*v. 3-76)

    -------
APPENDIX C. AUGUST 3, 1982 LETTER AND SEPTEMBER 1, 1982
RESPONSE REGARDING WASTEWATER REUSE

    -------
RECEIVED MJ6 - 6 1982

AUG V 1312

^ pr-1

I ' l . };. / l n o J i; L11 i r> c n , Ct i.

t'.M.agex , ll-c Pi net Public: Service.- District
P.O. Box :-i/.p.

Hilton Hoed Inland, Soutl: t'a t'Ol ir.a 2i'i2P
fce: Pi J Lor !ki-u Draft HIE
Di l r l-ji . LI1 icon:

l'PA if rev i i; tl.e proceus of cvsluatj rg ell the ccr>ricnte which
'•ore Ltc<-i.vvcv on the Drc.it CIS to that the finsl f.l t*.>rrativc>
c». looti en con k iande. lr the puLlic hearing held en tlx Draft
1-1P i-r-u i• lcJ.~QL<-c a vei y ii.tf.rer-tir.g altc motive . tPA ir i.lno
i i.tcrf rtxd i r. paxiir.izirg tl-c- reuse.- of wastewater «t veil a;.
Frc-ti et j ng f-hellf it";!"¦ v.atom. '-therefore , re believe that >out
>" Iternative (.'(-rc-rvef; a i-» o I c- thorough cnal'/iir? before out" final
" ('i^icr if i.i.oc .

• '-PA I 1.1, r.evcrnl ec-ncernr regarding vaLtevater mar.ager.cnt en
l'i J ton 1a a*. laiart.. In crd-er to fully con ci tier yet. r
<• 3 tei ],c.t ive, I an r treating thr-t you address: how y oi'r prcpc-ta.\
L f- i>c j vtthete cci cor na. Fi rtt, how and vl.er. does thi .<•
t-11<. i r.iit.i xv r <.povf wastewater dicchargc-e fron hevton Ccr.a 1
v'-ici: ctu^t tie i, eec! for t rhel 1 f i ah lo r veat i ng buffer cer.cV
•'¦ecci.',, v ;.at l.ind of back-up cyatei;. it propoaec eurir.g per iocs
°f high t ainiall or oqui[M< i t failure-? Vhire, why ic it
1 -o cc. cLity to pervice the o.irtir.g eeptic tank ar ear s ince
t'ULc ' l cnal} ai c ir.dicrtet; t> ptic t&nks at c l.ot causing the
nci,-point source pollution problems and very few diocur.ented
iaiav.ift ci tl.t re vu ster.e have bet n r.ctcd. Fcut thf l»ov dec s
tl'ir- a 3 tcri.ative avoid proi..otir»g l.igh der.rity gxcvtli and the
r^tultca t additiona l clo-curcc of chcl lliffh areec tsue to
non-pcir.t cource pclluticnV I'ir.clly, vhy dc ytu believe that a
recycle and reu~e cyi-ttin can be inpltiter.ted in a cert effective
and publicly ficci pta!>le Manner'.

RCocper/i;i,V/0 7-1 ^-82/Uf 0 300 X

cc :	_'rKandy Gi nbhc7

Fd banaL

OPU Rei-CIii.g File
PA'c PvOc.cj.ng File

    -------
-2-

To properly evaluate this new alternative which you have
proposed we request that you provide us with the following
specific additional information.

1.	Your proposal involves the expansion of the treatment
plant to 5.0 mgd. Please list the average monthly
flows which you project for this "ultimate build-out"
capacity.

2.	When is the expansion of the treatment plant to 5 mgd
expected to be completed?

3.	How does the PSD project to utilize the 1.75 MGD in
increased capacity at the treatment plant (i.e., how
much for existing homes on septic systems, how much
for individual vacant lots in existing developments,
and how much for new developments?)? When does the
PSD plan to initiate the removal of existing septic
systems from service and why?

4.	Please list the monthly flows which are currently
being applied to the two golf courses now in use.
Indicate monthly commitments which you have received
from the other courses which will be receiving
effluent.

5.	Please list the projected monthly loading rates for
the wetlands discharge area. What assumptions went
into projecting these rates?

6.	By month, what acreage of road medians, open space and
lawns will be required to dispose of the remainder of
the treated wastewater? Indicate on a map generally
where you expect these areas to be located. What
percentage of the road medians and open spaces are now
being irrigated?

7.	What are the drainage patterns of the proposed
disposal areas? How would your plan avoid direct
runoff of irrigated wastewater reaching surface waters
(e.g., irrigation waters hitting paved surfaces;
direct runoff into storm drainage systems, etc.)?

    -------
-3-

8. Generally describe the costs which will be associated
with the installation of this system. Costs should
include distribution to individual lots.

9.

10

How will cross connections be avoided when the lawn
irrigation system is set up?

,	anticipated from the potential human

What impacts are anut ?

contact with irrigated wastewater?

11 Describe what plans the PSD has for a back-up system

11. Descnoe wna1 * heavv rain or malfunction,
during periods of neavy to*..

u emu in addition to the current 1.8 mgd is
12'	p^d asking to discharge into Lawton Canal? For

I 1? How much additional acreage of shellfish
area lilV havfto^be closed for buffer,

13. How ,?»"	OTdTA as

existing norP on_point source problems caused by

increased growth and development?

I would lik.e. t0 n^nka/terfve. ^iVordef^o expedite
developing this new ait Piease submit your responses by
completion of the EI°' * for vour continued cooperation on
September 1, 1982. Thank you toi j

i. i •	•	.

this project.
Sincerely yours,

/s/ Howard D Z-^llor

Actinp,

Charles R. Jeter
Regional Administrator

°c: Roger Davis

    -------
SEA PINES PUBLIC SERVICE DISTRICT

P. O BOX 5 1 48

Hilton head island, s c. 29938
803/785-6224
41 BOW CIRCLE
PALMETTO Bay CENTER

September 1, 1982

Mr. Charles R. Jeter
Regional Administrator
United States Environmental

Protection Agency
345 Courtland Street
Atlanta, GA 3036 5

Re: Hilton Head Draft EIS
Our file 8-07

Dear Charles:

This is in response to your letter of August 3/ 1982 requesting
additional information on our alternative for wastewater reuse.
As stated in our presentation on June 23, 1982 at the public hearing
on the Draft EIS, there are a number of questions we have that will
take additional study and design before all the answers are available.
We are happy to provide what answers we can that should be adequate
for you to have confidence that our planned program will work.

