Policies Available to Local Governments for Sewage Treatment and Disposal Systems on Coastal Barrier-1989

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POLICIES AVAILABLE TO LOCAL GOVERNMENTS
FOR SEWAGE TREATMENT AND DISPOSAL SYSTEMS
0 ON COASTAL BARRIER ISLANDS
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SOUTHERN SHORES, NORTH CAROLINA
PROPERTY OF
DIVISION OF COASTAL MANAGEMENT
PLEASE DO NOT REMOVE

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O Policies Available to Local Governments for Sewage
Treatment and Disposal Systems on Coastal Barrier Islands
Southern Shores, North Carolina
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David J. Brower
Anna K. Schwab
Ann B. Weeks
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September 1989
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The preparation of this report was financed in part through a grant provided
by the North Carolina Coastal Management Program, through funds provided by
the Coastal Zone Management Act of 1972, as amended, which is administered by
the Office of Ocean and Coastal Resource Management, National Oceanic and
Atmospheric Administration.
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© Policies Available to Local Governments for Sewage
Treatment and Disposal Systems on Coastal Barrier Islands
Southern Shores, North Carolina
Table of Contents
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ExecutiveSummary. . . . . . . . . . . . . . . . . . . . . . . . . .
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Sewage Treatment and Disposal Systems: Question and Answers . . . . .
. v
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I. Development on Coastal Barrier Islands . . . . . . . . . . . . .
. 1
II. Coastal Barrier Island Characteristics: Implications for
Wastewater Treatment . . . . . . . . . . . . . . . . . . . . . .
. 4
a. The Unique Attributes of Barrier Islands. . . . . . . . .
. 4
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b. Vegetation . . . . . . . . . . . . . . . . . . . . . . . .
. 5
C. Barrier Island Zones: Suitability for Development. . . .
. 5
d. Barrier Island Soil Composition . . . . . . . . . . . . .
. 8
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e. Sewage Treatment on Barrier Islands . . . . . . . . . . .
. 9
III. Overview of Federal and State Wastewater Treatment and
Disposal Regulation . . . . . . . . . . . . . . . . . . . . . . .
. 13
a. Regulation in North Carolina . . . . . . . . . . . . . . .
. 14
b . The Federal Clean Water Act . . . . . . . . . . . . . . .
. 16
.IV. Methods for Sewage Treatment and Disposal . . . . . . . . . . . .
. 19
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a. Conventional Septic Systems . . . . . . . . . . . . .
. 19
1. How Conventional Septic Systems Work. . . . . . . . .
. 20
2. Regulation of Septic Systems . . . . . . . . . . . . .
. 23
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A. Septic Tank Regulation: Jurisdictional Lines
Between CHA and Local Government Units. . . . . .
. 23
B. Pre-emption of Local Boards of Health Rules . . .
. 24
_C. _Minimum Criteria for Septic Tank Regulations. . .
. 25
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D. Enforcement Provisions . . . . . . . . . . . . . .
. 26
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3.
Problems and Issues Associated with the Operation and
Regulations of Septic Tanks . . . . . . . . . . . . . .
27
A. Maintenance and Operation . . . . . . . . . . . . .
27
B. Septic Tanks and Barrier Island Land Use Planning
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C. Management Issues . . . . . . . . . . . . . . . . .
32
4.
Some Options for Local Governments. . . . . . . . . . .
33
b. Alternative Treatment Systems and Disposal Systems. . . . .
34
1.
How Alternative Treatment Systems Work. . . . . . . . .
35
A. Systems that Discharge to Surface Waters. . . . . .
36
B. Land Disposal Systems . . . . . . . . . . . . . . .
37
2.
Regulation of Alternative Treatment Systems and
Disposal Systems . . . . . . . . . . . . . . . . . . . .
42
A. DEM Permitting Authority: Minimum Design
Criteria . . . . . . . . . . . . . . . . . . . . . .
42
B.
Regulation of Public Utilities: Performance
Bonding Requirements . . . . . . . . . . . . . . . .
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C.
Homeowners' Associations: Operational Agreements
Required for DEM Permits . . . . . . . . . . . . . .
44
D.
Local Permit Programs . . . . . . . . . . . . . . .
45
E.
Enforcement Provisions . . . . . . . . . . . . . . .
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F.
Municipal Enabling Legislation. . . . . . . . . . .
49
G.
The Pre-emption Issue . . . . . . . . . . . . . . .
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i. Local Boards of Health Rules. . . . . . .
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ii. Regulation of Sewage Treatment and Disposal
Facilities Through Zoning . . . . . . . . . . .
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Through Zoning
3. Problems and Issues Associated with the Performance and
Regulations of Alternative Systems. . . . . . . . . .
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A.
System Performance . . . . . . . . . . . . . . . . .
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B.
Land Use and Planning Issues. . . . . . . . . . . .
69
C. Public Management Issues . . . . . . . . . . . . . . 71
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4.
Some Options for Local Governments. . . . . . . . . . .
72
A. Actions that can be Taken to Address Land Use
Planning Issues . . . . . . . . . . . . . . . . . .
73
B. Actions that can be Taken to Address Public
ManagementIssues . . . . . . . . . . . . . . . . .
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V. Policies
and Actions Available to Local Governments. . . . . . . .
75
a. Introduction . . . . . . . . . . . . . . . . . . . . . . . .
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b. Local
Actions Aimed at System Performance . . . . . . . . .
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1.
More Stringent Regulations for Septic Systems and
Alternative Systems for Which County (DHR/DHS)
Permits are Issued . . . . . . . . . . . . . . . . . . .
76
2.
County -wide or Municipal Programs to Track Septic
System Performance . . . . . . . . . . . . . . . . . . .
77
3.
Municipal, County, or Intergovernmental Programs to
Monitor Alternative System Performance. . . . . . . . .
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4.
Municipal, County, or Intergovernmental Programs for
the Permitting of Alternative Systems . . . . . . . . .
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5.
Local Government or Special Purpose Authority Assumption
of Responsibility for Operation and/or Maintenance of
Privately Constructed Alternative Systems . . . . . . .
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6. Land Controls on the Issuance of Building Permits . . . 81
Q 7. Local Authority to Abate Public Nuisances . . . . . . . 81
8. Local Water Conservation Programs . . . . . . . . . . . 82
c. Local Actions Aimed at Solutions to the Planning Issues
Raised by Alternative Systems . . . . . . . . . . . . . . . 83
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1. Prepare Local or Regional Plans for the Preferred
Location and Siting of Alternative Treatment and
Disposal Facilities . . . . . . . . . . . . . . . . . . 83
2. Revise Land Use Plans and Zoning to Reflect Island
O Carrying Capacity . . . . . . . . . . . . . . . . . . . 85
3. Prohibition of Alternative Systems in Certain
Zoning Districts . . . . . . . . . . . . . . . . . . . . 86
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4. Special Use Permit Requirement for Alternative
Systems. . . . . . . . . . . . . . . . . . . . . . . . 87
5. Environmental Impact Assessment for Developments Q
Utilizing Alternative Treatment and Disposal Systems. 87
References. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 90
Appendix A Organization Chart of the New North Carolina Department O
of Environment, Health, and Natural Resources
Appendix B Case Studies
Appendix C Memorandum of Agreement to Perform A Water Quality Management
Program in Wake County, N.C. Q
Appendix D Water Quality Work Plan for Mecklenburg County, N.C.
Appendix E A Proposal to Establish an Operation and Maintenance Program for
Sewage Treatment and Disposal Systems in Orange County, N.C.
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Appendix F "Package Sewage Plants: Burden or Breakthrough?"
Appendix G "Wastewater Management: Alternative Small Scale Treatment
Systems."
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Many people have contributed to the preparation of this document, too many to
mention here; but we do want to express our appreciation to Bruce Bortz,
Chariman of the Southern Shores Planning Board, for his many contributions
throughout the life of the project, from conceptualization to printing.
David J. Brower
Anna K. Schwab
Ann B. Weeks
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Q Executive Summary
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North Carolina's barrier islands are experiencing substantial growth and
development pressures. The very factors that make the islands so attractive --
their location and special ecosystems --also limit their ability to support
intense development.
The geography and geology of North Carolina's barrier islands have
especially important implications for the facilities needed to treat and
dispose of the sewage generated by the increasing year-round and summer
populations. The standard methods for sewage treatment and disposal --
conventional on -site septic systems, and publicly owned treatment plants that
discharge treated wastewater to surface waters --are problematic for use on
barrier islands. Less than half of the soils on the Dare County barrier
islands are suitable for conventional septic systems. The limits on their use
range from an inability to accommodate the extent of the local demand for
development, to presenting a threat of environmental damage if used to support
development at any level. Surface -discharging treatment works are not
feasible due to limitations in state law and regulation concerning water
pollution, particularly the discharge of potential pollutants to shellfishing
waters.
Faced with barrier islands' limitations for conventional sewage treatment
and disposal systems on the one hand, and their attractiveness to development
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on the other, the private development community has developed a solution --
privately owned and operated alternative treatment and disposal systems.
Alternative systems overcome many of the natural and regulatory constraints on
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more traditional means of sewage treatment and disposal, and therefore permit
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development in particularly fragile areas where development was formerly
infeasible. In addition, funding and staffing of existing state programs for
monitoring the performance of alternative systems has not kept pace with the
proliferation of alternative systems.
These alternative systems, which are regulated and permitted by the
state, pose several difficult legal and public management issues for county
and municipal governments seeking to control the rate and quality of
development on barrier islands. They include the nuances of the relationship
between the state permitting process for the systems and local governments'
authority to control the location and extent of development, and the
responsibility of the local government in the event of a system failure.
State law and regulation somewhat limit county and municipal governments'
authority to directly control the design and permitting processes for
conventional septic systems and alternative systems. There are, however,
several possible responses that concerned local governments can take to gain
more control over these treatment and disposal systems and their impacts.
These responses include actions aimed at controlling the systems' performance,
and actions aimed at controlling their location, in order to better control
the location and intensity of development activities.
Section V of the report outlines potential strategies which local
governments can pursue, including:
• More stringent local regulations for septic systems and alternative
treatment facilities
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• County or municipal programs to track system performance Q
• County, municipal, or intergovernmental programs for system permitting
• Local government assumption of responsibility for system operation and
maintenance
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• Local or regional planning for the preferred location and sizing of
alternative systems
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• Revision of local land use plans to reflect island carrying capacities
• Prohibition of alternative systems in certain zoning districts
• Special use permit requirements for alternative systems
• Environmental impact assessment for developments utilizing alternative
systems
Q County or municipal governments may implement one or more of these
regulatory and programmatic actions, either unilaterally or in cooperation
with the state and/or other local governments, in order to recognize and
Q respond to the issues raised by the new technology.
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Sewage Treatment and Disposal Systems: Question and Answers
(1) Zoning
A. Does the Town have to "allow" package treatment plants?
Yes, but not everywhere. It appears that it is possible to make
a alternative systems permitted uses only in certain zoning districts,
and not allow them in other districts. The more closely such
restrictions can be linked to environmental and other objective
standards, the more defensible such regulation would be. A local or
regional plan for alternative wastewater treatment and disposal
facilities which specifies location and sizing would make the
Q regulation even more defensible.
B. Can we require architectural compatibility?
Yes, but such a system of design control for alternative wastewater
treatment and disposal facilities must be part of an overall
community -wide program for architectural review. In addition to
architectural guidelines, landscaping requirement may be imposed,
again provided there is an overall community -wide program.
Restrictive covenants may also, of course, be imposed by developers
to effect architectural and landscaping restrictions.
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C. Can we determine locations for plants?
Yes. (See answer to question l(A) above.)
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D. Can we keep sewer lines from coming into town and leaving town?
Probably. Regulation would be strongest if based on a local, or
especially if based on a regional plan.
E. Can we specify the type of system, i.e., subsurface, rotor, or
low pressure?
No, but the community may be.able to provide incentives to
encourage the type of facilities it prefers. These incentives would
be most effective if supported by a local program involving public
sector responsibility for the operation and maintenance of the
facility, according to a scheduled, pre-set agreement.
F. Can we prohibit some types of systems:
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No (but.see answer to question l(E) above).
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G. How can we be assured that a sewer system will not increase density?
You cannot. An increase in density is the result of local zoning
and the adequacy of the available treatment facility. A facility
designed with capacity which could accommodate density in excess
of the zoning ordinance may result in strong arguments that the
density permitted by the ordinance be increased. Strong political
will and a long-term commitment to a land use plan are necessary
to achieve desired densities.
H. Can we require siting of a plant in relation to susceptibility to
storm damage?
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Yes, if there is a local or regional plan for alternative wastewater
treatment and disposal facilities in place which deals with the O
location of such facilities. Even in the absence of such a plan,
the town can preclude placement of facilities in high hazard areas,
such as V-Zones.
(2) Operation and Maintenance 0
A. Can the Town regulate the placement of sewer lines in town and/or
state public right of ways?
(See answer to question l(D) above.)
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B. Can we require the plant to have excess capacity?
Excess plant capacity cannot be required. However, if a local or
regional wastewater treatment and disposal facility plan is in place,
the local government may indicate the desired size of facilities and O
provide incentives for their construction.
C. Can we regulate "excess capacity"?
(Same as 2(B) above; see also answers to questions in Part (1) O
above).
D. Can we require certain parts of town or certain types of businesses
to "hook up" to a private system?
Probably not. However, if the system is taken over as part of an
integrated program for operation and maintenance, it may be possible
to require private "hook ups." Certainly such a requirement could
be made in event of private system failure and a public "take-over"
program is in place.
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E. Can we require a greater maintenance and reporting schedule
than the State or County?
Q No. However, the town may be able to work with the state to ensure
adherence to the existing maintenance and reporting schedule.
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F. Can we require the system operator to report directly to the Town
regarding operation and maintenance?
No. However, the county may enter a Memorandum of Agreement with
the DEM whereby the county would collect monitoring data on
facilities. The town could request receipt of copies of all
correspondence between the state, county, and system operator.
G. Can the town charge a yearly "fee" to cover costs of town
monitoring of the system's operation?
No. The county may charge a yearly fee if it enters Memorandum
of Agreement with DEM. (See answer to question 2(F) above.)
H. Can we charge a fee for inspection of the plant by the Town's
engineers?
No. (See answer to questions 2(F) and (G) above.)
(3) Structural
A. Can we require all plants to "interconnect" and be "compatible"
with other plants in town?
No. But the town may provide incentives through a local wastewater
treatment and disposal facility plan. Where such a plan is in
place and is part of a CAMA Land Use Plan, the Coastal Resources
Commission must deny development proposals which are inconsistent
with the plan.
B. Can we exceed DEM's construction standards for equipment,
transmission lines, etc.?
The prevailing wisdom is that the State has substantially pre-empted
C? municipal authority to regulate the technical aspects of this field.
However, a county health department program developed in accordance
with N.C.G.S. § 143-215.1 (f); 15 NCAC 2H § 0218(a) for permitting
alternative wastewater systems may include more stringent health -
related standards.
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C. Can the Town Engineer "inspect" all stages of construction for
compliance?
Yes, however, the town engineer would have no enforcement authority.
The engineer may inspect and report findings to the State.
D. Can we require additional safety and monitoring equipment than DEM
or the County requires?
No. (As described above in 3(B), the county may set more
stringent standards.
(4) Town Liability
A. What is the Town's moral and legal liability with private systems?
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A local government has an ethical and moral responsibility to
ensure that local quality of life, and the health, safety, and
general welfare of residents are adequately protected. Even though
the town's specifically legal authority may be slight, the town p
does have the ability to act within the political system.
B. Can we "turn off" electricity or water to customers of a private
plant when the plant is malfunctioning?
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Yes, if such malfunctioning can be abated as a public nuisance under
N.C.G.S. § 160A-193. (See answer to question 4(D) below.)
C. What are the various types of management options and municipal
partnerships available between the town and private sewage O
treatment plants?
The county may enter a Memorandum of Agreement with the State (see
answer to question 2(F) above). The town can probably work with the
county in establishing such an Agreement. Perhaps the only
management option between the town and private plants is through Q
implementation of a plan that would lead to a formal agreement
providing for full public operation and maintenance of the plant
according to a pre-set schedule. Through such a plan, the town
may be able to induce the developer of a facility to construct a
certain type and size of wastewater treatment system, with an eye
toward future municipal "take-over." U
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D. Can we "enforce", assess fines, issue citations to private plants
which are not in compliance with state laws and town ordinances?
Q If the plant is not in compliance with enforceable municipal
ordinances, the town may take appropriate enforcement action.
If the plant is not in compliance with state laws, the town does
not have authority to enforce, assess fines or issue citations.
However, if non-compliance of state laws constitutes a "public
health nuisance," the town may summarily remove, abate, or
Q remedy the situation. The expense of such action falls to the
person in default, and if not paid, a lien is created against the
land or premises where the trouble arose. (N.C.G.S. § 160A-193).
E. How and why do municipal "take -ovens" of private systems occur?
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Public take-overs of private systems may take place through an
integrated program whereby the developer of a system and the town
enter an agreement for eventual public assumption of operation
and maintenance responsibilities according to a pre -arranged time
schedule. In return, the developer agrees to construct the type and
Q size of facility that the town indicates it is willing to take
over.
Public takeovers of private systems also may occur in the event
of system failure when no other recourse is available. (One
recourse which may be provided for is take-over of a failed public
utility system by the Public Utilities Commission.)
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Policies Available to Local Governments for Wastewater
Treatment and Disposal Systems on Coastal Barrier Islands
Southern Shores, North Carolina
I. Development on Coastal Barrier Islands
Q Coastal barrier islands are unique landforms generally paralleling the
mainland, comprising a network that provides protection for diverse aquatic
habitats and serves as the mainland's first line of defense against the
O impacts of severe coastal storms. Located at the interface of land and sea,
the loose sediments of coastal barriers are buffeted by wind, wave and tide,
making these areas generally unsuitable for permanent development.
a Nevertheless, during the last twenty years residential and commercial
development on coastal barriers has proceeded rapidly, and substantial
development pressure now affects most regions of the Atlantic coast.
0 Continuation of this trend will have significant environmental impacts on
dynamic coastal barrier environments, and will result in significant and
recurring public costs for disaster assistance as well as construction and
O repair of utilities, bridges and roads.
All coastal barriers are affected to some degree by human activities.
Even completely undeveloped coastal barriers often have a considerable history
O of human use and occupancy, which has from time to time affected environmental
quality, vegetation, wildlife, and other factors. For the most part, these
impacts have been minor and well within the capability of the coastal barrier
O ecosystem to mitigate or repair in a short period of time. Significant
impacts - that is, those which interfere with the geological and ecological
processes responsible for maintaining coastal barrier ecosystems -
a are nearly always associated, either directly or indirectly, with intensive
development involving large capital investments on the site. Scientific and
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empirical evidence demonstrates that such development interferes with sediment
transport by wind, wave, and tides which, in varying proportions, maintains
coastal barriers as existing landforms. Also, the presence of large numbers
of people increases risks of pollution, destruction of wildlife habitats and
damage to protective dunes and stabilizing vegetation.
By the year 2000, most of the remaining miles of undeveloped and
unprotected coastal barrier shoreline (on the Atlantic Ocean and Gulf of
Mexico Coasts), and the acres of presently unprotected high lands potentially
suitable for development, will be committed either to legal protection or to
development. In addition, development will proceed in the transitional areas.
If we assume that commitments will be made in the same proportion as have
occurred in the past (1.1 miles of ocean shoreline committed to development
for every mile committed to protection), about 52% of the coastal barrier
shoreline will ultimately be developed and 48% protected.
Although geological and ecological impacts will occur whenever a barrier
island becomes substantially developed, impacts during the next 20 years will
be greatest in North Carolina, among a few other states, where large
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undeveloped coastal barriers still exist and development pressure is great.
Small undeveloped tracts adjoining already developed areas and areas closest
to metropolitan centers generally will be affected first, followed by more
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isolated areas. On a per residential unit basis, the impacts of development
will almost certainly be less than in the past. In recent years, state and
local regulations have increasingly restricted development in environmentally
critical areas, such as ocean facing dunes, wetlands, inlet hazard and erosion
prone areas, and areas subject to flooding, especially velocity flooding.
Development.planning..for.large.tracts.increasingly emphasizes cluster
development, which limits the areas of development impact and leaves
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substantial areas either undeveloped or in uses such as golf courses, which
involve minimal construction of buildings and conserve, in varying degrees,
some of the coastal barrier's natural landscape features. However, while
these trends will channel development into more environmentally compatible
locations, there is little evidence to suggest that they will reduce the
ultimate density of human population on coastal barrier islands. The
infilling of developed areas and the urbanization of presently undeveloped
areas will likely continue unabated. Limited curbing of government programs
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which enable or subsidize coastal barrier development may curtail the
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development process in some areas. The long-term effect, however, on an
aggregate basis, will be determined by the economic forces at work in the
market place, i.e., development pressures.
There is a finite supply of developable land on coastal barrier islands,
and continued rapid growth and high demand are probable. The increases in
urbanized land on coastal barriers in the last two decades are indicative of
this trend. The proliferation of development, predominately residential,
reflects the desire of an increasingly affluent, recreation -oriented
population to use the coastal barrier resources for private personal
enjoyment. The result has been a progressive commitment of vast expanses of
barrier island open space to long-term public and private uses. In addition,
coastal barriers are attracting increasing year-round populations. This is
particularly true in southern areas that are attracting large numbers of
retirees, or on coastal barriers that are becoming suburbs to major cities.
This trend puts even greater development pressures on barrier islands, since
these year-round populations lead to the increased availability of public
services and amenities, which in turn attract even larger populations. (U.S.
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Dept. of Interior, Coastal Barriers Task Force, 1983).
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II. Coastal Barrier Island Characteristics: Implications for Wastewater
Treatment
a. The Unique Attributes of Barrier Islands
Coastal barriers have special characteristics not found on the mainland
which tend to create unique conditions for permanent human use and occupancy.
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Barrier islands are dynamic systems in fluid equilibrium with powerful oceanic C>
and meteorologic forces that are constantly changing shape in response to
these forces. They support many unique ecosystems adapted to this unstable
environment. (Brower, et al., 1978). 4
Some of the unique attributes of barrier islands include:
• In response to sea level rise and coastal storms, most coastal
barriers are migrating rapidly (in geologic time) toward the mainland
while keeping the landform itself intact. Mainland areas can only O
erode back under such conditions and do not have migration
capability. Incidences of coastal barriers literally migrating out
from under the development upon them are legion.
0 Coastal barriers bear the full force of coastal storms and their
loose low lying sediments are much more likely to be massively D
reworked during storms than mainland. Barriers are typically subject
to wave attack from two sides (ocean and estuary), frontal attack by
storm winds, severe and rapid erosion and deposition of sediment, and
powerful velocity flooding which may rip wide swaths through barriers
during severe hurricanes. Mainland areas are not subject to
bidirectional floodings, and are much less subject to wind effects, O
rapid erosion, and velocity flooding.
• Natural coastal barriers and their dune systems provide the first
line of defense against storms for low lying mainland areas and
provide protection required for maintaining the productivity of the
estuaries behind the barrier (and the fishing and shellfishing D
industries dependent upon these estuaries). These properties create
a national economic interest in protecting barriers far exceeding
that associated with coastal mainland areas.
• The hazards associated with permanent human occupancy of coastal
barriers are generally much greater than for the mainland.
• Because of coastal barriers' high susceptibility to natural
disasters, public subsidies of development on them tend to be
recurring on a short-term basis. Subsidies in mainland areas tend to
be.one-time costs or recurring on a long-term basis.
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(U.S. Dept. -of Interior, Coastal Barriers Task Force, 1983).
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b. Vegetation
Vegetation on barrier islands is uniquely adapted to its harsh
environment. The vegetation on barriers has two distinctive characteristics:
toleration of the salt spray that is a major component of the beach -dune
environment, and the ability to sustain itself through burial by windblown
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sand, growing upward and outward as blowing sand accumulates around it. As a
dune grows and the grass continually recolonizes the sand surface, the dune
becomes stabilized. Later, nitrogen -fixing plants, such as bayberry and beach
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pea, invade the dune adding to the sand nitrates that fertilize other plants.
With long-term stability and shelter from salt spray, shrub thickets and
eventually woodlands can develop on the landward side of .the frontal dunes.
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Plants are important on the coastal barriers because they stabilize the
sand. Also, sand blown off beaches is trapped by beach grasses and sea oats.
It is easy to see how important it is to protect the vegetation indigenous to
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barrier islands. Even when vegetation lost to development projects is
replaced by landscaping, non-native plants may not be able to withstand the
climatic variables, effects of salt spray, overwash impacts, and wind and
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storm damage of the barrier island environment.
c. Barrier Island Zones: Suitability for Development
The coastal barrier is a system made up in varying degrees of a beach,
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beach dunes, upland flats and, on the backside, a zone of'marshes. (Figure
1). Each of these geomorphic elements has a characteristic shape that results
from a distinctive process or combination of processes. Each element has its
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own unique susceptibilities which make it less adaptable to most development,
including the installation of septic tank systems and some other types of
wastewater treatment systems.
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L/T Z.! t::�' rr.»jf!(.,•; ice:«.c 1:'1::.>C;. .. ;i.; .. :../t=:::�. ',:rr�i •.... ... _:-: i'- •;; {. Il.a � .Lc �.:. _' •.j` �4
LAGOON SEDIMENTS PEA OVERWASH SOIL DUNE DRIFT STEP SHOREFACE
LAYERS BEDDINO LINES SEDIMENTS
0
Figure 1: The Components of a barrier beach system
L
,
HST -high spring tide MSL-mean spring tide LST-low spring tidE
HNT-high neap tide LNT-low neap tide
Source: U.S. Dept. of the Interior, Coastal Barriers Task Force,
Undeveloped Coastal Barriers: Final Environmental Statement
(May, 1988), p. A-4.

