Kentucky Straight Pipes Report Harlan, Martin, and Bath Counties


^	m United States

bv Environmental Protection
M	Agency

December 2002

Kentucky Straight Pipes Report

Harlan, Martin, and Bath Counties

Prepared bv:

U.S. Environmental Protection Agency
Region 4

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Table of Contents

Page

Introduction 	1

Executive Summary	1

Background	2

Areas Assessed During June 2002 	6

Wastewater Treatment Options	9

EPA Recommendations	12

References	14

List of EPA, State, and Local Participants	 Appendix A

Summary of Photographs	 Appendix B

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Introduction

During June 25th-27th, 2002 representatives of the U.S. Environmental Protection Agency,
Region 4, the Kentucky Division of Water, and the Kentucky Health Department toured various
communities in Harlan,

Martin, and Bath counties in
eastern and central
Kentucky (Figure 1) to
assess the extent of
unpermitted sewage
discharges from "straight
pipes" and determine if an
alternative wastewater
demonstration project was
feasible in addressing the
water pollution issues. This
report provides background
on straight-pipe and other
wastewater problems,
summarizes the areas that
were visited during the

EPA/KY site assessments, and provides a summary of the viable options to address the
wastewater treatment issues. A complete listing of the EPA and State representatives who
participated in the site assessment are presented in Appendix A.

Executive Summary

The poor sanitary conditions and water pollution problems EPA observed in the Kentucky
counties of Harlan, Martin, Bath, and Montgomery were of the highest concern. The widespread
scale of both the straight pipe issues as well as package plant wastewater problems present an
environmental crisis which deserves attention from all levels of government. These conditions are
unprecedented in the United States and in many cases are comparable to the water pollution
problems that were prevalent in the 1950s and 1960s, prior to the Clean Water Act. At the
current rate of investment in the solutions to these problems, many more generations of
Kentucky citizens will continue to live under the same conditions that face many developing
countries. The Commonwealth of Kentucky, however, is to be complimented on their
recognition of the problem and the solutions they are currently implementing, which are outlined
in this report.

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Concerning the overall wastewater treatment problems, it was apparent that more than one
general solution should be considered in order to meet the wastewater needs of the region. These
solutions can be broken down into three categories. They are: (1) connection to an existing
wastewater plant that has the capacity; (2) cluster systems; and (3) on site systems.

Additionally, Kentucky should continue to investigate all sources of funding, implement reliable
and proven low-tech wastewater systems as opposed to package plants, and investigate the most
cost-effective means of sewering communities where needed. EPA involvement is crucial as the
estimated total cost to address this wide scale problem is over $3 billion dollars (based on The
States 1994 NEEDS Survey).

The original purpose of this project was to select a community for a pilot project which would
demonstrate concepts presented in EPA's "decentralized wastewater systems" initiative. EPA
believes that the Preston community in Bath County is an excellent location for a demonstration
project. A strong owner/manager was present (electric coop), land is available for treatment, and
the community is fairly compact. Dr. Richard Otis, a recognized national expert had been
retained for his technical knowledge. The City has already purchased the land for construction of
a wastewater treatment system and raised more than $150,000 towards project costs. The project
has also secured $235,000 from EPA's 319 program, and an additional Regional Geographic
Initiative grant proposal has been submitted to Region 4 for $75,000. A contract for design of the
collection system has been awarded to a local engineering firm, and development is underway. A
design-build contract for the 30,000 gallon/day treatment/disposal system will be advertised and
awarded by February 2003. Completion of the entire system is slated for late 2003. Efforts to
develop a program for promoting the demonstration project and facilitating technology transfer to
neighboring communities and local engineering firms have been initiated by East Kentucky Power
Company and other partners, and will be ongoing for the next two to three years.

Background

Since the implementation of the Clean Water Act, the US-EPA in conjunction with the State
Programs has been successful in identifying, permitting, and regulating most of our nations point
source discharges. Additionally, the EPA has been successful in providing federal funding to
construct wastewater treatment facilities to meet secondary limitations (currently over 3000 major
municipal facilities of greater than 1 mgd flow in the U.S.). Although the Clean Water Act has
been monumentally successful in reducing water pollution from point source discharges, many of
our nations communities are still without access to adequate sewage collection, treatment, and
disposal.