For convenience we have listed the questions with our answers
in the order they appear in the letter. From page 1:

1. How and when does this alternative remove wastewater discharges
from Lawton Canal which cause the need for a shellfish harvesting
buffer zone?

The projected ultimate maximum daily flow to the plant is:

Sea Pines	2,358,082 GPD

Forest Beach	1,741,336 GPD

Total	4,099,418 GPD say 4.1 MGD

The ultimate flow for Sea Pires does not include areas currently
served by septic tanks. If all lots served by septic tanks were
added, the total peak daily flow would increase by 355,510 GPD for

a total of 4.5 MGD. it should be noted that the plant flows fluc-
tuate greatly with the seasons. Metered flows for the period March

    -------
Mr. Charles R. Jeter

- 2 -

September 1, 1982

In taking a conservative approach we estimate peak ultimate
flows during March through September to be 4.1 MGD and 3.1 MGD the

remainder of the year.

Experience has shown that individual golf courses use up to
600,000 GPD during the hot summer months, but this cannot be guaranteed
for each day. Again, using conservative estimates, the flows may
be reused as follows:

x. • « „rn-iprts for the golf course irrigation and a portion

Construction projects tor^ h^completed by December, 1982.

of the wetlands ^riga	d tQ 60o,000 GPD the first year, 1.0

The wetlands progr	mgd fche third year. If this program

MGD the second year ld'achieve a zero discharge within three
goes as planned, we could acnieve

or four years.

2. What kind of backup system is proposed during periods of high

rainfall or equipment failure.

„	. -a nf hiah rainfall discharge to the wetlands and

During periods o	continue. Golf course irrigation would

landscape irrigatio	tests prove that the wetlands can handle

be cut back or stopp •	^ per acre {^5 MGD for 50 acres)

the planned 30,000 g D}an for an additional 50 acres of wetland
then it would be safe to plan r	^ ^

to also handle up to 1.5 muv iuj.

v,	consider spray irrigation on half the

Another approach	rate of two inches per week, allowing

600 acre Forest	L h careful study and planning, we believe

a disposal of 2.3 MGD.	to 2#5 to 3<(J MGD ±n the Porest

it will be possible to discnarge

Most of the land in North Forest Beach and Shipyard Plantation

Most or rne xaj	Forest Preserve before Pope Avenue

originally drained	developments around the Preserve have diverted

was constructed. Land ae th/preserve. Thus, there has been a

storm drainage aw Y i th natural inflow to the Preserve leaving
considerable reduction in

capacity for additional inri

_ 1 «	t-hat equipment failure would hinder the operation

_ ls, UJ f J-riiity given the redundancy when the present
of the treatment fa leted (see Exhibit B). During periods of

plant expansion is d /tertiary)effluent could be discharged
extreme rainfall Since the proposed treatment level i?s 5 mg/1
fo^B^oTcK^nd suspended solids» the,effluent will be higher quality
than storm drainage from the land.

5 Golf Courses

Wetlands & Forest Preserve

Landscaped Irrigation

Total Reuse

Summer
2.0 MGD
1.5 MGD
0.8 MGD
4.3 MGD

Winter

1.0	MGD
1.5 MGD
0.6 MGD

3.1	MGD

Preserve.

    -------
Mr. Charles R. Jeter	- 3 -

September 1, 1982

3. Why is it necessary to service the existing septic tank
since DHEC's analysis indicates septic tanks are not causino th*

non-point source pollution problems and very few documented failures

of these systems have been noted?	xaxxures

We do not believe it is necessary to eliminate all the seDtir
tanks in the service area. However, we have sized the treatmeni-
plant to handle these areas should we need to serve them in the
future. As indicated in the answer to question 1, the seDtie tanir
areas require a treatment capacity of 355,510 GPD. By not
these areas the peak flow to the plant in the summer will not exceed

The District's policy has been not to force sewers on the nror^<-
owners using septic tanks. We do respond to petitions from nroDerS
owners asking for sewer service for subdivisions or to the health
department when they determine an area no longer suitable for seDt'
tanks. in either event the property owners have to pay the caDital"0
costs for extending sewers into the area. This cost usuallv nine
approximately $3,000 per lot.	y

4. How does this alternative avoid promoting high density orowth
and the resultant additional closures of shellfish areas due to
non-point source pollution?

The fact is that while the EIS was being prepared, Sea Pines
and Forest Beach were being developed out according to master Dlan
that were adopted in the 1960's., Exhibit E is a master map of theS
Sea Pines District showing the current stage of development We
were unable to get a similar map for the Forest Beach District in
the time allowed for this reply. However, after checking with the
Manager of the Forest Beach District and from our own knowledge
of the District, there are only two or three small uncommitted tract-«
available for development. The sewage collection system in both
districts will be loaded to their limits when the ultimate flow
of 4.1 MGD is reached. Massive changes in the collection systems
would be required to increase flows beyond their present planned
limits. Recent moves in Beaufort County and on Hilton Head to mini-
mize land use densities would also help present "up-zoning" of Dronert-w
now developed.	"Percy

5. why do you believe that a recycle and reuse system can be imDle-
rctented in a cost effective and publicly acceptable manner?	~

The pipe system used to transport effluent to the five golf
courses in Sea Pines and Shipyard Plantations pass near projects
requiring high volumes of irrigation water. This pipe system would
£>e modified as needed and extended to provide irrigation water to
iigh use areas. If the pumping from the Ocila is not reduced th#»n
the District will be faced with paying its share of the cost to
3ipe water from off-Island sites. This option will be far more
expensive than expanding an existing reclaimed water system within
-he District.