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• The beach is generally composed of (a) the foreshore, the sloping
portion of the beach which interfaces the ocean: (b) the berm, an
abrupt rise of several feet behind the foreshore; and (c) the
O backshore which is the upper part of the beach between the berm's
crest and the dunes. (The berm is the area most directly affected by
waves during storms and, therefore, is the most unstable. It is non-
existent on some beaches, in which case, the foreshore extends
directly to the dune line.)
O a The dune zone on a barrier beach may consist of a single dune ridge,
several parallel dune ridges, or a number of curving dune lines
stabilized by beach grasses. There also can be an open dune region
without any distinctive lines. The dune zone then may extend as far
as the intertidal zone to the bay side or grade into barrier flats.
(Islands that are subject to periodic or regular overwash tend to be
© dominated by scattered dunes with extensive barrier flats.)
• The barrier's uRland flats are an extensive plain which may support
grasslands, shrub -thickets, or woodlands, but in most areas is
primarily dominated by grassland communities. Where the dune
development permits a degree of stability, woodlands and forests can
O grow on the flats.
• On the backside of the barrier is the intertidal zone of a lagoon
system or estuarine environment. This zone is divided into two
topographically distinctive parts: the high marsh and the low marsh.
The high marsh ranges from the highest spring tides to the neap tide,
O and is normally dominated by grasses such as salt meadow cordgrass
and spike grass. The low marsh, which ranges from the high neap tide
to mean sea level or below, is flooded during each high tide, and
typically is dominated by salt marsh cordgrass. It is the flooding
phenomenon in the low marsh which is largely responsible for the
teeming organic productivity of salt marshes.
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The beach is unsuitable for development due to its extremely unstable
nature. Even normal tidal action and other coastal dynamics such as sea level
rise and long -shore currents affect much of this area daily. Storms and high
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winds can change the morphology of the beach much more dramatically,
destroying or severely damaging any man-made structures in the area.
The dune zone is particularly unsuited for development and construction
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because of the extreme importance of the dunes' role as protectors of the land
behind them from ocean activity, and because of their natural dynamism. The
damage to or.destruction of dune vegetation (as well as the dunes themselves),
9
which frequently accompanies development of oceanfront property is
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particularly significant because of the importance of such vegetation in
trapping windblown sand, in building protective dunes, and in maintaining the
ecological diversity and stability of the coastal barrier ecosystem. Although
damage to dunes during storms followed by natural rebuilding is a continuous
process on most coastal barriers, the damage caused by development and
associated human activities is usually much more extensive and permanent. The
artificial removal of protective dunes opens the interior of the coastal
barrier and the landward aquatic habitats to greater ecological impacts from
storms than would otherwise occur. These impacts include landscape
modification by velocity flooding; saltwater intrusion into groundwater (which
will adversely affect the productivity of freshwater bogs and marshes,
maritime forests, and other interior habitats) and into landward aquatic
habitats (which may affect the productivity of species intolerant of high
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salinity during all or part of their life cycles); and accelerated replacement
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of vegetation characteristic of more stable areas, such as maritime forests
with grasslands, thickets, and shrubland communities characteristic of more
frequently disturbed areas. Entire biological communities may be destroyed
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and replaced by communities characteristic of disturbed habitats.
The upland flats area is frequently the site of development on barrier
islands. Although these areas lie behind the protection of the dune system,
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and are not directly impacted by wave and tidal action, tfiey are nonetheless
vulnerable to ocean activity, especially during high seas, where storm
overwash occurs through narrow dune gaps, or in places where the dune system
0
is weak. Overwashes literally push sand across a barrier from the beach and
dune zones. Any development in the area will obviously be impacted when this
occurs. _Furthermore, unique and fragile.ecosystems,..including the
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increasingly rare maritime forest, are located in this region, which can be
irreversibly impacted by development activities.
The intertidal marsh and lagoon areas of barrier islands are very
vulnerable to development activities, including the installation and operation
of nearby wastewater treatment systems. Pollution from runoff and from
wastewater treatment effluents has been reported in the vicinity of many
developed areas, resulting in the temporary closure of important shellfish
beds. It is a potential problem in all urbanizing coastal barriers because of
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the close proximity between development and aquatic habitats. As the less
flood -prone and erosion -prone areas on coastal barriers are developed,
development pressure will focus increasingly on the more low-lying and
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hazardous real estate which is unsuitable for development. The aesthetic and
recreational amenities of coastal barriers have no substitute in the market
place, and the economic incentives for developing available real estate will
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inevitably become greater. (U.S. Dept. of Interior, Coastal Barriers Task
Force, 1983).
d. Barrier Island Soil Composition
In addition to the peculiar characteristics which make each zone of the
coastal barrier island more or less suitable for development, the entire
barrier system itself is limited in its ability to adapt to man's activities.
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This is due in large part to the nature of the soil composition. All coastal
barriers are comprised of erodable materials --such as sand, gravel and small
rocks --which remain unconsolidated (i.e., loosely aggregated and not
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compressed into solid rock). Sea forces --tides, waves, winds and storm
floods --create and control them even when humans intervene with their modern
technology. Furthermore, coastal barriers tend to have very shallow aquifers,
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which are particularly vulnerable to depletion, salt -water intrusion, and
contamination from pollutants.
e. Sewage Treatment on Barrier Islands
The unique characteristics of barrier islands have implications, both
direct and indirect, for development. The geography and geology of barrier
islands have especially important implications for the facilities needed to
treat and dispose of the sewage (waste) generated by increasing year-round and
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summer populations. The standard method used in mainland areas -- public
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collection and treatment of sewage from homes and businesses, and disposal of
the treated wastewater in surface waters -- is problematic for use on barriers
for several reasons.
First, the disposal of treated wastewater to surface waters is
effectively precluded by regulation and financial considerations. The quiet
bays lying between the barriers and the mainland are not appropriate areas for
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the disposal of treated wastewater because of the threat of contamination that
such disposal presents to the shellfishing industry. State regulations
prohibit additional discharges of treated wastewater to shellfishing waters.
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Disposal to the ocean through a deep water outfall has been considered but
rejected as too costly, in part because of the width of the continental shelf
off of the North Carolina coast and resulting long length requirement for the
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outfall. Collection of sewage from the islands for treatment and disposal on
the mainland is not a feasible alternative due to the considerable distance
separating the mainland and the islands.
Second, the islands' very dynamic nature -- their continually changing
configurations and migration influenced by waves, tides, and wind -- also
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serves as a compelling argument against extremely expensive capital
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investments in centralized or regional sewage treatment and disposal
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facilities, the model for which assumes a relatively stable environment such
as that found on the mainland.
This was one of the overall conclusions that emerged from a series of
studies of the concept of regional public treatment facilities for the barrier
islands completed during the last fifteen years. In the late 1970's and early
1980's, the Areawide 201 plans for the Dare County barrier island systems
called for the development of regional publicly -owned sewage collection and
treatment facilities, utilizing long ocean outfalls for disposal of treated
wastewater. The regional treatment facility proposed for the northern Dare
County beaches (not including Hatteras Island) was projected in one study to
have a total capital cost range between $6.1 and 8.2 million in 1977 dollars
(Nierstedt et al., 1980). Present values of the operating and maintenance
costs associated with the facility were estimated to total between $1.6 and
$3.5 million over the 20-year design life of the facilities in 1977 dollars.
Federal support for those costs was not supported by the Environmental
Impact Statement (EIS) on North Carolina Barrier Islands Wastewater Management
completed by the Environmental Protection Agency in 1983. The EIS instead
called for a reexamination of other appropriate methods for sewage treatment
and disposal on barrier islands, noting that conventional septic systems and
community treatment facilities utilizing land disposal of wastewater were more
cost effective, and would likely have less growth -stimulating impacts than the
regional sewering concept presented in the 201 studies.
Development of costly regional public sewage collection and treatment
facilities is extremely unlikely to occur without federal financial support
for capital and operating costs. Barrier island communities must therefore
rely on a combination.of,on-site conventional septic systems and a variety of
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new land -based disposal technologies ("alternative systems") serving
developments of one unit or many.
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Conventional individual on -site septic tank systems have been and
continue to be the most common method for sewage treatment and disposal on
barrier islands in Dare County, and are expected to continue to be the most
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common method into the future. However, barrier island environments present
constraints to the use of conventional on -site systems, even when they are
properly sized to meet anticipated use demands. The fact that the water table
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on a coastal barrier island is often at or near the ground surface makes
septic system drainfields susceptible to failure, since proper drainage may be
impeded by saturated soil conditions. Furthermore, although the high sand
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content of local soils make barrier islands ideal under state regulations for
the installation of septic systems, these soils' permeability allows the
treated wastewater to percolate too quickly through the soil, so that it is
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not adequately filtered before it reaches the underlying shallow aquifer.
This can lead to contamination of the local drinking water supply where that
is taken from the unconfined or shallow aquifer. (Augspurger, 1989).
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On the Dare County barriers, only 23,380 acres (45.49%) of a total of
51,400 acres of land are classified under state regulations as suitable or
marginally suitable for conventional on -site septic systems (Booz, Allen and
Hamilton, 1985). As the supply of land that is suitable 'for septic systems
becomes increasingly scarce and the demand for new development increases, so-
called alternative systems will be used with increasing frequency.
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Alternative sewage treatment and disposal systems ('alternative systems')
can be used to overcome the natural constraints encountered on a single lot,
in order to permit development of --a single -dwelling unit; -they can also be
used to serve a cluster of dwelling units. While alternative systems may
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avoid some of the problems associated with conventional septic systems on
barrier islands, their installation and use only serve to exacerbate the long-
term development pressures experienced on coastal barrier islands. The use of
alternative systems allows development at greater densities than would
otherwise be possible, and opens up areas to development that formerly were
ff
considered undevelopable. Insufficient attention has been given to evaluating
the extent to which the enabled development of a coastal barrier may increase
the potential for loss of life and property, interfere with the processes
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responsible for perpetuating the coastal barrier system, or cause adverse
ecological and related socioeconomic impacts due to impairment of the
productivity of wetland, estuarine, and marine ecosystems.
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Currently, alternative systems are most often in private ownership, or
owned by private utility companies, outside of local control. Their
development and operations are regulated either by the state or by County
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health departments, depending on their size. Existing planning and management
frameworks have not been set up to respond to the new sets of issues that are
raised by alternative systems, especially those systems serving a cluster of
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houses or businesses.
The proliferation of alternative systems on North Carolina's barrier
islands therefore raises interesting legal and management questions for
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municipal and county governments which seek control over land use and
development patterns within their communities, and which are also concerned
about the potential for environmental impact that the use of clustered
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alternative systems may present.
It seems likely that increased development on coastal barriers is
inevitable. To the extent that this fosters economic growth.in communities
along the coast and affords greater opportunity for more people to enjoy the
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wonderful resources abundant on barrier islands, development is to be
encouraged. However, it is apparent from the above discussion of the
potential adverse impacts of development on the delicate ecosystems of barrier
islands, particularly the implications of wastewater treatment systems, that
wise management and control of development are essential. Ideally, this
regulation should take place in large part at the local government level,
thereby allowing communities to have direct control over activities which are
localized in nature and which affect the daily lives of residents. Planners
and managers of coastal communities cannot ignore the inter -relationship
between coastal barrier development and the availability of public and private
utility services, including traditional and alternative sewage treatment and
disposal. With an eye toward the long-term effects on the entire coastal
barrier system, planning for and regulation of these pre -requisites to
development must take place now.
III. Overview of Federal and State Wastewater Treatment and Disposal
Regulation
Both North Carolina and the federal government have enacted legislation
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designed to prevent untreated or improperly treated sewage from contaminating
the water resources of the state and the nation. This "environmental
legislation" establishes an elaborate regulatory regime which is imposed upon 0
and is enforceable against facilities which generate, treat, and/or dispose of
water pollutants. This regime is based on statutory limitations on the
pollutant components of treated wastewater which cannot be legally exceeded, p
and which are accompanied by mandatory monitoring and reporting provisions.
North Carolina, in addition to this water -resource protection
legislation, has enacted laws aimed specifically at the public health issues Q
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associated with sewage treatment and disposal systems operating anywhere in
the state. This legislation is implemented in large part through a permit
program. For some types of sewage treatment and disposal facilities, permits
are issued by the State. Other types of systems are regulated by county
governments, which review the systems' suitability, and issue permits if all
Y
applicable criteria have been met.
a. Regulation in North Carolina
All types of sewage treatment and disposal systems in North Carolina
IN
(including both septic and alternative treatment systems) must receive
government approval and a permit before the system project may be constructed,
altered,. extended, and/or operated. (N.C.G.S. § 143, Art. 21; N.C.G.S. §
X
130A, Art 11). Regulation is carried out by the Department of Natural
Resources and Community Development (NRCD), Division of Environmental
Management (DEM), with rules promulgated by the Environmental Management
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Commission (EMC), and by the Department of Human Resources (DHR) under rules
adopted by the Commission for Health Services (CHS). The DEM/EMC is
responsible for overseeing all systems operated by entities regulated by the
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state's Public Utilities Commission, whether publicly or privately owned.
Under N.C.G.S. § 130A-335(b), the DEM/EMC are responsible for overseeing
"[a]ny public or community sanitary sewage system." "Public or community
sewage system" is defined in the Act as "a single system of sewage collection,
treatment and disposal owned and operated by a sanitary district, a
metropolitan sewage district, a water and sewer authority, a county or
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municipality or a public utility." (N.C.G.S. § 130A-334(8)). "Sanitary
Sewage System" means "a complete system of sewage collection, treatment and
disposal including approved privies, septic tank systems, connection to public
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or community sewage systems, sewage reuse or recycle systems, mechanical or
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biological treatment systems, or other such systems." (N.C.G.S. § 130A-
335(11)).
The DEM/EMC are also responsible for overseeing any "sanitary sewage
system which is designed to discharge effluent to the land surface or surface
waters." This responsibility for overseeing waste disposal systems that
discharge to surface waters is given to the DEM and EMC by North Carolina law
in recognition of federal requirements administered by the Environmental
Protection Agency (EPA), so that a single state agency will be in a position
to administer the federally mandated permit system. (Nierstedt, et al.,
(1980).
While the DEM and EMC regulate public and community -owned and -operated
sanitary sewage systems and all surface discharging systems regardless of
ownership, the DHR and the CHS are responsible for "all other sanitary
systems." (N.C.G.S. § 130A-335(b)). Thus, privately -owned and conventional
septic systems, and privately -owned and operated alternative systems which
generally are the responsibility of a homeowners' association rather than a
public utility, are subject to laws and rules promulgated by the DHR and CHS.
These regulations are implemented for the most part by local boards of health.
The Division of Coastal Management (DCM) of the NRCD also has limited
authority under the Coastal Area Management Act (CAMA) to protect groundwater,
particularly with regard to the control of sewage, solid,'toxic and industrial
wastes, and saltwater intrusion. The DCM regulates development activities in
designated areas of environmental concern (AEC's). Any proposed development,
change or other use of land within any of the designated AEC's is subject to
review by means of development permits under the terms of CAMA. Generally,
the local government handles permits for development projects which are
classified as minor, while the Coastal Resources Commission (CRC) issues
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permits for major developments. The CRC establishes rules and standards for
AEC's, including regulations covering public water supply well fields and
small surface water supply watersheds. The Department of Human Resources is
responsible for identifying the well fields for inclusion in an AEC. The
Environmental Management Commission is responsible for designating outstanding
resource waters (ORW's) within AEC's, and to adopt additional standards to
protect them. Within the designated AEC's, no ground absorption sewage
disposal systems or underground pollution injection is allowed. The standards
also require that a development project not significantly limit the water
supply quality or recharge area, and that the project not cause saltwater
intrusion or discharge toxins. (N.C.A.C. 7H.0405(b)).
b. The Federal Clean Water Act
The Congressionally declared objective of the Federal Water Pollution
Control Act, popularly known as the Clean Water Act (CWA), is to "restore and
maintain the chemical, physical, and biological integrity of the nation's
waters." (33 U.S.C. § 1251(a)). The purpose of the Act is to set goals for
minimizing the discharge of all water pollutants, and to attain an acceptable
level of environmental water quality nationwide. The CWA makes unlawful,
except in compliance with a permit issued by the Environmental Protection
Agency (EPA) or authorized state agency, "the discharge of any pollutant by
any person." (§ 1311(a)). The list of elements constituting "pollutants" is
very comprehensive, and includes: "dredged spoil, solid waste, incinerator
residue, sewage, garbage, sewage sludge, munitions, chemical wastes,
biological materials, radioactive materials, heat, wrecked or discarded
equipment, rock, sand, cellar dirt, and industrial, municipal, and
agricultural waste discharged into water." (§ 1362(b) (emphasis added)).
"Discharge" is defined in the Act as "(A) any addition of any pollutant to
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navigable waters from any point source, (B) any addition of any pollutant to
the waters of the contiguous zone or the ocean from any point source other
O
than a vessel or other floating craft." (§ 1362(12)). It is clear from this
definition that pollutants may not be discharged into the ocean or other
"navigable waters," which as used in the CWA is a broad term, and encompasses
"the waters of the United States, including the territorial seas." (§
1362(7)). In order to be prohibited by the CWA, the pollutant must emanate
from a "point source," which means "any discernible, confined and discrete
conveyance, including but not limited to any pipe, ditch, channel, tunnel,
conduit, well, discrete fissure, container, rolling stock. . ." (§ 1362(14)).
Thus any sewage or solid waste which is discharged into nearly any water
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resource (including rivers, streams, lakes, ponds, estuaries, even wetlands
and marshes), and which comes from any discrete, discernible conveyance, is
prohibited by the CWA unless a permit has been obtained from the EPA.
O
33 U.S.C. § 1342 provides that the EPA, or a state agency under an EPA -
approved program, may issue permits to new and existing point sources,
providing certain conditions have been met. General conditions that must be
1*1
met before a permit will be issued include proper operation of any pollution -
control technology which is required; a waiver of any constitutional right to
prevent EPA or other authorized officials from entering the premises for
n
purposes of lawful inspection; and monitoring, record -keeping, and reporting
requirements. In addition to these conditions which are written into every
permit issued, point source operators must meet other specialized permit
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conditions. The permit must reflect the effluent limitation which has been
set by EPA on a nationwide basis for various industrial categories; the
facility cannot exceed that limit without violating the permit. If the
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particular point source applicant does not fall within a category for which a
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national effluent limitation has been issued, the point source must then
O comply with effluent limitations which are written into the permit by local
regulators under authority of the EPA.
The EPA sets effluent limitations on an industrial categorical basis to
reflect the degree of technology required to prevent the facility from
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exceeding the established pollutant limits. The 1977 amendments to the CWA
require that all private sources of water pollution attain the "best
practicable technology" (BPT) which is available for that particular industry
O
to clean up any effluents produced before they reach a water resource.
(§ 1311(b)(1)(A)). This level of technology was to be installed on all
sources by 1977; sources which are not yet in compliance are subject to
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sanctions for violation of the CWA. The 1977 amendments also set a higher
standard of technology which was to have been reached by March 31, 1989 for
all facilities generating "conventional pollutants" (basically, non -toxic
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pollutants). Four "conventional pollutants" were identified by Congress
directly in the CWA: "pollutants classified as biological oxygen demanding,
suspended solids, fecal coliform, and pH." (§ 1314(a)(4)). The EPA has
established and periodically revises a list of other conventional pollutants.
Facilities which deal with these pollutants must go beyond BPT, and install
the "best conventional technology" (BCT) currently available for pollution
O
clean-up and prevention. (§ 1311(b)(2)(E)). Publicly -owned treatment works
(POTW's) are required to achieve effluent limitations based upon "secondary
O treatment" levels of technology. (§ 1311(b)(1)(B)). EPA regulations define
"secondary treatment" as biological treatment of waste, after the waste has
been through a settling pond system (known as primary treatment) before it may
be released into a water resource.
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The CWA contains enforcement provisions which may be implemented by EPA
for violation of any effluent limitation or other permit requirement. The
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Administrator of the EPA may issue an administrative order, and after
consultation with the state where the violation occurs, assess a civil penalty
of up to $125,000 (§ 1319(g)). The Administrator may also commence a civil
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action for appropriate relief, including a permanent or temporary injunction,
in U.S. District Court. The CWA also imposes criminal sanctions, including
fines and imprisonment, against any person who negligently or knowingly
•❑
violates the CWA or a permit requirement.
IV. Methods for Sewage Treatment and Disposal
In the absence of publicly -provided treatment and disposal facilities, O
sewage generated on Dare County barrier islands is treated by the use of
conventional on -site septic systems and increasingly by the use of various
alternative systems. This section describes the systems that are in use, how O
they operate, how they are regulated, and some difficulties that may result
from their operation and from the current pattern of their ownership and
responsibility for them. This section provides background information for O
Chapter V, which describes policy options for local governments seeking to
come to terms with the issues associated with both conventional and
alternative treatment and disposal systems.
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a. Conventional Septic Systems
The traditional approach to rural residential and commercial development
relies on a septic tank and drainfield system for wastewater treatment and Q
disposal. Conventional septic tank systems are now and have historically been
the most common means of wastewater treatment and disposal on the North
Carolina barrier islands.
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1. How Conventional Septic Systems Work
Figure 2 illustrates the layout of a typical on -site system such as might
serve a residence or commercial operation. These systems are usually designed
to serve one home or small business, and are almost always located on the same
property as the facility generating the wastewater. They are very simple both
in terms of physical layout and the sewage collection, treatment, and disposal
processes involved.
As figure 2 illustrates, the typical on -site septic system layout
includes three basic components, all of which are located below ground on the
building site: a septic tank, a distribution box, and a wastewater absorption
field. Waste generated at the source flows -- unaided by anything but gravity
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-- into the septic tank, a large below -ground holding tank. In the septic
tank, the waste separates to wastewater and sludge which settles at the tank's
bottom. Some treatment also occurs in the tank via bacterial processes.
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From the septic tank, the wastewater flows to the soil absorption field
by way of a distribution box, a mechanical switching station which directs the
flow of wastewater to the pipes of the absorption field. The wastewater
absorption field is most commonly made up of several underground trenches
which have been excavated to a depth of anywhere between 25 and 36 inches,
lined with gravel and/or sand, and in each of which is laid a perforated pipe.
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The trenches are covered with more gravel and topsoil, and often stabilized by
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the planting of grass. The wastewater is directed through the distribution
box from the septic tank into these pipes, and flows -- again via gravity only
-- through the perforation in the pipes into the trenches and the soil beyond
them. Final treatment occurs in the soil via bacterial action and aerobic
decay processes.
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Sewage bacteria break up some waste solids in the
septic tank. Heavy solids sink to the bottom of the
tank as sludge. Grease and light particles float to
the top as scum. Liquid flows from the tank through
closed pipe and distribution box to perforated pipes
in trenches; then flows through surrounding crushed
rocks or gravel and soil to ground water. Bacteria
and oxygen in the soil help to purify the septic i
efflu nt (liquid). Tank sludge and scum must be
pumped out periodically. This is
HOUSE the most common onsite system.
(typical
waste DISTRIBUTION BOX _.ABSORPTION FIELD (TRENCH)
generator)
SEPTIC TANK - • ' '• - • •
scum
liquid
sludge--=T-.�:
gravel or crushed rock (unexcavated)
FIGURE 2 SEPTIC TANK AND SOIL ABSORPTION FIELD (TYPICAL TRENCH FIELDS)
FROM: U.S. Environmental Protection Agency, 1980. Small Wastewater Systems.
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For conventional septic systems, the size of the absorption field is a
function of the kind of soils that are present on the development site. Larger
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fields and lower dosing rates (gallons of wastewater per day per square foot
of land) will be required in soils that are only marginally suitable for
wastewater treatment. Modifications are possible to the general design as
described here, in order for an on -site system to conform with the particular
characteristics of a site.. Since 1982, the standard North Carolina
regulations have required lots served by septic systems to include enough
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adequate soil for an on -site backup field (or "repair area") in addition to
the primary field, to be used in case of system failure.
The short-term effectiveness of a properly installed septic tank and
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absorption field depends primarily on the characteristics of the soils located
within three feet of the surface, which absorb and treat the wastewater. The
ideal soil for septic tank operation is one that has a good mixture of sandy
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textures (for reasonable permeability) and loamy and clay textures to allow
the wastewater enough residence time in the soil for treatment to occur. Too
much sand can mean that wastewater percolates through to the underlying water
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table too quickly for the soil to provide any treatment. This can effect
local ground water quality. Too much clay or loam can mean that the soil
swells severely when it is wet. Wastewater will not move quickly enough
through the pores of such a soil to provide room for the additional wastewater
that needs to replace it, and during rainy seasons, the soil may completely
lose its capacity to absorb wastewater.
In addition, the local ground water level, the distance between the soil
surface and any impermeable layers such as bedrock, the slope of the land's
surface and subsurface, and the.proximity of the septic tank and absorption
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fields to surface water bodies all affect the design and performance of septic
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systems. On barrier islands, the two most important factors determining the
performance of conventional septic systems are soil texture and the depth to
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the water table.
Typical soil textures on barrier islands vary by location relative to the
sea and sound. Figure 1 illustrates a typical barrier island cross-section
9
and the soil types and vegetation that characterize various barrier island
ecosystems. The soil textures range from extremely sandy in the foredune,
overwash and berm areas to mucky and very poorly drained in bayside marshes
0
and lagoons.
Characteristic shallow depth to the water table is also a limiting factor
for.the use of septic tanks on barrier islands. In places on the Dare County
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barrier complex, the water table (upper unconfined or shallow aquifer) is
normally within four feet of the surface (EPA, 1983), and in some places,
normal water table levels are even closer to the surface. (Augspurger, 1989).
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This can limit septic tank performance during wet seasons when the water table
rises even closer to the surface because if the ground in the vicinity of the
absorption field trenches is saturated, it cannot absorb wastewater. The
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shallow aquifer is a primary source of drinking water for those on private
wells, and a secondary water source (through the fresh pond system) for the
northern Dare beaches. For this reason, potential contamination of the
0
aquifer becomes an important issue in areas where the water table is so close
to the surface that there is not enough soil between the trenches and the
groundwater to provide adequate wastewater treatment. This may be more of a
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problem on Hatteras Island than for the northern Dare beaches (Booz, Allen and
Hamilton, 1985; EPA, 1983). At least one study (UNC, DCRP, 1983) suggests
that it is.also.a problem on the Currituck Outer Banks. -The standard rule of
thumb is that there should be at least four feet of soil of average

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percolation rate between the .bottom of an absorption trench and the water
table in order for adequate absorption and treatment to occur. (Soil
Conservation Service, 1971). The 1985 Dare County Carrying Capacity Study
used six feet of soil as the rule of thumb in describing what is necessary for
groundwater protection on North Carolina barriers.
According to a 1985 study of Dare County's carrying capacity, the Soil
Conservation Service (CSC) has mapped 21 different soil types in the Outer
Banks area. Overall, less than 50 percent of the Outer Banks soils were found
to be suitable for conventional septic systems under state regulations, either
because of inadequate soil texture or too shallow local depth to the water
table. In addition, there was also found to be a great deal of irregularity
in soil type and suitability within short distances, so that soil type on a
lot may vary from suitable to unsuitable within a few feet (Booz, Allen and
Hamilton, 1985).
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2. Regulation of Septic Systems
A. Septic System Regulation: Jurisdictional Lines Between CHS and Local
Government Units.
Q Since conventional septic systems commonly serve single dwelling units or
small businesses, and utilize the ground absorption method for wastewater
disposal, their construction, alteration, and operation are most often
a controlled by standards established by the Department of Human Resources (DHR)
and the Commission for Health Services (CHS). County governments are also
involved in regulating certain private septic systems within their
O jurisdiction; whether the CHS or the local government is responsible for
actual review and permit issuance for a particular system depends upon the
system's size. Authority to review the plans and specifications for septic
O systems where the design sewage flow exceeds 3,000 gallons per day (GPD), such
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as those serving multifamily or larger commercial developments is reserved to
the DHR (10 N.C.A.C. 10A § 1938(e)). Smaller systems which generate less than
3,000 GPD of wastewater, such as on -site septic systems serving a single
private residence or business, receive permits at the county level, generally
from the health department.
Smaller systems which are under the aegis of a county government are
reviewed and approved according to rules set by the county board of health,
once those rules have been reviewed and found by the DHR to be "at least as
stringent as the Commission's rules, and sufficient and necessary to safeguard
the public's health." (N.C.G.S. § 130A-335(c)(1)(2)). The county board of
2
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health may adopt a more stringent rule than that of the Commission "where, in
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the opinion of the local board of health, a more stringent rule is required to
protect the public health." (N.C.G.S: § 130A-39(b)). Otherwise, the rules of
the Commission shall prevail over the local board of health rules. (Id.) The
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authority to adopt a more stringent rule is designed to enable county health
authorities to treat state rules as a floor or minimum, leaving discretion to
adopt local rules that exceed the state minimum rules in order to address
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localized health problems.
B. Pre-emption of County Boards of Health Rules
Although the statute allows more stringent rules governing septic tanks
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to be promulgated by county health authorities, there arise questions
concerning what other types of local regulation may be issued, and under what
limitations. In particular, an important issue involves whether or not local
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governments are pre-empted by their enabling legislation from disallowing the
use of septic tanks through provisions of their zoning ordinances, where
conventional.treatment service is technically.available. Many of these same
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concerns arise in the regulation of alternative treatment systems; for a more

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complete discussion of the pre-emption issue, see Section IV (b)(2)
("Regulation of Alternative Treatment and Disposal Systems") below.
C. Minimum Criteria for Septic Tank Regulations
N.C.G.S. § 130A-335(e) lists the elements which CHS and county boards of
health rules must, at the least, address. These minimum components are set
forth in more detail in state regulations at 10 N.C.A.C. 10A §§ 1934-1968, and
include: minimum standards for septic tank construction and materials (§
1952) and prefabricated septic tanks (§§ 1953-54); design criteria for
conventional and alternative systems (including some low-pressure pipe
systems) according to gallons of waste generated per day by the proposed
system user (§§ 1955-1957); acceptable soil 'dosage rates' in gallons per day
of wastewater per square foot of land (id.); and maintenance requirements (§
1961).
The county health department is responsible for investigating each
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proposed site before a permit can be issued, and must evaluate the following
factors: topography and landscape position; soil characteristics
(morphology); external and internal soil drainage; soil depth; whether
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restrictive horizons are present; the amount of space available for disposal
fields as compared to the amount of treated wastewater flow; and other
applicable factors involving accepted public health principles, such as the
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proximity of a large -capacity water -supply well, the potential public health
hazard of possible failures of systems involving large quantities of sewage,
and the potential public health hazard of possible massive failures of soil
absorption systems proposed to serve large numbers of residences, as in
residential subdivisions or mobile home parks. (§§ 1939-46). Based on the
site evaluation,the factors listed are determined.to be.'suitable,'
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`provisionally suitable,' or `unsuitable,' and the site is assigned the
appropriate classification. (§§ 1947-48).
The regulations also set forth locational requirements for ground
absorption systems, including minimum horizontal distances from various
sensitive areas within which a septic system may not be located. Some of
these parameters are specifically applicable to coastal areas, including the
requirement that all ground absorption systems be located at least 100 feet
from the normal high tide mark of waters classified as SA (shellfishing
quality), and at least 50 feet from any other stream, canal, marsh, or coastal
waters. (§ 1950(a)(4)(5)). Septic systems are not permitted in areas where
the seasonal high groundwater table level is within one foot of the ground
surface at any time of the year. (§ 1950(c)(1)).
D. Enforcement Provisions
The statute provides for the imposition of administrative penalties and
criminal sanctions for violations of the state public health laws. The
Secretary of the DHR may impose an administrative penalty on a person who
willfully violates Article 11 of Chapter 130A ("Sanitary Sewage Systems"), or
any condition imposed upon a permit issued under Article 11. (N.C.G.S. §
130A-22(c)). However, if it can be established that neither the site nor the
system may be improved or a new system installed so as to comply with Article
11, an administrative penalty may not be imposed. (Id.) These provisions
also apply to a local health director when any person willfully violates the
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rules adopted by the local board of health pursuant to N.C.G.S. § 130A-335(c),
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or who willfully violates a condition imposed upon a permit issued under the
approved local rules. (N.C.G.S. § 130A-22(h)).
The Statute also provides that the Secretary may bring a civil action in
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superior county court when a person fails to pay the penalty ordered by the
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Secretary. (N.C.G.S. § 130A-22(g)). Permits which have been issued may be
suspended or revoked whenever there has been a violation of the statute or the
rules of the Commission, or whenever a violation of a condition in a permit
has occurred. A permit may also be suspended or revoked upon a finding that
its issuance was based upon incorrect or inadequate information that
materially affected the decision to issue the permit. (N.C.G.S. § 130A-
23(a)). Immediate revocation or suspension of a permit by the Secretary is
authorized when a violation of the statute or rules presents an imminent
hazard. (N.C.G.S. § 130A-23(d)). An "imminent hazard" is defined as "a
situation which is likely to cause an immediate threat to life or a serious
risk of irreparable damage to the environment if no immediate action is
taken." (N.C.G.S. § 130A-2(3)). The statute also provides that anyone who
violates any of the provisions in Chapter 130A shall be guilty of a
misdemeanor. (N.C.G.S. § 130A-25).
3. Problems and Issues Associated With the Operation and Regulation of
Septic Tanks
A. Maintenance and Operation
o Septic systems are considered to have `failed' whenever adequate or
complete treatment of sewage or absorption of treated wastewater does not
occur. Failed septic systems can result in local public health hazards such
o as contamination of groundwater supplies, pollution of surface waters, or
standing pools of untreated sewage on the ground's surface. Signs of system
failure include odor, standing water over the septic tank or drainfield, and
o plumbing fixtures that do not function properly. Such signs indicate a
problem with the operation of the components of the system -- the tank needs
to be pumped out, the trenches are clogged, the absorption fields are
o saturated. Failures due to malfunctioning system components can cause
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contamination of nearby water bodies, including tidal creeks, bays, and
sounds.
Adequate system design and installation, and proper maintenance of septic
system components can prevent such failures from occurring. Unfortunately,
most homeowners are not familiar with their septic system's routine
maintenance requirements. This is especially true in the case of older
systems which are no longer under the control of the original owner. Most
North Carolina counties do not do much in the way of homeowner education about
adequate septic system maintenance.
Groundwater contamination can occur even where systems are correctly
installed and are being maintained in perfect condition, however, if not
enough soil or soil that is too sandy lies between the absorption field
trenches and the water table. The high permeability of the sandy soils in the
seaside portions of the islands that are so popular for development present a
high potential for groundwater contamination. That potential is unchecked by
the statewide regulations for septic system design which contemplate the
existence of subsurface soils that restrict wastewater percolation, not
subsurface soils that enhance it. In barrier island environments, the
regulations often do not require adequate soil depth between septic field
trenches and the underlying groundwater lens to provide protection.
(Augspurger, 1989). The regulations do not require filling or additional
native soil depth when the soils underlying an absorption trench are unusually
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permeable, even when those soils overlay a shallow water table lens. It has
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been shown that groundwater can be protected if the absorption field area is
excavated and filled with less permeable soils than the local sand, but this
is not a.regulatory.requirement...The majority of the North Carolina coastal
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counties, including Dare. County, use the standard state regulations and have
not adopted more stringent requirements for septic system design.
In addition to the potential for groundwater contamination, septic
systems have been shown to affect water quality in the bays and shallow canals
located between the barrier islands and the mainland. The results of a 1977
test illustrate the problem. Dye flushed from a toilet at East Bogue Banks
appeared in Bogue Sound approximately four hours later (Nierstedt et al.,
1980, p. 1-12). Because of the variability of local soil suitability for
conventional septic systems, even a properly installed system may present the
potential for such pollution.
B. Septic Tanks and Barrier Island Land Use Planning
The importance of local hydrogeology and local soil characteristics to
the use and performance of septic systems makes these factors also very
important to land use planning efforts in areas where conventional septic
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systems are the primary means for wastewater treatment and disposal. In
addition, in rural areas where no formal planning or zoning systems are in
place, reliance on conventional septic systems for wastewater treatment and
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disposal has resulted in a kind of de facto zoning. This occurs because lands
that do not meet state regulatory criteria for septic systems are the last to
be developed, and development occurs at the densities required to support
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local septic systems under local conditions.
Where groundwater protection is an issue, minimum lot sizes that are
large enough to support septic systems become even more important. According
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to a Dare County carrying capacity study completed in 1985, since 1981 the
County has required 15,000 square foot minimum lot sizes in areas that are
served by the. public.:water.supply.and 20,000.square.foot lots where private
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wells are utilized, because of concerns about groundwater contamination. The
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study notes that these minimum lot sizes are supported by the results of a
1984 study by Perkins which linked nitrate concentrations in groundwater to
the use of septic systems at various densities. At a density of 2.8 dwelling
units per acre, in a variety of geographic areas and soil types, mean nitrate
concentrations reached the Environmental Protection Agency's minimum drinking
water standard of 10 milligrams per liter (mg/1) (Booz, Allen and Hamilton,
1985). That density translates to a standard subdivision lot size of
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approximately 15,000 square feet. That minimum lot size does not take into
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account the need for an on -site `repair area' (an extra disposal field),
however.
On the Dare County barrier islands, the majority of the soils are not
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suitable for conventional septic systems, and therefore are not developable
without risk of ground and surface water contamination, unless some
alternative system is available. Of the 51,400 total acres of the Dare County
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Outer Banks (not including Roanoke Island), only 23,380 acres (45.49%) are
suitable or marginally suitable for conventional septic systems. When lands
that are protected from development due to -the fact that they 'are part of the
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Cape Hatteras National Seashore or the Bodie Island Park are excluded from
these figures, the results are slightly more encouraging: 19,080 acres
(61.55%) of 31,000 total are suitable or marginally suitable. The situation
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on the northern Dare beaches portion of the Dare County Outer Banks is better
than that on Hatteras Island. In the northern Dare beaches area 69.39% of the
total acreage is suitable or marginally suitable, while on Hatteras only
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38.61% is suitable or marginally suitable. (Booz, Allen and Hamilton, 1985).
Although these figures are encouraging for the northern Dare beaches area
relative to the rest of the Dare County.0uter.Banks, these figures still mean
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that 30.61% of the total acreage is not suitable for septic systems.

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And these figures may overstate the total acreages of suitable soils. A
carrying capacity study of the Currituck Outer Banks completed in 1983 points
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out that some of the Outer Banks soils considered suitable under the state
regulations are not classified as suitable for septic systems by the Soil
Conservation Service (SCS).
In many counties and municipalities, subdivision approvals are not linked
to the ability of each of the lots to support a septic system, even though the
overall minimum lot size may be based on the land area which is theoretically
required for one. Where septic test approvals are not necessary prior to the
subdivision of land into lots, and public treatment systems are not available,
a situation is created where new lots can be created which are not developable
using conventional septic systems without creating a potential environmental
problem. This is especially critical in areas such as the Outer Banks where
soil types are variable even in the short distances within a platted lot.
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Such variability makes land use planning and zoning based on the ability of
local soils to support septic systems very difficult.
Where land use planning is done on the basis of the land's carrying
capacity for septic systems, it is impossible to implement on this basis
without making some lands undevelopable and raising the regulatory takings
issue. The 1985 Dare County Carrying Capacity study, for example, defines an
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Environmentally Acceptable Dwelling Unit (EADU) as one which is built on
enough land to support a septic system (15,000 or 20,000 square feet is
assumed). The study also assumes that all new development will occur only in
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areas with suitable soils. Based on those assumptions, the study identifies a
limit of 24,200 total dwelling units using septic systems, and notes that
further development would require the.use-of-alternative.treatment and
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disposal system. Although the study noted that there are difficult policy
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questions concerning how best to deal with the problem of platted lots or
entire parent parcels that fail to meet the EADU criteria, it offered no
solutions.
C. Management Issues
The potential for septic system failures raises several management issues
for local governments. Conventional systems have an average design lifetime
of approximately 15 to 25 years, if properly installed and well -maintained.
After that time, new absorption field areas may need to be located in order
for systems to continue to provide adequate wastewater treatment. It has been
estimated that, nationwide, fewer than half of the septic systems in use
perform satisfactorily over their full design lives. In North Carolina,
septic systems over seven years old were permitted under regulations that did
not require each permitted lot to include a potential backup disposal field
area.
As septic systems fail due to their age or for other reasons, local
governments are faced with a public health problem which presents the need to
provide alternative means of wastewater treatment. Where publicly -owned
wastewater treatment facilities exist, such services can be extended. In
areas where they do not exist, county or municipal governments may be able to
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provide or assist in providing treatment by means of the alternative systems
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described below. Both of these options are costly, and neither is easy. Both
options raise questions about who should bear the financial responsibility for
the costs of the new treatment facilities -- the public sector or the private
A
homeowner who benefits directly.
Because accurate records often do not exist for older systems, it is very
difficult for local governments to predict .with much accuracy.the need to
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provide sewage treatment alternatives in .the case of septic system failures.