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EPA estimates that approximately 40 percent of Kentucky households are not connected to a
centralized sewer system. According to the Kentucky Division of Water's 1998 Report to
Congress on Water Quality, approximately 33 percent of the rivers and streams in the state are
impaired with high levels of pathogens due to improper waste disposal. The source of much of
this pollution is the
unpermitted discharge of
untreated sewage from
poorly maintained or
failing septic systems.

Some of these septic
systems have failing
drainage fields that leach
septage directly into a
nearby ditch or stream
Over the years, some
Kentucky residents who
could not afford a septic
system have improvised,
utilizing metal drums and
even refrigerators as
septic tanks. Most failing
septic systems simply
have a straight pipe that

transports raw or partially settled sewage directly into the closest ditch or stream (Figure 2). This
problem has been severe enough that in some areas of Kentucky swimming and fishing advisories
have been issued due to high fecal coliform bacteria levels. In its annual survey of waterways, the
Kentucky Division of Water lists several streams in eastern Kentucky - including the North Fork
of the Kentucky River, the Upper Cumberland River and a small portion of the Licking River -
that could make swimmers sick.

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Figure 2: Straight Pipe, Martin County, KY

According to a June 26th, 2002 article appearing in the Lexington Herald newspaper, it is
estimated that approximately 207,000 people living in the 17-county central Kentucky area
depend on failed septic systems or poorly operated package wastewater treatment plants. The
number of new homes being built without centralized sewer systems is estimated at 52,000 for the
17 county central Kentucky area, and it is expected that 32 percent of the people living in the
region in 2020 would still not be connected to a sewer.

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Figure 3: Package Plant, Hindman, Kentucky

Adding to the water pollution
woes are poorly operated and
maintained wastewater
package plants. Package
plants are small-scale
wastewater treatment plants
that are purchased and
installed as a complete
fabricated unit (Figure 3).

Because the entire treatment
process is housed in a single
unit, package plants are cost-
effective and do not require
large tracts of land. They
have been widely used in
remote areas of Eastern and
Central Kentucky to serve
schools, subdivisions, rest
areas, commercial
establishments, and mobile
home parks. It was originally
held that because of the long
detention time in the
biological portion of the
package treatment process
(Figure 4), that the biological
cell mass would consume
itself, thus no sludge
management and disposal was
necessary. This has proven
to be grossly in error, as
package plants actually
generate solids in the

treatment process, which subsequently must be properly managed and disposed of. Thus, a
package plant requires some degree of operator attendance and expertise, including careful
attention to process control and adequate management of the wastewater solids. However,
because many small communities lack money and trained staff, most package plants are poorly

Figure 4: Aeration Tank, Hindman, Kentucky

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operated or in some cases, are not operated at all. Consequently, the solids that are produced in
the package plant build up and ultimately are discharged into the receiving stream. This results in
high concentrations of sewage sludge, nutrients, and pathogens that contaminate the rivers and
streams. Because of the large numbers of poorly operated package plants, the Kentucky Division
of Water has made efforts to reduce or eliminate package plants and has moved to "Regionalize"
wastewater treatment. In the 1994 report Reeionalization of Wastewater Treatment Facilities in
Kentucky, the KY-DOW concluded that the large numbers of package plants were a cause of
great concern for present and future water quality in Kentucky. EPA's experience in other
Region 4 states has shown similar concern and problems with package plants. The State of
Tennessee has documented numerous problems with package plants and enacted legislation in the
mid-1990s that prohibited the installation of package plants for flows less than 15,000 gallons per
day.