    -------
Mr. Charles R. Jeter

- 4 -

September 1, 1982

Reclaimed water has been used in Sea Pines and Shipyard for
four years, with great public acceptance. A more extensive system
has been in use in St. Petersburg, Florida, for seven years with
complete public acceptance. Reclaimed wastewater has been in use
in California since the early 1900's with complete public acceptance.
An extensive four year regional study on health effects of water
reuse in Whittier, Los Angeles County, California was completed
in July, 1982. (I believe the study was partly funded by the EPA.)
After four years of study, no health effects could be found at all
from the use of reclaimed water. Most, if not all residents of
the Public Service District are aware of the Ocala's declining capacity
and would welcome the opportunity to use reclaimed water in order
to conserve potable water. This was evidenced at the public hearing
by comments made by the Sea Pines Association of Property Owners
and by the Island Commission in support of our plan. We have also
had individuals request to connect to the new system serving the
golf courses.

In response to your questions on pages 2 and 3 the following
information is provided:

1. The average monthly flows expected at ultimate buildout would
be:

Month

Avq Daily Flow

Jan

1.6 MGD

Feb

1.6 MGD

Mar

1.8 MGD

Apr

3.6 MGD

May

3.4 MGD

Jun

4.1 MGD

Month

Avg Daily Flow

Jul

4.0 MGD

Aug

3.3 MGD

Sep

2.7 MGD

Oct

2.1 MGD

Nov

1.7 MGD

Dec

1.6 MGD

These average daily flows do not include wastewater from the septic
tank areas. It should be noted that the District has had to plan
the treatment plant for a peak daily flow assuming a near 100%
occupancy. Such a peak day will occur xn August, but not for each
day of the month. The reason August is not the peak month is because
the occupancy rate on the Island is very low the last week of August
due to school starting. The average daily flows for the winter
months are also projected at less than 50% of the summer flows.

There may be individual days during the holidays that exceed this
average but the occupancy in general during these months is very
low. These projections are made with the assumption that occupancy
rates will remain the same for the future.

2. The major components of the 5.0 MGD treatment plant are currently
under construction and will be completed in December, 1982. The
only components that are not adequate for 5.0 MGD are the sludge
digester, the tertiary filters and the disinfection system. Commitments
to provide service have been limited to 3.25 MGD because of the
inability to dispose of the excess treated effluent. These additional
components would be constructed according to a time schedule established

    -------
Mr. Charles R. Jeter

- 5 -

September 1, 1982

by DHEC under the "Consent Order." The timing will be based on
design, permit approval, construction and funding. Some of the
components mav be phased with the demand. Everything should be
completed within three to five years depending on the results- of
the wetlands monitoring program.

3.	As discussed in previous answers, the actual increase over the
present commitment of 3.25 MGD is only 850,000 GPD for a total of
4 1 MGD The septic tank areas will use an additional 355,510 GPD
if required. New development needs are approximately 550,000 GPD

and capacity for vacant lots in existing developments is approximately
300,000 GPD.

4.	The flow to the existing two golf courses are presented for
July, 1981 through July, 1982.

Total Gal/Month Avg Daily Flow
Month	Million Gallons		MGD

353	1.139
July .

Aug	missing

missing

Sept 20 6	0.665

0ct H'I	0.663

Nov H' 9	0.642

?eC 16 9	0.545

? 14! 6	0.521

Fek 14 1	0.455

Mar 5 X	0.170

APr 0*4	0.271

MaY 9'5	0.317

,51	0.810
July za"L

Sfrr-,, rhe low flows during April - June, 1982 were caused bv con

°n at the treatment Plant. The golf, courses had to use «6n
ter as a back-up that was not metered.	Use WeH

Formal agreements have been executed with the Sea Pine«s
:3*ny, owner of the four golf courses in Sea Pines Plantation 101
incSth the Hilton Head Company, owner of the 27 hole golf coL

Pyard for sPraVin9 treated effluent on the respective qolf
t "rfef* Each agreement commits to using treated effluent for •

tai irrigation needs. The Sea Pines Company is obligated fco
3 least 1.075 MGD for disposal on the golf courses or in the iwfe^Ve
jfeserve, and the Hilton Head Company is obligated to accept at
3iSSK 375'000 GPD* These commitments combined with the 1.8 MGD
ischarge to Lawton Canal accounts for the permitted 3.25 MGD plant

Pr°jected monthly loading rates were identified bv Wilhnv
-h^ and Associates in their report dated April, 1981, The inff-! v
J *e y®ars of operation were approved by DHEC using a constant
loading rate for each year. A monitoring program will be

    -------
Mr. Charles R. Jeter

- 6 -

September 1, 1982

conducted to determine the effect/ if any, for the three different
loading rates. They are:

The assumptions are based on soils tests, rainfall, evaporation,
and nutrient uptake by plant material. This report was reviewed
and approved by DHEC and by the South Carolina Coastal Council.

6.	Time does not allow us to provide acreage of road medians, open
space and lawns available for spray irrigation by your requested
response date. We have, however, completed a study of potable water
use for Sea Pines and the entire Island. Copies of the tables related
to Sea Pines and Forest Beach are attached as Exhibit C. We have
found that landscape irrigation for both Districts accounts for

an average of 668,000 GPD during the winter and 810,000 GPD during
the summer. Single-family houses in Sea Pines use an average of
600 to 800 GPD during nine months of the year with 25% of the customers
using an average of 2,3 78 GPD during the summer. The major portion
of this water is used for landscape irrigation.

Our goal would be to stop using potable water for landscape
irrigation and use, in its place, reclaimed water. We are not
suggesting that rates of application be changed by the existing
water users. Therefore, it may be somewhat meaningless to estimate
the acreage of lawns, etc., to be irrigated. From a preliminary
review we believe that we can reduce the use of potable water from
our groundwater supply by 2 MGD. A system supplying water in normal
quantities, as now experienced, to the landscape irrigation systems
as well as to the golf courses would use all the water the treatment
facility could supply. Such a system would save the District money
in expansion to its water system that would be required unless the
projected demand can be satisfied with reclaimed water.