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Because the costs of potential solutions to septic tank failure are beyond
many homeowners' means, local governments must step in to assist with
financing, or be willing to allow the persistence of a public health hazard.
In barrier island areas, the hazard includes potential serious contamination
of both the groundwater source, and shellfishing waters in the bays lying
between the barriers and the mainland.
4. Some Options for Local Governments
County governments in North Carolina may adopt standards for septic
system design and siting that are more stringent than the standard regulations
set forth by the state Department of Human Resources. As mentioned above, the
state regulations are set as state-wide standards; county governments are
clearly allowed by State law and regulation to develop regulations that may be
more appropriate to particular local conditions. The authority to issue and
enforce such regulations lies with county boards of health; although the State
(Department of Human Resources) must approve the local rules. Such rules
might include minimum lot sizes for use with septic systems, minimum depth to
aquifer requirements, even where (as is the case with sandy soils) the State
classifies the underlying soils as suitable to provide adequate filtering and
treatment at shallower depths.
Local governments can enhance their ability to plan a response to
possible future septic system failures by developing programs to keep track of
septic system location, permitting histories and performance. Such programs
could be run by the county on a county -wide basis. As an alternative, they
might be run by a barrier island municipality in cooperation with the county
government, and be applicable only within one municipality. A third option is
a cooperative arrangement between all of a barrier island's municipalities and
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the county government, with the program in place only in the barrier island
portions of the county.
Finally, local governments can implement land use plans and zoning and
subdivision ordinances based on the ability of local soils to support
conventional on -site septic systems. Such regulations might include
requirements that all new platted lots must test positively for septic system
suitability before plat approval is given, or that the subdivider or developer
must show proof that treatment can be provided. To the extent that
implementing such a strategy creates large areas that are undevelopable using
conventional septic systems, local governments should be prepared to allow
alternative treatment systems to be utilized. Alternatively, they might seek
legislative authority to develop a density transfer program that would allow
the owners of such properties to trade density from their properties to other
more suitable areas.
b. Alternative Treatment and Disposal Systems
Since the 1970s, community sewage treatment and disposal alternatives to
both conventional on -site septic systems and publicly -provided wastewater
collection and treatment have been studied with the encouragement of EPA. On
the basis of these tests, alternative systems are being hailed as reliable and
cost-effective methods for overcoming the natural and economic problems with
the more traditional treatment and disposal methods (Wiswall, et al., 1985;
Jewell, 1980; Kendig, 1989; and others).
One result of the use of alternative systems is that previously
unbuildable or marginally developable lands are made increasingly attractive
to development at much higher densities than would otherwise be possible. The
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new alternatives may serve many lots or businesses, and may be located off-
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site. They are being used with increasing frequency by the private sector to
provide treatment in areas where public service is unavailable and
conventional septic systems cannot be used. Increased use of alternative
systems will affect the spatial organization of suburban and rural
communities, and will present important long-term management issues for local
governments (Hanson and Jacobs, 1989; Golden, 1988).
Alternative clustered or community systems are proliferating in North
Carolina barrier island communities as developers seek higher densities on
valuable shoreline real estate. The systems allow development to overcome the
natural limitations of local soils and regulatory restrictions on additional
surface discharges of treated wastewater which would otherwise limit the
amount of development possible. Their use, performance and regulation should
be carefully considered by local governments interested in long range land use
and financial planning and growth control issues.
1. How Alternative Systems Work
Two types of sewage treatment and disposal systems are the most common
alternatives to conventional on -site septic systems or publicly -provided
sewage collection, treatment and disposal. The first type involves the
discharge of treated wastewater directly into surface waters, and is
technically similar to most public treatment plants. These systems are
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`alternative' primarily because they serve several or many homes or
businesses, and yet are owned and operated by the private sector. The second
type serves several or many homes or businesses, and is characterized by land
application of treated wastewater -- either sprayed over the land's surface,
or forced under pressure into the ground below the surface. These systems
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involve both an alternative technology and the issues associated with private
ownership and operation of an essentially public facility.
Alternative systems of both kinds are utilized by private developers to
provide a centralized, essentially 'public' service -- sewage treatment and
disposal -- to a cluster of homes or businesses, where such service is
otherwise unavailable. Such privatization is becoming increasingly common
nationwide. Alternative systems are especially popular in areas such as North
Carolina's barrier islands where real estate is extremely valuable, soils
exhibit limited capability to support conventional septic systems, and
publicly -owned and operated treatment facilities do not exist, and are
unlikely to be developed.
A. Systems that Discharge to Surface Waters
These systems, often referred to simply as 'package plants', include a
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prefabricated treatment facility that uses essentially the same sewage O
treatment techniques as do public treatment plants, but at a smaller scale.
Because of the high capital costs they involve, they are primarily used to
support large residential developments, hotels, or commercial centers. Sewage Q
is collected from each house and/or business, and flows by gravity or is
pumped to the central treatment plant. The plant includes a series of
aeration, separation, and filtration chambers where biological and mechanical d
processes provide separation of the wastes into sludges (solid matter) and
wastewater, which is treated either to a secondary or tertiary level when the
plant is operating properly. The treated wastewater is then discharged O
directly to surface water bodies.
Treatment plant components are manufactured off -site and shipped to and
assembled at the development site. The plants are generally sized to serve
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one subdivision or business development, although they can be and sometimes
are sized with excess capacity. This excess capacity may be included in the
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design in order to serve adjacent undeveloped lands, or to provide service to
areas served by septic systems in the event that those systems fail.
The initial capital costs and ongoing operation and maintenance costs of
561
these facilities tend to be higher than those for the other alternative
treatment systems described here. One reason for this is the state and
federal regulatory requirements for secondary or in some cases tertiary
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treatment of wastewater before discharge.
On North Carolina's barrier islands, existing package plants utilizing
surface discharge are used primarily to serve hotels, commercial centers, and
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restaurants. On the Dare County barriers, there were three privately owned
surface discharging package plants in 1985 (Booz, Allen & Hamilton, 1985).
The bays and sounds lying between the barriers and the mainland are the
7
receiving waters for the treated wastewater from these facilities. The state
has classified many of these waters as prime shellfishing areas and has
prohibited new wastewater discharges to them in order to reduce the potential
for contamination. Because of this it is very unlikely that additional
surface discharging package plants will be developed. The existing plants
will continue to be in use, however, and their performance will be of concern.
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B. Land Disposal Systems
These systems utilize the absorptive capacity of land near the
development site for treated wastewater disposal. Treatment of the sewage
101
prior to disposal may be provided either by a large septic tank which provides
the basic biological and bacterial process known as primary treatment, or by a
prefabricated.treatment facility similar to those used in surface discharging
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facilities, which provides some level of treatment beyond primary. These
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systems can be used as individual on -site systems to overcome the restrictions
on individual lots, or they can serve a cluster of homes or businesses. It is
this latter use that raises the majority of land use planning and management
issues associated with the proliferation of these systems, and for that
reason, their use in clusters will be the focus of this discussion.
Systems which discharge water to the land surface -- spray irrigation
systems. In these alternative systems, sewage treatment generally occurs in
the same or a similar kind of prefabricated package treatment plant as is the
case when the treated wastewater is discharged into a surface water body.
Most states require that at least secondary treatment occur when the
wastewater disposal method is spray irrigation (Wiswall, et al., 1985). North
Carolina regulations require only primary treatment and chlorination unless
the wastewater is to be used to irrigate public or semi-public lands such as
golf courses, or in the case of industrial waste treatment. (15 NCAC 2H
§ 0219(k)). In 1985, there were four privately owned spray irrigation systems
serving large developments in Dare County. (Booz, Allen & Hamilton, 1985).
Once it has been treated, the wastewater is applied to the land surface
as irrigation is needed, using sprinklers or spray nozzles, either in fixed
locations or on movable pipeline (common in agricultural applications).
Adequately sized lagoons or large holding ponds must be available to store the
treated wastewater before its applications, since irrigation cannot occur
continuously. Once applied to the land, nitrogen and other nutrients in the
wastewater are taken up by plants, and the water is further cleansed as it is
filtered through the ground and back into the water table.
The rate at which treated wastewater can be disposed of using spray
irrigation.systems.varies.depending on the weather, the needs of the crop type
being irrigated, and the underlying soil's drainage characteristics. The
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amount of land and wastewater storage area required for these systems will
also vary depending on these factors, and therefore spray irrigation can be a
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very land -intensive method for effluent disposal. Where cash crop production
is not a necessary secondary benefit of these systems, application rates can
be increased, and land requirements reduced (Wiswall, et al., 1985).
Subsurface Disposal Systems. Alternative systems that force treated
wastewater into the soil are often used to serve a cluster of dwelling units
or a large commercial development. They are used when land is too expensive
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or too scarce to support a spray irrigation system, where surface water bodies
are not available to accept treated effluent, or where conventional septic
system absorption field disposal is not feasible. In these situations,
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subsurface disposal systems allow for development at higher densities than
would be possible using conventional individual on -site septic systems.
The Low Pressure System. Figure 3 illustrates a typical low pressure
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disposal system. The most obvious difference between this kind of system and
a conventional septic system disposal field is the use of a pump to pressurize
and distribute the treated wastewater and `force' it into the soil under
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pressure (2 to 5 pounds per square inch). The fact that the wastewater is
pumped under pressure allows the absorption fields to be located off site from
the waste -generating facilities. For this reason, one low pressure system can
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be used to support a cluster of homes or businesses. Community low pressure
systems are becoming common in newer developments on the North Carolina
barrier islands. The 1985 Dare County Carrying Capacity Study noted that
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there were, in Dare County, over 100 of these systems larger than 3,000
gallons per day at the time the study was completed. Appendix A describes the
history of some of these systems as well as similar systems in place in other
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North Carolina barrier island areas.
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A network of small diameter perforated plastic pipes are
buried six to eight inches deep in four to six inch wide
trenches. Pump forces wastewater through pipes in
controlled doses so that the liquid is discharged evenly
into the soil. Site and soil characteristics determine
the pipe layout and pipe hole size and number, as well as
the total land area needed to absorb a given amount of
wastewater. Waste is collected from a number (cluster)
of generators, and treated in a communal septic tank or
tanks, or given secondary treatment in a surface package
plant.
secondary treatment
or septic stank
waste flow a
via gravity from
a cluster of
waste generators
PUMP trenches lain with
/ perforated plastic piping
FIGURE 4. LOW PRESSURE SUBSURFACE PIPE DISTRIBUTION
FROM: U.S. Environmental Protection Agency, 1980.- Small Wastewater Systems.
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Low pressure ground absorption fields can be used for disposal of treated
wastewater from a septic tank or tanks, or from a conventional above -ground
package treatment plant providing secondary or even tertiary treatment. The
component parts of the disposal system include the pump or pumps used to move
the wastewater from the treatment facility to the disposal field area, a
distribution box which directs the flow of pressurized wastewater into various
parts of the fields, and the absorption fields themselves.
Most commonly, the fields are excavated trenches which are similar to but
shallower than those found as part of conventional septic systems. The
trenches are lain with perforated PVC plastic piping, and overlain with sand
.and topsoil fill on which grass cover is planted. Wastewater is forced under
0
pressure through the holes in these pipes into the soil where it is further
treated by the microorganisms living there.
Because the treated wastewater is under pressure, soils which would be
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marginal or unsuitable for conventional septic system disposal fields due to
their limited ability to absorb treated wastewater become acceptable for low
pressure systems.- This effect occurs because the pressurized wastewater is
2
distributed evenly along all of the length of the PVC piping, and is forced
further into the surrounding soils, rather than being unevenly distributed
along the piping as is the case in a conventional gravity -dependent system.
Low pressure absorption field trenches also need only be $ to 18 inches deep,
rather than the 25 to 36 inch depth required for conventional trenches. This
allows their use in shallower soils than are required for conventional fields,
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and in areas where the distance between the water table and the ground surface
is smaller than would be acceptable for a conventional system. Because
bacteria, air and organic matter that provide additional wastewater treatment
re,
are found in greater concentrations in the upper 12 to 24 inches of soil,
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where low pressure system trenches are located, than at the 25 to 36 inch
depth of most conventional septic field trenches, aerobic treatment in the
soil is encouraged in a low pressure system.
Mound Disposal Field Systems. The only difference between these disposal
systems and low pressure systems is that treated wastewater absorption takes
place in slightly different kinds of fields. Waste collection and treatment
for a mound system can occur in the same ways as for a low pressure system,
and treated wastewater is pumped under pressure to an absorption field. As
illustrated in Figure 4, however, the absorption fields are developed above
the ground's natural grade, from non-native soils, in order to provide
adequate treated wastewater absorption and additional treatment where no
adequate native soils exist. The resulting `mound' is a sand and topsoil
mixture in which the PVC piping is laid and the pressurized wastewater is
distributed. The soil and sand mixture is covered by a clay cap and more
topsoil, and stabilized with grass cover.
Mound systems are 3 to 4 times as costly to install as low pressure
systems and therefore are generally used only where even low pressure systems
are infeasible. Mounds are used when native soils are extremely permeable and
do not provide adequate wastewater residence time for treatment; when native
soils are poorly drained or mucky; and where the water table occurs at a very
shallow depth below grade. All of these conditions are present in various
parts of coastal barriers, making the mound system a likely candidate to
support development in these difficult areas.
Evidently there has not yet been much success with the use of mound
systems on North Carolina barrier islands, and there are few in operation.
Difficulties have included.the breaching of the side walls of the absorption
field mounds (EPA, 1983; Nierstadt, et al., 1983). Mounds are described here
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Liquid effluent is pumped from a storage tank where it is held
following treatment in a septic system or a secondary treatment
facility. The liquid is pumped through perforated plastic piping
in a sand mound that covers the ground's natural grade. The mound
also is made up of gravel and natural soil, through which the
liquid is filtered. The top of the mound is vegetated.
MOUND ABSORPTION perforated pipe egetation
FIELD -- CROSS absorption
SECTIONAL DIAGRAM p Sol field
Inlet pipe from septic ,`.� OIL FILL • '
or secondary treatment •�� �� •�� ��' .
serving a cluster of
waste generators natural grade
FIGURE 5. Mound System used with a septic tank or secondary treatment system.
FROM: U.S. Environmental Protection Agency, 1980. Small Wastewater Systems.
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not because they are in current proliferation, but because as advances in the
technology are made, these systems may begin to be used with more frequency,
R
especially in areas where soils are completely unsuitable for other types of
subsurface or land application. This technology may be the one which opens up
the potential for the development of extremely sensitive areas.
2. Regulation of Alternative Treatment and Disposal Systems
A. DEM Permitting Authority: Minimum Design Criteria
As previously mentioned (page 14), regulatory authority for alternative
M
systems is divided in North Carolina between the Department of Natural
Resources and Community Development (NRCD) and the Department of Human
Resources (DHR). Specifically, the Division of Environmental Management (DEM)
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of the NRCD and the Environmental Management Commission (EMC) have been
granted jurisdiction to approve systems that (a) are designed to discharge
treated wastewater to surface waters, and (b) that are public systems or
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community systems designed to discharge treated wastewater to the land
surface or subsurface. (N.C.G.S. § 130A-335(b)). Public systems include
those owned and operated by a sanitary district, a water and sewer authority,
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a county or municipality, or a public utility. (N.C.G.S. § 130A-334(8)). All
other alternative land -discharging systems -- those that are owned and
operated by a homeowners' association -- are permitted by the Commission for
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Health Services (CHS) through the Department of Human Resources (DHR). The
CHS and DHR have no permitting authority over systems discharging to surface
waters.
The DEM issues permits for the construction and operation of public or
community systems, as well as for their alteration, extension or changes in
the method of.their operation. (N.C.G.S. § 143-215.1(a)(2)(3)). All
facilities requiring a DEM permit must be designed following good engineering
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practice and not result in nuisance conditions. -The regulations lay out in
detail minimum design standards which must be met by all facilities before a
permit will be issued. (15 N.C.A.C. 2H § 0219; 15 N.C.A.C. 2H § 0139). Of,
particular interest to.barrier island communities are the required "buffer
zones" for treatment works and disposal systems. A distance of at least 100
feet from normal high waters is required for waters classified as SA
(shellfishing quality). Facilities involving subsurface disposal must be at
least 50 feet, and those involving non -discharge surface disposal must be at
least 100 feet from any other stream, canal, marsh or coastal waters. (15
N.C.A.C. 2H § 0219(j)(5)(d)(f)).
The DEM has the power to grant permits with conditions attached as
necessary to achieve the purposes mandated by statute (§ 143-215.1(b)(1), as
well as to modify or revoke any permit upon adequate notice to any person
affected. (N.C.G.S. § 143-215.1(b)(3)). The DEM may also conduct inquiries
or investigations before taking action on a permit application, and may
require an applicant to submit plans, specifications, and other information
considered necessary to evaluate the application. (N.C.G.S. § 143-
215.1(c)(1)). Permits are issued or renewed for up to five years.
Facilities requiring a DHS permit must meet standards set out in the
"Planning and Permitting Procedures and Design Guidelines for Subsurface
Sewage Systems Where the Design Flow Exceeds 3,000 Gallon' Per Day," by the
DHS under the regulatory authority established in 10 NCAC 10A .1900. These
standards require DHS and county health department assessment of disposal site
suitability. Where DER permits are given (for public or community systems),
there is no requirement that the county health department evaluate these
parameters. The DHS standards also contain other design criteria that are
generally held to be more stringent than the DEM standards, by members of the
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public utility and regulatory communities. (Davis, 1988, personal
communication; Lowery, 1988, personal communication; Osborne, 1987, personal
communication).
B. Regulation of Public Utilities: Performance Bonding Requirements
The public utility companies which are responsible for operating DEM-
permitted alternative systems, and which may also own the systems, are
regulated by the North Carolina Utilities Commission. The Utilities
Commission requires such public utilities to post a performance bond on each
system for which a DEM permit is issued. The bond is held by the commissioner
for the lifetime of the utility contract to operate the system (the five-year
period during which the DEM permit is valid). It can be called in by the
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Utilities Commission to make needed repairs or improvements to systems that
malfunction and/or fail due to operator negligence. The performance bond is
required to be a minimum of $10,000 per facility, up to a maximum of $200,000,
'O
at the Utility Commission's discretion, based on the size of the facility and
the particular public utility's track record.
C. Homeowners' Associations: Operational Agreements'Required for DEM
Permits
In cases where a non -discharge alternative system permit is issued by the
DEM for the operation of a treatment works for a private multi -family or
single family residential development, in which the owners of individual Q
residential units are required to organize as a homeowner's association of a
subdivision, condominium, planned unit development, or townhouse complex, the
public utility applicant must enter into an operation agreement with the EMC
as a condition of any such permit granted. The agreement must address, as
necessary, construction, operation, maintenance, assurance of financial
solvency, transfers of ownership and abandonment of the system, and must be Q

O 45
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modified to reflect any changed condition at the system or in the development.
The EMC may require any other private residential subdivision, condominium,
planned unit development or townhouse complex which is served by a private
treatment works and does not have a homeowner's association, to incorporate as
a lawfully constituted homeowner's association, and after such incorporation,
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to enter into an operational agreement with the EMC and the applicant as a
condition of any such permit granted. (N.C.G.S. § 143-215.1(d)(1)).
D. Local Permit Programs
Local governments (which include municipalities, counties, local boards
or commissions, water and sewer authorities, or groups of municipalities and
counties) may establish and administer their own general permit programs in
lieu of the state permit program for the construction, operation, alteration,
extension or change of proposed or existing public and private sewer systems
(including both facilities which discharge to surface waters and those which
do not) within their utility services areas. (N.C.G.S. § 143-215.1(f)).
Permits issued by approved local programs serve in place of permits issued by
the division. (15 N.C.A.C. 2H § 0218(a)). The service area of a municipality
is defined to include only that area within the corporate limits of the
municipality in its extraterritorial jurisdiction where sewer service is
already being provided by the municipality to the permit applicant or where
C3
connection to the municipal sewer service is immediately available to the
applicant; likewise, the service areas of counties and the other entities or
groups include only those areas where sewer service is already being provided
IN
to the applicant by the permitting authority or connection to the permitting
authority's system is immediately available. (N.C.G.S. § 143-215.1(f)).
Applications for approval of local sewer -system programs must provide
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adequate information to assure compliance with the requirements of N.C.G.S.
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§143-215.1(f). To receive certification from the EMC, a local program must
meet certain criteria; the program must: (1) provide by ordinance or other
191
local law for requirements compatible with the Statute and EMC rules; (2)
provide that NRCD receives notice and a copy of each application for a permit
and that it receives copies of approved permits and plans; (3) provide that
U
plans and specifications for all construction, extensions, alterations, and
changes be prepared by or under the direct supervision of an engineer licensed
to practice in the state; (4) provide for the adequate enforcement of the
program requirements; (5) provide for the adequate administrative
organization, engineering staff, financial and other resources necessary to
effectively carry out its plan review program; (6) provide that the system is
0
capable of interconnection at an appropriate time with an expanding municipal,
county, or regional system; (7) provide for the adequate arrangement for the
continued operation, service, and maintenance of the sewer system; and (8) be
0
approved by the EMC as adequate to meet the requirements of the statute and
implementing rules. (N.C.G.S. §143-215.1(f)). The regulations lay out
additional requirements that must be met by applicants for approval of local
programs, some of which include: (1) copies of permit application forms,
permit forms, minimum design criteria, and other relevant documents to be used
in administering the local program must be submitted; (2) the local
8
government's attorney must certify that the local authorities for processing
permit applications, setting permit requirements, enforcement, and penalties
are compatible with those for state -issued permits; (3) if the treatment and
disposal system receiving the waste is under the jurisdiction of another local
unit of government, then the program application must contain a written
statement.from that local unit of government that.the.proposed program
complies with all its requirements and that the applicant has entered into a
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satisfactory contract which assures continued compliance; (4) each project
permitted by the local sewer system program shall be inspected for compliance
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with the requirements of the local program at least once during construction;
and (5) a quarterly report shall be submitted to the state listing the names,
permit numbers and other information regarding permitees. (15 N.C.A.C. 2H §
0218(b)). The EMC may deny, suspend, or revoke certification of a local
program upon a finding that a violation of any criteria has occurred.
(N.C.G.S. § 143-215.1(f)). The regulations also provide that once a local
permit program is in place, appeal from individual permit denials or issuance
with conditions the permit applicant finds unacceptable are to be made to the
local program authority or to an appropriate judicial level. The EMC will not
a
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consider individual permit denials or issuances with conditions. (15 N.C.A.C.
2H § 0218(f)).
E. Enforcement Provisions
N.C.G.S. § 143-215.6 lays out enforcement procedures for Article 21 of
Chapter 143 ("Water and Air Resources"), which include the imposition of both
civil and criminal penalties. The EMC may assess a civil penalty of up to
0
$10,000 per day against any person who violates any classification, standard,
limitation, or management practice established pursuant to N.C.G.S. § 143-
214.1 (water quality standards) or § 143-215 (effluent standards). (N.C.G.S.
Q
§ 143-215.6(a)(1)(a)). A civil penalty may also be assessed against a person
101
who is required and fails to secure a permit, or violates any of its terms.
(N.C.G.S. §143-215.6(a)(1)(b)), or who refuses access to the EMC to any
premises for lawful inspection. (N.C.G.S. § 143-215.6(a)(1)(e)). If a civil
penalty is assessed and has not been paid within 30 days after receipt of
notice, the•EMC may institute a civil -action in superior county court
0
(N.C.G.S. § 143-215.6(a)(4)). The assessment and imposition of civil
❑E

48
penalties, and the decision to sue in civil court lie in the discretion of the
EMC (the term "may" as opposed to "shall" in this statutory subsection
indicates enforcement is discretionary). The EMC may enforce the statute
through civil penalties whenever a violation has occurred, whether the guilty
party acted with or without intent or negligence. The NRCD may also file a
civil action in the name of the State in superior county court through the
State Attorney General for injunctive relief to restrain any violation or
101
threatened violation either before or after the institution of any other
a
action or proceeding authorized by the statute. (N.C.G.S. § 143-215.6(c)).
The statute further provides that criminal sanctions shall be imposed
upon any person who willfully or negligently violates the same provisions
O
covered by the section for civil penalties, as well as for violation of EMC
regulations. The violation will be considered a misdemeanor, punishable by a
fine of up to $15,000 per day of violation (not to exceed a cumulative total
fl
of $200,000 for each 30 days of violation), or by imprisonment up to six
months, or both. (N.C.G.S. §143-215.6(b)(1). Criminal sanctions are also to
be imposed upon any person who knowingly makes any false -statement,
0
representation, or certification in any application, record, report, plan or
other document filed or required to be maintained by statute or regulation.
Sanctions may also be imposed against anyone who falsifies, tampers with, or
U
knowingly renders inaccurate any recording or monitoring device or method
required to be operated or maintained. Any such violation will be a
misdemeanor, punishable by a fine up to $10,000 or by up to six months
0
imprisonment, or both. (N.C.G.S. § 143-215.6(b)(2)). The imposition of these
criminal penalties does not lie in the discretion of the EMC (use of the words
"shall be guilty, of ". indicates automatic. sanctionupon. determination of
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violation). The criminal sanctions are not based on strict liability;
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instead, a showing of willfulness or negligence must be made prior to the
imposition of a fine or jail sentence. Note: If the county takes over
X
authority for alternative systems through a local permit program established
under 15 NCAC 2H § .0218(b), it also may take over enforcement for those
systems it has permitted.
F. Municipal Enabling Legislation
Under N.C.G.S. Chapter 160-536, Article 23 ("Towns and Cities"),
municipalities may establish a municipal service district of sewage collection
M
and disposal systems of all types: "A city may provide services, facilities,
functions or promotional or developmental activities in a service district
within its own forces, through a contract with another governmental agency,
M
through a contract with a private agency, or by a combination thereof."
However, a town's authority to actually address and control particular
activities under this provision remains unclear.
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►�
Pursuant to N.C.G.S. § 160 A-196, local governments near the coast
(specifically, "Cities that (in whole or in part) are adjacent to, adjoining,
intersected by or bounded by the Atlantic Ocean and Roanoke, Albemarle,
S
Currituck or Pamlico Sound") may enact ordinances to regulate tie-ons to
sewage systems within their corporate limits. This explicit authority
includes regulation of tie-ons to public treatment systems which are under the
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local government's control, and extends to treatment systems over which other
entities (such as the county, private systems, local sewer districts) maintain
control.
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The statute apparently grants towns broad powers to control sewage
treatment plants. However, the extension of authority made explicit by the
statute may have.implications regarding the -issue of pre-emption of municipal
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authority; the fact that the legislation is necessary in order for local
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governments to control all tie-ons within their jurisdictions suggests that
locals do not have this authority in the absence of special legislation (see
n
discussion of the pre-emption issue below). Under N.C.G.S. § 160A-185, "a
city may by ordinance regulate, restrict, or prohibit the emission or disposal
of substances or effluents that tend to pollute or contaminate land, water, or
air, rendering or tending to render it injurious to human health or welfare,
to animal or plant life or to property, or interfering or tending to interfere
with the enjoyment of life or property." Thus, through its ordinance -making
0
power, a city may supplement state and federal pollution laws and regulations,
so long as any ordinance enacted is not inconsistent with the state and
federal laws. Under this provision, a city may choose to impose restrictions
0
on wastewater disposal systems within its jurisdiction supplemental to but not
more stringent than state or county board of health requirements; such
additional restrictions could include mandatory minimum lot sizes; greater
Q
specificity of soil type restrictions; restrictions applicable to unique
coastal barrier characteristics; and similar requirements. A question
regarding enforcement of these additional restrictions remains open, however.
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Since the county health department is responsible for implementing the
wastewater rules and regulations it has adopted, the county department may be
unwilling to enforce supplemental requirements imposed by individual
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municipalities. In practical terms, due to the manner in which the state-wide
county board of health system has been set up, a municipality is not likely to
be able to establish its own public health department through which to
101
implement a Section 160A-185 pollution ordinance. However, a city may be able
to require a waste treatment system to obtain a city permit, in addition to
the permit.that.the system must receive -from -the state or county board of
a
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health, before that system would be allowed to dispose of polluting substances
or effluents within the municipality's boundaries.
0
G. The Pre-emption Issue
i. Local Boards of Health Rules
Often local governments wish to regulate privately owned wastewater
W
treatment and disposal systems (either septic tanks or alternative systems)
more stringently than does the State. Some counties and municipalities would
like to prohibit the facilities in their jurisdictions altogether, or to
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relegate them to.only certain districts. Some forms of local regulation in
addition to state -issued rules are permitted by statute; other types of
management, such as approval and locational requirements, may be effected
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through the local government's zoning powers. However, whether government
action is taken through the promulgation of public health rules or through
enactment of zoning ordinances, the issue of state.or federal pre-emption of
J
local regulation may arise.
County boards of health are given the statutory responsibility by
N.C.G.S. § 130A-39(a) "to protect and promote the public health" and "to adopt
2
rules necessary for that purpose." G.S. § 130A-39(b) provides that, "A local
board of health may adopt a more stringent rule in an area regulated by the
Commission for Health Services or the Environmental Management Commission
X
where in the opinion of the local board of health, a more stringent rule is
required toRrotect the public health; otherwise, the rules of the Commission
for Health Services or the Environmental Management Commission shall prevail
over local board of health rules" (emphasis added).
The authority to adopt "a more stringent rule" in areas regulated by the
two named state environmental commissions obviously is designed to enable
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county health authorities to treat state rules as a floor or minimum, which
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may be augmented by stricter local rules where necessary to protect the public
health. The plain language of G.S. § 130A-39(b) obviously signifies that
R
there is at least some authority for county health authorities to go beyond
state requirements in setting local rules.
Despite the empowerment of local boards to adopt some localized rules
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even in areas subject to State regulation, the issue of what type of local
rules is permissible under G.S. § 130A-39(b), and under what limitations they
may be adopted, still may arise. The statute clearly states that local rules
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must be enacted "to protect the public health;" they will be subject to
question if not health -related. However, the statute is framed in language
calculated to protect the local board's judgment against close judicial
1*1
scrutiny. It says that a more stringent rule may be adopted where, "in the
opinion of the board of health," it is required to protect the public health.
This kind of language often is interpreted as granting broad agency discretion
1A
and calling for judicial deference to agency action when such action is
reviewed by a court. One would expect that the courts would sustain a local
finding that a rule was required in order to protect the public health unless
7
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the action was found to be arbitrary, capricious, or an abuse of discretion.
The rule might even be insulated entirely from judicial review as
"legislative" in character.
E e
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The fact that § 39(b) refers to "a more stringent rule" (singular),
rather than "more stringent rules" (plural) may be of relevance in determining
whether a proposed local rule is "more stringent" than the related state rule.
O
Had the phrase been stated in the plural form, it would be easier to justify
an interpretation that § 39(b) local rules may be valid if they are, in some
overall sense, "more stringent" than state rules.- Conservatively, local
boards would be well advised to break down complex local rules into segments
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that can be compared, one by one, with the relevant state rule, in order to
determine whether the local "rule" is "more stringent." Courts do not always
pay attention to whether a statutory provision is singular or plural, but it
would be unwise to count on this here..
The wording of § 39(b) is too general to determine with confidence what
constitutes a "more stringent rule" within the meaning of the statute, and
there have been no appellate decisions interpreting the section. Arguably, an
absolute local prohibition against treatment facilities might be considered a
"more stringent rule" than a state rule that merely establishes standards and
specifications but contains no prohibition. If so, it must be asked whether
the county health board or any local governing body may totally prohibit an
action that has been authorized by a state permit or license. The North
Carolina Supreme Court has answered "no" to a similar question in Tastee-
Freez. Inc. v. Raleigh, 256 N.C. 208, 123 S.E.2d 632 (1962), invalidating a
A
Raleigh ordinance that prohibited push -cart ice cream peddlers who had
obtained State privilege licenses under G.S. § 105-53.
The principles of state pre-emption, including that expressed in the
X
Tastee-Freez decision, are codified in G.S. § 160-174. This section provides
in part that a city ordinance is not consistent with state or federal law if
it . . (b)(2) makes unlawful an act, omission or condition which is
F
expressly made lawful by state or federal law." At the very least, the
Tastee-Freez decision as codified in G.S. § 160A-174(b)(2) raises serious
doubts about the authority of the board of health to prohibit a state -approved
treatment system.
G.S. § 160A-174(b)(5) may also have implications for locally promulgated
rules which attempt to prohibit.the use of package treatment plants and other
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54
alternative systems within the unit's jurisdiction. Subsection (b)(5)
provides that "An ordinance is not consistent with state or federal law when:
u
The ordinance purports to regulate a field for which a state or
federal statute clearly shows a legislative intent to provide a
complete and integrated regulatory scheme to the exclusion of local
regulation.
The most relevant North Carolina substantive legislation implicated by § D
160A-174(b)(5) is the statute governing the water pollution control powers of
the Environmental Management Commission (EMC) - G.S. §§ 143-211 et sec.,
especially §§ 143-215,-215.1, and-215.3.
The fact that state law assigns to EMC the authority to approve treatment
systems suggests that the State does intend to "provide a complete and
101
integrated regulatory scheme," thereby excluding local regulation. Some O
communities have passed ordinances prohibiting package treatment plants in
watershed areas. However, since there have been no reported cases concerning
the pre-emptive implications of this legislation, the authority to take such C?
action is subject to question, and no definitive legal answer can be given
until the matter is resolved in court. (Brough, 1988).
Leaving aside the absolute prohibition of State -approved treatment O
systems, such provisions as can be found in the water pollution control
legislation concerning state -local relations indicates the General Assembly
intended to leave most local powers in this area undisturbed. Thus, G.S. § O
143-215.7 provides that, "This Article shall not be construed as . . .
affecting the powers, duties and authority of . . . local health departments
or as affecting the charter powers, or other lawful authority of municipal O
corporations, to pass ordinances in regard to sewage disposal." (Note the
specific reference to "municipal corporations" and local health departments,
but not to counties.) As an analogy, a similar, if narrower, "hands -off" O
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policy on local powers is reflected in a savings clause of the oil spill
control law which states, "nothing in the article shall be construed to deny
201
to any county, municipality . . or other authorized local governmental
entity, by ordinance, regulation or law, from exercising police powers with
reference to the prevention and control of oil or other hazardous substances
u
discharged to sewers or disposal systems." (G.S. § 143-215.82).
Two other related provisions deserve mention here. In the state air
pollution control law, also overseen by the Environmental Management
n
Commission, there are detailed provisions concerning local air pollution
control programs that narrowly circumscribe the ways that local governments
can undertake such programs and prohibit local programs from being established
J
and administered without EMC approval. (G.S. § 143-215.112). One might infer
from the absence of similar provisions concerning local water pollution
control programs (other than the provisions of Chapter 130A) that the General
P
Assembly meant to leave greater flexibility for local water pollution control
activities.
The other related section is the so-called "Hardison Amendment," which
X
expresses the intent of the General Assembly that the water effluent standards
and management practices adopted by the EMC shall be no more restrictive than
the most nearly applicable federal effluent standards and management
S
practices. (G.S. § 143-215). This section makes no mention of locally
adopted water effluent standards or management practices. By contrast, the
similar "Hardison Amendment" in the air pollution control statute does provide
.X
that the air quality rules and standards and air emission standards adopted by
the EMC "or by any other State or local regulatory_ body" shall be no more
stringent than -required to comply with federal requirements. (G.S. § 143-
Eel
215.107 (emphasis added)). One might read the express reference to local
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56
standards in the air pollution control statute, and the absence of any such
reference in the similar water pollution control section, as indicating an
intent not to apply the policy of the Hardison Amendments to local water
pollution control ordinances, but it is about as likely that the more specific
language of the Hardison air provision merely reflects a somewhat greater
attention to detail in a later statute.
It should be reiterated, however, that a local ordinance or rule which
prohibits a particular waste disposal practice that had been specifically
approved pursuant to State law still encounters the specific assertion of G.S.
§ 160A-174(3) that an ordinance which makes unlawful an act expressly made
lawful by state law is "not consistent with state law." In this respect, it
is difficult to avoid the plain import of North Carolina pre-emption law,
reinforcing the Tastee-Freez case.
L01
In sum, even though the provisions of § 160A-174 are found only in the
Q
city chapter of the General Statutes, it is probably reasonable to treat this
section as a generally applicable codification of pre-emption concepts and to
use it as a "checklist" for evaluating potential pre-emption problems in any
O
local ordinances or rules. The basic elements of the checklist identified in
G.S. § 160A-174 are:
a. Express pre-emption [paragraph (4)];
b. Implied pre-emption by a pervasive scheme of state regulation
[paragraph (5)];
c. Partial pre-emption by conflicting provisions in a state law and
local ordinance [paragraphs (2) and (3)].
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N.C.G.S. § 160A-174
Q § 160A-174. General ordinance -making power.
M
(a) A city may by ordinance define, prohibit, regulate, or abate acts,.
omissions, or conditions, detrimental to the health, safety, or welfare of its
citizens and the peace and dignity of the city, and may define and abate
nuisances.
(b) A city ordinance shall be consistent with the Constitution and laws
of North Carolina and of the United States. An ordinance is not consistent
with State or federal law when:
(1) The ordinance infringes a liberty guaranteed to the people by the
Q State or Federal Constitution
(2) The ordinance makes unlawful an act, omission or condition which is
expressly made lawful by State or Federal law;
(3) The ordinance makes lawful an act, omission, or condition which is
t3 expressly made unlawful by State or Federal law;
(4) The ordinance purports to regulate a subject that cities are
expressly forbidden to regulate by State or Federal law;
(5) The ordinance purports to regulate a field for which a State or
U Federal statute clearly shows a legislative intent to provide a
complete and integrated regulatory scheme to the exclusion of local
regulation;
(6) The elements of an offense defined by a city ordinance are identical
to the elements of an offense defined by State or Federal law.
E
The fact that a State or Federal law, standing alone, makes a given act,
omission, or condition unlawful shall not preclude city ordinances requiring a
higher standard of conduct or condition. (1971, c. 698, s. 1.)
Whether the term "stringent" encompasses local rules which are more
X
comprehensive in scope than the state rules is another question to which only
litigation can provide a definitive answer. For instance, if the board of
health's rule establishes requirements or procedures that are not specifically
M
addressed at all by the state law or rule (e.g., the local rule spelled out a
detailed monitoring and inspection protocol while the state rule did not
mention inspections or monitoring), such a rule would be more comprehensive
X
than the state rule, but whether a court would consider it more stringent is
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58
.�
unclear. If the board of health wished to include such provisions in its
rule, the board's position would be strengthened by including one or more
provisions that are clearly more stringent than comparable parts of the state
rule.
Regulation by County Commissioners
A related question which arises as part of the pre-emption issue is the
role of county boards of commissioners (as opposed to local boards of health)
in regulating treatment systems. The county commissioners and the board of
health essentially have dual authority to adopt health regulations - the board
of health under G.S. § 130A-39 as discussed above, and the county
commissioners under G.S. § 153A-121(a). While a "more stringent" local rule
passed by a board of health for public health reasons under G.S. § 130A-39 is
not pre-empted by state law or regulation, there is no similar provision in
G.S. Chapter 153A (general ordinance making power); thus a commissioner's
ordinance would be much more vulnerable to pre-emption by state law.
Furthermore, the authority of the commissioners may be undercut by the
ordinance -making powers of cities under G.S. § 160A-174 et sec. Specifically,
G.S. § 160a-185 expressly empowers cities to adopt ordinances to regulate
emission or disposal of effluents that pollute land, water, or air, these
ordinances to "be consistent with and supplementary to state and federal laws
and regulations." It might be argued that the express grant of this authority
to cities by implication raises questions about the authority of county
commissioners to regulate the same subject. (To a lesser degree the same
argument might apply also to health board rules).
County commissioners' ordinances that would prohibit surface and
subsurface wastewater disposal systems are subject to the same objections
derived from the Tastee-Freez decision that were previously noted as to health
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board rules. It is likely that any local prohibition against package
treatment plants or other alternative systems that have been approved by the
State would be vulnerable to judicial invalidation, whether embodied in a
health board rule or a commissioners' ordinance.
In summary, the following observations regarding State pre-emption of
local regulation can be made:
1. The approval of alternative treatment systems has not been expressly
pre-empted in toto by state law.
O 2. A local ordinance or rule that completely prohibits a system within
the local jurisdiction in the face of a state permit approving a
particular system would probably be pre-empted on the reasoning of
the Tastee-Freez decision, as codified in G.S. § 160A-174.
3. The issue of implied pre-emption of local ordinances or rules
O regulating treatment systems short of outright prohibition is not
clearly settled under the North Carolina water pollution control
statutes. On the one hand, those statutes do contemplate a
comprehensive system of state regulation in keeping with the policies
of the federal Clean Water Act. On the other hand, such evidence as
can be found in the state law indicates that the General Assembly did
a not intend to entirely exclude local water pollution control
ordinances, or to circumscribe them as narrowly as local air
pollution control ordinances are circumscribed. In the final
analysis, a rule adopted by the board of health under G.S. 130A-39(b)
that regulates (but does not prohibit) treatment systems more
stringently than does a state permit should be better able to
Q withstand a pre-emption attack than a county commissioners' ordinance
to the same effect. (Heath, 1989).
Federal Pre-emption
Whether local units of government may regulate location and approval of
alternative treatment systems through the promulgation of health rules raises
questions of federal as well as state pre-emption. The general concepts of
O federal pre-emption may be summarized as follows: (1) state statutes may be
entirely pre-empted by exRress language of federal laws; (2) state statutes
may be entirely vre-empted by implication from a pervasive scheme of federal
O regulation that leaves no room for state law or by the very nature of a field
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60
completely dominated by federal law; and (3) state statutes may be void to the
extent that they conflict with valid federal regulations -- as where
compliance with both federal and state law is impossible, or state law is an
obstacle to executing federal law. The main object in searching for possible
federal pre-emption, then, will be (a) to determine whether there is express
pre-emption or a federal scheme of regulation so pervasive as impliedly to
preclude state regulation (i.e., does federal law "cover the field"?), and (b)
to determine whether state law conflicts with federal law.
The relevant federal legislation is the Federal Water Pollution Control
Act Amendments of 1972, popularly known as "The Clean Water Act" (CWA) (33
n
101
U.S.C. § 1251 et sec.). Congress explicitly provided that the CWA would not
O
11(1) preclude or deny the right of any state or political subdivision thereof
[emphasis added] ... to adopt or enforce (A) any standard or limitation
respecting discharges of pollutants, or (B) any requirements respecting
O
control or abatement of pollution," so long as the state or local provisions
are not less stringent than the federal provisions. (33 U.S.C. § 1370(1)).
Therefore, it appears Congress did not intend the CWA to raise any substantial
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pre-emption issues regarding regulation of wastewater treatment facilities by
the states or their political subdivisions.
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ii. Regulation of Sewage Treatment and Disposal Facilities Through
Zoning
Towns, cities and counties in North Carolina may regulate and control the
siting of buildings, activities and utilities within their jurisdiction
through exercise of their police power. The regulation or prohibition of
W
surface discharging package treatment plants and other alternative treatment
and disposal systems through local zoning ordinances, however, may involve
issues of pre-emption by the State.
C
In contrast to state legislation governing facilities for treating or
disposing of hazardous waste (see, e.g., G.S. § 130A-293), the legislation
governing sewage treatment and the disposal of wastewater includes no explicit
0
pre-emption language that might cast doubt on local zoning authority. A
review of state law governing treatment and disposal operations (G.S. § 143-
215.1 and applicable regulations) suggests that the primary purpose of the
legislation is to control water pollution, not necessarily to control the
siting of sewage treatment facilities. The Division of Environmental
Management assumes the location of such operations has been properly zoned for
Lei
purposes of determining whether any surface -water discharge or alternative
disposal method will be allowed, and if so, the nature and extent of such
disposal. Zoning standards that do not conflict with the scope of
U
environmental health regulations should not be subject toga valid pre-emption
claim.
The question of whether a privately -owned and -operated waste treatment
4
plant and related operations which have been approved and licensed by a state
agency are subject to the locational restrictions of zoning has not been
directly addressed by North Carolina courts. However, current law suggests
PC
that treatment operations owned by units of government and licensed by the
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State are subject to zoning; if so, it is likely that private operations are
as well. Such private facilities are typically provided to support "trade,
industry, residence, or other purposes" (G.S. § 153-A-340), uses of private
property that clearly are subject to [County] zoning. In addition, there is
no reason to believe that the State's wastewater treatment and disposal
legislation pre-empts regulating the location of privately -owned plants if it
does not also pre-empt the zoning of plants owned and/or operated by local
units of government.
Despite the fact that in North Carolina local governments appear to enjoy
the power to apply zoning regulations to at least some features of public and
0
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private sewage treatment and disposal operations, many zoning ordinances do
O
not regulate sewage treatment plants and disposal operations with much
precision. Many ordinances do not specifically provide for sewage treatment
operations; they apparently treat sewage plants as "public utilities," a term
O
that may also include private facilities. Often sewage treatment works are
allowed in virtually all zoning districts, apparently on the theory that
treatment facilities should be allowed in proximity to the development that
O
generates the need for them. Some jurisdictions distinguish regional
treatment facilities (typically owned and operated by a public agency)
allowing them only in industrial or related districts. In recent years, a
O
growing number of smaller -scale privately -owned "packagel"waste treatment
systems have been put into operation. In some cases these systems are
designed to serve a particular type of project or land use (e.g., a shopping
a
center, apartment complex). However, such systems cannot neatly be classified
as "accessory" to a particular project or land use since a particular system
may serve.several activities, even if the plant is restricted to treating and
O
disposal of "domestic" wastes. Finally, a small but growing number of local
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governments specifically prohibit public or private sewage treatment plants or
community sewage treatment facilities in certain districts. (See, e.g.,
O
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Section XXXXV(G)(1)(a) of the Durham County Zoning Ordinance, banning such
plants in the water quality areas of the watershed district.) The Code of
Ordinances of the Town of Southern Shores contains provisions regarding the
location of wastewater systems in its jurisdiction:
Sec. 9-7. Location of Wastewater Systems
(a) The Town shall not permit a private on -site wastewater system to
O serve any dwelling units which are located in environmentally
sensitive areas, i.e., floodplain, wetlands, and areas of
environmental concern, until the development has been conditionally
approved by the state division of coastal area management (CAMA)
and/or the U.S. Army Corps of Engineers and county board of health.
O (b) No wastewater system will be permitted on lands not owned or leased
by the owner for the purposes intended.
(c) Only private wastewater systems shall be permitted in an area zoned
RS-I.
O (d) No service pipe or wastewater transport pipe shall be allowed to run
across any property, without proper easement rights or encroachment
agreements for the pipeline corridor. (Ord. No. 85-0049, § 1-0006,
12-3-85).
Private wastewater systems are defined in Sec. 9-1 of the Ordinance
O as "any treatment works which is neither a community (serving at
least fifteen service connections (dwelling units) used by year-round
residents) or noncommunity system (serving hotels, motels,
restaurants, schools, factories, and other public accommodations).
Included are single family and multi -family dwelling units, some
private business offices or any system restricted to public use.
When a permit has been issued at the state level for a privately -owned
community sewage treatment and disposal facility, a local unit of government
O would probably find it difficult to justify zoning regulations that would
completely prohibit such plants from the jurisdiction, even if the plant
serves land uses and activities located in other zoning districts. State
O policy, as implemented through the permitting system, treats such plants as
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legitimate forms of sewage treatment and disposal. Furthermore, it is common
zoning practice to allow such plants in most zoning districts. This is
O
particularly true if an ordinance makes relatively few specific references to
private treatment plants and manifests no clearly -demonstrated system for
regulating or prohibiting plants in the various districts. Express language
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clearly prohibiting or restricting such plants in particular zoning districts
is probably necessary to ensure that these attempts are not pre-empted by
state environmental health law.
❑c
If a sewage treatment and disposal plant is proposed in a district where
it is allowed and is subject to zoning, its location may be restricted by
conditions placed on its location and operations under the terms of a special
4
use permit, where such permits are required by the ordinance for that
district. In issuing such permits the governing board may "impose reasonable
and appropriate conditions and safeguards upon these permits." (G.S. § 153A-
O
340). The question of what type of condition may be added to a special -use
permit governing a treatment and disposal facility is related to the question
of when a particular zoning requirement may be pre-empted by state
A
environmental health law. The jurisprudence on this point is skimpy.
However, conditions related to buffering and screening of the site would
probably be legitimate. Conditions governing the location on the site of
0
buildings and structures and various operations might be acceptable, but only
to the extent that they do not interfere or conflict with the treatment and
disposal operations specified by the DEM. The Code of Ordinances of the Town
O
of Southern Shores addresses some of these concerns:
Sec. 9-9. Design and Appearance Compatibility
(a) The town shall require that any proposed wastewater plant or system
be compatible with its natural surroundings through plant design O
and/or screening vegetation.
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(b) All above -ground structures associated with wastewater treatment
plant design, other than municipal or community -wide treatment
O facilities shall be subject to the following provisions:
U
(1) Excepting the drain fields, treatment works serving
nonresidential users shall not be located less than one hundred
(100) feet from an RS-I zoning district as measured from the
building to the nearest property line.
(2) The design and construction of the treatment works shall comply
with such additional requirements as may be made by the town, and
shall be specifically required to comply with the following
technical and aesthetic standards:
© a. The exterior of the treatment works shall be architecturally
compatible in features and materials with the other
building(s) in the project and shall have suitable vegetative
landscaping and screening to be compatible with local
aesthetic and environmental conditions.
O b. The treatment works shall incorporate all technological
improvements which are feasible and practicable as of the time
of construction.
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(Ord. No. 85-0049, § 1-0008, 12-3-85)
Conditions that would purport to restrict or stipulate the nature of the
waste that could be handled by the plant would be impermissible. Although it
is possible that zoning regulations limiting the area and particular land uses
served by the plant might be upheld if the rationale for doing so were clearly
spelled out in the ordinance, an attempt to impose such restrictions on a
plant through an ad hoc condition added to a special -use permit for the plant
O
would probably fail. (See Davidson County v. City of High Point, 85 N.C. App.
26, 354 5.E.2d 280 (1987), aff'd on other grounds, 321 N.C. 252, 362 S.E..2d
553 (1987)). (Ducker, 1989).
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3: Problems and Issues Associated with the Performance and Regulation of
Alternative Systems
The issues associated with the use of alternative systems can be grouped
O under three general headings: issues associated with system performance, land
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use and planning issues associated with the use of alternative systems, and
public management issues raised by the privatization of these essentially
O
public facilities.
A. System Performance
The performance of surface discharging treatment plants is not generally
W
affected by a site's physical conditions in the way that land application
disposal plants are. A surface water body with adequate capacity to accept
treated wastewater flows is a physical constraint on the use and performance
1*1
of these alternative systems. Aside from being inappropriate to place a
sewage treatment plant in steeply sloped areas or in floodprone areas without
floodproofing and elevation, there are few additional constraints on their
O
location.
Failure of a surface discharging plant generally can be linked to
inadequate operation and maintenance of the treatment system. They are
O
complicated systems, and when neglected, surface discharging plants are quite
likely to malfunction, providing inadequate waste treatment and causing
pollution of the waste -receiving water. When these plants are in private
A
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ownership, there are few controls on a surface discharging system's
operations. In North Carolina, the regular sampling required under the DEM-
issued federal permit (NPDES permit) monitoring reports is the responsibility
A
of the plant's operator, not a state office or a local health department.
According to one former private treatment plant operator and an official of
the state DEM, there are no controls on the appropriate time of day for a
O
sample, and `creative sampling' and reporting can mean that failures go
unnoticed by state officials for long periods of time (Lowery, 1988 and 1989;
Kreutzberger, 1989).
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Although sRray irrigation system technology is widely held to be one of
the most environmentally sound wastewater disposal methods available (ICMA,
1985; US EPA, 1983), these systems can also fail for several reasons. Failure
in these systems includes the spraying of inadequately treated wastewater or
leaks or complete breakdowns in mechanical systems. Because the treatment
plant portion of the system is often very similar to a surface discharging
plant, the risk of failure due to inadequate plant operation and maintenance
is also similar. Incomplete wastewater treatment, including the failure to
completely separate solids, can cause clogging in the disposal spray system
and lines. Inadequate maintenance of the various mechanical systems involved
in the pumping and spray systems can also result in system failure. Improper
installation of any of the components of spray irrigation systems can also
cause system failure.
Low pressure and mound systems were the most successful of the subsurface
O
disposal systems tested by the U.S. Environmental Protection Agency during the
[01
early and mid-1970s. Even so, failures have occurred, some within months of
installation. Experts believe that such early failures occur primarily
because the plants are not installed correctly (Wiswall, et al, 1985; EPA,
1983).
Because they are so new, there is little information on the long-range
O
performance of low pressure and mound systems in the field. These systems are
also being designed and built to serve larger and larger developments,
although the positive experience with them has been in cases where they served
O
relatively small scale projects. In North Carolina, there is beginning to be
a history of alternative systems failures -- especially alternative systems
utilizing subsurface discharge disposal. -These failures have been linked to
O
improper installation and inadequate maintenance (Hazen and Sawyer, 1988).
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`Failure' in a subsurface discharging system such as low pressure system
or mound system means that the system's disposal fields are not operating
properly, and they are not continuing to absorb treated wastewater at the rate
for which they were designed. This can occur for a variety of reasons.
First, they may have been inadequately sized to handle the actual amount of
wastewater flow due to a lack of conservatism in the original design, or the
hook-up of new waste generating units to a system designed to serve a smaller
development. One portion of a system of fields may be saturated because of
failure of the system of switches that alternates which set of fields is being
'dosed' with treated wastewater at any given time. The pipes and fields can
also become clogged with residual solids. Failure can occur because disposal
fields were laid in areas that had been previously disturbed, either compacted
or filled with imported material. Where sewage treatment is provided by a
septic tank or tanks, failure can sometimes be traced to inadequate
maintenance of the tanks themselves, especially too infrequent removal of
sludges, causing lower treatment of wastewater and higher solid content in the
wastewater. Where treatment takes place above ground in a conventional
package plant, the same risk of failure due to inadequate maintenance and
operation exists as for a surface discharging system.
The regulatory requirements for low pressure systems include requirements
for periodic submittals of various kinds of certification's and monitoring data
to the state permitting office. Several studies have shown, and state
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Department of Environmental Management staff confirm, that the state offices
O
which receive this data are not staffed adequately to keep track of it. The
recent proliferation of non -discharge systems in the state means that it is
often five years -between state inspections of non -discharge facilities (Booz,
O
Allen & Hamilton, 1985; Hazen and Sawyer, 1988; Kreutzberger, 1989).