In 1997 the Commonwealth of Kentucky formed an organization known as PRIDE (Personal
Responsibility In a Desired Environment). The PRIDE initiative was formed to provide the first
comprehensive, region wide, state/local/federal funding to clean-up of the regions rivers and
streams of sewage and garbage while ending illegal trash dumps, promoting environmental
education, and renewing pride in southern and eastern Kentucky. PRIDE has provided funding
for about 3,500 new septic systems in the past year with plans to replace some 14,000 more with
$9 million in federal funds earmarked for the program, according to Janet Bridges, chief financial
officer for the organization. Along with the $9 million in federal money for grants to poor
homeowners, PRIDE has made $15 million available to cities and counties to extend sewage lines
into areas without service. In August 2001, the Commonwealth of Kentucky announced a
"straight pipe" initiative, a program which focuses on eliminating straight pipe discharges in 40
counties of eastern and central Kentucky. It is estimated that 36,000 homes in this area have
failed septic systems or straight pipe discharges.

Although PRIDE has been successful in correcting many of the regions wastewater woes, the
problem of straight pipe discharges is still widespread. Many of eastern and central Kentucky's
communities need to be sewered and equipped with an on-site wastewater treatment system or a
full-scale municipal wastewater treatment plant. It is estimated that Kentucky will need over $3
billion dollars of funding to address the wastewater problems throughout the state (States 1994
NEEDS Survey). EPA believes the cost for eastern Kentucky alone to be in the $1 billion dollar
range. Just eliminating the current straight pipe situation is estimated to cost in excess of $300
million dollars. Thus, it is critically important that this problem receive attention from all levels of
government.

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Areas Assessed during June 2002

Harlan County:

Figure 5 shows the location of the communities of Path Fork, Cawood, and the Town of Evarts,
Kentucky. All are located in Harlan County. This region has historically been a coal mining area
located in the heart of the Cumberland mountains, which is characterized by moderate to steep
hillsides and narrow valleys. Large open tracts of land are minimal, which places constraints on
wastewater treatment options. Consequently, small-scale wastewater package plants are
prevalent. There are 18 community water systems and 355 companies that have been issued
NPDES permits to discharge wastewater, including 21 package plants. Harlan county has a
population of approximately 33,202 with 15,017 housing units. Figure 5 also shows photographs
from each community. A complete summary of EPA photographs is attached in Appendix A.

Path Fork, Cawood, and Evarts are located along tributaries of the upper Cumberland River and
each had numerous examples of "straight-pipe" discharges.

Figure 5: Harlan County, Kentucky

Community of Pathfork, KY

Wastewater Package Plant: Evaits, KY

Septage from C awood, KY Motaile Horn e Park

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Martin County:

Figure 6 shows the communities of Warfield and Lovely Kentucky, and the Town of Kermit,

West Virginia. These communities are part of the Tug Valley Sewer Authority and include more
than 1300 households (estimated). The sewer authority encompasses six communities with two
community drinking water systems and three schools. The communities are located along the Tug
River, which flows into the Big Sandy River along the Eastern Kentucky-West Virginia border.
Martin County, Kentucky has a population of 12,578. There is one community water system and
221 NPDES wastewater discharge permits, including 4 package plants.

Figure 6: Martin County, Kentucky



Strai^it Pipe: Kermit, WV

Straight Pipe: Warfield, KY

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Bath County:

The community of Preston, Kentucky is shown in Figure 7. Preston is located in Bath County in
East Central Kentucky and is part of the Slate and Hinkston watersheds of the Licking River
Basin. The topography in this area is not as restrictive as the mountainous region of eastern
Kentucky, and consists of moderately steep and rolling hills ranging from 700 to 1300 feet above
sea level. Large open tracts of land make this region feasible for lagoon type wastewater
treatment systems. Bath County has a total population of 11,085 with approximately 4,994
housing units. There are 3 community water systems, 11 NPDES wastewater discharge permits,
and 3 package plants.

Figure 7: Bath County, Kentucky

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Montgomery County

The community of Sid Caulk Lake located in Montgomery County was also visited during this
assessment. Concern was expressed that septic systems at numerous homes around the lake were
causing pollution problems. Examination of the bacteria data that the Health Department had
gathered for this community did not indicate a problem severe enough to cause public health
concerns. EPA feels that the slightly elevated bacteria levels can best be addressed by correcting
problems with individual on-site systems that are not functioning adequately.