Indicated on the enclosed map (Exhibit E) are locations of
approximately 130 acres of existing irrigated land in Sea Pines
and South Forest Beach that is adjacent to or close to existing
golf course irrigation distribution mains. At a rate of one inch per
week, this 130 acres would use 504,000 GPD. When adding other areas
to this such as Shipyard, North Forest Beach, Palmetto Bay, Harbour
Town, South Beach and single-family lots with irrigation systems,
we feel that our estimate of 0.8 MGD for summer and 0.6 MGD for
winter as stated at the beginning of this letter is conservative
indeed.

7.	The existing irrigation systems for landscaped areas use many
small sprinkler heads. Hilton Head is generally flat sandy land.
The existing and future irrigation systems could be inspected by
the District and heads could be adjusted to prevent runoff. In
general this is not considered to be,a problem.

/

198 3

1984

1985

xL, 600, 000 GPD
'1,000,000 GPD
1,500,000 GPD

18.250 Million Gal/month
30.417 Million Gal/month
45.625 Million Gal/month

    -------
w	_	- 7 -	September 1/ 1982

Mr. Charles R. Jeter	'

cost associated with a Sea Pines - Forest

8.	We cannot es 11	tem without more time and detailed planning.

Beach reclaimed wt £ those areas along the route of existing

The initial cost to p	, . reiatively low; however, we will

reclaimed water	tiary filters and disinfection system to

have to include the tertiary

meet DHEC requirements.

nrnnram will have to be established. We

9.	A cross-connection p g underground irrigation systems having

would allow connection y ^er areas such as St. Petersburg,

no hose bibs. We Will vise,7ot.ems to incorporate their experience
Florida, that have similar systems t

i	vrvrfv am

into our program.

n 1a„0i of treatment and disinfection, we would

10.	with the Pr°P°®®f . f om potential human contact with irrigated
expect no adverse imPac?	J Daper from the EPA titled "A Water
wastewater. We are enclosi:ng Jgburg, Florida" (Exhibit D). We
Quality Success Story - ft. Flora Mae Wellings, Director of
have retained the services Center of the State Department of
Florida's Epidemiology Res® . our preliminary work. We would
Health to consult with us au y _ on our treatment system if
Propose to consult with Dr. the reCyCie project.

we are given conceptual appr

. on the first page of your letter (item

11.	This question was asKe	question.

2) . Please refer to our answer xo

vstem is approved, we believe that

12.	if the reclaimed water sy allQwed 1#8 MGD discharge to Lawton
we will not exceed the Pre?®" I discharge to zero. If the Forest
Canal and will begin reducing J	for the five goif courses during
Preserve is not approved as.*,°h ve to discharge the golf course
extremely wet weather, we wixx ^ have pointed out, the quality
irrigation water to the can • ^an the surface runoff.

°f the discharge would oe better

^ „«« non-point problems. We explained
•*¦3. The plan does not a ^r, h maior portions of Sea Pines and Forest
at the public hearing that the ™*Jan/reCOmmendations for controlling
Beach are developed. All s ve]_0proent.
run off have dealt with n

• +.c are created by special legislation
The Public Service Distr.Assembly with specific responsibilities
of the South Carolina General Ass	granted to either District.

stated, linage is not	has enacted new development

Beaufort County has this f!}f°^oint pollution problems.

regulations that address the non v

show that increased growth

,	A look at the enclosed ^Ph«ltesponse is not possible.

eyond our plans discusse	conslderations of our plan and

,r review ana. ^molete your review. As
hon^ appPCXate<5wers are adeqU'ate _ questions we, cannot answer

°Pe that these answers y	are ®any

Pointed out several times, -

    -------
Mr. Charles R. Jeter

- 8 -

septemoer i, dusz

at this time, but we do feel that the facts presented are adequate
for approval to pursue the plan. Please contact me if we can be
of further assistance.

Very truly yours,

SEA PINES PUBLIC SERVICE DISTRICT
i- fj

R. Arnold Ellison, Jr., P.E.
Manager

RAE/apm

enclosures

cc: Roger Davis

William Foster

    -------
ACTUAL W. W.

FLOW AT SEA PINES

    -------
GENERAL PROCESS FLOW

i«ni«r

M1MU1

ci«nri(tl



SCHEMATIC

CIA*1NC»«

KlUTtO



fUMK -Wl
MMlCft©* lYSTt*
nfmom Ml

    -------
TABLE B-13

HILTON HEAD ISLAND
CURRENT WATER USE FOR SEA PINES PSD



Current
No. Units

Tot. Avg.
Winter
MGD

Tot. Avg.
Spring
MGD

Tot. Avg.
Summer
MGD

Tot. Avg.
Fall
MGD

Annual
Usage
10& Gal

Single-Family Residential

2,391

1.077

1.454

1.915

1.629'

546.75

^ondomi ni um/Mul ti-Family

1,649

0.756

0.320

0.434

0.368

169.02

Sprinklers

118

0.322

0.362

0.576

0.540

162.02

Restaurants & Lounges

26

0.043

0.066

0.0B4

0.059

22.53

Retail Shops

35

0.025

0.031

0.051

0.044

13.59

Offices

34

0.030

0.030

0.053

0.052

14.85

Other Commercial

21

0.009

0.010

0.016

0.017

4.68

Total

4,274

2.262

2.273

3.129

2.709

933.59

    -------
TABLE B-14





HILTON HEAD

ISLAND









CURRENT WATER USE FOR

FOREST BEACH PSD









Tot. Avg.

Tot. Avg.

Tot. Avg.

Tot. Avg.