O 69
Appendix A includes a survey of the histories of several non -discharge
permits issued in North Carolina coastal counties. These case histories
u
document the fact that the regional offices are often unable to keep up with
the work required to properly monitor the performance of such facilities. In
several instances, required certifications that the plants have been built in
.X
accordance with the permit plans have not been received. In other cases,
required groundwater monitoring wells had not been constructed several years
after the facilities began operations, even though groundwater monitoring data
X
are required to be submitted to the state several times a years.
B. Land Use and Planning Issues.
Control over the location and timing of public sewer extensions has long
X
been used as a means of local growth control. The ability of local soils to
support conventional septic systems has also been used as one parameter to
define environmentally sound carrying capacities in land use plans and the
X
zoning schemes that implement them.
The private sector's ability to utilize alternative treatment and
disposal systems to serve new development means the loss of these traditional
X
sources of local government control over the location of urban densities.
This is an especially important issue in coastal island environments, where
the carrying capacity concept is most useful in land use planning, and where
X
available undeveloped land is a limited and valuable resource. Appendix A
documents a case (Outer Banks Beach Club) in which a private developer
received a permit and constructed a treatment and spray irrigation disposal
X
system large enough to serve not only his development but also twenty other
large businesses, over the protestation of the local government.
To the extent that these systems.permit the development in areas which
101
have been protected only in the sense that they cannot be developed using
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conventional systems, local governments will need to rethink strategies for
the preservation of these areas, if such preservation is desired. For
example, an alternative system permits a developer to fill a wetland and build
a home that will be served by a communal treatment system located several lots
or even several subdivisions away. In order to preserve such environmentally
sensitive areas local governments now need to be much more explicit and
determined in their methods.
Because the state regulates and permits alternative systems, there are
questions about the extent to which local governments in North Carolina have
the legal authority to control them through local zoning or subdivision
ordinances. (Brough, 1987 and 1988; Heath 1989; Ducker, 1989). These
questions include whether subdivisions or development plan approvals can be
conditioned on aspects of system designs, and whether local governments can
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set standards for system operations and maintenance as a condition of such
O
land use permit approvals. It is also not clear whether such systems can be
completely prohibited by a local government. This is especially an issue
where public sewage treatment service is not available, since if a property
O
cannot be served by a conventional septic tank due to its soil
characteristics, a regulation prohibiting alternative systems would make the
property effectively undevelopable.
C4FA
Finally, alternative systems have regional as well as purely local
implications for land use planning. When alternative systems are located near
jurisdictional boundaries and/or sized to serve more than just one subdivision
O
or development project, one jurisdiction's decision can impact another's land
use planning and growth control efforts.
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C. Public Management Issues
Public management issues associated with the increased use of alternative
O
treatment and disposal systems are of two general types. These include issues
❑c
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related to responsibility and risk assumption in the event of the failure of
alternative systems under private control, and questions about whether more
local control over alternative systems is possible, in order to reduce the
likelihood of failures and plan for public response in the event of failure.
These issues arise because of the fact that the systems are essentially public
facilities, involving public health risks, but which are privatized -- owned
and operated by the private sector.
Where alternative treatment systems are developed and used, the
responsibility for their operation and maintenance lies generally either with
a homeowners' association (or the owner of the commercial complex if one is
served), or with a private utility company licensed by the state. In either
case, homeowners or businesses pay for regular operations and maintenance
activities. Local experience has shown that private utility companies are
much more successful at insuring good long term operating performance of
alternative systems than homeowners' associations. Homeowners' associations
are not likely to have the expertise or familiarity with proper management
practices for use in caring for such systems, and may seek to reduce costs by
avoiding or postponing necessary maintenance activities. 'However, where a
private utility company has responsibility for a system there is still
potential for avoidance or postponement of the costs of adequate operations
O
and maintenance.
Failure of an alternative system creates public health risks. The damage
done by one alternative system failure, especially if that system serves a
U
large number of housing units or a large commercial facility, is equivalent to
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the cumulative damage of many conventional septic system failures occurring
simultaneously. But the probability of such a simultaneous failure of many
individual septic systems is very low compared with the probability of failure
of one centralized treatment system. This makes the overall risks associated
with alternative system failure much higher than those associated with
traditional septic system failures.
This situation is complicated by the fact that since the systems are
under private control, and regulated by the state, most county or municipal
governments in which they are located have no authority over them. These
local governments therefore have no way of reducing the likelihood of their
0
failure or planning accurately for response to failures. Yet the local
O
government or county health department may end up being at least partially
responsible for providing a solution to a system failure. Although the state
technically has the authority to shut down a system that is not operating
properly, this is unlikely to occur, since the homes and businesses served by
the system would be left without adequate facilities. State proceedings to
force private operators to fix the systems can take long periods of time,
during which the systems will continue to function inadequately. Even when
local governments do not pay directly to fix improperly functioning plants,
they pay indirectly in the sense that they experience the environmental costs
of the failure.
4. Some Options for Local Governments
The options that are available to county and municipal governments which
seek solutions to the issues raised by the increased use of alternative
systems are of two general types: (a) actions that can be taken address the
land use planning.issues associated with alternative systems, and (b) actions
that can be taken to address the public management concerns they raise.
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A. Actions That Can be Taken to Address Land Use Planning Issues
County and municipal governments will need to take into account the
potential for use of alternative treatment and disposal systems in development
when updating their land use plans and the zoning regulations that implement
such plans. The secondary impacts of the increased densities that are
possible using alternative systems, including increased stormwater runoff, and
increased potential population growth should be factored into carrying
capacity analyses. This is necessary since the standard measure of carrying
capacity associated with the ability of local soils to support conventional
septic systems is no longer meaningful with the advent of the alternative
systems.
It has been suggested that county and municipal governments have some
authority to use their zoning and subdivision ordinances to prohibit the use
of alternative systems in portions of their jurisdictions, for environmental
protection purposes (Ducker, 1989). In addition, local governments may be
able to require that developers receive special use permits for the
development of alternative treatment and disposal facilities. Through that
process, local governments may impose landscaping or other requirements not
having to do with the systems' technical design or operations. County or
municipal governments can also withhold building permits for the waste -
producing facility until the state has received a certification that an
alternative system has been built to the standards required by its permit.
County or municipal governments may also want to indicate to private
developers, through local or regional plans, the preferred location for large
alternative treatment systems. Local governments may prefer that several
larger facilities be developed,:.serving more than one development, rather than
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the proliferation of smaller systems that is encouraged under current
conditions.
B. Actions That Can Be Taken to Address Public Management Issues
Similar to their authority in the case of conventional septic system
regulation, county governments can develop standards that are more stringent
than those required by the state for smaller, locally permitted subsurface
discharging alternative systems. It is not clear whether or not county health
departments can require more stringent standards for larger systems that
receive state permits, however. It may be that they can if they are also
willing to assume responsibility for the whole system of permitting,
inspection, monitoring, and enforcement.
Local governments' authority to gain some control over the ongoing
operation of alternative systems is slightly more clear. Municipal and/or
county governments are not restricted from employing their own team of system
experts to monitor the performance of alternative systems, although some
agreement must be reached with the private owner/operator of a system in order
to facilitate such inspections. In addition, at least one county has an
agreement in place with the state Department of Environmental Management,
whereby the county assumes from the DEM all the responsibility to track the
operation of alternative systems within its borders. Mecklenburg County keeps
track of all the self -monitoring reports submitted by system operators and has
a staff to perform regular unannounced site inspections. Enforcement of
permit violations that are discovered through such monitoring remains with the
state.
Finally, local governments may want to consider taking over complete
responsibility for the operations and maintenance of alternative systems
developed at the. expense of the private sector. This option goes hand in hand
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with the idea of local or regional planning for the preferred location and
sizing of regional alternative facilities. Regionalization of such facilities
would simplify governments' assumption of responsibility for their operation
and maintenance.
O V. Policies and Actions Available to Local Governments
a. Introduction
There are two general categories of actions that local governments
O (counties or municipalities) may take in order to resolve the issues raised by
the use of septic systems and clustered alternative systems for sewage
treatment and disposal. Local governments can take actions designed to gain
O more control over and more information about the performance of the systems,
in order to deal with the public health issues raised by the potential for
their failure. Local governments can also respond to the land use planning
O issues raised by these systems through their land use planning and zoning
processes.
Some of these potential solutions require interjurisdictional cooperation
O at various levels because of the existing legal and regulatory frameworks in
which they must occur. Interjurisdictional discussion and cooperation is also
essential, in a less direct way, in order to achieve the highest level of
O success with any of the solutions set out here. Although barrier islands may
be cut by arbitrary governmental boundaries, their natural systems are
inextricably interconnected. The natural systems that are least likely to
O respect political boundaries -- barrier island groundwater resources and the
bays and estuaries -- are also the systems that can be most adversely affected
by local sewage treatment and disposal policies.
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b. Local Actions Aimed at System Performance
1. More Stringent Regulations For Septic Systems and Alternative Systems
for Which County (DHR/DHS Permits are Issued. O
State law and regulations allow county health departments to develop more
stringent regulations than the state standards for design and siting of septic
systems and the generally smaller alternative subsurface disposal systems that O
are the responsibility of homeowners' associations, and receive county
permits. These standards may include minimum lot size requirements (for
septic tanks), lower maximum wastewater application rates than those set out Q
in the state standards, and other design criteria that take into account the
natural constraints on septic and alternative systems that are specific to the
barrier island environment.
Implementing this solution may require interjurisdictional cooperation at
some level. It may require the County to agree that such more stringent rules
U
are needed for all areas within its jurisdiction, although if that is O
difficult to secure, the more stringent rules can be written to be applicable
only for the barrier island portions of the County. This is possible provided
that it can be shown that such rules which apply only to barrier island Q
environment are not arbitrary -- that without them the public health on
barrier islands would be jeopardized, but that a similar effect would not
occur, in the absence of such rules, on the mainland. In the case of the Q
barrier island which includes Nags Head and Kill Devil Hills, the argument can
be made that more stringent controls are necessary in order to provide
additional protection for the shallow aquifer, which surfaces as the fresh Q
water ponds that are the public water supply source for the two towns.
There are few additional costs associated with an interjurisdictional
agreement wherein the county adopts and enforces more stringent design Q
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standards. The costs are only those associated with printing the regulations
and training existing staff in their implementation.
2. County -wide or Municipal Programs To Track Septic System Performance.
This option involves the establishment of a program at -the county or
municipal level. The program would include an information system to keep
track of the location, age, and performance of conventional septic systems,
and staff to remind owners of the need for routine maintenance activities.
Such a program can go a long way towards preventing septic failures. In
addition, such a system helps local governments to anticipate potential
failure areas, and plan a response. This possible solution requires
expenditure of public funds for personnel and other operating expenses to
O
establish and implement the program.
3. Municipal, County. or Intergovernmental Programs to Monitor
Alternative System Performance
O Programs may be set up by municipal or county governments, or by groups
of municipalities and/or counties, to track alternative systems' performance
as well. (15 NCAC 2H § .0218). At a minimum, such programs involve
O collecting information on all the state permits issued for surface discharge
and land discharge ('non -discharge') alternative treatment systems within the
relevant area, collecting the self -monitoring reports submitted by the
9 systems' operators to the Department of Environmental Management (DEM), and
notifying the DEM of any permit violations. These programs can extend (as
does the program in place in Mecklenburg County) to regular site inspections,
O surface discharging plant treated wastewater effluent sampling and analysis by
the County itself, and investigation of complaints about system performance.
Such programs can also include on -site investigations during the plant
O permitting and construction phases to ensure that design and installation are
adequate.
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A
A local monitoring and inspection program can be established to
supplement DEM field staff monitoring and inspections efforts, or to totally
O
replace the need for DEM efforts. At the least intensive level, a program can
be set up as a unilateral action by a municipality or county to keep track of
system performance, independent of the DEM's efforts. At a more intensive
O
level, a program to take the place of the DEM monitoring and inspections
efforts can be established through an intergovernmental agreement between the
entity that seeks it and the Department of Environmental Management. Such an
O
agreement is known as a Memorandum of Agreement (MOA). Mecklenburg County
currently has an MOA in place, although the county began its watchdog program
as a unilateral action. Wake County is also about to implement a program of
U
monitoring and inspection based on an MOA. Discussions with the County staff
indicate that having the MOA in place has resulted in many improvements in
communication between the County, DEM and system operators. (Wiggins, 1989).
O
Copies of the DEM-Mecklenburg County MOA and Work Program and.a draft of the
Wake County documents are attached as Appendix B.
Under the regulations governing alternative systems permitted by DEM, if
O
the DEM has issued a system permit, it cannot delegate the power to enforce
the permit. This includes the right to revoke the permit. Mecklenburg
County's experience with its monitoring program has been that system
performance has improved overall, as operators become aware of the additional
ongoing scrutiny, and that enforcement measures have become less necessary
since the program's inception. Mecklenburg County staff speculate that the
O
additional communication that has resulted from having the MOA in place would
make enforcement easier to request from DEM if that were ever to be necessary.
(Wiggins, 1989).
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9
A new county or municipal monitoring and inspection program can be funded
from property tax revenues. Where such a program is run by a regional special
purpose entity, such as a water and sewer authority, it may be possible to
fund a monitoring and inspections program through increased water and sewer
fees. This is most appropriate where the new program is specifically designed
to protect local water supply resources.
4. Municipal, County, or Intergovernmental Programs for the Permitting
of Alternative Systems.
O Counties have clear statutory authority to establish a program for the
issuance of county permits for alternative systems, under more stringent
standards than those used by the state, provided that the local board of
O health determines that such controls are needed to protect the public health
[NCGS 130A-39(b)]. Such a program would be set up within the county health
department and all aspects of the program would have to receive state
O approval.
It seems that municipalities' authority to set up a similar local
permitting program may extend only to municipalities which have a `utility
O service area' as defined by the statute. A `utility service area' includes
those places where the municipality is already providing centralized sewage
collection and treatment service. [15 NCAC 2H 0218, and NCGS 143-215.1(f)].
O The permitting entity would be the municipal water and sewer department. An
intergovernmental entity, such as a sewerage district or utility that is
established to provide more control over alternative treatment and disposal
O systems through planning, or monitoring, or maintenance could also assume a
permitting role.
If the entity in question were to receive the authority to establish a
O permitting system, it could also use its own more stringent standards in the
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permitting process. Again, these standards would have to receive state
approval. The state can also grant the authority for permit revocation and
other enforcement action to the new local permitting authority.
The implementation of a new local permitting program could be funded
through a system of fees similar to those charged by the state for reviewing
permit applications. The fee systems would require approval by the state along
with all the other aspects of the local permitting program. Where the new
permitting program is part of a broader program -- for example a program of
monitoring, and/or maintenance -- other funding mechanisms can be used, as
described further in section b.5 below.
5. Local Government or Special Purpose Authority Assumption of
Responsibility for Operation and/or Maintenance of Privately Constructed
Alternative Systems
A county or municipal government, or a combination of governments acting
together through a special purpose authority can assume responsibility for
alternative treatment and disposal systems built by the private sector. Such
responsibility can include only system maintenance or it can extend to full
responsibility for system operation, including taking over the ownership of
such systems.
This concept can be most powerful when it is set up in conjunction with a
local or regional plan for the location and sizing of such systems, as
described in c.l below. In addition, where the local program also includes
the permitting programs described above, there is direct local control
established over the design of the systems that will eventually be taken over.
In the absence of a local permitting program, the use of desired standards for
system design can be established as a prerequisite for eventual local
assumption of responsibility, although such standards cannot be required of
all systems.
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7
Implementation of a local or regional program of alternative system
operation and maintenance can be financed in various ways. A local (municipal
or county) program can be funded in the same ways that local water and sewer
service is funded. Operations and maintenance funding may come from revenues
generated through taxation and user fees; capital improvements may be funded
through the sale of revenue bonds. If the effort is made by a group of
governments acting together under a regional plan, a regional special purpose
authority may be established and given authority to change user fees, and
issue bonds. The North Carolina Water and Sewer Authority Act, NCGS 162A-1
through 19, sets out the process by which such authorities can be created, and
their general powers and duties. A regional special purpose authority _(the
Orange Water and Sewer Authority) provides conventional public water and sewer
service in southern Orange County.
6. Local Controls on the Issuance of Building Permits
Counties or towns can institute policies whereby building inspectors may
hold building permits until all state certifications have been issued,
including the state's acknowledgement of receipt of the built -as -designed
certificate that is a requirement for alternative treatment facilities. This
can reduce the likelihood that homes will be connected to alternative
treatment systems that are not built as designed or that are not installed
O
adequately.
7. Local Authority to Abate Public Nuisances
Where an alternative system failure presents a condition which is a
X
public nuisance, a county or municipal government may condemn the facility.
The authority to condemn facilities that are public nuisances comes from NCGS
§ 160A-193 for.municipalities, and from NCGS § 153A-140 in the case of
r*,
X
counties.
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82
Southern Shores has in its ordinances a section (Chapter 9, Section 10)
describing actions that may be taken by the Town to abate `wastewater
O
nuisances.' A wastewater nuisance is defined as any odor or noise
offensive to individuals, or conditions detrimental to the public health which
violates the rules and regulations of the county health department and/or the
101
5
town." The ordinance requires the town, on learning of the existence of a
wastewater nuisance, to notify the county health department, and "
institute such actions as may be necessary to immediately abate such
O
conditions." If, within a reasonable period of time after having been ordered
to abate the nuisance the responsible persons have not done so, the town is
required by the ordinance to correct the nuisance conditions, and assess the
O
costs of correction to the property owner.
8. Local Water Conservation Programs.
Water conservation programs aimed at reducing the amount of water going
O
into septic and alternative treatment and disposal systems can improve the
performance of such systems by reducing the rates at which local soils are
required to absorb wastewater. Local conservation programs can make users
O
more aware of the relationship between the volume of wastewater that must be
treated by the system and the system's performance. This type of program will
be most successful where the targeted group owns their homes. Conservation
programs may have limited usefulness in an area such as tfie Outer Banks, where
the population during periods of peak demand is composed largely of temporary
visitors.
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c. Local Actions Aimed at Solutions to the Planning Issues Raised by
Alternative Systems
O 1. Prepare Local or Regional Plans for the Preferred Location and Siting
of Alternative Treatment and Disposal Facilities.
This option can be used by a county or municipal government or a
combination of local governments which seek more control over the location and
O
sizing of alternative treatment and disposal facilities, and greater ability
to anticipate the consequences of their development. The concept is most
O powerful when used in conjunction with a county, municipal, or
interjurisdictional program for permitting, and/or monitoring and inspection,
and/or maintenance, or in conjunction with a plan for the eventual assumption
of full public responsibility for the operation of such systems once they have
O
been constructed by the private sector.
The concept requires the local government or group of governments to
O prepare a plan or plans similar to a utilities plan prepared for conventional
X
municipal or regional sewage treatment facilities. The plan would identify
acceptable locations and capacities for such alternative treatment and
disposal facilities as are developed by the private sector, based on local or
regional plans for growth. It might also identify high hazard or
environmentally sensitive areas where alternative treatment and disposal
facilities would not be permitted. The alternative sewage treatment and
disposal facilities plan should be incorporated into local land use plans
prepared under Coastal Area Management Act (CAMA) requirements. In addition,
language should be added to the CAMA plans that clearly indicates that the
O
alternative sewage treatment and disposal facilities plan is necessary to
avoid the cumulative effects (direct or indirect) of unplanned and unchecked
proliferation of alternative systems on water quality. If this is done, the
O
Coastal Resources Commission can deny permits for developments that are
9

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inconsistent with the alternative treatment and disposal facilities plan.
[1989 Session Laws, C.51]
Coy
The alternative sewage treatment and disposal facilities plan will be
most powerful when, in addition to being incorporated in the CAMA land use
plans for the region, it is accompanied by a local or regional program leading
O
to eventual full public sector responsibility for the alternative systems
developed under it. Where such a program is an option, the promise of
eventual public acceptance of responsibility for a system can be used as an
O
incentive for its developer to follow more stringent standards for its design.
Although local governments are preempted by the state from requiring more
stringent design standards for alternative treatment and disposal systems,
O
local governments can indicate that they will only assume responsibility for
systems built to the locally acceptable standards. This incentive can be used
even if the local or regional program does not extend to complete system take-
- O
over, but involves public responsibility for system maintenance, or even only
for regular monitoring and inspection. In any case, local design standards
can be suggested as part of an alternative systems plan.
L
The alternative treatment and disposal systems so planned for could be
regional or areawide in nature, built at small scale by a first developer and
enlarged or expanded by the next, up to the maximum capacity allowed by the
O
plan. Alternatively, the plans might call for such plants to be built as
individual separate facilities, built one at a time for each development as it
is developed.
Preparation and implementation of an alternative sewage treatment and
disposal facilities plan can be a useful response to several levels of local
desire for more control over alternative systems. A plan can be useful for a
community that wants only to know and direct where such systems will be
7
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located, and their expected sizes, so that plans can be made to respond to any
potential problem with their operation. Such communities may also wish to
provide developers with further guidance as to the preferred locations, sizing
and technologies for use in serving their projects. At the next level of
desire for additional control, an alternative treatment and disposal
facilities plan incorporated into the CAMA land use plan can be used as a
growth control measure. Such plans are also crucial to the efficiency and
success of local or regional programs for system monitoring, inspection,
maintenance, or full ownership and operational responsibility.
Finally, such planning can be done regionally -- barrier island wide --
not just in a jurisdiction -by -jurisdiction basis. This will afford the most
control over the potential impacts of alternative systems. A regional or
joint plan reduces the likelihood that an oversized system will be built right
at a jurisdictional boundary to serve developments in two jurisdictions. To
O
be effective, a joint plan must have the support of all the parties to it, not
only during its preparation, but during its implementation.
2. Revise Land Use Plans and Zoning to Reflect Island Carrying Capacity.
X
Carrying capacity analyses are being increasingly used as the basis for
local land use planning and zoning decisions, especially in coastal areas, and
for self-contained island environments. Traditionally the limits on sewage
.X
treatment facilities have been one of the most important parameters used to
identify an area's carrying capacity. As we have discussed, the proliferation
of clustered alternative systems has effectively removed that constraint.
u
That does not have to mean that it should be dropped when analyzing carrying
capacity, but rather that as plans are revised it should be rethought.
Although they may be technically possible by relying on alternative
M
systems, allowing increased density supported by clustered alternative
X