Wastewater Treatment Options

During the EPA visit, it was apparent that more than one solution should be considered in order
to meet the regions' wastewater needs. These solutions can be broken down into three
categories. They are: (1) connection to an existing wastewater plant that has the capacity; (2)
cluster systems; and (3) on-site systems. Table 1 shows a list of projects which were financed by
the U. S. Corp of Engineers in Eastern Kentucky. This data was obtained from the Kentucky
PRIDE website. It is assumed that the costs presented are total cost estimates. This data was
examined because it was readily available, and could give a snapshot of the cost of providing
wastewater service in the area. The sample is too small, and there are too many unknowns with
regards to the project data to draw any firm conclusions.

1. Connection to existing POTW

This data does support the logical conception that if an existing treatment plant is close-by and
has capacity, the cheapest solution for unsewered communities is to connect to the plant.
Unfortunately, this solution is not always available due to the remoteness of many communities,
or the lack of capacity at a near-by treatment plant.

It is suggested that alternative, small diameter sewers which utilize septic tanks at each residence
be considered for communities which are within range of a POTW. Small diameter sewers can be
built for substantially less money than conventional sewers. Where conditions for installing pipe
are less than favorable due to rock, poor soils, high water table, etc., the costs savings can be even
more substantial compared to conventional sewers.

EPA Region 4 personnel visited a town in Tennessee which added a subdivision to the town's
wastewater plant using small diameter sewers. Using attenuation in the system and the septage
pumping station, they were able to pump off-peak, thus not overloading the capacity of the
treatment plant.

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PROJECT

COST

RES

S/RES

TYPE

Means Community (Menifee County)

$300,000

$3,333

B urns i de Col 1 ecti on S ys tern (P ul as ki County)

$1,100,000

287

$3,833

S ally S te\ens Branch (F loyd County

$300,000

$5,000

LS & S

Corbin - S amps on S treet S ewer Line Extension (Laurel County)

$81,400

$5,427

Royalton - Watewater Treatment and S ewer Line E xt. (Magoffin Co)

$1,125,000

205

$5,488

Paintsville - Greentow/n S ewer Line Extension (Johnson County)

$330,000

$5,500

City of Allen(Floyd County

$472,000

$7,867

LS & S

Mi ddl es borough - Ches ter and P arker S ewer L i ne E xt (B el 1 Co)

$344,300

$9,305

Mountain Water District - S outh Williamson S ewer (Pike County)

$3,820,000

371

$10,296

Hardshell /Caney Creek Area (Breathitt County)

$825,000

$11,786

Letcher - Cluster Treatment System (Letcher County)

$382,800

$12,760

Jenkins - Forest Hills S ewer Collection (Letcher County)

$342,100

$14,874

North Fork Clean Water Project (Letcher County)

$485,000

$16,167

Lovely (Martin County

$99,800

$16,633

Vicco - Wastewater Treatment Plant (Perry County)

$2,454,400

132

$18,594

Elkhorn City (Pike County

$780,000

$23,636

City of Whites burg / Long B ranch (Letcher County

$635,000

$28,864

$13,876,800.00

1531

$9,064

CS - Cluster system

L S & S - L ift S tation & S ewer

SS - Complete conventional sewer system

S - Conventional Sewer

TP - conventional treatment plant

TABLE 1

2. Cluster Systems

A cluster system is generally considered to be a system which serves two or more households.
Larger systems serve entire subdivisions. A cluster systems provides treatment close to the point
of generation. Cluster systems are not new. Typically they were used for developments which
were remotely located. Conventional sewers and package, activated sludge wastewater plants
were the overwhelming choice of systems installed.

Package Plants have been a source of problems for state regulators. In the document,
Reeionalization of Wastewater Treatment Facilities in Kentucky: Progress. Problems. &
Recommendations, written by the Kentucky Division of Water, the problems with package plants
are well documented. Other Region 4 states have also documented problems with package
treatment plants. The State of Tennessee documented similar problems and enacted legislation
which prohibited package plants for flows less than 15,000 gallons per day. However, Tennessee
State Inspectors indicated they had documentation which showed severe performance and
compliance problems with many package plants, regardless of design flow. The 15,000 gpd flow
rate was a political compromise.