Annual



Current

Winter

Spring

Summer

Fall

Usage



No. Units

MGD

MGD

MGD

MGD

106 Gal

Single-Family Residential

513

0.116

0.182

0.212

0.287

71.73

Condom i n i um/Mult i-Fami1y

3,163

0.519

0.690

0.882

0.693

250.56

Sprinklers

46

0.346

0.352

0.376

0.436

135.90

Restaurants & Lounges

19

0.018

0.024

0.025

0.017

7.55

Retail Shops

35

0.006

0.005

0.007

0.006

2.16

Offices

27

0.015

0.010

0.022

0.021

6.12

Other Commercial*

36

0.138

0.ZT8

0.156

0.157

60.21

Total

3,839

1.158

1.481

1.680

1.617

534.24

^Includes:













Adventure Inn (66 rooms) Hilton

Head Inn (200 rooms)

Holiday Inn (200 rooms) Sea

Crest (90 room

Winter 279 GPD/room



263 GPD/room



220 GPD/room



174 GPD/roo^n

Spring 550 GPD/room



360 GPD/room



321 GPO/room



332 GPD/room

Summer 545 GPD/room



456 GPO/room



361 GPD/room



445 GPD/room

Fall 300 GPD/room



422 GPO/room



222 GPO/room



310 GPD/room

    -------
TABLE B-ZZ

HILTON HEAD ISLAND
PROJECTED WATER USAGE FOR TOTAL DEVELOPMENT
AREAS 1, 4 & 5 SEA PINES PSD

Type Customer
Winter

Single-Family Residential
Condominium/Multi-Family
Sprinklers
Restaurants
Retail Shops
Office Buildings
3ther Commercial
Winter Totals

Total
No. Units

4,128
3,492
135
35
50
60
25

Avg Daily
Use/Unit
GPD

450
144
2,730
1,470
363
898

7,925

Total Avg
Daily Usage
MGD

1.858
0.503
0.369
0.198
0.018
0.054
0.011
OTT

Total
Qtr.Usage
105 Gal

167.22
45.27
33.21
17.82
1.62
4.86
0.99

270.99

Spring

Single-Family Residential	4,128

-ondomini um/Multi-Family	3,492

sprinklers	"5

Restaurants	35

detail Shops	50

)ffice Buildings	60

)ther Commercial	25

Spring Totals	7,925

608
194
3,064
2,500
617
1,298

2.510
0.677
0.414
0.338
0.031
0.078
0.012
O66

225.90
60.93
37.26
30.38
2.79
7.02
1.08
36373?

Summer

Jingle-Family Residential
londomi n i urn/Mul ti - Fami ly
Sprinklers
Restaurants
Retail Shops
Jffice Buildings
)ther Commercial
Summer Totals

:all

4,128
3,492
135
35
50
60
25

rm

>ingle-Family Residential

4,128

•ondomin i um/Mul ti-Fami ly

3,492

Sprinklers

135

Restaurants

35

letail Shops

50

•ffice Buildings

60

'ther Commercial

25

Fall Totals

7,925

800
263
4,880
2,500
490
1,711

681
223
4,580
2,500
351
1,675

3.302
0.918
0.659
0.338
0.025
0.103
0.019

"OP"

2.811

0.779

0.618

0.338

0.018

0.101

0.021

4.787

297.18
82.62
59.31
30.38
2.25
9.27
1.71

-mm

252.99
70.12
55.62
30.38
1.62
9.09
1.55
42T737

°tal Annual Usage

1 ,540.44

B-39

    -------
TABLE B-23

HILTON MEAD ISLAND
PROJECTED WATER USAGE FOR TOTAL DEVELOPMENT
AREAS 2 & 3 FOREST BEACH (FOREST BEACH PSD)

Type Customer

Total
No. Units

Avg Daily
Use/Unit
GRD

Total Avg
Daily Usage
MGD

Total
Qtr Usage
10 Gal

Winter

Single-Family Residential	603

Condominium/Multi-Family	2,958

Sprinklers	30

Restaurants	25

Retail Shops	50

Office Buildings	50

Hotel/Motel Rooms	731

Winter Totals	4,447

Spring

Single-Family Residential	603

Condominium/Multi-Family	2,958

Sprinklers	30

Restaurants	25

Retail Shops	50

Office Buildings	50

Hotel/Motel Rooms	731

Spring Totals	4,447

Summer

Single-Family Residential	603

Condominium/Multi-Family	2,958

Sprinklers	30

Restaurants	25

Retail Shops	50

Office Buildings	50

Hotel/Motel Rooms	731

Summer Totals	4,447

Fall

Single-Family Residential	603

Condominium/Multi-Family	2,958

Sprinklers	30

Restaurants	25

Retail Shops	50

Office Buildings	50

Hotel/Motel Rooms	731

Fall Totals	4,447

Total Annual Usage

197
164
6,652
969
142
543
235

213
218
7,660
1,279
169
528
364

371
279
8,173
1,293
191
820
430

325
219
9,472
909
166
779
317

0.119

0.485

0.200

0.024

0.007

0.027

0.172

1.034

0.128
0.645
0.230
0.032
0.008
0.026
0.266
T73IF

0.224

0.825

0.245

0.032

0.010

0.041

0.314

1.691

0.196
0.648
0.284
0.023
0.008
0.039
0.232
1.430

10.71
43.65
18.00
2.16
0.63
2.43
15.48
93.06

11.52
58.05
20.70
2.88
0.72
2.34
23.94
1205

20.16

74.25
22.05

2.88
0.90
3.69

28.26
152.19

17.64
58.32
25.56
2.07
0.72
3.51
20.88

128.70
508.95

B-40

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United Slates
Environmental Protection
Agency

Office of Water

Regulations and Standards (WH-551)
Washington, DC 20460

October, 1980

A Water Quality
Success Story

St. Petersburg, Florida

"Waste treatment management plans and practices
shall provide for the application of the best
practicable waste treatment technology before
any discharge Into receiving waters, Including
reclaiming and recycling of water. .

Section 201(b) - Water Pollution
Control Act Amendments of 1972

"St. Petersburg's attitude toward environmental
matters and toward regulatory agencies is remarkable
and refreshing. With persistence and good humor,
St. Petersburg has pursued a goal of water reuse*
Innovative techniques require careful documentation
and an abundance of patience. We are proud of St.
Petersburg on both counts."

K.J. Starzinger, State of Florida
Department of Environmental Regulation

ftice described by the Christian Science Monitor as "one or
America's ten most liveable cities," the City of St. Petersburg's
[uality of life is unique.