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treatment systems will bring additional environmental costs that must be
factored in as well. The relevant issues to consider are: (1) how much
groundwater recharge area is necessary to maintain aquifer yields, and (2) how
much marsh land must remain undeveloped to protect estuarine water quality and
coastal fisheries. The additional environmental damage that can be caused due
to major flooding of an above -ground treatment or disposal facility or holding
area over that which would be caused by an equivalent flood if septic systems
were utilized should also be included.
For these reasons, land use planning and zoning schemes developed on the
basis of carrying capacity can and should be upheld by municipal governments
in the face of arguments that previously limiting parameters have been
overcome by new technologies.
3. Prohibition of Alternative Systems in Certain Zoning Districts.
Richard Ducker, of the Institute of Government, has stated that he
believes it is within a local government's authority to prohibit the use of
privately owned clustered alternative treatment systems in specific zoning
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districts. He has written specifically on this issue, identifying protective
O
zones for surface water supply watersheds as proper for such limitations. It
would seem that alternative systems could similarly be regulated in aquifer
or estuarine protection areas. In addition, alternative sewage treatment and
O
disposal facilities could be prohibited in high hazard areas, such as flood V-
zones. In any case, the prohibition of alternative systems through zoning is
made more legally supportable by the existence of a local alternative sewage
O
treatment and disposal facilities plan which is incorporated into the CAMA
land use plans for the area.
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4. Special Use Permit Requirement for Alternative Systems.
In zoning districts where the use of clustered alternative systems is
determined to be permissible, local governments may require them to obtain
special use permits. In such cases, Richard Ducker has suggested that the
kinds of conditions that may be placed on such permits would be limited to
those such as site screening and buffering requirements, which are clearly not
preempted by existing state environmental health standards. According to
Ducker, zoning/special use permit conditions that attempt to control the
technical design of the facility including controls on waste type or loadings
would be preempted by state regulation. Architectural review of the exterior
appearance of alternative treatment and disposal facilities can be imposed
through a Special Use Permit review process only to the extent that such
review is part of an existing locality -wide design review process. In other
words, a local government cannot regulate or review the appearance of
alternative treatment and disposal facilities only. Such regulation or review
must also be required for other types of developments as well.
5. Environmental Impact Assessment for Developments Utilizing
O Alternative Treatment and Disposal Systems.
Chapter 113A Section 8 of the North Carolina General statutes allows
local governments (municipal or county) to require private developers of major
O development projects to submit detailed statements concerning the
environmental impacts of their projects. Major developments include
subdivisions, other housing developments, and commercial and industrial
© developments greater than two contiguous acres in area. Local governments are
not given authority by this source to deny applications for developments on
the basis of the contents of such statements. NCGS § 113A-8 has been
O interpreted by a representative of the Attorney General's office to require
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that a state agency must consider the information included in an environmental
document generated under a local ordinance implementing NCGS § 113A-8, in
making its decision on any state permit required for the project (McLawhorn,
1988). This interpretation means that the DEM must consider the environmental
impact of a development project including or dependent on an alternative
system, in deciding whether or not to issue the required permit for the
system. The Statute (113A-8) does not set any standards or threshold levels
for environmental impact, to serve as the basis for permit denial, however.
In addition, if a state agency, after considering the information
generated in a local environmental statement, issues a required permit, GS
0
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160A-174 may preempt the town or county from denying a development permit for
O
the facility on the basis of information contained in the environmental
statement and considered by the state agency. However, as described earlier
in Section IVb(2)(g) of this report, the lack of case law on this point in
O
North Carolina means that the extent to which this limits a municipality or
county is uncertain.
The ability of a county or municipal government to deny a development
permit application on the basis of information generated by an environmental
assessment could be achieved under the local zoning authority, rather than
under the authority granted in NCGS 113A-8. The local zoning ordinance can
include provisions requiring that an environmental assessment be submitted
along with the other materials required for review of development permits.
The ordinance would also have to include specific threshold levels for
environmental impacts in order to enable the denial of a permit on the basis
of such impacts.
Although.including an environmental assessment requirement in local
zoning ordinances is a more powerful tool for local governments than requiring
•❑
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environmental impact statements order NCGS § 113A-8, it is also more costly.
If environmental statements are generated under the authority granted in
O
§ 113A-8, they may be reviewed for completeness and content by the state
clearinghouse. There is no need for local staff expertise. If the local
zoning authority is used, the local staff must include the expertise to review
J
the documents produced for completeness, and analyze the severity of impacts
documented. This kind of expertise can be very expensive, especially for a
small town.
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References
Augspurger, Thomas P. Assessment of Coastal North Carolina Domestic
Wastewater Disposal Alternatives. North Carolina Department of Natural
Resources and Community Development, Division of Coastal Management, May,
1989.
Booz, Allen and Hamilton, Inc. Dare County Carrying_ Capacity Study. Prepared
for the Dare County Carrying Capacity Commission. November, 1985.
Booz, Allen and Hamilton, Inc. Dare County Carrying Capacity/Development
Study Final Report. Prepared for the Dare County Carrying Capacity
Commission. August, 1986.
Brough, Michael. Attorney, Michael Brough and Associates, Durham, North
Carolina, Personal Communications 1988 and 1989.
Brower, David J. et al. Shorefront Access and Island Preservation Study.
Washington, D.C.: NOAA/OCZM, 1978.
Brower, David and Luther Propst. "Hatteras Island Water Supply and Wastewater
Disposal Study." Report prepared for the Dare County Planning Board,
1983, 28 pp.
Brown, James C. "The Role of Conventional Wastewater Treatment in Coastal
Areas" in Proceedings of the Southeastern Conference on Water Supply and
Wastewater in Coastal Areas, James Stewart, ed. pp. 75-82. Raleigh, NC:
North Carolina Water Resources Research Institute, 1975.
Charlotte Observer, Charlotte, NC. May 31, 1988, p. 1. "Outer Banks Locals
Distrust Rules, Growth Alike."
Cheremisinoff, Paul N. "Special Report: Industrial/Municipal Water and
Wastewater Package Treatment Systems." Pollution Engineering, Volume 18,
Number 4, April 1986.
Davis, Patrick. OWASA Assistant to the Director for Planning and Research.
Personal communications, 1987-1988.
Ducker, Richard, Assistant Director, Institute of Government, University of
North Carolina at Chapel Hill. Letter to Mr. Thomas Russell Odom (Durham
County Attorney), January 24, 1989.
Durham/Chapel Hill Herald, Durham, NC. April 7, 1989. "Chatham Mulls Sewage
System Supervision."
Golden, William and Monica Staaf. "Package Treatment Plants: Burden or
Breakthrough?" The Municipal Forum, Volume 9, Number 2. Summer 1988.

O 91
C
Hanson, Mark,E. and Harvey M. Jacobs. "Private Sewage System Impacts in
Wisconsin -- Implications for Planning and Policy." Journal of the
American Planning Association (Spring 1989): 169-180.
Hazen and Swayer PC. Orange County Alternative Wastewater Treatment Study.
Prepared for Orange County, NC, August 1988.
Heath, Milton, Assistant Director, Institute of Government, University of
North Carolina at Chapel Hill. Letter to Mr. Thomas Russell Odom (Durham
O County Attorney), January 3, 1989.
International City Management Association. "Wastewater Management:
Alternative Small Scale Treatment Systems". ICMA MIS Report, Volume 17,
Number 4, April 1985.
O Jewell, Linda. "Alternatives for Septic Disposal on the Site." Landscape
Architecture Magazine, November 1980.
Kreutzberger, William. Department of Environmental Management, Raleigh, NC.
Personal Communication December 15, 1988.
O Leopold, Luna and Thomas Dunne. Water in Environmental Planning. New York,
NY: WH Freeman and Company, 1978.
Lowery, William, former alternative treatment plant operator, Chatham County,
NC. Personal communication 1988 and 1989.
O McLawhorn, Daniel F. "Local Government EIS Authority Under the State
Environmental Policy Act." Office of the Attorney General of North
Carolina, Raleigh, N.C., 1988.
Mecklenburg County Department of Environmental Protection. Memorandum of
Agreement with the Department of Environmental Management 1988-1989.
O Charlotte, NC, 1988.
Mecklenburg County Department of Environmental Protection. Water Quality Work
Plan Supporting the Memorandum of Agreement with the Department of
Environmental Management, 1988-1989. Charlotte, NC, 1988.
O News and Observer, Raleigh, NC. July 25, 1988. p.lC "Carteret Towns Grapple
with Wastewater Disposal Problems", December 10, 1989, p. lA "North
Carolina Coastal Growth in Limbo, Coastal Zoning Rule Faces Currituck
Vote". December 14, 1988, p. 1C "Developers `Borrow' Septic Space."
Nierstadt, Raymond and Daniel Okun, Charles O'Melia, Jabbar Sherwani, Milton
O Heath, Warren Wicker, and Larry King. "Wastewater Management in Coastal
North Carolina". Raleigh, NC: Water Resources Institute, Report No.
165.
Osborne, Dennis. President, North State Utilities, Inc, Raleigh, NC.
Personal communications, 1987-1988.
Ramsay, Dennis. NC Department of Environmental Management, Raleigh, NC.
Personal Communication, April 1989.
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Spirn, Anne Winston. The Granite Garden: Urban Nature and Human Design. New
York, NY: Basic Books, 1984.
Tabors, Richard, Michael Shapiro, and Peter Rogers. Land Use and the Pipe.
Lexington, MA: Lexington Books/D.C. Heath and Company, 1976.
U.S. Department of Agriculture, Soil Conservation Service. Soils and Septic
Tanks. Agriculture Information Bulletin 349, Washington, D.C.: U.S.
Government Printing Office, 1975.
U.S. Department of Interior, Coastal Barriers Task Force. Undeveloped Coastal
Barriers: Final Environmental Statement. Washington, D.C.: U.S.
Department of Interior, May, 1983.
U.S. Environmental Protection Agency Office of Research and Development.
Design Manual for Onsite Wastewater Treatment and Disposal Systems.
Washington, DC: U.S. EPA, October 1980.
U.S. Environmental Protection Agency. Draft Environmental Impact Statement:
North Carolina Barrier Island Wastewater Management. Atlanta, GA: U.S.
EPA, June 1983.
University of North Carolina at Chapel Hill: Department of City and Regional
Planning. Carrying Capacity Study: Currituck Outer Banks. Report
prepared for Currituck County, 1983.
Wicker, Warren J. "Management and Financing Alternatives for Waste Disposal
in Coastal Areas" in Proceedings of the Southeastern Conference on Water
Supply and Wastewater in Coastal Areas, James Stewart, ed., pp. 35-42.
Raleigh, NC: North Carolina Water Resources Research Institute, 1975.
Wiggins, Barbara. Mecklenburg County Department of Environmental Protection.
Personal communication, March, 1989.

2
O O O O O O O O O O
appendi
ces

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rol
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APPENDIX A
Environment, Health, & Natural Resources
Organization Chart
I
I
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I _
I
1
I
I
I
I
I
L
Secretary
Wiliam W. Cobey. Jr.
1
Deputy Secretary I Deputy Seuetary
EnvitormeM and I Health and
Natural Resources I Administration
Or. Ernest A. Cad George H. Rudy
Wdode Resources - - —
---AlDenyrtaTamkco--
CharlesFuthvood _.— Bob 14101M t ----
I --- Posutron PrevMlron --I
noQN SCMCNr 1
— PunFAnal,-.----)
Oon Fosmer
---- nepbnat Managers---�
Asheville
Ann On
F eyet[evsie
niCherd 9.shop
MorreWflo
At /alton
naterph
Larry South
WasNnpton
Lorraine SNm
Wilrntnglon
Bob Jamleson
Winston Salem
Margaret Plemmons
Chbl Medical Examiner
Adminlstwiva Ass
Dr. John Bulls
J. Murry
— _-9 ..
Gov Waste Marra emeM
Chat IdurN
Estelle Fulp
_ - --- Of _Linda Little
--
DersonnA Director
Health Education
Amin Khalil
Deblois Beany
Legislative Altairs
Sandia Long -
-- localMeath Servkes —
— East
Steve Martin
— North Camel
Pat Cunningham
-- South Cordial
PM Cunningham
__-- West
T.B Haynes
- - ------
Assistant Secretary
Assiaent Secretary
Slate Ileaah Director
Assistant Secretary
O
Protect
Em:ythe
Natural
nesou'c
Ad(Vacaation
Mc
Edythe MtKimey
-- - •�
Dr. Lynn Muchmo.e
Muchmes ----
or. Ronald Lenin!
---- ------ •I
(Vacant) -
---.-
- Coastal Management
- Forestnesourcos
AdultHeaeh
Computer Systems
Or. George Everett
Harry Laymen
Dr. Georiean Slood
Nancy Kuivda
- Ernkonmeraal Managi.
- Parks i Recreation
- Daniel Itesbh
Fiscal Management
k. ra..: Y:....
Z.. Vd. C....
.....:Ps..
Beb rv:t-t
OI
- Lard Resources
Soil A Water Consery
Environmental Health
- General Services
S••r� r'±�.aw
Dovid Sides -
Fick Rowe
Laird Davison
Marine Fisheries
Special Nolects
Epidemiology
- Intormalon Services
Or BA Hoganh -
Cherylle Deal
Dr. J N. MacCormack
Deeon Atkinson
- nadiation Saleq
zoologcal Park
Laboratory Services
- Legal Aaars
ODayw
Proven
Bnb rry
Dr. Samuel Merntl
Joe Stale
1 Sold Waste Management
Maternal Chid Health
- Planning tl Assessment
Dn Meyers
Or Ann Wolle
C+ug lev.n.
Willer nesemces
John Moms
ME
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rel
APPENDIX B .
Case Studies
p DARE COUNTT
Outer Banks Beach Club (OBBC)
• Kill Devil Hills
11-81 DEM issues non -discharge permit *6979, to the Outer Banks Beach
O Club (OBBC). The permit issued was for a spray irrigation system that
includes a 36,000 gallon per day (GPD) tertiary treatment plant, with
wastewater disposal by rotary distributors. The facility was to serve
a Laundromat and swimming pool (4,000 GPD) in addition to
apartment (condominium) units. The state regulations at the time
O assumed that apartment dwellers use approximately 75 GPD per
person, that two people would occupy each bedroom in an apartment,
and therefore that the remaining capacity (32,000 GPD) would serve
71 3-bedroom apartment units or 53 4-bedroom units.
2-82 A letter was sent from DEM to the president of the OBBC, approving
100,000 GPD system rather than the 36,000 GPD system permitted
under *6979. The letter refers to a DEM interoffice memo dated 2-
18-82, in which the situation is described. According to the memo,
after obtaining permit s6979, the president of OBBC decided that it
would be cheaper and easier to get a permit for a 100,000 GPD
system than to build a 36,000 GPD system and enlarge it later. The
100,000 GPD system as proposed and approved included two phases,
each involving a 50,000 GPD tertiary treatment plant. The first phase
0 would be built immediately, and would eventually serve the
laundromatlswimming pool facility, 40 3-bedroom units, 40 1-
bedroom units, and 60 2-bedroom units (a total committed treatment
capacity of 46,000 GPD). The memo noted that the total project
would cover 80 acres of land, with approximately 255,000 square
0 feet (5.9 acres) of land devoted to wastewater treatment and
disposal. Regulations for wastewater disposal in coastal areas were
satisfied -- those required 2500 square feet of disposal field area for
each 1000 GPD of wastewater disposed (or a total of 250,000 square
feet or 5.73 acres of land). It was recommended by the DEM that the
p rotary distributors be placed on the portions of the site where the
seasonal groundwater level was 36 inches below the ground surface.
4-82 DEM letter to OBBC's attorney. OBBC had a permit (s6507) for a force
main and pump station that was set to expire. The force main and
p pump station were carrying waste flows from the OBBC development
(-condos-) to an adjacent treatment plant owned by the Ocean Acres
Utility Company. The force main and pump station permit could not
be renewed until the existing agreement between OBBC and Ocean
Outer Banks Beach Club - page 1

Acres Utility was renewed. That agreement included the terms and
conditions under which Ocean Acres Utility accepted OBBC's wastes
for treatment, and was originally made in March 1981 and valid for a
year only. Because OBBC was waiting to hear formally about its
request for a permit for a 100,000 GPD facility, it had not yet
constructed the system permitted under *6979, which it had
originally expected to have in place by the time -the original
agreement with Ocean Acres Utility expired.
DEM extended permit *6507 -- Ocean Acres Utility agreed to continue
to accept waste from OBBC for treatment, but only until 7-1-82. A
maximum of 10,000 GPD of waste would be accepted under the
agreement.
5-82 Permit *6979R is issued, for a 100,000 GPD tertiary treatment plant,
with spray irrigation disposal through four 57 foot diameter rotary
distributors. The permit would be valid through 6-87.
7=82 Lab report reporting the results of effluent quality monitoring at the
OBBC plant. Samples contained 17,000 fecal coliform per liter, 36 mg
suspended solids per liter.
8-82 Lab report reporting the results of effluent quality monitoring at the
OBBC plant. Samples contained 2200 fecal coliform per liter, less
than I mg suspended solids per liter.
DEM agreed to allow the OBBC treatment facilities to serve the Outer
Banks Homestyle Laundries, which would generate 13,500 GPD of
flow, instead of 13,500 GPD of flows as originally set forth as being
served by the Phase 150,000 GPD plant at OBBC (see 2-82 entry).
DEM noted that the size of the residential portion of the OBBC
development would need to be reduced accordingly, in order not to
overload the treatment plant.
2-83 Letter from DEM to OBBC president, to establish a monitoring
0 schedule for groundwater quality at the OBBC plant. DEM would
require four monitoring wells, and testing
on the following schedule:
wastewater flow: daily
continuous sample
biological oxygen demand monthly
grab sample
chemical oxygen demand monthly
grab sample
O total suspended solids monthly
grab sample
fecal coliform bacteria monthly
grab sample
residual chlorine daily
grab sample
O Outer Banks Beach Club - page 2

o total Bjedahl nitrogen
ammonia/nitrogen
nitrates and nitrites
water level
quarterly grab sample
quarterly grab sample
quarterly grab sample
monthly
0. DEM wanted the wells installed no later than 5-1-83, and a diagram
of the site was to be sent to DEM with the first monitoring report.
2-83 Permit =6979R was amended to allow OBBC to accept 1200 GPD of
waste from an additional four unit apartment building containing
o eight bedrooms total.
7-83 Letter from DEM to the person responsible for OBBC's treatment plant,
describing a meeting held in 6-83 to discuss a recent spill of raw
sewage at the plant, the lack of adequate monitoring data, and the
proper placement of the groundwater monitoring wells. Only three of
the four wells had been constructed, and those had been improperly
located.
0 8-83 Letter from DEM to the person responsible for OBBC's treatment plant,
noting that there had been no word about OBBC's progress towards
relocating the required monitoring wells.
Second DEM letter to OBBC. DEM noted that the plant had been
inspected, that three monitoring wells were improperly installed, and
the fourth well had not been built.. In addition, all of the wastewater
pumps were out for repairs, leaving only a temporary pump to move
waste from the plant to the wastewater distribution system. The
rotary distributors were not receiving proper maintenance. The
0 situation required correction.
10-83 Lab report reporting the results of groundwater quality monitoring at
the OBBC plant. All four wells were in. All samples contained less
than 10 fecal coliform per liter.
o
4-84 OBBC requested an additional permit amendment to allow Todd
Realty to hook up to the existing system. Todd Realty would add
2450 GPD to the wasteflow. The file notes that only one 50,000 GPD
treatment plant had been built as of 4-84, and that it was treating or
o was expected to eventually treat the wastes from:
Beach Club I 24,000 GPD from 160 bedrooms (condo units)
Beach Club II 21,600 GPD from 144 bedrooms
Apt complex (8BR) 1200 GPD
O
Outer Banks Beach Club - page 3

Laundromat 15,000 GPD
Adding Todd Realty, as requested would mean that the total flow to
the system would be 45,950 GPD.
DEM noted that since the treatment plant's capacity (50,000 GPD) was
almost being reached that OBBC should plan to have the second
50,000 GPD plant constructed by the summer of 1985.
5-84 Letter[?) from DEM to OBBC documenting 4-5-84 inspection at the
plant. DEM noted problems with aeration facility -- the contents of
aeration basins were not treated to the extent they should have been
(they were 'nearly septic'), and one of the rotary distributors was not
functioning.
7-84 DEM interoffice memo. Representatives of the Town of Kill Devil Hills
had met with DEM to express concerns about a wastewater connection
to the OBBC system. The Town had been trying to tap into its own
water system to provide water for a house near OBBC, and had hit a
force main containing raw sewage under pressure, running between
OBBC and the Ocean Acres Utility plant.
DEM interoffice memo. The line between OBBC and the Ocean Acres
Utility plant had been disconnected at the Ocean Acres Utility plant in
1982, but that the sewerage had never been removed from the line
between OBBC and Ocean Acres.
Letter from DEM to OBBC, formally approving the Todd Realty hook-
up to the OBBC plant. (See 4-84).
8-84 Letter from DEM to OBBC, noting that the existing 50,000 GPD
treatment plant has experienced problems with hydraulic surges -- at
peak periods, more waste was travelling to the plant than it could
handle, and there was no means by which the peak wastes could be
stored and the flow through the plant evened out to allow propert
treatment. The rotary distributors were also not functioning well;
there was 'ponding` of wastewater at the distributors. DEM
requested that these conditions be repaired.
9-84 Letter from DEM to OBBC, noting that DEM understood that the OBBC
wanted to add 200,000 GPD of tertiary treatment capacity to the
O permit (06979R) -- to bring the total permitted treatment capacity at
the site to 300,000 GPD. Waste disposal would be by rotary
distribution. DEM approved this permit amendment informally, but
O Outer Banks Beach Club - page 4

101
0 noted that the interim approval would be voided unles plans and an
application were submitted by the end of the month.
12-84 DEM memo to OBBC describing problems with the flow equalization
basins at the OBBC plant. As described above, in 8-84, the OBBC plant
0 had experienced problems with hydraulic surges which did not allow
for proper treatment to occur at all times, because too much waste
had to be handled by the system during peak periods. The memo
noted that this problem was typical of all wastewater treatment
plants on the Outer Banks (because of the peak conditions associated
O with tourist season and big weekends). DEM requested that OBBC
provide some data on waste flows every half hour for 24 hours, and
copies of charts on which the information was collected, for five of
the highest waste flow days of the year.
O DEM interoffice memo. DEM staff had reviewed OBBC's application
materials to expand the treatment facility to 300,000 GPD. Staff had
two areas of concern: 1) adequate flow equalization was needed to
avoid the problems associated with waste surges; 2) the reported
amount of waste flowing into the existing 50,000 GPD treatment plant
O was 117,200 GPD.
1-85 DEM issued a new permit (*6979-R2), to be valid from 1-85 until 1-
90, to allow the completion of the original 100,000 GPD treatment
plant system. The first 50,000 GPD plant was already built under
*6979 R; this new revision allowed a new kind of plant to be built as
the second half of the project.
DEM letter to Ray Sturm of Bill Devil Hills, responding to his concerns
0 about a spill of untreated wastewater from the OBBC system. The
problem was due to frozen pipes, and should have been corrected
immediately.
2-85 Letter from DEM to Dare County Health Departments to keep them up
0 to date on the DEM permits issued to OBBC. At that point, OBBC had a
permit and authorization to construct 100,000 GPD of treatment
capacity. 50,000 GPD was already built. DEM's records indicated that
OBBC had received approval to accept 61,800 GPD of wastes (although
the units from which some of this would flow were not yet complete),
0 and OBBC had made two additional requests to allow them to accept
new hook-ups to the system: a 14-lot subdivision called Ocean Bay
Court which was expected to generate 6300 GPD, and a motel of
indeterminate size. The DEM environmental engineer who was the
0 Outer Banks Beach Club - page 5

n
0 author of this letter noted that '...if the town of Kill Devil Hills, Dare
County Health Department, and the Division (DEM) all work together
we can eliminate the possibility of further situations developing such
as the Ocean Acres subdivision'.
Letter from DEM to OBBC, describing an inspection of the OBBC
treatment plant. An inspection of the wastes in the aeration basin
showed that they were not being adequately treated. Neither rotary
distributor was rotating. The operator had not been at the treatment
0 plant for 30 days. In addition, the DEM engineer noted that he had
been unable to contact the operator by any method for two weeks.
3-85 DEM interoffice memo providing comments about OBBC's request to
add an additional 200,000 GPD to the treatment capacity at OBBC.
0 The memo noted that flow equalization was needed at Outer Banks
treatment plants, and that the amount of flow equalization proposed
for the expansion was not sufficient. In addition, the memo reports a
discrepancy between the amount of waste that the design engineer
claims is currently flowing into the existing plant and the amount
0 that DEM believes is flowing in.
4-85 Letter from OBBC requesting that a motel be allowed to hook up to
the OBBC plant (See 2-85). The additional waste flow would be
40,600 GPD. Cover memo from DEM notes that the existing treatment
plant will be over capacity if this is allowed.
5-85 Letter from DEM to Kill Devil Hills Town Manager, to apprise him of
the situation concerning the OBBC treatment plant, and to ask for
'...the town's assistance in helping to control the volume of flow to
this privately owned treatment plant'. At that pointy OBBC was
operating a 100,000 GPD plant, the request for an additional 200,000
GPD was being reviewed, and OBBC was also talking about another
expansion to bring the total waste treatment capacity of the system
to 500,000 GPD.
Letter from consulting engineers for the project to DEM, describing
the design for a surge tank and pumps for the expanded project. A
32,000 surge tank is proposed to provide for some flow equalization.
The letter notes that several plant operating deficiencies have been
corrected: for example, defective pumps have been replaced and
adjustments have been made to aeration tank air. Closer operating
supervision would be occurring, along with an overall plant cleanup.
In addition the letter notes that the requested additional treatment
Outer Banks Beach Club - page 6

and capacity that has been requested is necessary because of the
Town of Kill Devil Hills 'lack of response to provide [for] a need' for
the treatment.
DEM interoffice memorandum, in which the reviewing environmental
O engineer notes that the flow equalization capacity proposed for the
expanded treatment plant was insufficient and should be redesigned
to at least 57,500 GPD at a minimum. The state engineering group's
review noted that a 60,000 GPD equalization capacity was necessary.
O DEM issues permit'6979-R3 for an expanded plant, to a total of
300,000 GPD, with a 32,492 GPD equalization basin. The permit notes
that, based on the performance of the 32,492 GPD equalization basin
with the first 100,000 GPD plant, if additional equalization appears to
be needed, start up of the second and third plants won't be allowed
p until additional equalization is added.
7-85 DEM letter to OBBC, describing the results of a plant inspection. The
treatment plant appeared not to be functioning property, again
providing insufficient aeration. The pumps were not functioning.
O
8-85 DEM letter to the plant expansion design engineers, describing the
results of a plant inspection made on 8-9-85 as part of the review for
the permit application requesting the 200,000 GPD expansion. The
letter notes that there is enough land of adequate quality on the site
O to provide acceptable wastewater treatment and disposal for an
additional 200,000 GPD.
Im
11-85 DEM interoffice memo, noting that the town of Kill Devil Hills had
denied permission for the construction of the second 100,000 GPD
plant at OBBC. Because of this, the hookup of the motel (40,600 GPD)
and two additional new hookups (18,910 GPD and 14,400 GPD could
not be approved. The memo describes an understanding on DEM's
part that the Town's denial of the permit for construction 'could be
rescinded at some time in the future'.
12-85 An application was made to DE1fi fvi a U n jvv,vvv viL ucauljaut,
plant at OBBC.
O Monitoring data for the existing plant is in the file.
1-86 Letter from DEM to the Town Manager of Kill Devil Hills, to inform the
Town that DEM has received an application for an expansion of the
0 Outer Banks Beach Club - page 7

OBBC treatment plant to 500,000 GPD capacity. Comments are
requested by 2-14-86.
Letter to DEM from the OBBC plant operator, confirming that 1,000
gallons of raw sewage was spilled at the plant on 1-14-86. The spill
had been caused by clogged lines which had been reduced in size by
the operator in order to overcome other problems that resulted from
pumps that were too large (poorly designed).
2-86 Leger from DEM to the Town Manager of Kill Devil Hills, enclosing
information about the proposed treatment plant expansion at OBBC
DEM interoffice memo, describing the 1-86 sewage spill and letter
from the OBBC operator, and noting that the DEM review of the
original design had recommended a redesign of the flow equalization
system that had caused the spill, but that the permit was given for
the original design. The permit was given with the understanding
that if a problem such as the spill occurred the inadequate system
would need to be replaced with a mor appropriate system. In
addition, the lines that had clogged had not been installed according
to the permitted design.
Letter from Kill Devil Hills' Planning Director to DEM, commenting on
the proposed 500,000 GPD treatment facility permit under
O consideration by DEM. He points out that `There appears to be an
administrative loop -hole or lack of intergovernmental coordination in
the permit process for privately owned wastewater treatment
facilities. At the local government level, our biggest concern is
identifying the need for such a facility. ..As of this date, I am not
0 aware of any proposed development that would justify a facility of
the magnitude requested by the Outer Banks Beach Club.' He goes on
to request that the DEM include a statement on the permit that DEM
approval of the facility does not preclude local permits for actual
construction of the facility. He notes that the site of the OBBC plant is
0 zoned for residential uses, including wastewater plants associated
with a residential use. Because the Town does not know what kinds
of facilities are planned to be served by the OBBC plant, no
certification of zoning compliance for those uses can be given. He
notes that "if the facility currently ... is intended as a private sector
0 'for profit' wastewater operation, it would fall into a commercial
classification and would not be compatible with the land use and
zoning guidelines in affect [sic] at the site.' Finally, he notes that the
Town is in the process of establishing a zoning district in which a
O
Outer Banks Beach Club - page 8

privately owned wastewater facility would be in use, and putting it in
place at the OBBC site.
3-86 DEM Regional Office comments concerning the proposed expansion
design, including: (1) the fact that there is no sludge handling
0 facility proposed, even though the expanded capacity will be very
high; (2) inadequate information has been submitted about various
system component designs; (3) Some components, particularly the
sand filter and clarifiers are not adequately designed. The DEM
Regional Office recommended that sludge handling facilities be
0 provided on -site.
Letter from the Director of DEM to OBBC, noting that, given the
amount of sewage inflow that has been permitted by DEM to flow into
the OBBC treatment facility, the existing 100,000 GPD plant will soon
O be in violation of NCGS 143-215.67(a), which does not allow disposal -
in excess of constructed treatment works capacity, unless an
additional treatment plant is built, or some of the tributary
wastewater is handled by another source.
0 4-86 Letter from OBBC to DEM's Director, noting that OBBC was ready to
construct the additional treatment facilities needed as soon as the
permit to allow their construction is issued.
The design engineers note in an additional letter to DEM that the
plant's design is configured to allow for additional expansion in the
future.
5-86 Letter from DEM to an out-of-state developer, noting that the
0 developer's request to hook up a new project in Kill Devil Hills to the
OBBC treatment plant could not be authorized because only 125,000
(?) GPD of treatment capacity exists at the site and it is at its
maximum loading. The letter notes that an application was in review
at the time for an additional 500,000 GPD expansion, and that DEM
0 saw no problem -with eventual hook up of the developer's 29,850 GPd
project once the permit was issued and the new facility was
constructed.
DEM permit s 13195 was issued to OBBC for the construction of an
0 additional 500,000 GPD treatment plant. The permit would be valid
through 5-91, and covers construction of the facilities only; approval
for operation would need to be obtained in writing from DEM before
any wastewater could be accepted. Approval for operation would be
0 Outer Banks Beach Club - page 9

contingent on having on -site sludge holding facilities in place at the
site by 5-87, and having approved plans by that date for on -site
sludge handling facilities, although they would not be required to be
built by that time. In addition, the permit is conditioned on the
inspection and approval of the new rotary distributor units by DEM
before they can be connected to the plant. Three new groundwater
wells were required to be installed, to monitor water quality in the
vicinity of the new rotary units.
Attached to the permit is a copy of an excerpt of a report completed
in 1984 by Russnow, Kane & Andrews, hydrogeologists, noting that
the ground near the existing two rotary distributors was at that time
exhibiting reduced infiltration capacity and potential control
problems" because the difference between the elevation of the base
of the rotary distributors and the water table was insufficient to
protect the groundwater mound directly beneath the rotary
distributors. The groundwater mound was 1 to 2 feet below the
ground surface. The consultants recommended that "care should be
taken to assure that all low areas are maintained and filled if
necessary to provide a buffer for the groundwater mound. If
possible, the existing rotary distributors should be elevated at least
three feet to reduce existing problems."
8-86 DEM Interoffice memo, listing all the OBBC permitted inflows to that
date, which total 132,000 GPD. The memo notes that OBBC operates a
100,000 GPD system, and has received a permit to construct an
additional 500,000 GPD system, but that that has not yet been built.
For that reason, an additional request to hook 36,700 more GPD from
the Calico Jack Bar and Restaurant into the system should be granted
conditionally -- on the condition that flows may not start until OBBC
0 has received authorization to operate the new 500,000 GPD facility.
9-86 DEM letter to the Dare County Health Director, noting that wastewater
from the Calico Jack Bar and Restaurant has been accounted for in the
total flow which will be tributary to the OBBC plant.
10-86 A well construction permit was issued for four groundwater
monitoring wells to serve the OBBC plant.
11-86 Letter from DEM to OBBC, describing an inspection of the original
OBBC treatment plant, which was found to be functioning adequately.
The rotary distributors providing for disposal, however, were in a
state of disrepair and malfunctioning. The rotary arms were leaning
0 Outer Banks Beach Club - page 10

badly and were not evenly applying wastewater. The motors driving
O the rotors were not working properly, and obviously had not been
maintained in a long time. The distributor beds had deep ruts in
them because of the uneven wastewater loading. It was clear that
adequate maintenance of the rotary area was not occurring. DEM had
had problems with similar kinds of rotary facilities elsewhere, and
0 recommended their replacement with different systems which
require less intensive maintenance.
Letter from DEM to OBBC, concerning the amount of permitted inflow
and its relationship to the constructed treatment works. By 11-86,
O OBBC was permitted for 169,100 gallons of inflow, but had only a
100,000 GPD plant in operation, although the 500,000 GPD facility
was in construction. DEM had also received a request to hook 30,000
additional GPD, from the Albemarle Apartments, into the OBBC
facility. OBBC had not yet received permits to construct the rotary
0 distributors needed for disposal of the extra volume of wastewater.
12-86 DEM Interoffice memorandum noting that OBBC had requested
permission to construct a force main from a Wendy's restaurant to
the OBBC plant, allowing an additional 3920 GPD of flow to be treated
O by the OBBC plant. Total permitted flow to the existing 100,000 GPD
OBBC plant as a result of the addition would be 2 03,02 0 GPD (note:
although all of this volume had been permitted to flow to the OBBC
plant, several of the waste generating facilities had not yet been built,
O so the actual flow to the plant was less than the permitted flow) The
memo noted that although the treatment plant to handle the flows
was in construction, OBBC had not yet requested a permit to construct
the rotary distributor system. DEM would recommend approval of
the permit to build the force main and allow Wendy's to hook on, so
0 long as the conditions on the permit included one that would prohibit
the actual operation of the force main until the new rotary
distributors at the OBBC plant had been constructed.
3-87 Permit 13195 was amended to allow the eventual construction of 12
O rotary distributors to serve the new 500,000 GPD plant. DEM was
concerned about the design of the rotary distributors, however, and
issued the permit to allow the construction of 3 distributors at first,
with the construction of the remaining 9 not to be allowed until the
satisfactory performance of the first 3 distributors had been
p demonstrated.
0 Outer Banks Beach Club - page 11

4-87 Request from OBBC to modify 13195 again, to change the number of
rotary distributors from 12 of one type to 2 of another type. OBBC
requested that the amendment be issued very quickly.
6-87 DEM issued well permits to allow the construction of three additional
groundwater monitoring wells at OBBC's distributor site.
8-87 DEM interoffice memorandum, stating that OBBC's engineer had
requested permission to amend the OBBC permit to allow the
construction of one of the mechanical components of the plant serving
the rotary distributors. DEM's reviewer noted that he had no
objections to the modification, but that the modified component had
already been built, and that DEM should request a written
explanation from the OBBC engineer as to why that work had taken
place without a permit.
10-87 Letter from DEM to Van's Pizza, verifying that the OBBC treatment
facility was capable of treating an additional 7120 GPD of wastewater
flow. (This letter was not a permit, but a verification to a private
developer of available treatment capacity under the DEM-permitted
OBBC facility).
11-87 Letter from DEM to the Town Manager of Kill Devil Hills, stating that
the OBBC treatment plant had the capacity to serve the proposed
Wilbur Wright motel, which would generate 11,780 GPD in
wastewater flow.
O
12-07 DEM re -modified permit 13195 to allow the construction of 2 rotary
distributors rather than the 12 required under the original (3-87)
modification, and allowing the construction of the modified
0 component that had been built in 8-87. The letter announcing the
permit amendment notes that "[i]n the future, constructing
wastewater treatment facilities without first acquiring the
appropriate permits could result in enforcement action being taken
against Outer Banks Beach Club, Inc."
O
2-88 Letter from DEM to OBBC's design engineer, saying that there would
be no problem from DEM's perspective in allowing a Dairy Queen (920
GPD) to hook up to the OBBC system, but that an official request to
hook up would have to be made and a permit granted.
O
0 Outer Banks Beach Club - page 12