Activated sludge is a complex wastewater treatment process which requires highly trained
individuals to properly operate and maintain the system. Small communities are often unable to
hire and retain operators with the skills necessary to run one of these systems. Poor operation

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and maintenance has been the leading cause of the failure of these systems. Even large
communities have problems with these systems.

Kentucky also noted that package plants lacked proper O&M due to poor management. The
Division of Water further states in this document, "Kentucky's DOW has endorsed a policy
developed by the U.S. EPA of encouraging the consolidation of the physical operation of
wastewater treatment and/or the responsibility for overseeing the service, where possible. "

EPA's initiative on Decentralized Wastewater Systems recognizes that management of the system
is usually the most important factor when failures of these systems are examined. Management
entities which do not have the legal authority, financial resources, personnel resources, and the
flexibility to coordinate and change, are not likely to prosper in the wastewater business.

Wastewater treatment systems have been developed over the past couple of decades which do not
have the considerable O&M burden that activated sludge systems require. These systems which
are described in several EPA publications, which are listed at the end of this report, are relatively
simple and easy to maintain and operate when compared with activated sludge. EPA Region 4
personnel have had considerable experience with lagoon systems, intermittent sand filters, and
recirculating sand filters, all of which are examples of proven and reliable low-tech wastewater
systems.

3. On Site Systems

During the June 2002 EPA site assessments, several on-site systems were seen or discussed
including constructed wetlands, peat systems, individual retention lagoons, and recirculating and
intermittent sand filters. EPA encourages the state to evaluate the effectiveness of different onsite
treatment systems. EPA's Onsite Wastewater Treatment Systems Manual. February 2002, should
be consulted in this endeavor and presents methodology for evaluating system performance. The
Kentucky concept presented in the document on regionalization which places a single responsible,
entity in control of all wastewater treatment, including onsite systems, in a geographical area, is
an attractive idea.

However, Kentucky DOW has recognized that many topographic and geological characteristics
place constraints and adversely affect the performance of septic systems. Many existing septic
systems in Kentucky were installed prior to the enactment of state regulations requiring proper
installation. Consequently, many of these older systems continue to cause problems.

As a component of the PRIDE initiative, PRIDE, in association with the local Area Development
District (ADD) and Resource Conservation and Development District (RC&D), has established a
grant program for low-income homeowners to hook onto an existing sewage treatment line or to
install a septic system. To date, more than $1,300,000 in grant funds have been awarded to
homeowners in the PRIDE region. To qualify for a grant, the homeowner must meet the HUD
poverty guidelines, be the deed holder, and must have existing electricity at the home.

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EPA Recommendations

Recommendations for Wastewater Demonstration Project.

Some of the communities that were visited, such as the Sunshine community near Harlan,
are close enough to a wastewater plant with capacity such that connecting to the existing
wastewater plant would be the best solution for the community. Other communities, such
as Warfield will probably be better served by a large central system.

EPA feels that in order to have success in the decentralized arena, a strong
management/owner must be identified. Although the trailer park at Crummies Creek
presented an attractive project, it lacked a strong management entity. Without this
necessary entity, EPA does not feel that this system would be sustainable. However, it
was about the right size (20-30 trailers), was compact, and had land available for a
treatment system.

Recommendations concerning "Straight Pipe " and other Wastewater Issues:

The Kentucky Division of water should continue to implement the concepts and ideas
contained in the document, Reeionalization of Wastewater Treatment Facilities in
Kentucky: Progress. Problems. & Recommendations. EPA believes this is an excellent
document which lays out a good, viable plan for solving the State's wastewater problems.

Kentucky should continue to investigate and seek all possible sources of funding. The
States 1994 NEEDS Survey documented over $3 billion dollars of wastewater funding
needs in the entire state. EPA believes the cost for eastern Kentucky alone to be in the $1
billion dollar range. Just eliminating the current straight pipe situation is estimated to cost
in excess of $300 million dollars.