Located on the southern tip of semi-tropical, scenic Pinellas
Jounty on upper Tarapa Bay, St. Petersburg is cooled by the waters
nd breezes of Tampa Bay and the Gulf of Mexico. Nowhere in the
ity are you more than four miles away from open water. And
owhere else have people enjoyed St. Petersburg's Sunshine'Offer
- a free newspaper on days that the sun doesn't shine on the
ity, an offer made good only 259 times since the publisher of the
t. Petersburg Evening-Independent started it in 1910.

I

*V4I8.|T

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-2-

People flock to urban areas for many reasons — the promise
of profits in a booming local economy, the lure of high-paying
jobs in a dynamic industrial center — but people came to St.
Petersburg by the thousands to enjoy its waterways, its warm
cLinate, and its recreational and retirement opportunities.

Numbering a little over 100,000 in 1950, the city grew to
nearly a quarter of a million by 1977. Moreover, this city
increase has been matched by Pinellas County's growth. Today it
is Florida's most densely populated county.

This population explosion has had a heavy impact on upper
Tampa Bay's quality of life. And one vital aspect of that quality
is providing an adequate potable (drinkable) water supply.

ST. PETERSBURG IS A WATER SCARCE CITY

Much of Pinellas County's history is the story of a continual
search for potable water.

Florida is blessed with the Floridan Aquifer, a thick .
underground layer of potable water which, unfortunately for St.
Petersburg, becomes salty 500 feet under the city. A much
shallower aquifer is located from ground level to a depth of 150
feet, but its water smells of sulfur and is used only for limited
shallow well irrigation.

St. Petersburg's first public water supply was Mirror Lake in
1889, a water body located in the heart of the city, but
population growth soon outstripped the lake's capacity to supply
enough potable water and city officials looked for other sources.
These early attempts to find potable water, which included
drilling wells, were unsuccessful, except to prove that salt water
Intrusion has impacted Pinellas County's potable water.

St. Petersburg was water scarce In 1'930 when the city
purchased its first wellfield to the north of the city to develop
the Costne-~Odessa wellfield which still supplies the city by
pipeline today. .

As the population grew, so did the demand for potable water*
In 1962, St. Petersburg expanded its wellfield holdings by
acquiring the Lutz wellfield northeast of the city, and Weekl
Watehee Spring^. Today, it obtains potable water from its own
wells and from the wells of the West Coast Regional Water Supply
Authority.

Thanks to the foresight of a long line of city officials, to
ownership of its wellfields and approximately 50 miles of
transmission lines, and to its working agreements with the West
Coast Regional Water Supply Authority, St. Petersburg has an
adequate potable water supply through the year 2000.

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-3-

But time passes quickly# If the city decided to rely solely
on these present arrangements, how and where would it get potable
water after that?

TIIE CITY TAKES ACTION

Sack In the early 1960's, St. Petersburg had upgraded its
four waste treatment facilities in its northeast, northwest,
southeast and southwest areas to secondary treatment* While these
secondary facilities provided adequate treatment to their
lischarges into Tampa Bay, neighboring communities continued to
lischarge inadequately treated municipal wastes into the bay's
surface waters.

Aware of EPA reports which concluded that Tampa Bay's
ihoreline was highly polluted, and also aware that the Florida
.egislature was about to pass a strict water quality bill (the
'ilson-Grizzle Act of 197? which mandated advanced waste treatment
f all municipal and industrial discharges into Tarapa Bay), in
971 the St. Petersburg City Council authorized a research and

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-4-

engineering study to deterraine the most cost effective water
treatment program to conserve potable water and provide best
protection for the water quality of Tampa Bay and adjacent Boca
Ciega Bay.

Working with the Florida Department of Pollution Control, the
U.S. Geological Survey, and the firm of CH2M-HHI, St.

Petersburg's engineering consultants, the St. Petersburg Public
Utilities Department conducted a pilot study to determine the
feasibility of eliminating the direct discharge of the city's
treated waste effluent into Tampa Bay, and to evaluate the
effectiveness of using treated wastewater for spray irrigation
within an urban setting*

The study concluded that given St. Petersburg's potable water
shortage, spray irrigation using treated wastewater was more
feasible and considerably nore cost effective than advanced waste
treatment followed by discharge into Tampa Bay.

On the basis of these conclusions, St. Petersburg decided to
solve its wastewater disposal problem and its chronic potable
water shortage by using advanced secondary treatment and spray
irrigation of the treated effluent to its green areas to save its
potable water for drinking, bathing, and cooking. Once treated to
safe levels, the effluent would be transported by a distribution
system to spray irrigation sites such as city parks, golf courses,
school playgrounds, fields and lawns. Finally, a standby-
deep-well injection system would be constructed to place treated -
effluent underground during high ground water conditions or
extended periods of rainfall.

Determined to go ahead with its wastewater recycling program,
St. Petersburg gave it the green light by including it in its
capital investment program budget for 1972.

In a series of newspaper articles written to enlist financial
support from its citizens, the city conducted a massive public
education campaign to 'make them aware of its potable water
shortage, the need to recycle treated wastewaters for irrigation
to relieve this shortage, and also make them aware that the
Southwest Florida Water Management District had placed
restrictions on using St. Petersburg's potable water supplies for
irrigation.

On October 1, 1972, Congress passed the Federal Water
Pollution Control Act Amendments of 1972 which overhauled previous
«ater quality legislation and began the most comprehensive program
of wacer pollution control in the nation's history by mandating a
sweeping federal and state effort to clean up America's waterways.

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-5-

Shortly after the Act was passed, the St. Petersburg City
Council and representatives of CH2M-HHI approached the EPA's
Regional Office IV in Atlanta, Georgia, and the Florida Deparraent
of Pollution Control — known since 1975 as the Florida Department
of Environmental Regulation — in Tallahassee for implementation
funds for a major water recycling program for treated effluent,
cooplete with effluent distribution, spray irrigation and
underground storage.

The City Council bbtained 75 percent federal implementation
funding for the project. These funds, and the money raised by the
city from the sale of revenue bonds, provided the capital to
expand and upgrade the city's existing waste treatment facilities
to advanced secondary treatment, and to plan, design and construct
pipeline distribution systems, deep-well injection systems, and
spray irrigation facilities.