3-88 DEM received an application for a permit to allow the hook up of a
Taco Bell restaurant (3200 GPD) to the OBBC system. DEM
recommended approval.
4-88 DEM grants permits for the hook up of the Dairy Queen (820 GPD is
permitted) and Van's Pizza (7120 GPD)
O 6-88 Letter from DEM to a shopping center developer, noting that OBBC's
treatment facilities were capable of handling the additional 21,000
GPD that the developer sought to hook up to the system.
O 8-88 DEM permits the Comfort Inn (24,225 GPD) to hook up to the OBBC
system.
10-88 DEM permits the 21,000 GPD shopping center to hook up to the OBBC
system.
O
1-89 Letter from a developer requesting that he be. allowed to add an
additional 3360 GPD of wastewater from a condominium project to
the OBBC plant. DEM note that at this point in time, OBBC's plant
operating capacity was 200,000 GPD, with a 100,000 GPD plant under
O construction, 263,765 GPD permitted inflow, with 170,840 GPD
actually connected, and facilities under construction that would
generate 22,950 GPD. In addition, there were two requests Mart
and the Dare County Schools) totalling 40,368 that had been given
preliminary approval by DEM, but were not yet permitted to hook up.
O
3-89 DEM letter to OBBC, noting that one of the conditions of permit 13195,
as amended (issued in 12-87) was that OBBC was to submit to DEM a
certification from a professional engineer that the facility had been
installed in accordance with the requirements of the permit that had
O been issued. As of 3-89, no such certification had been received by
DEM for the OBBC facility.
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Outer Banks Beach Club - page 13
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CARTERET COUNTY
O Genesis Condominiums
Atlantic Beach
1981 DEM issued a permit for a 15,400 gallon per day {GPD} treatment
O plant, and a spray irrigation system for disposal of the treated
wastewater, to Genesis Development Inc.
1982 Genesis requested and received a permit modification to allow a
30,500 GPD plant rather than the original 15,400 GPD plant. The
0 plant would be hooked up to the same spray irrigation wastewater
disposal system as permitted under the 1981 permit, with no changes
to any portion of the spray irrigation system's design.
3-83 Letter to Genesis Development from DEM informing Genesis that the
0 groundwater monitoring schedule required under the spray irrigation
disposal system permit was not being followed. At that point, no
monitoring information had been received by DEM.
6-85 DEM letter to the Genesis Condominiums homeowners' association to
O inform them that the sewage treatment plant and spray irrigation
disposal system was in noncompliance with its permit because:
1. the required standby power generator was not operable
2. there was no hose available to clean the facilities, which is part of
the required regular maintenance program
O 3. the spray arm mechanism (called a rotary distributor system) for
distribution of treated wastewater was leaking from a cracked flange,
and wastewater was therefore not being distributed properly
4. the rotary distributor arms were clogged with solid material,
which indicated that regular cleaning was not occurring, and also that
O the wastewater treatment being provided by the plant was not
complete. There was enough particulate matter still suspended in the
treated wastewater to clog the holes in the distributor arms.
5. there was vegetation growing on the surfaces of the rotary
distributors, another sign that they were not being maintained
0 adequately.
2 -8? DEM letter to Genesis Development noting that their sludge disposal
method was inadequate and in noncompliance with their permit.
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5-87 DEM inspected the Genesis Condominiums treatment and disposal
facility. The facility was found to be in noncompliance with the DEM
permit because:
1. the standby power generator still was not operable
2. there was still no hose available to clean the facilities
3. the rotary distributor was still leaking from a cracked flange
4. the rotary distributor arms were still being clogged with solid
material
5. there was still heavy growth of vegetation on the surfaces of the
rotary distributors
6. the plant's power supply box was rusted and had holes in the top
7. the plant needed painting.
6-87 DEM letter to Genesis Condominiums homeowners' association
informing them of the results of the May 1987 inspection, and
also that the plant was in noncompliance with its DEM permit.
The letter informed the homeowners' association that the permit
had expired as of December 1986, and that no request had yet
been made for the reissuance or renewal of the permit The
homeowners' association was notified that if no action was taken
within 10 days the enforcement process would be initiated,
possibly leading to the assessment of civil penalties: 'Failure to
take appropriate and timely action to resolve the problems
noted above will result in the initiation of enforcement actions,
and may lead to the assessment of civil penalties'.
7-67 Application was made by the homeowners' association to DEM,
through Tarheel Technical Associates for a nondischarge permit for
the 30,500 GPD plant and spray irrigation system for the disposal of
the treated wastewater.
8-87 DEM letter to Tarheel Technical Associates, requesting more
information regarding the permit application, including: scaled map
showing location of the condominiums relative to two local roads and
relative to the Atlantic Ocean, and showing the location of the plant
and the rotary distributors in relation to the property boundaries.
2-88 DEM again inspected the site. The inspection took 40 minutes. It was
still clear that routine maintenance of the plant and the disposal
system was a problem. This was indicated by the continued presence
of heavy vegetation on the rotary distributors. The plant was
deemed to be running satisfactorily, on a scale of 'satisfactory',
'marginal', or 'unsatisfactory'.

A7
p 3-88 DEM issued a new permits essentially extending the old permit for the
treatment and disposal facilities, to the homeowners' association. The
permit will be valid until March, 1993. The conditions of the permit
included the submission of daily and monthly self -monitoring reports
to the DEM regional office in Wilmington. In addition, because two of
O the original monitoring wells had been constructed improperly, they
were to be abandoned as a condition of the permits and three new
wells were to be constructed.
1-89 DEM inspected the site. The old improperly constructed groundwater
O monitoring wells had not yet been abandoned, nor had new wells
been built as stipulated by the condition of the March 1988 permit.
3-89 DEM letter to the Genesis Condominiums homeowners' association
informing them that the treatment and disposal facilities were in
p noncompliance with their DEM permit because they had failed to
submit groundwater monitoring information to the DEM Wilmington
Regional office.
DEM letter to the Genesis Condominiums homeowners' association
O informing them that DEM had not yet received the required
certification from a professional engineer (PE) that the permitted
treatment and disposal facilities had been constructed in accordance
with the requirements of the permit and the approved plans and
specifications.
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BRUNSWICK COUNTY
Bald Head Island Utility Company (BHIUC)
3-83 DEM issues permit number 7964 for the use of several disposal
system designs to serve the TimberCreek Development and Marina
Complex, also known as the Bald Head Island Creekside Development
and Marina Complex The permit allows the use of various designs
for specific lots or sections of the development, to serve single family
homes on Bald Head Island. One of the permitted systems includes a
50,000 gallons per day treatment plant and a system of lagoons.
Treated wastewater from the plant is discharged into a man-made
golf course pond system, for evaporation and groundwater recharge.
One of the conditions on the permit is that the golf course not be
irrigated with the wastewater, but that a separate pond be developed
for irrigation purposes. The other possible treated wastewater
disposal technologies, under the permit include mound systems, low
pressure pipe systems, and conventional septic systems.
4-86 Bald Head Island Utility Company applied for permit for a low
pressure pipe and mound combination disposal system to serve ten
lots. (application number 007344)
DEM requested more information on BHIUC's permit application for
the low pressure pipe disposal system, regarding the location and
depth of the groundwater table at the proposed disposal site. DEM
correspondence said they needed the information within 60 days or
the application (number 007344) would be returned.
2-87 DEM letter to BHIUC, stating that the disposal field site called out on
the application for the mound system was "unsuitable" because the
water table was located within a few inches of the ground surface or
at the surface, and that the first 12 inches of ground below the
surface were of "black organic soil" [wetland]. In order to install the
mound system, all vegetative cover would have to be removed from
the site, along with the first 12 inches of soil, which would have to be
replaced with sandy fill.
8-87 DEM issued permit 14922 to allow the Marina Phase I section of the
development to discharge 13,770 GPD of untreated sewage into the
50,000 GPD TimberCreek treatment facility.

v
4 12-87 DEM issued permit 15537 to allow the Stede Bonnet Close section of
the development to discharge 2160 GPD sewage into the 50,000 GPD
TimberCreek/Creekside treatment facility.
The DEM groundwater section requested more information from
O BHIUC on a permit application that had been submitted for the spray
irrigation disposal system for Stage 11.
1-88 DEM comments on the design of the spray irrigation system proposed
to serve Stage I I. The DEM requested that the fields be relocated so
O that they are parallel to the ocean shoreline rather than
perpendicular to it, and that the spray irrigation arms be moved so
that they are not within 500 feet of the proposed public water supply
well for the development.
p 3-88 The DEM returned to BHIUC the application (number 007344)
submitted in April 1986 for the low pressure pipe and mound
combination disposal system to serve 10 lots. DEM noted that they
had asked in April 1986 that more information regarding local
groundwater conditions be supplied within 60 days. The permit
O application was being returned to BHIUC because DEM never had
received the requested information.
The original permit (7964) allowing the use of several disposal
system designs to serve the TimberCreek Development and Marina
O Complex, expired.
4-88 DEM returned to BHIUC a permit application submitted in 1987 for
Bald Head Island Stage II disposal fields, because the groundwater
information that had been requested had not yet been received.
Ar,
BHIUC applied to DEM for a permit for a low pressure pipe disposal
system to serve Bald Head Island Phase I. The application (number
0 10 155) included 11,733 square feet of disposal fields, to dispose of
8800 gallons per day of treated wastewater from 22 lots. At 400
O gallons per day per lot, this yielded an hydraulic loading rage of 0.75
GPD per square foot.
DEM internal comments regarding application number 0010155: 'You
should be aware that the groundwater people have serious
O reservations about this project and system' -- referring to the low
pressure pipe disposal system.
0 2

6-88 DEM issued permit 16387 for Stage I I, POD I, to allow this section of
the development to discharge 10,800 GPD into the TimberCreek/
Creekside plant. At that point, 2 5,2 90 GPD was already on line. The
application for permit number 16387 noted that the capacity of the
treatment plant was 35,600 GPD, although the treatment plant
permitted under the original permit had a capacity of 50,000 GPD.
DEM issued permit 16350 for Stage I I, POD 11, to allow this section of
the development to discharge 14,000 GPD into the TimberCreek/
Creekside plant. According to the application for permit 16350, at
that point, 36,090 GPD was already flowing to the plant.
DEM returned to BHIUC a permit application for Stage 11, POD I I I,
which would have added an additional 12,800 GPD to the treatment
plant. The application was returned because the volume from the
previously approved projects (50,900) exceeded the plant capacity
(50,000 GPD).
7-88 DEM issued a permit for a water supply well for the development,
producing 72,000 GPD
9-88 A DEM site inspection finds the treatment plant to be well maintained
and operated, and the treated wastewater effluent clear.
BHIUC made an application to expand the original treatment plant to
100,000 GPD capacity, from the originally permitted 50,000.
DEM internal notes on the review process for the treatment plant
expansion application indicate that no groundwater monitoring data
had ever been supplied on the original permit [which the notes said
was issued in November 1984, although the file indicates was issued
in March 19831, and that groundwater monitoring wells had only just
been completed.
11-88 DEM issued permit 10916 to allow the construction of an additional
evaporative lagoon for treated wastewater disposal from the original
treatment plant.
DEM issued permit WQ0000194 to allow the Stage I I POD I I I section
of the development to add an additional 12,800 GPD of untreated
sewage to the plant. At that point, the plant was committed to treat
50,900 GPD of wastewater. The application for this section had
previously been returned by DEM (see note at June 1988).
3

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o DEM issued permit WQ0000191 to allow the Creekside section of the
development to add an additional 14,400 GPD of sewerage to the
plant. At that point, the plant was committed to treat 62,890 GPD of
wastewater.
DEM issued permit WQ0000192 to allow the Ibis Roost section of the
development to add an additional 12,400 GPD to. the plant. At that
point, the plant was committed to treat 77,290 GPD of wastewater.
12-88 This is the date of a portion of the site plan for the Bald Head Island
p development, found in the file. The portion of the site plan in the
DEM file shows that at least 2512 DUs were planned for the
development
3-89 DEM letter to BHIUC, notifying them that the original permit (7964)
p had expired in March 1988, and that no application for renewal had
been received by DEM. One of the conditions on the original permit
was that the permittee apply for renewal of the permit at least six
months before it expired. Because of this, DEM also returned several
new applications for additional systems under 7964, noting that these
C� could not be processed until 7964 was renewed.
DEM letter noting that they had not yet received the required
certification by a Professional Engineer that the hook up from the
Stede Bonnet portion of the development to the treatment plant had
been built-in accordance with the permit and plans issued in
December 1987.
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CARTERETCOUNTT
Emerald Plantation Utilty Company (EPUC)
--------------------------------------------------------------------------------
10-85 DEM issues a nondischarge permit (12366) to the Emerald Plantation
Utility Company for a 55,000 GPD treatment plants with 18,300 sq ft
of subsurface discharge fields. The design hydraulic loading rate
(HLR) is 3.0 gallons of treated wastewater per day per square foot of
drainage field (GPD per sq ft). The facility is planned to eventually
serve: 48 townhouses, 36 patio homes, an 80,000 square foot
shopping center, and a 200 seat restaurant.
7-87 A letter was sent to DEM from the Emerald Plantation Utility
Company (EPUC), saying that treated wastewater flows (12,300 GPD)
from a new shopping center (Emerald Plantation Village) can be
handled by existing wastewater plant and disposal fields.
1-88 A letter was sent to EPUC from the DEM, to notify EPUC that their
self -monitoring reports had not been submitted as required, and
therefore that they were in noncompliance with their permit. In
addition, the letter noted that an inspector had discovered that a
standby power unit had not yet been installed even though one was
required under the original permit. Accompanying notes state that
verbal assurances of EPUC's intention to install the standby unit had
been received by DEM.
2-88 DEM issues a permit to allow Emerald Plantation Village to hook up
to existing Emerald Plantation sewerage system, adding an additional
12,300 GPD of treated wastewater flow to the existing system. The
permit application notes that the treatment plant has 55,000 GPD of
treatment capacity, and 14,400 GPD of that capacity was committed
to serve previously approved projects, 2,000 GPD was flowing into
the system, and an additional 12,300 would flow from the new hook
up. In other words, 26,300 GPD of treatment plant capacity would
remain after the shopping center hookup.
3-88 DEM receives an application for a nondischarge permit for a low
pressure pipe disposal system for treated wastewater from a 55,000
GPD treatment facility with a 11,500 gallon equalization chamber, two
27,500 gallon aeration tanks. The treated wastewater disposal
system planned would take the place of the original disposal field
system, and would include 36,720 sq ft of subsurface discharge fields.
No hydraulic loading rate is specified in the application, although if

IN
the whole field is used, it works out to 1.5 GPD per sq ft if whole field
o is used. This is half the hydraulic rate originally approved (see
October 1985 notes), and is therefore a more conservative approach.
5-88 DEM internal notes to the file concerning EPUC's permit application
for the low pressure pipe disposal system. The notes state that
Q although the original permit was issued with an application rate of
3.0 GPD per square foot of land, 'an evaluation of the system at this
high rate can not yet be done because the system is still lightly
loaded". The DEM groundwater section had concerns about the 3.0
GPD rate, thinking that it might have the potential to overload the
p local soils and lead to groundwater contamination due to inadequate
ability of the overloaded soils to provide additional treatment to the
wastewater before it reaches local groundwater sources.
6-88 DEM issues permit 12366R for the low pressure pipe system
p described in the March 1988 notes above, with a hydraulic loading
rate of 1.5 gallons per day per square foot.
12-88 Emerald Plantation Utility Company submits a groundwater quality
self -monitoring report.
O
2-89 DEM letter to Emerald Plantation Utility Company saying that their
original permit had expired on October 31, 1988, but that no request
for a new permit or a permit extension had yet been received. All
DEM nondischarge permits include a condition that the permit holder
O must apply for permit renewal at least six months before the permit
is to expire. '
3-89 DEM letter to Emerald Plantation Utility Company saying that they
had not yet received the required certification by a Professional
O Engineer that the treatment plant and disposal fields had been built
in accordance with the permitted standards and in accordance with
the approved plans.
Letter from Emerald Plantation Utility Company to DEM saying that a
O permit modification is necessary because the original permittee had
been bought out by another company.
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CARTERET COUNTY
West Pine Knoll Shores
--------------------------------------------------------------------------------
9-82 DEM issued nondischarge permit number 5907 for a 36,650 gallon
per day (GPD) capacity treatment plant and a low pressure pipe
treated wastewater disposal field system. The permit would be valid
for five years, expiring September 1987.
Permit 5907 was amended at some point between 1982 and 1987 to
allow the construction of 40,000 GPD treatment plant expansion.
5-87 The permit was amended (by the issuance of 5907R) to allow a
60,000 GPD expansion of the treatment plants so that the permitted
treatment capacity would be 160,000 GPD.
9-87 DEM letter to the West Pine Knoll Shores system's designer, noting
that the required groundwater monitoring well permits had been
issued.
12-88 West Pine Knoll Shores requested DEM to modify permit 5907R to
reduce the permitted capacity of the treatment plant by 25,000 GPD
to 135,000 GPD.
3-88 DEM internal memorandum to the Permits and Engineering Division
from the Regional Office, reporting on an inspection of the West Pine
Knoll Shores facility. A permit renewal application had been
submitted, and that had prompted the site inspection. - The inspectors
had found the West Pine Knoll Shores plant to be "well -operated, all
units functional", which was "a vast improvement over plant
performance in the past". The inspectors noted that sewage inflow
rates to the plant in the summer had exceeded the plant's capacity,
and that an expansion of the facilities was necessary.
One problem discovered during the inspection was that only one
quarter of the required low pressure pipe disposal field had been
built, which meant that inadequate disposal facilities had been
provided.

CARTEM COUNTY
Peppertree Resorts
--------------------------------------------------------------------------------
12-81 DEM issued permit number 7078, for a nondischarge system including a
50,000 gallons per day (GPD) capacity treatment plant and 2.1 acres of low
pressure pipe field for disposal of the treated wastewater. The hydraulic
loading rate (HLR) proposed for the fields was 0.546 GPD per square foot.
The permit noted that only half of the field area was to be built in the first
phase. The permit was to be valid for five years, to expire in December,
1986.
0 1-87 The Peppertree utility requested that permit 7078 be renewed.
2-87 DEM inspected the treatment and disposal facilities permitted under DEM
permit 7078, and found them to be "fairly well maintained and operated",
although no monitoring of the treated wastewater effluent, as required by the
permit, was being done.
3-87 DEM letter to the Peppertree utility describing proper disposal practices for
the sludge waste from the Peppertree plant.
o DEM renewed permit 7078 (as permit 7078R) for an additional five years.
[The permit was not actually issued until November 1987 -- see below]
7-87 DEM issued a well construction permit for groundwater monitoring wells at
the Peppertree site.
O
11-87 DEM letter to the Peppertree utility, issuing permit 7078R (the renewal of the
original permit 7078). The system included a 46,220 GPD treatment plant
and 1.9 acres of field [a modification from the original permit -- to reflect
what had actually been built]. DEM had not yet received the required
certification from a Professional Engineer that the plant was built in
accordance with the approved plans and permit.
2-88 DEM inspected the plant, and found it to be in compliance with the reissued
O permit, although there were some problems. The plant operator's
performance against the required effluent and groundwater self -monitoring
program was classed as marginal -- inaccurate data had been submitted.
2-89 DEM letter to the Peppertree utility noting that DEM had not received any of
0 the required groundwater monitoring reports for the facilities permitted
under permit 7078R, and that Peppertree was in violation.
X

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O �l
APPENDIX C
MEMORANDUM OF AGREEMENT
O TO PERFOR14 A WATER QUALITY MANAGEMENT PROGRAM, G�
IN WAKE COUNTY, NORTH CAROLINA
0P1
AGREEMENT The North Carolina -Division of Environmental Management (DEM)
hereby agrees with the Wake County Board of Health (the "Board")
while exercising the powers of a board of health, that Wake
p County will perform within its jurisdiction those functions of a
water Quality management program described below.
PURPOSE The purpose of this document is to describe a broad working
p agreement between the Board and DEM which will most effectively
protect and enhance the Quality of water in Wake County. This
goal will be accomplished by establishing the basic functions to
O be performed by the Board in general terms. The specific
methods, procedures and protocols of each duty will be described
in the annual work plan. Lastly, it is the intent of this
O agreement that both parties perform their respective duties in a
manner which provides timely communication, sharing of
information and resources, and which demonstrates a spirit of
O cooperation to best accomplish the goals of the arrangement.
SCOPE DEM does not relinquish any of its responsibilities, powers or
authority by the execution of this agreement. The functions to
O be performed by the Board or its designee are described as
X
36E
Rev. 12/88
follows:

I. National Pollution Discharge Elimination System (NPDES)
Duties
As will be more specifically provided in the work plan, for
IQ
minor non -municipal NPDES sources:
A. Conduct on -site investigations during the initial O
application phase of the permitting process.
B. Conduct. on -site inspections during construction of
permitted facilities. O
C. Conduct on -site inspections of operating facilities,
D. Sample, analyze and interpret NPDES discharge and
ambient water quality parameters. The North Carolina O
Division of Environmental Management Laboratory
protocols will be followed and all lab facilities
utilized must receive certification under DEM's O
certification program.
E. Sample, analyze and interpret ambient stream
parameters and -groundwater parameters, where O
appropriate.
F. Receive and interpret self monitoring data from NPDES
sources. These data will be supplied by DEM on a O
periodic basis.
G. Investigate complaints and incidents involving NPDES
permit holders.
II. Non -Discharge Wastewater Permitting Duties
A. Conduct on=site inspections during construction of
O
permitted facilities.
B. Investigate complaints and incidents involving
non -discharge permits.
0

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III. Incidence Response Duties
A. Respond to all incidents involving potential
contamination of the surface waters and groundwaters
of the county and take action to contain, control and
© correct the situation. DEM reserves the right to
assume lead authority whenever necessary.
IV. Well Construction Duties
p Conduct well inspections and otherwise communicate with the
groundwater industry to insure that the county and DEM well
construction and quality standards are met.
p V. Reporting Duties
Submit timely reports as required to DEM concerning Article
I - IV above.
O VI. Work Plan Duties
Submit a work plan to DEM on an annual basis containing a
description of the methods, procedures, and protocols to be
O used and the responsibilities for both DEM and the Board.
The detailed work -,plan will be negotiated on at least an
annual basis.
® PENALTIES .The DEM shall retain exclusive authority and responsibility for
the assessment of administrative penalities or for instituting
legal action for violations of State statutes and regulations.
a COORDINATION The staffs of DEM and the Board will make all reasonable efforts
OF ACITVITIES to coordinate activities.. -.When coordination is not possible,
nothing will preclude either DEM or the Board from conducting
Q its activities unassisted. In this instance,, activities will
be coordinated as soon as possible after the activity.
0 3

FOLLOW-UP
ACTIVITIES
GROUNDWATER
PROTECTION
TERMINATION
EFFECTIVE DATE
All problems or violations of environmental laws or regulations
found that are the responsibility of DEM shall be reported to 0
and coordinated through the DEM Raleigh Regional Office.
It is understood that this agreement and the protocols which
will be developed will not prevent the Board from setting up and D
performing a local groundwater protection program within the
jurisdiction of Wake County.
The DEM or the Board, without giving cause, may terminate this
agreement by providing at least 30 days written notice.
This agreement shall become effective on the date which the
second party executes the agreement, as shown below. p
for the Division of Environmental
Management
4 (Date)
4
for the Wake County Board of
Health
(Date)
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CO
N
Im
1E
FISCAL YEAR 1989
WATER QUALITY WORK PLAN I ' DRAFT
for the period
April 17, 1989.through September 30, 1990
V
WAKE COUNTY DEPARTMENT OFNEALTH
0
0
O Submitted To:
NORTH CAROLINA DEPARIMENT OF NATURAL RESOURCES
AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
POST OFFICE BOX 27687
RALEIGH, NOR1H CAROLINA 27611
im
rol
Submitted By:.
WAKE•COUNTY OEPARIMENT OF HEALTH
ENVIRONMENTAL HEALTH DIVISION
WATER QUALITY SECTION
POST OFFICE BOX 949
RALEIGH, NOR1H CAROLINA 27602

L . (:
103
PURPOSE
160
The purpose of this work plan is to outline the specific commitments and
procedures which are to be followed by both the Wake County Department of Health
(WCDH) and the North Carolina Division of Environmental Management (DEM) in order 4
to more effectively protect and enhance the quality of the water in Wake County
through a mutually cooperative effort on the part of both agencies. It is the
intent of this work plan to bring together the efforts of the water quality
programs for WCDH and DEM and eliminate the duplication of effort between the two
agencies. It.is not the intent of this work plan to limit either DEM or WCDH from
acting under their own pertinent authorities if either believes it is in the best 0
interest of the environment to do so. The development of this work plan is a
requirement which has been specified in the Memorandum of Agreement which was
entered into between DEM and the Wake County Department of Health on O
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WAKE COUNTY DEPARTMENT OF HEALTH
PROGRAM DESCRIPTION
The purpose of the WCDH Water Quality Program is to maintain or restore the
p chemical, physical and biological integrity of the water of Wake County and to
ensure compliance with local, state, and federal water quality standards. Efforts
to fulfill this purpose primarily involve the assessment of water quality through
p an established water quality monitoring program, and the identification and
elimination of sources of pollution through a number of program activities.
WCDH is dedicated to providing an integrated and comprehensive water quality
O program for the citizens of Wake County. The program receives policy guidance
through the Wake County Board of Health and Wake County Environmental Health
Committee. The program is currently budgeted for four (4) full-time staff members,
O three (3) part-time employees working in our well program, one (1) secretary and
one (1) organic chemist. The Water Quality staff receives support from the WCDH
Laboratory and the Water Quality Laboratory of the City of Raleigh. New laboratory
O facilities are due for completion by January, 1990. Secretarial, financial and
budgetary support is provided by the WCDH administration.
The allocation of program resources and the development and implementation of
0 program activities and procedures as well as the assessment of program
effectiveness is primarily the responsibility of the Program Manager of the Water
Quality Program. Staff members are responsible for fulfilling assigned program
O activities in accordance with established guidelines and procedures and fulfilling
the obligations specified in this work plan.
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PROBLEM ASSESSMENT
C
Field investigations by Environmental Health Division staff during 1988
revealed numerous conditional violations of the National Pollutant Discharge
Elimination System (NPDES) permit, visual process inefficiencies and effluent O
characteristics indicating that point sources of pollution are degrading the
quality of surface waters in the County aSong many stream segments. Sludge
accumulation, particulate matter in the effluent, non-functional chlorinators and 4
dark odorous effluent is evidence that water quality is being negatively impacted
by treated wastewater effluent.
A review of field inspection reports and correspondence from DEM act to 0
collaborate WCDH findings as discussed above.
EM
IKO
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IN
OBJECTIVES
n
National Pollutant Discharge Elimination System (NPDES) 1
(For minor sources as defined in the MOA between the State of North Carolina !f
O and the United States Environmental Protection Agency Regarding Delegation of
NPDES Authority)
0 1. DEM will provide WCDH with a copy of all permit acknowledgement letters and
applications for both major and minor non -municipal discharges. WCDH may
conduct on -site investigations during the initial phase of the permit review
O process for proposed discharge facilities. WCDH may submit comments to the
Raleigh Regional Office (RRO) for inclusion in the permit file. Such comments
may be transmitted to the Raleigh office prior.to their permit review.
O 2. DEM will provide WCDH with a copy of all discharge permits and authorizations
to construct as well as approved plans and specifications for all major and
minor non -municipal discharges. WCDH may conduct on -site inspections during
O the construction of discharge facilities and will make the necessary reports to
RRO.
3. WCDH will conduct Compliance Sampling Inspections (CSI), Reconnaissance
Inspections (RI) or Compliance Evaluation Inspections (CEI) at least quarterly
at all major/minor non -municipal permitted wastewater treatment facilities in
Wake County. WCDH will sample, analyze and interpret NPDES discharge and
O ambient water quality parameters as it deems necessary. Inspection reports and
draft letters will be submitted directly to RRO.
4. WCDH will sample, analyze and interpret lake, stream and ground water
O parameters as it deems necessary. WCDH will report to RRO all monitoring data
which indicates a violation of state water quality standards.
4
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5. DEM will provide WCDH with self -monitoring data from all NPDES non -municipal
sources in Wake County on a quarterly basis. p
6. RRO will refer to WCDH all complaints and incidents received for minor
non -municipal permitted discharges in Wake County. WCDH will respond to all
complaints and incidents of this nature within at least three (3) working days O
from when reported to WCDH. All attempts will be made to respond to these
complaints and incidents on a same day basis. Inspection reports will be
submitted directly to RRO.
Non -Discharge Wastewater Permitting
1. DEM wil provide WCDH with a copy of all permit acknowledgement letters and
applications for non -municipal non -discharge facilities. WCDH may conduct
O
C-07
on -site investigations during the initial phase of the permit review process O
for proposed non -discharge facilities. WCDH may submit comments to RRO for
inclusion -in the permit file. Such comments may be transmitted to the Raleigh
office prior to their permit review.
2. DEM will provide WCDH with a copy of all permits as well as approved plans and
specifications for non -municipal non -discharge facilities. WCDH may conduct
19
on -site inspections during the construction of all permitted facilities. O
Deficiencies will be reported to RRO.
3. RRO will refer to WCDH all complaints and incidents received for non -municipal
non -discharge facilities in Wake County. WCDH will respond to all complaints O
and incidents of this nature within at least three (3) working days from when
reported to WCDH. All attempts will be made to respond to these complaints and
incidents on a same day basis. Inspection reports will be submitted directly O
to RRO when deficiencies are detected.
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Emergency Response
WCDH will appropriately respond to emergency situations which involve potential
contamination of surface and/or ground waters of the state which lie within the
p geographical boundaries of Wake County. Response to such incidents will be
within two (2) hours from when reported. All attempts will be made to respond
li -
to these incidents immediately upon being reported. DEM will reserve the right
p to assume lead authority during these incidents whenever it deems necessary.
WCDH will submit written reports to RRO concerning all emergency response
investigations.
Citizen Complaints
Q RRO will refer to WCDH all complaints and incidents which involve water quality
concerns in Wake County. WCDH will respond to all complaints and incidents of
this nature within at least three (3) working days from when.reported to WCDH.
0 Reports will be submitted to RRO concerning those situations which impact water
quality.
0 Well Construction
WCDH may conduct a limited number of well inspections in an effort to enforce
0 DEM well construction standards in addition to enforcing WCDH's current well
regulations. The number of well inspections conducted will depend on available
resources. Inspection reports will be submitted directly to RRO when
Q deficiencies of DEM's well construction standards are detected.
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Reports
0
1. Both WCDH and DEM will submit in a timely and effective manner the reports,
data and other information which are necessary to ensure that the
responsibilities outlined in this work plan are fulfilled effectively. O
2. RRO will review and process WCDH reports in a timely and effective manner.
Enforcement
101
WCDH will act on behalf and through RRO concerning matters covered by this work
plan and will recommend to RRO appropriate action to enforce applicable O
regulations of the North Carolina Environmental Management Commission. DEM
will review all information and evidence provided by WCDH and will take
appropriate action in a timely manner consistent with DEM policies and O
procedures.
Coordination of Activities
FEI
1. WCDH's Program Manager will report to and coordinate through RRO concerning all
problems or violations of environmental laws or regulations which are the O
responsibility of DEM.
2. RRO will assume the lead role in setting up training sessions, planning
meetings and other activities necessary for the successful fulfillment of the O
objectives outlined in this work plan. RRO will notify WCDH of training
sessions, planning meetings and other activities concerning this agreement and
the waters of the state within the geographical boundaries of Wake County. O
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Laboratory Certification
n
WCDH will maintain DEM laboratory certification for all the parameters included
in the minor non -municipal NPDES permits issued in Wake County.
J
Program Evaluation
p During the month of September of each year beginning in 1990, an evaluation of
the program as established under this work plan will be conducted by DEM and
WCDH. This evaluation may consist of file reviews and field evaluations of
O staff as well as a review of future training needs and resource commitments by
WCDH. Following the evaluation, necessary modifications of this work plan will
be made for the next fiscal year's activities provided that both DEM and WCDH
O agree that the MOA should continue.
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PROGRAM IMPLEMENTATION STRATEGY
Eel
National Pollutant Discharge Elimination System (NPDES)
(Minor Discharges as Previously Defined)
101
1. DEM will copy WCDH on all permit acknowledgement letters and applications for
both major and minor non -municipal ditcharges in Wake County. WCDH may conduct
on -site investigations following the receipt of this permit information from O
DEM. Written comments may be submitted to RRO from WCDH concerning the
issuance of the discharge permit. These comments will contain factual
information regarding the nature of the proposed discharge site and receiving
waters as well as possible alternatives. Other factual information applicable
to the issuance of the permit may also be provided. Written comments will be
submitted within ten (10) days upon receipt of a copy of the application. All O
such information will be placed into the permit file by RRO and provided to the
Raleigh office for consideration during their permit review process.
2. DEM will provide WCDH with a copy of all discharge permits issued including O
major and minor non -municipal sources: DEM will also provide WCDH with a copy
of all authorizations to construct as well as approved plans and
specifications. This information will be provided to WCDH within seven (7) O
working days following approvals. WCDH may conduct on -site inspections during
the construction of permitted discharge facilities. WCDH may also conduct an
as -built inspection upon completion of construction prior to the discharge of O
effluent. The guidelines to be used during these inspections are the approved
plans and specifications as provided by DEM. RRO will be notified in writing
concerning the inspections conducted and all deficiencies detected. O
9
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F
The Activity Report Form (Appendix A) will be used as the standard reporting
0 mechanism. All written correspondence with the permit holder will be performed
by RRO. WCDH will submit to RRO a suggested draft letter for transmitting
inspection results to the permit holder. WCDH will be copied on all
0 correspondence from RRO. WCDH will conduct follow-up investigations as
requested by RRO.
sir
3. WCDH will conduct Compliance Sampling Inspections (CSI), Reconnaissance
p Inspections (RI) or Compliance Evaluation Inspections (CEI) of all major/minor
non -municipal permitted wastewater treatment facilities at least quarterly.
The inspections will be performed by WCDH in accordance with the Environmental
0 Protection Agency Compliance Inspection Manual, June 1984. The EPA Form
3560-3, NPDES Compliance Inspection Report, will serve as the standard
reporting form to RRO concerning these inspections. All written correspondence
0 with the permit holder will be performed by RRO. WCDH will submit to RRO a
suggested draft letter for transmitting inspection results to the permit
holder. WCDH will be copied on all correspondence from RRO. WCDH will conduct
O follow-up investigations as requested by RRO.
4. WCDH will sample, analyze and interpret lake, stream, and ground water
parameters as it deems necessary. During the second quarter of 1989, the WCDH
O will develop a surface water and stream monitoring data collection program for
Wake County. Monitoring points and test parameters will be coordinated with
programs currently underway by City of Raleigh, Triangle J Council of
O Government and DEM. RRO will be issued a copy of the annual Water Quality
Monitoring Report for Wake County which summarizes data collected during the
calendar year from monitoring sites located on lakes and streams within the
O County. WCDH and RRO will coordinate monitoring activities in an attempt to
prevent any duplication of efforts. WCDH will issue immediate notification to
RRO when monitoring data indicates a violation of state water quality standards.
0 10