On-site systems should continue to be evaluated. All systems are not equal, and todays
solution can often become tomorrow's problem. Many different systems have been tried in
Kentucky. Some of the systems that EPA saw or discussed with state personnel have a
questionable technical basis. An objective evaluation of these different system
performances under local conditions should eliminate some systems, and provide some
standardization. Care should be taken not to stifle innovation.

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For collection systems, alternative, small diameter sewers should be used wherever
possible. These systems are one of the more important developments in wastewater
technology in many years. Properly used, they can represent an impressive savings over
conventional sewers.

Where possible, low tech, easy-to-operate wastewater treatment plants should be strongly
promoted for small communities. Package, activated sludge plants have historically been
plagued with numerous problems. Systems which utilize other technologies, such as
lagoon systems or intermittent sand filters, are available at lower capital cost and
considerable lower O&M cost. The one disadvantage of these systems is land
requirements which may be considerably larger that the land required for an activated
sludge system. This will be a challenge for Eastern Kentucky, where suitable land for
construction is often difficult to obtain.

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-References-

1.	Dave Harmon, "Straight Pipe Dilemma: We All Live In a Watershed', Kentucky Division
of Water, http ://kywatersheds. org/straight_pipe_dilemma.htm.

2.	Mike Davis, "Lack of sewers poses health threat for many", Lexington Herald-Leader,
June 26th, 2002.

3.	U.S. Census Bureau, Census 2000 Report, http://www.census.gov/

4.	U.S. Environmental Protection Agency, Envirofacts,
http ://www. epa. gov/enviro/index i ava. html

5.	Roger Alford, "Appalachia Residents Clean up Waste", Associated Press.

6.	U.S. Environmental Protection Agency, 1985. Technology Assessment of Intermittent
Sand Filters. Office of Research and Development, MERL, Cincinnati, Ohio

7.	U.S. Environmental Protection Agency, 1980. On site Wastewater Treatment and
Disposal Systems. Office of Research and Development, MERL, Cincinnati, Ohio

8.	U.S. Environmental Protection Agency, 1991. Alternative Wastewater Collection Systems.
Office of Research and Development, Office of Water, Washington, DC

9.	U.S. Environmental Protection Agency, 1992. Wastewater Treatment/Disposal for Small
Communities. Office of Research and Development, Office of Water, Washington, DC

10.	U.S. Environmental Protection Agency, 2002. Onsite Wastewater Treatment Systems
Manual. Office of Research and Development, Office of Water, Washington, DC

11.	Laura Risler, Reeionalization of Wastewater Treatment in Kentucky. Kentucky Division
of Water, June 1994.

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Appendix A

Listing of EPA, State, and Local Representatives

Personnel

Organization

Phone Number

Bruce Henry
Mike Bowden
Diana Woods
Lee Colten
Rob Miller
Ted Withrow
Pamla Wood
Clark Allison
Mike Matto
Sally Purvis
Celia Barker
Scott Drake

EPA, Region 4
EPA, Region 4
EPA, Region 4
KY-DOW, Frankfort
KY-DOW, London
KY-DOW, Morehead
KY-DOW, Frankfort
NRCS-USDA

Gateway District Health Department
Montgomery County Health Department
Bath County Health Department
East KY Rural Electric Co-op

404/562-9754

706/355-8734

404/562-9438

502/564-3410

606/878-0157

606/784-6635

502/564-3410

606/789-7706

606-674-6396

606-498-0719

606-674-2371

859-744-4812

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Appendix B
Summary of EPA Photographs:

« 'V

Straight Pipe Drainage: Path Fork, Kentucky
(Harlan County)

Straight Pipe Discharge: Kermit, West Virginia

Straight Pipe:Preston, Kentucky
(Bath County)

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Straight Pipe Drainage: Kermit, West Virginia

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Straight Pipe: Martin County

Straight Pipe Drainage: Preston, KY





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Failed Septic System: Preston, KY

Infiltrator Drainage System: Preston, KY

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Failed Septic System: Preston, KY

Septic drainage: Preston, KY

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Straight Pipe: Martin County, KY

Straight Pipe:Martin County, KY

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