Since the projected irrigation sites were accessible to the
public, the degree of treatment to be determined at the treatnent
plants was of considerable concern, for the city wanted to avoid
human enterovirus-induced public health hazards from the treated
effluent.

Working with Dr. Flora Mae Wellings, one of the world'*
leading environraental virologists and Director of the Florida
Epidemiology Research Center in Tampa, and with the U.S.

Geological Survey and the Florida Department of Natural Resources,
St. Petersburg provided most of the money for a research effort to
develop best practicable treatment to eliminate human
enteroviruses — polio, Coxsackie, and enteric cytopathic human
origin (ECHO) — all of which produce sickness in human beings
ranging from stomach upsets to polio, meningitis and heart disease
present in treated wastewaters sprayed on land.

ENTEROVIRUS REMOVAL ACTIONS

A test project conducted by Dr. Wellings and her staff showed
:hat human enteroviruses present in secondary wastewaters seeped
:hrough Florida's sandy soil, and that enteroviruses from these
wastewaters were present in ground water at depths of 10 and 20
feet after rainfall.

Working with Dr. Welling's staff, CI^M-Hill's engineers
letermined that the safest approach from the public health
tandpoint was to remove enteroviruses in wastewater during
rcatment before spraying these waters on land surfaces.

Dr. Wellings' staff and CH M-Hill conducted a follow-up study7
o test various types of filter aids and filter materials. Data
rom this study showed rhat alum fed into t>ie wastewater stream
efore it passes through a sand and charcoal multi-media filter
ystem, followed by a 30-jpinute chlorination contact period, was

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the most effective method for removing enteroviruses. The
effluent would then receive further, extended chlorination in
covered effluent storage tanks, and additional chlorination during
transport to the irrigation sites, when necessary.

As a result of these investigations, the alutn-fed multi-media
system — which enhances solids-associated enterovirus removal —*
was adopted for all of St. Petersburg's advanced secondary
treatment plants.

FEDERAL CLEANUP ACTIONS

In a letter written on May 19, 1974, to the EPA Regional
Administrator in Atlanta, the St. Petersburg Audubon Society
urgently requested that EPA construction grants to upgrade and
expand the city's Southwest Wastewater Treatment plant be approved
as soon as possible.

"We urge your prompt approval," the letter began, "of the
grant to the City of St. Petersburg for its Southwest Wastewater
Treatment Plant improvements provided under the Federal 1972 Water
Act.

"Ihis will be the first major plant in the country to
accomplish zero discharge to surface waters, total wastewater
reuse and recycling, and best practicable wastewater treatment.
The plans for this facility are of major importance, both iocally
and nationally, as an example of what can be accomplished. Your
approval of the grant can start our city on the way to the
ultimate goal of your agency and the Congress. Further, and of
great importance, is a ruling of the Southwest Florida Water
Management District prohibiting the use of potable water for green
areas. This, together with increasing salt water intrusion, will
place the reuse of treated wastewater for irrigation as the sole
dependable source for golf-courses, parks, and other critical
areas vital to our quality of life.

"We believe the accomplishment of the city in the research
and planning that has been done merits immediate approval of these
funds."

The EPA responded.

On July 14, 1974, the EPA awarded St. Petersburg $14 million
to expand and upgrade its 9 million-gallon-per-day capacity
Southwest Waste Treatment Plant to provide advanced secondary
treatment for 20 million gallons per day of municipal discharges,
and also to construct an effluent distribution system, deep-well
injection systems, and spray irrigation facilities.

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-7-

To spray
irrigation sites

\l

Wastewater in

Wastewater Basin
for backwashing
of filters

Chlorine
Contact
Basin



Multi - media
filters









Flow Schematic, Southwest Wastewater Treatment Plant and Recycling System
(Courtesy, CHZM-HILL, Engineering Consultants)

On line in 1977, the new treatment facility — known am elm
Southwest Wastewater Treatment Plant and Recycling System —
consists of the following:

•	An activated sludge advanced secondary treatment plant
which removes 90 percent of the biochemical oxygen
demand (a measure of the organic matter In water which
consumes oxygen during biological processes that break
it down) and suspended solids in its discharges*
Treatment includes grit removal, aeration (using oxygen
to break down organic wastes) and clarification
(reducing the concentration of suspended matter In
water).

•	The advanced secondary treatment processes include alum
addition, multi-media filtration of suspended solids,
flash chlorination for enterovirus disinfection, and
covered effluent storage tanks to meet night peak
spraying demands. This system produces water which
meets the present Florida numerical standards for
potable water, except for nutrients which are used for

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-8-

urban irrigation. The chlorination and multi-media
filtration system reduces enteroviruses to a
non-detectable level. The effluent has a clarity of
about 2.0 Jackson Units (a measure of turbidity in
water); Florida's clarity requirement for drinking water
is no more than 5.0 Jackson Units.

•	An effluent distribution and spray irrigation system
which uses all of the treated effluent except during
periods of heavy rainfall. The spray irrigation system
is compatible with the need for water and nutrients of
the plant life being treated. Thus, nature provides
final treatment to state drinking water standards
through its controlled nutrient consumption, returning
high quality water to the ground water table.

•	A 20-million-gallon-per-day capacity deep-well injection
system which places treated plant effluent underground
during periods when total plant production cannot be
used.

The Southwest Wastewater Treatment Plant and Recycling System
is served by a master pumping station located at the storage
tanks. This facility can either pump treated effluent into the
Southwest recycled wastewater distribution system — identified by
brown-painted, yellow-striped hydrants and completely separate
from the potable water distribution systeo which brings water into
St. Petersburg from the north — or to the deep-well injection
systeo as a backup during heavy rainfall. Recycled water system
components located above ground are color-coded and shaped
differently than those of the city's potable water distribution
systeo, ensuring that potable water and recycled water will not be
mixed.

On June 27, 1975, the EPA awarded St. Petersburg $18.8
million to expand and upgrade its 8 million-gallon-per-day
capacity Northeast^ Wastewater Treatment Plant to provide advanced
secondary treatment for 16 million gallons per day of municipal
discharges, and also construct an effluent distribution systeo,
deep-well injection systems, and spray irrigation facilities.