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5. WCDH will receive and interpret NPDES self -monitoring data for all
non -municipal NPDES sources (major and minor). The data will be supplied by O
DEM on a quarterly basis. The means for supplying this data will be specified
by DEM. Self -monitoring data will be reviewed by WCDH staff on a regular basis
and prior to conducting a CSI or CEI.
6. WCDH will respond to all reported complaints and incidents involving
major/minor non -municipal NPDES discharge facilities in Wake County. All such
0
reports which are received by RRO will be referred to WCDH within two (2) 0
working days. WCDH will respond to these reports within at least three (3)
working days from when received at WCDH and every attempt will be made to
respond on a same day basis. WCDH will conduct on -site inspections and collect p
samples when necessary to identify problems and concerns. WCDH will issue
verbal notification to RRO regarding the complaint prior to conducting on -site
investigations. RRO will also be notified in writing concerning all O
inspections conducted in response to reported complaints and incidents for
major/minor non -municipal NPDES facilities. The WCDH Citizen Request/Work
Order form (Appendix C) will be used as the standard reporting mechanism. The O
citizen making the complaint or reporting the incident will be issued verbal
notification by WCDH regarding the on -site investigation. All written
correspondence with the permit holder will be performed by RRO. WCDH will O
submit to RRO a suggested draft letter for transmitting inspection results to
the permit holder. WCDH will be copied on all correspondence. WCDH will
conduct follow-up investigations as requested by RRO.
11
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Non -Discharge Wastewater Permitting
1. DEM will copy WCDH on all permit acknowledgement letters and applications for
proposed non -discharge facilities in Wake County. WCDH may conduct on -site
O investigations following the receipt of this permit information from DEM.
Written comments may be issued to RRO from WCDH concerning the issuance of the
permit. These comments will contain actual information applicable to the
0 issuance of the permit as well as possible alternatives. Written comments will
be submitted within ten (10) days upon receipt of a copy of the application.
All such information will be placed into the permit file by RRO and provided to
0 the Raleigh office for consideration during their permit review process.
2. DEM will provide WCDH with copies of the non -discharge permits as well as
approved plans and specifications within seven (7) days following approval.
O WCDH may conduct on -site inspections during the construction of all permitted
facilities. WCDH may also conduct as -built inspections following
construction. Reviews of these facilities may consist of inspections of
O non -discharge treatment systems as well as inspections -of -the on -site manholes
and the "flashing° of sewer lines within the collection system. The guides to
be used for conducting these inspections are the approved plans and
O specifications as provided by DEM. RRO will be notified in writing concerning
those inspections which reveal a failure to comply with approved plans and
specifications. The Activity Report form will serve as the standard reporting
0 mechanism. All written correspondence with the permit holder will be performed
by RRO. WCDH will submit to RRO a suggested draft letter for transmitting
inspection results to the permit holder. WCDH will be copied on all
0 correspondence. WCDH will conduct follow-up investigations as requested by RRO.
12
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3. WCDH will respond to all reported complaints and incidents involving
non -discharge wastewater systems in Wake County. All such reports which are p
received by RRO will be referred to WCDH within two (2) working days. WCDH
will respond to these reports within at least three (3) working days from when
received at WCDH and every attempt will be made to respond on a same day O
basis. WCDH will conduct on -site inspections and collect samples when
necessary to identify problems and co cerns. WCDH will issue verbal
notification to RRO regarding the complaint prior to conducting these on -site O
investigations. RRO will also be issued written notification regarding these
inspections. The WCDH Service Request/Work Order form will serve as the
standard reporting mechanism. The individual making the complaint or reporting O
the incident will be issued verbal notification by WCDH regarding the on -site
investigation. All written correspondence with the permit holder will be
performed by RRO. WCDH will submit to RRO a suggested draft letter for
transmitting inspection results to the permit holder. WCDH will be copied on
all correspondence. WCDH will conduct follow-up investigations as requested by
RRO.
u
Emergency Response
WCDH will conduct field investigations in response to all emergency situations
which threaten to contaminate the surface and/or ground waters of the state
0
0
within Wake County. All such reports which are received by RRO will be 0
immediately referred to WCDH. With some emergencies which are reported by
citizens, WCDH may determine that potential environmental impacts are minimal
or nonexistent. In these cases, WCDH will not respond to the incident or 0
report to RRO but will instead refer the reporting individual to RRO for
13
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notification purposes. In all cases when WCDH determines that the environment
O is threatened by an emergency situation, every effort will be made to conduct
field investigations immediately upon receipt of notification. Information
concerning the emergency situation will be recorded by WCDH on their Service
O Request/Work Order form. The information will be relayed to RRO staff by
telephone immediately upon WCDH having received notification of the incident
provided the report is received during normal working hours. If the report is
p received during non -working hours, the twenty-four hour emergency reporting
line will be contacted after the on -site investigation has been conducted.
WCDH recognizes that RRO reserves the right to assume lead authority in
O emergency response matters whenever it deems necessary. It is the WCDH's
intent to contact RRO from the scene of emergencies which are judged by WCDH to
require involvement by RRO personnel. At the scene of the emergency, WCDH will
O direct the initiator of the spill to immediately notify RRO regarding details
of the situation. WCDH will provide RRO with written reports for all field
investigations conducted in response to emergencies. The WCDH Service
O Request/Work Order form -will serve as the standard reporting mechanism. All
reports will contain information concerning the type and quantity of
materials) involved, initiator-of,-the,spill and location where the spill
O occurred, time and cause of the incident, surface water which may be impacted,
as well as information relating to the control of the situation and other
pertinent details. The individual reporting the incident will be issued verbal
O notification by WCDH regarding the field investigation. All written
correspondence to the initiator of the incident will be performed by RRO. WCDH
will submit to RRO a suggested draft letter for transmitting inspection results
O to the permit holder. WCDH will be copied on all correspondence. WCDH will
conduct follow-up investigations as requested by RRO.
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Citizen Complaints
M
WCDH will respond to all citizen complaints regarding water quality concerns in
Wake County. All such complaints which are received by RRO will be referred to
WCDH within at least two (2) working days. WCDH will respond within at least 0
three (3) work days from their receipt of the complaint. WCDH will conduct
field investigations in response to citizen complaints when it is deemed
necessary in order to ensure the protection of water quality. WCDH will report O
to RRO all field investigations conducted concerning situations which impact
water quality. The citizen lodging the complaint will be issued verbal and/or
written notification by WCDH regarding the field investigation. The WCDH p
Service Request/Work Order form will serve as the standard reporting
mechanism. All written correspondence to violators of state water quality
regulations will be performed by RRO. WCDH will submit to RRO a suggested O
draft letter of notification concerning water quality violations. WCDH will be
copied on all correspondence to violators by RRO. WCDH will conduct follow-up
investigations to ensure the correction of violations and/or water quality O
concerns.
Well Construction
WCDH will conduct a limited number of well inspections in an effort to ensure
that DEM well construction standards are met as well as those inspections O
required by WCDH's well regulations. WCDH will submit written reports to RRO
when deficiencies are detected as a result of these well inspections.
15
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O
The DEM Ground Water Form 36 or WCDH's well site location permit will serve as
'0 the standard reporting mechanisms. The extent of WCDH's well inspection
program for DEM well construction compliance will depend on available
resources. All written correspondence concerning the violation of state ground
0 water regulations will be performed by RRO except those covered by local
regulations. WCDH will submit to RRO a suggested draft letter of notification
concerning ground water violations. WCDH will be copied on all correspondence
0 to violators by RRO. WCDH will conduct follow-up investigations to ensure
compliance as requested by RRO.
0 Reports and Information
WCDH and RRO will exchange written and verbal correspondence in a timely and
O effective manner to ensure the fulfillment of all the activities outlined in
EO
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this work plan. Listed below is a summary of the written and verbal
correspondences to be exchanged between RRO and WCDH.
WCDH To RRO
Type Correspondence
1. Factual information regarding issuance
of discharge and non -discharge permits.
2. Inspections of discharge facilities
during construction as well as draft
letter to permittee.
16
Form Used
Letter
Activity Report/Draft Letter

it
D
3.
Inspections of non -discharge facilities
Activity Report/Draft Letter
during construction if deficiencies are
detected as well as draft letter to
permittee.
4.
NPDES inspections (quarterly) and draft
EPA 3560-3/Draft Letter
letter to permittee.
5.
Notification of complaints/incidents
Verbal
involving minor discharge and
non -discharge facilities prior to
conducting on -site investigations.
6.
Inspections of major/minor non -municipal
Service Request/Work Order
discharge and non -discharge facilities
Draft Letters
in response to complaints/incidents as
well as draft letter to permittee.
7.
Sampling data which indicates that
Verbal/Copy of Data
state water quality standards have
been exceeded.
8.
Notification of field investigations
Service Request/Work Order
in response to reported emergency
Draft Letter
situations, as well as any draft letters.
9.
Written correspondence with citizens
Copies of Letters
lodging complaints or reporting
incidents.
10.
Inspections in response to citizen
Service Request/Work Order
complaints regarding water quality
Draft Letter
violations as well as draft letters.
17
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11.
Inspections of well construction if
0
deficiencies are detected, as well as
draft letters.
12.
Problems or violations of environmental
O
laws or regulations which are detected
and are the responsibility of DEM.
lik
0
DEM To WCDH
Type Correspondence
1.
Copies of acknowledgement letters and
0
discharge permit applications for
non -discharge and discharge facilities
_
(major and minor non -municipal).
0
2.
Copies of transmittal letters and
discharge (major and minor non -
municipal) and non -discharge permits
0
within seven (7) days after issued.
3.
Copies of transmittal letters and
authorizations to construct within
O
seven (7) days after issued.
4.
Copies of transmittal letters and
approved plans and specifications for
O
discharge (major or minor non -municipal)
and non -discharge facilities within
seven (7) days following approval.
O
18
Ground Water Form 36
Draft Letter
Verbal and Otherwise
Form Used
Copies of Acknowledgement
Letters with Attachments
Copies of Transmittal
Letters with Attachments
Copies of Transmittal
Letters with Attachments
Copies of Transmittal
Letters with Attachments
0

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S.
NPDES self -monitoring data for all
To be specified by DEM
major and minor sources including
O
municipalities (quarterly).
6.
Referral of complaints/incidents for
Verbal/Copies of•Written
minor discharge and non -discharge
Complaints
O
facilities within two (2) working days.
7.
Copies of all written correspondence
Reports/Letters
to discharge and non -discharge permit
O
holders in Wake County.
8.
Referral of emergencies reported in
Verbal
Wake County.
O
9.
Referral of citizen complaints regarding
Verbal/Copies of Written
water quality concerns in Wake County.
Complaints
10.
Copies of all written correspondence -to
_-Reports/Letters - ---
O
violators of water quality regulations
as well as any other pertinent
correspondence relating to this work
O
plan or water quality in Wake County.
11.
NPDES inspections and draft letters to
EPA 3560-3/Draft Letters
municipal permittees.
O
12.
Meeting and training activities.
Varied
19
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Enforcement
O.
WCDH recognizes that DEM will retain exclusive authority and responsibility for
the assessment of administrative penalties or for instituting legal action for
O violations of state statutes and regulations. WCDH will be responsible for the
acquisition of the necessary evidence for the initiation of administrative or
legal action by DEM as outlined in td-Enforcement Manual by DEM. WCDH may
O contact RRO to discuss potential enforcement actions.
Coordination of Activities
C
1. WCDH will report to and coordinate through RRO concerning all problems or
violations of environmental laws or regulations which are detected and are the
O responsibility of DEM. RRO will notify WCDH concerning activities to be
undertaken in Wake County which relate to the activities outlined in this work
plan.
0 2. RRO will have the lead responsibility in setting up meetings, training, etc.
which it feels is essential to the success of this work plan. WCDH will ensure
its staff's attendance and support during such meetings and training
O opportunities. WCDH and RRO will hold meetings as necessary to fulfill the
objectives of this work plan.
20

A
AGREEMENT The undersigned does hereby agree to support the fulfillment of
this work plan which has been developed for the Memorandum of 0
Agreement entered into between the Wake County Board of Health
while exercising the powers of a board of health and the North
Carolina Division of Environmental Management on 0
TERMINATION This work plan will terminate on September 30, 1990 unless prior
arrangements are made between the signing parties.
EFFECTIVE DATE This agreement shall become effective on the date which the second 0
party executes the agreement, as shown below.
R. Paul Wilms, Director
North Carolina Division of
Environmental Management
Leah M. Devlin, D.D.S., M.P.N., Director
Wake County Department of Health
Date
Date
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Fj

O SERVICE REQUESI/WORK ORDER
:a:[ti•::::iYLfi.:F.1b:ICJLfHf�1TN
Emergency
Date Hour
Section Log No.
O REQUESTING PERSON:
Tel. No.
B-5
Address City Zip_
PROPERTY CONCERNED: Facility Name
O Address City Zip_
M
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9
SERVICE REQUESTED:
NOTIFICATION OF FINAL DISPOSITION 10 REQUESTING PERSON:'
/ WRITTEN VERBAL
Environmentalist's Signature Date.
REVIEWED BY: / RECALL DATE:
Section Head's Signature Date

7/7
::1aCi�::iYCfr:.F.11al.'TGfH!l+IIN
Appendix A
ENVIRONMENIAL HEALTH DIVISION
SECTION: WW Q SHW = WQ =
ACTIVITY REPORT
TYPE OF ACTIVITY
Field Report Consultation
Inspection Office Report
Phone Call Ed. Presentation Other
Page of
=_sas3aazaazaaa�z3a=asazaazazsaaza=3zss=:raz:=z==zaaaasn=zz=__a=z=ssazaaam=z==as=vx:a
Name (Facility/Indv.) ' Phone
Address City Zip
z=a..aaz=zaas3aaz=a=ss=as33n=saco3ass--_s._3-•-__--a3aza.asaaas=az=csaaosszsa=aaa:z339
REPORT
17
A
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0
0
o
• O
saazaaana3ssvzaazsaazza3zaaaa3s3�aazaa:_333z=ssersaazaazaaa==ss=aaazzaaacaaz=a3zaaaz
Environmentalist Date
Reviewed By Date O

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APPENDIX D
FISCAL YEAR 1988
WATER QUALITY WORK PLAN
for the period
October 1, 1988 through September 30, 1989
O _ Submitted To:
N.C. DEPARTMENT OF NATURAL RESOURCES
AND COMMUNITY DEVELOPMENT
DIVISION OF ENVIRONMENTAL MANAGEMENT
WATER QUALITY SECTION
O POST OFFICE BOX 27687
RALEIGH, NORTH CAROLINA 27611
O Submitted By:
MECKLENBURG COUNTY DEPARTMENT OF ENVIRONMENTAL PROTECTION
ENVIRONMENTAL MANAGEMENT DIVISION
WATER QUALITY SECTION
1200 BLYTHE BOULEVARD
CHARLOTTE, NORTH CAROLINA 28203
O
7

PURPOSE
The purpose of this work plan is to outline the specific
commitments and procedur.en `-.ich are to be followed by both the
Mecklenburg County Departme of Environmental Protection (MCDEP)
and the North Carolina Divis_:n of Environmental Management (DEM)
in order to more effectively protect and enhance the quality of
the water in Mecklenburg County through a mutually cooperative
effort on the part of both agencies. It is the intent of this
work plan to bring together the efforts of the water quality
programs for MCDEP and DEM and eliminate the duplication of
effort between the two agencies. It is not the intent of this
work plan to limit either DEM or MCDEP from acting under their
own pertinent authorities if either believes it is in the best
interest of the environment to do so. The development of this
work plan is a requirement which has been specified in the
Memorandum of Agreement (MOA) which was entered into between DEM
and the Mecklenburg County Board of County Commissioners on
August 27, 1986. ID
a'A 114OA- we-44
L� A 4�� cfocv-
MCDEP PROGRAM DESCRIPTION
The purpose of the MCDEP Water Quality Program is to maintain or
restore the chemical, physical and biological integrity of the
water of Mecklenburg County and to ensure compliance with local,
state, and federal water quality standards. Efforts to fulfill
this purpose primarily involve the assessment of water quality
through an established water quality monitoring program, and the
identification and elimination of sources of pollution through a
number of Program activities.
MCDEP is dedicated to providing an integrated and comprehensive
water quality program for the citizens of Mecklenburg County.
The Program receives policy guidance through the Mecklenburg
County Board of Cc,:,.-nissioners and Mecklenburg County
Environmental Protection Commission. The Program is currently
budgeted for nine (9) full time staff members, two (2) temporary
technicians and two (2) secretaries. The Water Quality Staff
receives support from the MCDEP Laboratory which i-s certified for
performing water quality analyses. Secretarial, financial and
budgetary support is provided -by the MCDEP Administration.
The allocation of Program resources and the development and
implementation of program activities and procedures as well as
the assessment of program effectiveness is primarily the
responsibility of the Supervisor of the Water Quality Program.
Staff members are responsible for fulfilling assigned program
activities in accordance with established guidelines and
procedures and fulfilling the obligations specified in this work
plan.

L
PROBLEM ASSESSMENT
O
Interpretation of 1987 water :uality monitoring data for.
Iecklenburg County, which ware-ollected by the MCDEP dater
Quality Proaram and analyzed b� the MCDEP Laboratory, reveals
that point and non -point sources of pollution are degrading the
quality of surface waters in the County along many stream
O segments. Monitoring data collected downstream of several major
and some minor NPDES sources reveals that water quality is being
negatively impacted by treated wastewater effluent. High
Biochemical Oxygen Demand (BOD) and low Dissolved Oxygen (DO)
measurements were obtained on numerous occasions below these
discharges. An occasional high fecal coliform count was
O observed. High BOD values and fecal coliform counts were also
detected below numerous sewer leaks and other point source
discharges. Monitoring data also reveals that non -point source
discharges from agricultural and urban areas are negatively
impacting stream segments in Mecklenburg County. Appendix A
0 contains the locations of lake and stream monitoring sites in
Mecklenburg County and results for monthly monitoring from
Januar;: through December of 1987.
Data compiled in the United States Geological Survey report on
"Water Quality Reconnaissance of Charlotte and Mecklenburg County
O Streams" as well as the interpretation of data from other sources
act to collaborate MCDEP findings as discussed above.
OBJECTIVES
r
National Pollution Discharge Elimination System (NPDES)
(For minor sources as defined in the MOA between the State of
N.C. and the U.S. Environmental Protection Agency Regarding
Delegation of NPDES Authority)
C�7
1. DEM will provide MCDEP with a copy of all permit
acknowledgement letters and applications for both major and
minor discharges. MCDEP may conduct on -site investigations
during the initial phase of the permit review process for
proposed discharge facilities. MCDEP may submit comments to
O MRO for inclusion in the permit file. C Gen YI PAO
1
2. DEM will provide ::CDEP with a copy of all disc arg permits
and authorizations to construct as well as approved plans
and specifications for all major and minor discharges.
O MCDEP may conduct on -site inspections during the
construction. of Discharge facilities and will make the
necessary -reports to MRO.
C

3. MCDEP will conduct Compliance Sampling Inspections (CSI),
Reconnaissance Inspections (1,I) or'Compliance Evaluation O
Inspections (CEI) at least: biann •lly at all minor permitted
wastewater treatment facilitieF °n Mecklenburg County.
MCDEP will sample, analyze and interpret NNPDES discharge and
ambient water quality parameters as it deems necessary.
Inspection reports and draft letters will be submitted
directly to MRO. O
4. MCDEP will sample, analyze and interpret lake, stream and
ground water parameters as it deems necessary.
5. DEM will provide MCDEP with self monitoring data from all
NPDES sources in Mecklenburg County on a quarterly basis. 4
6. MCDEP will respond to reported complaints and incidents
involving minor permitted discharges in Mecklenburg County.
Non -Discharge Wastewater Permitting
1. DEM will provide MCDEP with a copy of all permit
acknowledgement letters and applications for non -discharge
facilities. MCDEP may conduct on -site investigations during
the initial phase of the permit review process for proposed
non -discharge facilites. MCDEP may submit comments to MRO O
for inclusion in the permit file. C197
2. DEM will provide MCDEP with a copy of all permits as well as
approved plans and specifications for non -discharge
facilities. MCDEP may conduct on -site inspections during the
construction of all permitted facilities and will make the
necessary reports to MRO.
3. MCDEP will respond to reported complaints and incidents
involving non -discharge facilities in Mecklenburg County.
Emergency Response
MCDEP will respond to reported emergency situations which
involve potential contamination of surface and/or ground
waters of the State which lie within the geographical
boundaries of Mecklenburg County.
Citizen Complaints
MCDEP will respond to reported citizen complaints and
incidents involving water quality concerns in Mecklenburg
County.
O
Groundwater
MCDEP will respond to reported citizen complaints and
incidents involving possible groundwater contamination in
Mecklenburg County.
O
I

J
Rpports And Information
O
Both MCDEP and DEN, will submit in a mely and effective
manner the reports, data and other is --mation which are
necessarx, to ensure that the responsib-L-ities outlined in
this work plan are effectively fulfilled. MRO will review
and process MCDEP reports in a timely and effective manner.
Enforcement Vl1lw
a
MCDEP will act on behalf and t� h MRO concerning
g
matters covered by this work plan and will compile data and
information for enforcement of applicable regulations of the
p North Carolina Environmental Management Commission.
Coordination of Activities
MCDEP and MRO will maintain open lines of communication and
when necessary coordinate activities to ensure the
0 successful implementation of the MOA. MCDEP and MRO will
hold meetings as often as necessary but at a minimum of
quarterly in order to discuss work plan implementation and
program effectiveness.
O Laboratory Certification
MCDEP will maintain DEM laboratory certification for all the
parameters included in the minor NPDES permits issued in
Mecklenburg County.
PROGRAM IMPLEMENTATION STRATEGY
National Pollution Discharge Elimination System (NPDES)
Q (Minor Discharges as Previously Defined)
1. All written comments submitted to MRO by MCDEP concerning
the issuance of NPDES permits will contain factual
information regarding the nature of the proposed discharge
site and receiving waters as well as possible alternatives.
O Other factual information applicable to the issuance of the
permit may also be provided. MCDEP will submit written
comments to MRO within ten (10) working days following
receipt of a copy of the permit application by MCDEP. All
such information will be placed into the permit file by MRO
and provided to the Raleigh office for consideration during
O their permit review process.
A
4

2. Copies of discharge permits and authorizations to construct
as well as approved puns and specifications for major and
minor NPDES facilities in Mecklenburg C •nty will be
provided to MCDEP by Drat within seven (7. working days
following approvals. inspections of these, facilities by
MCDEP will be performed under the guidelines of the approved
plans and specifications as provided by DEM. MRO will be -
notified in writing concerning the inspections conducted and
all deficiencies detected. The Activity Report Form
(Appendix B) will be used as the standard reporting
mechanism. All written correspondence with the permit
holder will be performed by MRO. MCDEP will submit to MRO a
suggested draft letter for transmitting inspection results
to the permit holder. MCDEP will be copied on all
correspondence from MRO. MCDEP will conduct follow-up
investigations as requested by MRO.
3. All inspections of NPDES facilities will be performed by
MCDEP in accordance with the Environmental Protection Agency
(EPA) Compliance Inspection Manual, June 1984. The EPA Form
3560-3, NPDES Compliance Inspection Report, will serve as
the standard reporting form to MRO concerning these
_ inspections.
All written correspondence with the permit holder will be
performed by MRO. MCDEP will submit to MRO a suggested
draft letter for transmitting inspection results to the
permit holder. MCDEP will be copied on all correspondence
from MRO. MCDEP will conduct follow-up investigations as
requested by MRO.
4. MCDEP and MRO will attempt to coordinate monitoring
activities to prevent any duplication of efforts. MCDEP and
MRO will notify one another when monitoring data indicates a
violation of State water quality standards.
5. Self monitoring data provided by DEM will be reviewed by
MCDEP staff on a regular basis and prior to conducting a CSI
or CEI.
6. MCDEP will respond to reported complaints and incidents
involving minor NPDES discharge facilities in Mecklenburg
County within three (3) working days from when received at
MCDEP and every attempt will be made to respond on a same
day basis. All such reports which are received by MRO will
be referred to I4CDEP within two (2) working days. MCDEP
will conduct on -site inspections and collect samples when
necessary to identify problems and concerns. MCDEP will
issue verbal notification to MRO regarding the complaint
prior to conducting on -site investigations. IRO will also
be notified in writing concerning all inspections conducted
in response to reported complaints and incidents.

rX
The MCDEP ServicE� P.equest:/Work Order form (Appendix C) will
p be used as the standard reporting mechanism. The individual
making the complaint or reporting the inciden' will be
issued verbal notification by MCDEP regarding c_ • on -site
investigation. All written correspondence with -.ie permit
holder will be performed by MRO. MCDEP will submit to MRO a
suggested draft letter for transmitting inspection results
Q to the permit holder. MCDEP will be copied on all
correspondence. MCDEP will conduct follow-up investigations
as requested by MRO.
Non -Discharge Wastewater Permitting
p 1. All -written comments submitted to MRO by MCDEP concerning
the issuance of non -discharge permits will contain factual
information applicable to the permit application as well as
possible alternatives. Other factual information
applicable to the issuance of the permit may also be
provided. MCDEP will submit written comments to MRO within
O ten (10) working days following receipt of a copy of the
permit application by MCDEP. All such information will be
placed into the permit file by MRO and provided to the
Raleigh office for consideration during their permit review
process.
© 2. Copies of non -discharge permits as well as approved plans
and specifications will be provided to MCDEP by DEM within
seven (7) working days following approval. Reviews of these
facilities by MCDEP may consist of inspections of
non -discharge treatment systems as well as inspections of
O the on -site manholes and the "flashing" of sewer lines
within the collection system. The guides to be used for
conducting these inspections are the approved plans and
specifications as provided by DEM. MRO will be notified in
writing concerning those inspections which reveal a failure
to comply with approved plans and specifications. The
© Activity Report form (Appendix B) will serve as the standard
reporting mechanism. All written correspondence with the
permit holder will be performed by MRO. MCDEP will submit
to MRO a suggested draft letter for transmitting inspection
.results to the permit holder. MCDEP will be copied on all
correspondence. MCDEP will conduct follow-up investigations
O as requested by MRO.
3. MCDEP will respond to reported complaints and incidents
involving non -discharge facilities in Mecklenburg County
within at least three (3) working days from when received at
MCDEP and every attempt will be made to respond on a same
p day basis. All such reports which are received by MRO will
be referred to MCDEP within two (2) working days. MCDEP will
conduct on -site inspections and collect samples when
necessary to identify problems and concerns. MRO will be
issued written notification regarding these inspections.
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Th(- I"ICDEP Snrvice Reque::'.J1 ork Order form (Appendix. C) will
serve as the starda.-O reporting mechanism. The individual
making the complaint (-)r reporting the incident wi'' be
issued verbal notification by MCDEP regarding the (,. ,ite
investigation. All written correspondence with the p,:rmit
holder will be performed by MRO. MCDEP will submit to MRO a
suggested draft letter for transmitting inspection results -
to the permit holder. MCDEP will be 'copied on all
correspondence. MCDEP will conduct follow-up investigations
as requested by MRO.
Emergency Response
MCDEP will respond to all reported emergency situations in
Mecklenburg County within two (2) hours from when received
by MCDEP. " All emergency situations in Mecklenburg County
which are reported to MRO will be immediately referred to
MCDEP. With some emergencies which are reported by
citizens, MCDEP may determine that potential environmental
impacts are minimal or nonexistent. In these cases, MCDEP
will not respond to the incident or report to MRO but will
instead refer the reporting individual to MRO for
notification purposes. In all cases when MCDEP determines
that the environment is threatened by an emergency
situation, every effort will be made to conduct field
investigations immediately upon receipt of notification.
Information concerning the emergency situation will be
recorded by MCDEP on the Emergency Alert/Response Form
(Appendix D). The information will be relayed to MRO staff
by telephone immediately upon MCDEP having received
notification of the incident provided the report is received
during normal working hours. If the report is received
during non -working hours, the 24 hour emergency reporting
line will be contacted if deemed necessary by MCDEP. MRO
reserves the right to assume lead authority in emergency
response matters whenever it deems necessary. It is MCDEP's
intent to contact MRO from the scene of emergencies which
are judged by MCDEP to require involvement by 14RO personnel.
At the scene of the emergency, MCDEP will direct the
initiator of the spill to immediately notify MRO regarding
details of the situation. MCDEP will provide MRO with
written reports for all field investigations conducted in
response to emergencies. The Emergency Alert/Response Form
will serve as the standard reporting mechanism. All reports
will contain information concerning the type and quantity of
material(s) involved, initiator of the spill and location
where the spill occurred, time and cause of the incident,
surface water which may be impacted, as well as information
relating to the control of the situation and other pertinent
details. The individual reporting the incident will be
issued verbal notification by MCDEP regarding the field
investigation. All written correspondence to the initiator
of the incident will be performed by MRO. MCDEP will submit
to MRO a suggested draft letter. MCDEP will be copied on
all correspondence. MCDEP will conduct follow-up
investigations as requested by MRO.

C
Cit:i.zc-► Complaints
n
MCDEP will respcnd to citizen complaints regarding water
quality concerns in Mecklenburg County within three (3)
working days from when reported to MCDEP and every attempt
will be made to respond on a same day basis. All such
citizen complaints which are received by MRO will be
Q referred to MCDEP within two (2) working days. MCDEP will
conduct field investigations in response to citizen
complaints when it is deemed necessary in order to ensure
the protection of water quality. MCDEP will report to MRO
all field investigations conducted concerning situations
which impact water quality. The citizen lodging the
L� complaint will be issued verbal and/or written notification
by MCDEP regarding the field investigation. The MCDEP
Service Request/Work Order form (Appendix C) will serve as
the standard reporting mechanism. All written
correspondence to violators of State water quality
regulations will be performed by MRO. MCDEP will submit to
0 MRO a suggested draft letter of notification concerning
water quality violations. MCDEP will be copied on all
correspondence to violators by MRO. MCDEP will conduct
follow-up investigations to ensure the correction of
violations and/or water quality concerns.
0 Groundwater
MCDEP will respond to incidents regarding possible
groundwater contamination vithin Mecklenburg County within
three (3) working days from when reported to MCDEP and every
Q attempt will be made to respond on a same day basis. All
such incidents which are reported to MRO will be referred to
MCDEP within two (2) working days. MCDEP will conduct field
investigations in response to these reported incidents when
it is deemed necessary in order to protect water quality.
If a sample is taken in response to the incident, the first
Q four pages of the Pollution Incident Reporting Form (PIRF)
(Appendix E) will be completed and a copy will be sent to
MFO. Samples can be analyzed by:
❑c
a) The MCDEP lab following the same EPA Parameters that
are used by the State lab.
b) The State lab - MRO will pick up the samples from MCDEP
and send the.: to the lab.
When the analyses are completed, whomever receives the
results will send a copy to the respective agency. If the
0 sample is negative the PIRF is tabulated by MRO. If the
sample is positive MCDEP, MRO or both in a cooperative
effort will set up an investigation to determine the source
.of contamination. When the investigation is completed a
summary of the investigation will be written by the
O investigating agency and a copy will be sent to the
appropriate agency and the reporter of the incident.
W

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BIRO will rc:l,ic'w a11. data r,nc3 investigation summaries and
issue any notices of nonccimpliance.
If a sample is not taken an incident will be downgraded to a
technical assistance. All :information will be recorded on a
Service Request/Work Order Form (Appendix C). MRO will not
receive a copy of a technical assistance report. The
citizen reporting the incident will be issued verbal and/or
written notification by MCDEP regarding field
investigations.
Reports And Information.
Listed below is a summary of the written and verbal
correspondences to be exchanged between MRO and MCDEP.
MCDEP To MRO
Type Correspondence
1. Factual information regarding issuance of
discharge and non -discharge permits.
2. Inspections of discharge facilities
during constructicn as well as draft
letter to permittee.
3. Inspections of non -discharge facilities
during construction if deficiencies are
detected as well as draft letter to
permittee.
4. NPDES inspections (biannual) and draft
letters to permittee.
5. Notification of complaints/incidents
involving minor discharge and
non -discharge facilities prior to
conducting on -site investigations.
6. Inspections of minor discharge
and non -discharge facilities in
response to complaints/incidents as
well as draft letter to permittee.
7. Sampling data which indicates that State
Water Quality standards have been exceeded.
8. Notification of field investigations in
response to reported emergency situations,
as well as any draft letters.
9. Written correspondence with citizens
lodging complaints or reporting incidents.
Fnrm TTcari
L�LLei-
Activity Report
/Draft Letter
Activity Report
/Draft Letter
EPA 3560-3/
Draft Letter
Verbal
Serv. Request/
Work Order
Draft Letter
Verbal/Copy of
Data
Emergency
Alert/Response
Form/Draft
Letter
Copies of
Letters
❑!
1*1
•❑
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1.0.
Inspections in response to citizen •
Serv. Request/
complaints regarding water quality
Work Order/
violations as well as draft letters.
Draft Letter
11.
Notification of field investigations in
PIRF (first 4
response to groundwater incidents when
pages)
p
samples are collected.
12.
Problems or violations of environmental
Verbal and
laws or regulations which are detected
otherwise
and are the responsibility of DEM.
o
DEM TO MCDEP
Type Correspondence
Form Used
1.
Copies of acknowledgement letters and
Copies of
discharge permit applications for
Acknowledgement
o
non -discharge and discharge facilities
Letters with
(major and minor).
Attachments
2.
Copies of transmittal letters and
Copies of
discharge (major and minor) and non-
Transmittal
discharge permits within 7 days after
Letters with
issued.
Attachments
3.
Copies of transmittal letters and
Copies of
authorizations to cons':.r:sct within 7
Transmittal
days after issued.
Letters with
Attachments
4.
Copies of transmittal le`ters and approved
Copies of
plans and specifications for discharge
Transmittal
(major or minor) and non discharge facili-
Letters with
ties within 7 days following approval.
Attachments
5.
NPDES self monitoring data for major
To be specified
and minor sources (quarterly).
by DEM.
P
0
6. Referral of complaints/incidents for
minor discharge and non -discharge
facilities within 2 working days.
7. Copies of all written correspondence to
discharge and non -discharge permit
holders in Mecklenburg County.
B. Referral of emergencies reported in
Mecklenburg County.
9. Referral of citizen complaints regarding
water quality concerns in Mecklenburg Co.
Verbal/Copies
of Written
Complaints
Reports/Letters
Verbal
Verbal/Copies
of Written
Complaints
W
10

10. Reforral of groundwater. incidents•in Verbal/ Copies
Mecklenburg County within 2 working days. of Written
Complaints
11. Copies of all written correspondence to Reports/
violators of water quality regulations as Letters
well as any other pertinent correspondence
relating to this work plan or water quality
in Mecklenburg County.
12. Meeting and training activities. Varied
Enforcement
MCDEP recognizes that DEM will retain exclusive authority
responsibility for the assessment of administrative
penalties or for instituting legal action for violation of
State statutes and regulations. DEM will provide MCDEP with
a copy of DEM's enforcement procedures as well as all
current State Water Quality regulations and will provide
copies of any future changes. MCDEP will be responsible for
the acquisition of the necessary evidence for the initiation
of administrative or legal action by DEM in Mecklenburg Q
County as outlined in DEM's enforcement procedures. MCDEP
may contact MRO to discuss potential enforcement actions.
Coordination of Activities
MCDEP will report to and coordinate through MRO concerning O
all problems or violations of environmental laws or
regulations which are detected and are the responsibility of
DEM. MRO will notify MCDEP concerning activities to be
undertaken in Mecklenburg County which relate to the
activities outlined in this work plan. MRO will assume the
lead responsibility in setting up meetings, training and
etc. which it feels is essential to the success of this work
plan. MCDEP will ensure its staff's attendance and support
during such meetings and training opportunities.
Program Evaluation
MCDEP will submit to MRO a written report the first of each
month which will contain the number of activities performed
during the previous month toward the fulfillment of this
work plan including the number of reconnaissance and
compliance sampling inspections conducted, service requests
closed and overflowing sewers investigated as well as the
number of fish kills and oil/chemical spills reported to
MRO. During the month of July 1989, an evaluation of the
program as established under this work plan will be
conducted by DEM and MCDEP. This evaluation may consist of
file reviews and field evaluations of staff as well as a
review of -future training needs and resource commitments by
MCDEP. Following the evaluation, necessary modifications of
this work plan will be made for the next fiscal year's
activities provided that both DEM and MCDEP agree that the
MOA should continue.