This facility went on line in mid-1980.

Then on September 31, 1978, the EPA awarded St. Petersburg
§33.4 nillion to expand and upgrade its 9 million-gallon-per-day
capacity Northwest Wastewater Treatment Plant to provide advanced
secondary treatment for 20 million gallons per day of municipal
discharges, and also construct a pumping station, force mains, an
effluent distribution system, and spray irrigation facilities.

This plant is expected to be operational in 1982.

Apart from differences in treatment capacity, the Northeast
and Northwest facilities are identical in design to the Southwest
plant.

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-9-

Finally, between September 1979 arid March, 1980, the EPA
awarded St. Petersburg $348,220 to design a diversion sewer
system, pumping stations, and structural modifications to its
conventional 19-raillion-gallon-per-day capacity secondary
Southeast Wastewater Treatment Plant, which still discharges into
Tampa Bay. Projected to be constructed and operational by the
nid-1980's, these ancillary facilities will divert 6.6 oillion
gallons per day of this plant's municipal discharges to the
Southwest facility, and 6.2 million gallons per day to the
Northwest facility for treatment and spray irrigation. The
Southeast facility's remaining 6.2 million gallons per day of
treated wastewater will be distributed, as needed, to the
metropolitan spray irrigation system.

RESULTS

According to St. Petersburg Public Utilities Division
Director Vincent D. Patton: "By using recycled water for
irrigation, St. Petersburg has reduced its peak demand upon
potable water sources in areas that are presently being sewered by
as much as AO percent, effectively forestalling the day when more
potable water pumping and transmission facilities will be needed.

"In addition, the cost effectiveness of this unique
wastewater treatment and recycling system is shown by the fact
that capital costs, operating and maintenance costs, and energy
requirements are about half the cost of a conventional advanced
wastewater treatment system. This is because nutrient removal,
the most costly treatment cycle, is completed by nature.

"In December, 1976" Patton says, "the total capital cost of
the Southwest Wastewater Treatment and Recycling System u*s $19
million. We've estimated that an advanced waste treatment system
discharging into Tampa Bay and meeting Wilson—Grizzle Act
requirements for a treated effluent containing no more than 5
milligrams per liter (mg/1) of biochemical oxygen demand, no more
than 5 mg/1 of suspended solids, and no more than 3 and 1 mg/1 of
nitrogen and phosphorus, respectively, would have cost
approximately $40. million.

"Finally," Patton says, "assuming that only half of the
treated wastewater is sold to commercial customers at the going
rate of $1.00 per acre per month, as the rest of the effluent
Ust^lbution system is completed and additional spray sites are
:onn£cted, we expect a very large increase in the amount of
reclaimed water use for this purpose. We intend to have this
system pay for its operating costs."

There are other outstanding, long-tera benefits.

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-10-

"Land acquisition," says Patton, "a major capital outlay in
any irrigation program, has been eliminated fron the St.

Petersburg system. Private and public landowners have provided
green spaces at no cost and have agreed to pay the city for using
treated effluent.

"St. Petersburg," Patton concludes, "has limited the use of
potable water for irrigation by confining it to lawn-sprinkling on
small land parcels. Today, treated wastewater distribution
systems are being extended to each of the city's quadrants. In
1980, approximately 1,000 acres are under irrigation, and
thousands more will be irrigated once the new distribution systems
are completed. Finally, ftreated wastewater piped to color-coded
hydrants connected to the distribution system also provides fire
protection for the local citizen."

The Southwest Wastewater Treatment Plant and Recycling System
has the distinction of being the first regional plant of its kind
in the nation to produce an effluent in which human enteroviruses
are not detectable.

"Over the years," Dr. Wellings 6ays, "ny staff has monitored
the wastewater from this facility. We've found that when design
criteria are met, no enteroviruses can be demonstrated in the
chlorinated effluent. Even during start-up periods when
malfunctions usually occur,, and before effluents are discharged
into the distribution lines, enteroviruses are demonstrated very
rarely.

"The probability of contracting an enteroviral infection from
exposure to these effluents is so remote," Dr. Wellings
emphasizes, "that I consider it almost nonexistent. Actually, the
chance of contracting such an infection from friends and relatives
is far more likely. However, be cautious. First of all, I don't
intend to drink the effluent to prove my point, but on the other
hand I wouldn't be concerned! if I stood near the spray field. Any
contact except actually swallowing the effluent — which could
cause stomach upsets — doesh't worry me."

Known for her wit as well as her scientific accomplishments,
Dr. Wellings adds another precaution. "Murphy's Law," she says,
"is still in effect: "If anything can go wrong it will.' There
must be careful and continued supervision of all aspects of this
waste treatment system. If a breakdown does occur, disposal
methods other than spray irrigation must be used immediately.
However, provisions for these emergency alternatives are built
into the St. Petersburg system."

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-11-

EPILOCUE

According to Joseph Franzmathes, Director, EPA Region IV
Office of Program Integration and Operations: "St. Petersburg's
accomplishment is most noteworthy. For it is one of the very few
cities to have gone through the full research and implementation
cycle of enterovirus removal to the point that it enlisted the
services of a noted virologist to ensure, once and for all, that
there would be no health hazard to human beings exposed to its
treated waters.

"I am equally enthusiastic about St. Petersburg's emphasis on
water reclamation in a water short area, for it will certainly
have a beneficial, long-range effect on any future water
shortages. There's absolutely no question that in terms of civic
responsibility and innovative sanitary engineering, St. Petersburg
is an extremely progressive community."

In April, 1977, the Southwest plant catapulted St. Petersburg
into the national limelight when the National Society of
Professional Engineers selected the project as one of the ten
outstanding engineering achievements of 1976.

It should be noted that this achievement received equal
recognition with another example of technical virtuosity; the
Viking Mars Landing Spacecraft, one of the other nine recipients
honored that year.

(We wish to thank CH_M-Hill, Engineering Consultants, Clearwater,
Florida, for allowing us to use its article New Water. This
informative publication has provided much of the material used in
:his story.)

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