❑N
Appendix A
Bacterioloriir-al Monitoring Sites
p Niecklf.nl,ura County Lakes
Mountain Island Lake
Q
MF3 - Hwy 16 boat launch
MF4 - Public beach off of Hwy 16
(Hubbies Bubble Up)
MF7 - Shuffletown boat launch and swimming area
MF12 - Latta Plantation Park
Lake Wylie
MF15 - Small Marina off Youngblood Road
MF26
- Red Fez Shrine Club
MF27
- IN-WTPs at Dockside Restaurant and Hideaways
MF28
- River Point I%IITP
MF29
- McDowell Park WI-TP
WF32
- McDowell Park Copperhead Access
WF33
- Long Cove Marina
WF34
- Terry's Marina, Harbor Estates WWTP
WF37
- Lake Wylie Marina, Buster Boyd Access
O
WF39
- Camp Thunderbird
WF40
- Moore's Landing and Marina
WF44
- Gaston Co. Wildlife Club
WF51
- Emerald Point IA TP
1IF67
- Belmont WWTP
O
1IF69
- Boat Launch at mill
WF70
- Boat Launch off Hwy 74
WF72
- Mt. Holly WWTP
WF72a
- Sandoz WWTP
Lake Norman
NF8 -
Vineyard Point Marina
NF9 -
Eastport Boat Club
NF10 -
Kingspoint Marina
NF11 -
Wher Rena Marina
NF15 -
Ramsey Creek Park Access
p
NF28
- Outrigger Harbor
NF70
- Harborgate Condominiums
NF40
- Holiday Harbor/Windward
NF51
- Marina
NF52
- Lake Norman Yacht Club
4
Total
Number Of Sites = 32
CO

101
Appendix A
General Water Qu::lity monitoring Sites
Mecklenl)u:,g County Lakes
Mountain Island Lake
Ca26 - Near Mountain Island Dam
Ca30 - Gar Creek Cove
Ca31 - McDowell Creek Cove, WTITP
Ca40 - Headwaters, below Cowans Ford Dam
Lake Wylie
CaO - Near Lake Wylie Dam
CalA - Allison Creek
Ca9.5 - South Fork of the Catawba
Ca15 - Paw Creek Cove
Ca22 - Dutchman's Creek
Ca24.5 - Headwaters at Mountain Island Dam
Lake Norman
Ca42 - Ramsey Creek Arm
Ca43 - Cowan's Ford Dam
Ca48 - Reed's Creek Arm
Ca49 - Main Channel
Total Number Of Sites = 14
E
a❑
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M
,Appcnclix A
MECKLENBURG
COUNTY STI-'.iAM MONITORING SAMPLE SITES
SITE
STREAM
LOCATION
JUSTIFICATION
MY
South"Prong
Hwy 73 Culvert: S. of
To define water
of West
Davidson & E. Rocky
quality in 1-1. Rocky
Rocky River
Road
River drainage.
0
MYlA*
W. Rocky
E. Rocky Ricer Rd. Culvert:
To define water
River
E. of Davidson & Hwy 73
quality in W. Rocky
River drainage
MY10*
Clarke
Harris Rd. Bridge: W. of
To define water
p
Creek
Poplar Tent Church Rd. in
quality in Clarke
Cabarrus County
Crk. drainage area
MYll**
Mallard
Morehead Rd. Bridge: S.
To define water
Creek
of Hwy 29 and Charlotte
quality in Mallard
Motor Speedway and N. of
Crk. drainage area
Q
Harrisburg in Cabarrus
County
MY11A*
Mallard
Above Mallard Creek WWTP
To define water
Creek
at the plant off of Hwy 29
quality in Mallard
Crk. above Ballard
6
Creek Wastewater
Treatment Plant
MY12*
Back
Caldwell Rd. culvert: S.
To define water
Creek
of Harrisburg and Hwy 29
quality in Back
4
in Cabarrus County
Creek drainage area
MY13*
Reedy
Reedy Creek Rd. Bridge:
To define water
Creek
S. of Plaza Rd. Ext. and
quality in Reedy
N. of Harrisburg Rd.
Crk. drainage area
intersections
MY7
McKee
Camp Stewart Rd. Bridge:
To define water
Creek
S. of intersection with
quality in McKee
with Harrisburg Rd. and
Crk. drainage area
and N. of intersection
with Rocky River Church Rd
O
MY8
Clear
Ferguson Rd. Bridge: S. of
To define water
Creek
Cabarrus Rd. and N. of Brief
quality in Clear
-Rd. intersection
Crk. drainage area
MY9
Goose
Stevens Mill Rd. Bridge:
To define water
(l
Creek
E. of Idlewild Rd. and
quality in Goose
W. of Lawyers Rd. inter-
Crk. drainage area
sections
❑c

0
MC2A-I*
McDowell
Gilead 2%6. Bridge: Ist
To define water
Creek
Bridge (a.`tcr. Culvert)
quality in N. Branch
d
after Ramon Rd. and
McDowell Crk.
and before. Oliver Hager
Farm Rd.
MC4A*
McDowell
Neck Rd. Bridge: W. of
To define water
Creek
of Beatties Ford Rd. and
quality in McDowell
O
Arthur Allen Dr. and
Crk. drainage area
before McDowell Creek
Treatment Plant
MC50*
Gar
Beatties Ford Rd. culvert:
To define water
Creek
S. of Sample Rd. and Latta
quality in Gar
a
Plantation Park and N. of
Crk. drainage area
McCoy Rd. intersections
MC7A
Long
Beatties Ford Rd. Bridge: S.
To define water
Creek
of Mt. Holly-Huntersville
quality in Upper
q
Rd. and N. of Miranda Rd.
Long Crk. drainage
intersections
area
M.C8A-1*
McIntyre
Miranda Rd. Bridge: W. of
To define water
Creek
Beatties Ford Rd. and E. of
quality in Upper
Sunset Rd. intersections
Long Creek drainage
a
area
?C13 Gum Branch Gum branch Rd. Bridge: W. of. To define water
Hwy 16 and E. of Cathy Rd. quality in Gum
intersections Branch drainage area
MC14 Long Creek Mt. Hollv Rd. (Hwy 27) To define water
Bridge: bridge before Catawba quality in Long
River between Mt. Holly- Creek area
Huntersville Rd. and Tom
Sadler Rd.
11-:C17 Paw Hwy. 74 Culvert: Culvert
Creek just past Sam Wilson Rd.
before Little Rock Rd.
intersection
MC22 Irwin
West Blvd. Bridge: Bridge
at I-77 overpass
To define water
quality in Paw Creek
drainage area.
To define water
quality in upper
Irwin Crk. drainage
and above Irwin
Creek Treatment
Plant
MC23 Sugar Hwy. 49 Bridge: 1st Bridge To define water
Creek S. of Billy Graham Parkway quality in Sugar
and Woodlawn Rd. Creek below Irwin
intersection Crk. treatment plant
NJ
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MC25 Co;fey Ih•:y.49-Cu1.vert: S. of To define water
Creak Arrowood. Rd. and N. of.Sandy quality in Coffee
Porter Pd. intersections Creek drainage area
MC2G Sugar Nations Ford Rd. Bridge: S. To define water
Creek' of Arrowood Rd and N. of quality in Irwin -
Downs Rd. intersections Coffey -Sugar Crk.
drainage area above
influence of King's
Branch
MC26A Kings Arrowood Rd. Culvert: E. of To define water
Branch Nations Ford Rd. and W. of quality in Kings
Old Pineville Rd. and South Branch drainage area
Blvd. (Hwy 521)
MC27
Sugar
Hwy. 51 Bridge: E. of Downs
To define water
Creek
Circle and W. of Pineville,
quality in Big Sugar
N.C.
-Irwin Crk. drainage
basin before S.C.
MC29
Little
Park Rd. Bridges: N. of
To define water
Sugar
Selwyn Next to the Giant
quality in Little
Creek
Genie Shopping Center
Sugar. Crk. above
Sugar Creek
Treatment Plant
MC29A
Little
49 Culvert. Culvert located
To define water
Sugar
behind the Park-N-Shop at
quality in upper
Creek
Tryon Mall
Li.ttle.Sugar Crk.
drainage area
0 MC30B
Briar
Central Avenue Bridge:
To define water
Creek
between St. George St.
quality in upper
and Arnold Dr.
Briar Crk. drainage
area
0 MC31
Briar
Park Rd. Bridge: Bridge
To define water
Creek
N. of Tyvola Rd. and S. of
quality in Briar
Selwyn Rd. intersection
Crk. above influence
near Hagaman's Animal
with Little Sugar
Hospital
Creek
p MC32
Little
Sharon Rd. West Bridge:
To define water
Sugar
E. of South Blvd. and
quality in Little
Creek
W. of Park Rd.
Sugar Crk. below
Sugar Creek
Treatment Plant
4 MC35
Campbell
Margaret Wallace Rd.
To define water
Creek
Bridge: 1st Bridge
quality in Campbell
N. of Hwy 74
Crk. drainage area
above McAlpine
Greenway
�01

n
-MC36
Irvi_ii,
Sam Newell Rd. Culvert:
To define water
Creek
W. of Sam Newell Rd. and
quality in Irvins
Hwv 74 Intersection
Crk, above MCAlnirie
Greenway
:•IC367v*
Irvins
Sera Newell Rd. Bridge:
To define water
Creek
S. of Margaret Wallace
quality in Irvins
and Sam Newell Road
Crk. above McAlpine
Intersection
Greenway
►•IC38
McAlpine
Sardis Rd. Bridge: Between
To define water
D
Creek
Sardis Lane and Sardis Rd.
quality in McAlpine
North Intersections
Crk. below McAlpine
Greenway
MC39
McAlpine
Hwy. 51 Bridge: Between
To define water
Creek
Carmel Rd. and Elm'Lane
quality in McAlpine
O
Intersections
Crk. above influence
of Four Mile Crk.
MC40A*
Four Mile
Elm Lane West Bridge: S.
To define water
Creek
of Hwy 51 and N. of
quality in Four Mile
Providence Rd. West
Crk. drainage area
MC42B
McMullen
Randolph Rd. Culvert:
To define water
Creek
Between Sharon Amity
quality on upper
Rd. and Sardis Rd.
McMullen Crk.
drainage area
d
tC43
McMullen
Johnston Rd. Bridge:
To define water
Creek
N. of Hwy 51 and S. of
quality in McMullen
Park Rd. Ext.
Crk. above influence
of McAlpine Crk.
O
MC45A*
McAlpine
Hwy 521 Bridge: 2nd
To define water
Creek
Bridge S. of Pineville
quality in McAlpine
and Hwy 51
Crk. below McAlpine
Treatment Plant and
before S.C. •
o
MC47
Steele
Choate Circle Bridge: E.
To define water
Creek
of Moss Rd. and W. of
quality in Steele
Carowinds Blvd.
Crk. drainage area
MC49A*
Little
Hwy. 521 Bridge: 1st
To define water
Sugar
Bridge S. of Pineville
quality in Little
a
Creek
and Hwy 51 and N. of
Sugar Crk. drainage
Dorman Rd.
basin before S.C.
MC51* Six Mile Marvin Rd. Bridge: S. of
Creek Wade Ardery Rd. and N. of
Joe Kerr Rd. on Union
County Line
Total Number Of Sites = 41
* New Sites - 1985
** New Sites - 1988
To define water
quality in Six Mile
Crk. below Parks p
Farm Treatment Plant
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07/09/87
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07/09/87
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07/09/87
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07/09/87
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07/09/87
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07/09/87
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07/09/87
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F.:4GF 5

LAKE: U; ACTLRIA 1907
PAGE 11
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07/10/87
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07/10/87
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07/10/87
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07/10/87
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07/10/87
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07/10/87
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07/10/87
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07/10/97
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07/10/87
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07/10/87
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07/10/67
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07/10/97
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07/10/87
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07/13/87
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07/13/87
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07/13/87
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07/13/87
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07/13/87
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07/13/87
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07/13/87
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07/13/97
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07/13/97
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07/13/37
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07/13/87
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07/14/87
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07/14/87
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07/14/87
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07/14/87
220
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07/14/87
320
0

LAKE BACTERIA 1907
PAGE I
FECAL FEq?L
51 T E
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071 / 87
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07/14/87
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07/21/87
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LAKE BACTERIA 1987
PAGF. F3
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DATE
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No . / 1 OOm 1 No. i
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07/21/F;.
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/87
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07/21/67
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/67
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/22/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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07/28/87
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LAKE DACTER I A 1.997 PAGE 11
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COL IFORM
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08/26/67
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00/26/87
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08/26/87
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08/26/87
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08/26/87
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08/26/87
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08/26/87
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08/26/87
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08/31/87
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08/31/87
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E E E E E E E

_
ENVIRONMENTAL I1nNi,GI:h1I:v.T DIVISION Page of
ST:CTI()N: i,q ��� slily
••.; �set+j , ' ACTIVITY REPORT
1'YF11: OF' ACTIVITY
Field Report �!� Con-ultation
—� Inspection Office Report
_i Phone Call i—i Ed. Presentation Other i O
Dame (Facility/Indv.): Phone:
Address: City: Zip: O
Description Activity
'T"TTT-TTi
REPORT fl
❑c
Environmentalist: Date:

SERVICE REQUESTMO•RK ORDER
Emergency? Y N
Date: Hour:
Section: .g No.:
REQUESTING PERSON: Tel. No.
8-5
Address City Zip
PROPERTY CONCERNED: Facility Name
Address City Zip
SERVICE REQUESTED:
ASSIGNED TO: TAKEN BY:
DATE I ACTIVITY REPORT
NOTIFICATION OF FINAL DISPOSITION TO REQUESTING PERSON:
WRITTEN VERBAL
Environmentalist's Signature Datr
REVIEWED BY: __— _. —_— _ __._-1 --- RECALL DATE:

A
f71:CKLENDURG COUNTY DEPATITMI:TIT OF I:NVIRONPIFNTAL PROTECTION
B'MIiRGI:'NCY ALERT/RESPONSH FORM
DATE REPORTED TIt•1I. REPORTED SECTION LOG NO.
REPORTED BY TELEPHONE NO.
ADDRESS CITY _ ZIP
PROPERTY CONCERNED: FACILITY DAME
ADDRESS CITY _ 'LIP
SERVICE REQUESTED
......................
ASSIGNED TO TAKEN BY
ALERT O
TYPE DATE / / TIME
--------------
REG NOTIF BY REC BY DATE / / TIME
MATERIAL SPILLED
(1)-------------------------- QTY/UNIT __ H/S _ R/Q _ 0
--------- ------ -
(2)---------------------------- QTY/UNIT __ H/S _ R/Q _
------- ------ -
LOCATION
NEAREST CITY -----------------------COUNTY !•IECKLENBURG R
EGION 03
SPILLER TELEPHONE
--------------------------------------------- --- --- ----
STREET CITY STATE NC ZIP
RESPONSIBLE -PARTY (REFER TO COMMENTS FOR ADDRESS
NATURE OF SPILL CAUSE
-------------- -----------------------
SOURCE________________________(DESCRIBE IN COMMENTS)
CONTAMINATION::N,-7SPECIFY CLASS GW _ CLASS
SOIL AQ _ OTHER ----------
FISH KILL/ESTIMATED It
-
CONTAINMENT (Y/N) _ METHOD _____________________________________________
CLEANUP (Y/N) _ METHOD -------------------------------------------- 0
BY WHOM
---------------------------------------------
DISPOSAL METHOD BY WHOM __
------------------ ----------------- -----------
SITE ------- CONFIRMED (Y/N)
------------------------------------------------
RESPONSE
RESPONSE (Y/N) _ TYPE (I=INVESTIGATE, T=TELEPHONE) _ NOV SENT (Y/N) _
BY WHOM ______ DATE / / TIME
------------------------ - -- --
INCIDENT CLASSIFICATION (MIN=I•IINOR, !•'-OD=MODERATE, MAJ=MAJOR) ---
STATUS --CLOSED DATE / / E/A PENDING DATE / f
OTHER _ DATE
-------------------
INVESTIGATION COSTS MANHOURS n $ .00 LAB COSTS $ .00
MILEAGE COSTS COUNTY $ .00 PRIVATE $ .00 OTHER $ .00
TOTAL COST OF EMERGENCY INVESTIGATION $ .00
OTHER AGENCIES INVOLVED
------------------------------------------------------
NARRATIVE COMMENTS
----------------------------------------------------------------------------a
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
------------------------------------------------------------------------------
----------------------------------------------------------------------------c
------------------------------------------------------------------------------
------------------------------------------------------
:------------------------
NOTIFICATION OF FINAL DISPOSITION TO REPORTING PERSON
/ WRITTEN _ VERBAL _
ENVIRONMENTALIST'S SIGNATUR DATE
REVIEIti'ED BY: / RECALL DATE:
SECTION HEAD'S SIGNATUREDATE

f'J I , VL, v , ,V,. ,..v..+�.• , „�, vl, , „V�7 t �Jlllvt
InCu1�,nl �
Cvunty: POLLUTANTS INVOLVED
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Al
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1.1ATr -1 1. .:
IMPACT ON SURFACE WATERS
At.1JU'1T t71',;UVf'tii [1
Distance to Stream (ft)
Amount in :'Dater (gal)
:'JATERS �--:.CTED 1. Ycs 2. 'lo ::o 3.F:tonUally
F
'lame -I-,tream
Stream Class
1`I ;H KILL: 1. YE No
RISK ASSESSMENT
Use these __�_Qs: High= 3 :coeraie=2 Low_1 None=0
Resource --reat r,��'�'.5::AT_R Amount Infiltrating Land
Vertical ;raUs _ ...:a-ninart
Horizontal
real _. ,c-: SURFASE :7ATER AIR
G • ztenfial S.-c--'a^ce
Serioucre.s
overall=e;:tcnal orcern
iclease Ci._:e t':e A:;Drcoriate Fesconse(s):
j 1. This it:,;o^t Dose: acditior•al treat to ht;-• an health by:(1) inhalation (2) absorption (3) ingestion
j
_. . his 1!-,real to t`•e er it:^ment by colential adverse effects on :
1 (11 se's,ti•:e areas (2) wil�llife ` J f:sh
POTENTIAL SOURCE OF POLLUTION
SOURCE C- P OTE'1'IAL POLLU?I-'l
TYPE OF POLLUTANT
LOCATION
SETTING
I
1. Interticra! c:,m) ?. Sewer line
1. Pesticide/herbicide
1. Facility
1. Residential
2. Pit, ponc, lagoon t0. Stcc%cile
2. Radioactive waste
2. Railroad
2. Industrial
3. Leak--u-.-ergroun-. 11. LanVill
3. Gasoline/diesel
3. Waterway
3. Urban
4. Spray irritation 12. Spill --surface
s, Other petroleum prod.
4. Pipeline
4. Rural
H I 5. Land aG:,lication 13. V.'eI1
:. Sewage/septage
S. Dumpsite
6. Animal feedlot 14. Dre:ge Spoil
6, Fertilizers
6. Highway
7. Source unknown. 1S.NonD:int source
7. Sludge
7. Residence
8. Septic tank
a. Solid waste leachate
5. Metals
8. Other
MULTIPLE SOURCES AT SITE:
POLLUTION CONFIRMED
1. Yes 2. No
i0.Othor inorganics
1. Yes 2. No
II.Other organics

V%,)LLU I IUIN 1114%a1UL1V 1 r/Lrkar1 111V1a rUr1M Q
Incident +
County:
RESPON31BLE PARTY
Responsible curly/'James Telophune
Company Street Address
City
County
State
ZIP Code
REASON FOB INCIDENT
SOURCE 1?1 USE
O. N/A
PCRMIT TYPE
OWNERSHIP
OPERATION TYPE
1. Transportation Accident
1. Yes
2. tJ0
0. N/A
0. PJ/A
0. N/A
1
2. Mechanical failure
SOURCE PEa1.11TTEC
t. Nondischarge
t. t.luniclpal
1. Public Service
3. Facility dF:ign
1. Yes
2. No
2. Oil terminal
2. Military
2. Agricultural
PERMIT NUMBER
4, Inventory only
3. Landfill
3. Unknown
3. Other Source
5. Human error
SOURCE ON
4. Mining
4. Private
4. Educational
6. vandalism
ERRIS LIST
1, Yes
5. NPCES
5. Federal
S. Industrial
7, Unknown
7, f:n
G. RCRA
6. County
G. Commercial
=RnIS NUMBER
7. Air
7. State
7. Mining
J
t,o^tair,nen% ICCnU:. SIG.
earesi Populated
ACTIONS TAKEN
ngs--Type and Distance
W
101
M
X
0
Eel
Precipition/yleather Date
U

C
x
rm
x
u
J
X
Al
n
POLLUTION INCIDENT REPORTING FORM
Counly —_
LOCATION OF INCIDENT
Strt•ut Addrw- ,, Noad City/Town GGunty
Datu Incrrlunt (-jccurred Time Incident Occurred 7 1/2 Ou. 'lame Lat. : Deg: Min: Sac:
Long, . Deg: Min: Sec:
Draw Sketch of Area
ATTACH PHOTOCOPY OF MAP SHOWING: t. Pollutant Source 2. Threatened Water SuDplles
0 3. Direction of Overland Flow

J
• {tip, ) r ` � . f
{ y�j i •� q� y 1
i
O O O O O O Q A O O
I

O APPENDIX E
A PROPOSAL TO ESTABLISH AN OPERATION AND MAINTENANCE PROGRAM
FOR SEWAGE TREATMENT AND DISPOSAL SYSTEMS IN ORANGE COUNTY
O
O SUBMITTED TO:
The Orange County Board of Health
Ruth Royster, Chair
O
O SUBMITTED BY:
Environmental Health Division
Orange County Health Department
Dan Reimer, MPH, Director

TABLE OF CONTENTS
Ion
.DEVELOPMENT OF THE PROGRAM .
. . .
.
.
.
.
.
. .
.
.
.
Page
1
DEFINITIONS . . . . . . .
.
. . .
.
.
.
.
.
. .
.
.
.
Page
2
O
EXISTING PROBLEMS . . . .
.
. . .
.
.
.
.
.
. .
.
.
.
Page
4
STATEMENT OF PURPOSE. . .
.
.
Page
6
MAJOR PROGRAM COMPONENTS
O
I - CLASSES OF SYSTEMS .
.
. . .
.
.
.
.
.
. .
.
.
.
Page
7
II - TYPES OF SERVICES.
.
. . .
.
.
.
.
.
.
Page
8
III - TABLE OF PROGRAM
SERVICES
.
.
.
.
....
Page
10
O
IV - RESPONSIBILITIES
1
Page
11
V - SCOPE
._
Page
12
PROPOSED FUNDING MECHANISMS
. . .
.
.
.
.
.
. .
.
.
.
Page
13
O
IMPLEMENTATION SCHEDULE .
.
. . .
.
.
.
.
.
. .
.
.
.
Page
14
CONCLUSION . . . . . . . .
.
. . .
.
.
.
.
...
.
.
.
.
Page
15
t*l
O

x
DEVELOPMENT OF THE O&M PROGRAM
O
The events (not in order) and conditions needed to prepare
for the start-up of the O&M program.
1) The current Orange County regulations governing
sewage treatment and disposal systems will be amended
O and rewritten as necessary to accommodate the broader
scope of the program.
2) A memorandum of agreement will be arranged with the
Division' of Environmental Management which will
designate authority to the Orange County Board of
O Health to monitor discharge systems.
3) The Orange County Board of Health must apply for and
receive jurisdiction from the Division of
Environmental Management to permit, evaluate,
monitor, and regulate systems currently under their
O jurisdiction which do not discharge to the surface
waters.
4) The county attorney must review the program to assess
possible legalities, liabilities, and ramifications
O of the program.
5) The costs of the program must be determined and a
definite funding mechanism established. An outside
consultant may be necessary for this step.
O 6) Provisions must be made to have the necessary lab
work done.
7) The mechanism of arranging for pumping systems must
be determined.
O 8) The board of health must give final approval on all
aspects of the program.
9) The county manager and county commissioners should
review and approve the program and the budget for the
necessary staffing and equipment procurement for the
O program.
10) The program should go through public notice.
1
9

DEFINITIONS
Effluent - The liquid discharge of a septic tank or other
sewage treatment device.
Inspection - An evaluation of all components of any given
sewage treatment and disposal system to determine
performance and compliance of the system with applicable
rules and regulations.
Maintenance Agreement - An agreement between the Orange
County Health Department and the system owner addressing the
responsibility and schedule of maintenance of the sewage
disposal system. The responsibilities may include solids
removal, grease removal, electrical component checks, or any
other items considered critical to the operation of the
system.
Repair - Any work done to a sewage disposal system other than
routine maintenance or pumping.
Sewage Treatment and Disposal System - A complete sanitary
system of sewage collection, treatment, 'and disposal. The
following classes comprise systems currently permitted in
Orange County and do not include any experimental systems.
Ground Absorption System - These systems consist of
primary treatment (usually a septic tank) with a
subsurface disposal field for the septic effluent. They -
rely on the soil to treat and dispose of the effluent.
They may be modified with pump chambers, other
appurtenances, -or further treatment of the effluent
before disposal. Conventional, pump conventional, low
pressure pipe, and mound systems comprisethemajority
of systems in this category. These systems do not
usually require an engineer's design.
Non -Discharge systems - These systems are similar to
ground absorption 'in the primary treatment of the
sewage. After the primary treatment, the effluent is
treated at least once more before being disinfected.
The effluent is. then distributed to the surface of the
ground by mechanical means. Spray irrigation systems
are the principal systems in this category in Orange
County. These systems require an engineer's design.
Discharge systems - These systems are designed to treat
wastewater in a variety of manners. The treated
wastewater is disinfected and discharged to a flowing
stream for disposal. The main systems in this category
are package treatment plants and subsurface sand filter.
2

Septage - A fluid mixture of partially treated sewage
solids, liquids, and sludge of human or domestic waste origin
O pumped from septic tanks or grease traps, privies.
Sludge - Any solid or semi -solid waste generated from a
wastewater treatment plant or a water supply treatment plant.
Upkeep Agreement - An agreement similar to the maintenance
O agreement that addresses the upkeep of the system and
vegetative cover for the disposal field area. This agreement
would also address the accessibility of the system components
for inspection.
3
O

EXISTING PROBLEM
In 1981 a survey of on -site septic systems was conducted in
Orange County as part of a statewide septage study. The
survey revealed that 10-11% of the ground absorption systems
were failing at the time and that 65% of tanks in the county
have never been pumped. In order for a system to function as
designed, the septage must be removed from the septic tank
periodically. Pumping the tank at least every five years as
a matter of maintenance accomplishes this goal. By the time
a system exhibits problems, (which is when the homeowner will
usually first have the tank pumped,) it is too late for the
system to recover fully. Thus what is actually a routine
maintenance procedure is often being used as an ineffectual
repair or as crisis maintenance.
With the rising number -of septic systems relying on pumps,
mechanical and electrical controls, and small diameter pipes,
it is becoming imperative that a homeowner be educated about
what is treating and disposing of his sewage. Through the
state mandated reinspection program of low pressure pipe
systems, the staff has found that homeowners are unaware of
nearly every aspect of their septic systems. As a result the
system is not properly maintained or operated. In many cases
the homeowners are disconnecting alarms, covering access
turn -ups, valves, electrical controls, and tank manholes
necessary -for proper functioning. Drainfields and designated
repair areas have not been properly maintained or preserved.
They are regularly destroyed and replaced by swimming pools,
outbuildings, etc.
Package treatment plants, spray irrigation systems and sand
filter systems, while .not experimental, are systems that
require close monitoring and supervision both during
installation and while in operation. These types of systems
are typically used where soil and site conditions prohibit
the use of ground absorption systems and where sewer
connections or extensions are not available. They are used
mainly for cluster housing, mobile home parks, subdivisions,
businesses, and industry. The Division of Environmental
Management (DEM) currently -approves and permits these
systems, however actual site visits and monitoring by the'DEM
staff are severely limited due to staffing levels and limited
resources. This results in systems which are improperly
installed and systems which. fail for long periods of time
without corrective action. Consequently, surface waters and
the environment receive untreated or insufficiently treated
sewage.
Likewise, large ground absorption and engineered systems lack
local oversight upon installation and during operation.
The Division of Health Services (DHS) or DEM are currently
responsible for approval of plans, installation inspections,

0
and monitoring. Due to limited resources and inspections,
Q these systems are seldom in full compliance and there is
little or none of the required monitoring done. The
consequence.of a large system failure is an obvious risk to
public health and the environment in the form of ground water
pollution and sewage discharge to the ground surface or to
the surface waters.
�7
�o�

STATEMENT OF PURPOSE
The ultimate goal of the proposed operation and maintenance
(O&M) program is the protection of ground and surface waters
in Orange County and in surrounding areas of which Orange
County is an integral part of the drainage basin. The
program will also ensure that all sewage treatment and
disposal systems included in the program will be operated in
a safe and approvable manner so as not to be hazardous or
unhealthy to the user or to the general public.
All sewage treatment and disposal systems included in the
program will be inspected and/or monitored on a regular basis
to assure proper operation and maintenance of the systems. O
Currently, the Orange County Health Department is
reinspecting low pressure pipe sewage disposal systems in a
program mandated by the North Carolina Division of Health
Services. These inspections along with field experience with
other types of systems have shown a definite need for an
ongoing program of system maintenance. The proposed program O
will require existing regulations to be expanded to legalize
procedures and will also require a memorandum of agreement to
be developed with the Division of Environmental Management to
monitor certain systems. To enhance the inspection of
systems, the staff is -also proposing to conduct effluent Q
sampling, stream sampling, and oversight of sludge disposal
sites for certain classes of systems.
The staff realizes that a major part of a program such as
this will be to educate the users and the public about sewage
treatment and disposal. Technical assistance and educational
literature will be available for all participants in the
program or others who are interested in the program. All new
permitees will be given an initial packet of information
concerning the program and their system. Such measures
should greatly increase user awareness in the operation and
maintenance of their systems.
If the program is implemented, all the citizens of Orange
County should realize benefits from the program. Benefits
will include cleaner ground water, cleaner surface water,
reduced water borne disease transmission, and extended sewage
disposal system life.
A

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MAJOR PROGRAM COMPONENTS
I - CLASSES OF SYSTEMS - The following classes of sewage
treatment' and disposal. systems are the major classes to
be considered in the proposed operation and maintenance
for Orange County.
CLASS I - All on -site, ground absorption, sewage
disposal systems serving a single residence with 600
gallons per day or less design sewage flow. This class
includes conventional, pump conventional, and low
pressure pipe systems serving single family dwellings
with five bedrooms or less which do not require
engineered design.
CLASS II - All other ground absorption systems with 3000
gallons per day or less design sewage flow. This class
O includes large residential systems, businesses. with
ground absorption systems, cluster ground absorption
systems, and engineered ground absorption systems with
3000 GPD or less design flow.
CLASS III - All other single family dwelling systems.
0 This class includes individual sand filters and spray
irrigation systems.
CLASS IV - All other ground absorption and non -discharge
systems. This class includes ground absorption systems
greater than 3000 GPD design and any non -discharge
0 system serving more than a single residence.
CLASS V - Any discharge system -serving more than a
single residence. This class includes community package
plants and sand filters.
CLASS VI - Sludge disposal sites. This class includes
any site in the county being used for sludge disposal
regardless of the origin of the sludge.
1*1
0
7
O •

n
II - TYPES OF SERVICES - The following are descriptions of
the services to be provided in the O&M program.
COMPLAINT INVESTIGATION - Complaints of any nature
concerning sewage disposal will be investigated and
proper corrective action will be taken if warranted.
EDUCATION AND TECHNICAL ASSISTANCE - These services will
be a critical aspect of the program. Educational and 4
informational literature is already being developed by
the staff to inform system owners on what they can do to
enhance the performance of their systems. Technical
assistance will be available from the Orange County
Health Department, the North Carolina Division of Health 0
Services, and the North Carolina Division of
Environmental Management.
EFFLUENT SAMPLING - These samples will be taken on non -
discharge and discharge systems at a point after all
treatment is complete. The primary purpose of these
samples is to determine if the treatment is effective.
ENFORCEMENT ACTIONS - These actions will be initiated on
ground absorption -and non -discharge systems by the
Orange County Health Department. Any problems found
during inspections and monitoring of discharge systems Q
will be referred to the Division of Environmental
Management for enforcement.
INSPECTIONS - Inspections of.varying frequencies will be
conducted on all systems that are in the O&M program.
The frequency of inspection will depend on the size and
class of the system. During inspections, all components
of treatment and. disposal will, be evaluated for
performance and effectiveness.
INSTALLATION INSPECTIONS - These inspections will be
conducted on all ground absorption and non -discharge
systems that are installed in Orange County. These
inspections are already required for systems that are
permitted by the Orange County Health Department.
MONITOR WELL SAMPLING - These samples will be collected
from monitor wells that are required for sludge disposal
sites or for large on-site.systems.
PLAN REVIEW - All engineered plans or plans developed by
consultants for ground absorption and non -discharge
systems will be reviewed by the Orange County Health
Department and approval will be recommended only when
the plans meets all standards and specifications of the
appropriate regulations. Plans may also need to go to
another agency for review and approval.

x
PUMPING - The service of septic tank pumping will be
provided by the Orange County Health Department for all
Class I and Class II systems that are in the O&M
program. This service will be contracted to the private
sector and provided at a minimum of every five years or
as needed to provide proper septic tank operation. The
remaining classes of systems which utilize septic tanks
Q will be required to have a regular scheduled pumping of
their tanks by an approved pumper.
STREAM SAMPLING - Streams will be sampled routinely for
Class V systems to monitor the effectiveness of the
treatment and disposal of the systems. The stream
O quality will be analyzed both upstream and downstream of
the discharge point. Streams may also be sampled on
other types of systems if there is a suspicion of stream
degradation resulting from the malfunction of.a system.
E
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III - TABLE OF PROGRAM STRUCTURE
O
CLASS
I
II
III
IV
V
VI
O
TYPE OF
DISPOSAL
GA
GA
ND/D
GA/ND
D
/
FLOW/USE
SFD
NON SFD
SFD
NON SFD
NON SFD
/
Q
(GPD)
<600
600-3000
>3000
>600
ENGINEER
ENGINEER
INSPECTION
1/YR
2/YR
4/YR
4/YR*
4/YR*
4/YR
FREQUENCY
O
SEPTAGE
OCHD
OWNER
OCHD
OWNER
OWNER
/
RESPONS.
Q
SAMPLING
/
/
EFFLNT
EFFLNT
EFFLNT
EFFLNT
(4/YR)
STREAM
STREAM
STREAM
MNTWELL
MNTWELL
CURRENT
OCHD
OCHD
DEM
DEM/DHS
DEM#
DEM#
O
JURISDICTION
�0:
GA - Ground absorption systems
ND - Nondischarge systems
D - Discharge systems 4
GPD - Gallons of waste flow -per day
SFD - Single family dwelling
*-Phased into 12/year in 1992
#-Permitting and enforcement will remain with DEM
EFFLNT - Effluent
MNTWELL - Monitor well
10 0

X
IV - RESPONSIBILITIES - Responsibilities are categorized into
two separate areas, the system owner's and the health
department's.
SYSTEM OWNER - The system owners would be responsible
for all of the following:
1) Pay fees ( if fess are the funding mechanism) as
set by the Orange County Boards of Health and
Commissioners
2) Install a water meter if they are not on a public
or private water supply with individual meters.
3) Preserve and maintain their initial system area
and their repair area _according to health
D department standards.
4) Keep their water use within the design flow of the
operations permit for that system.
5) Allow reasonable access to their property for
inspections, -monitoring, and pumping activity by
the health department.
6) Report any known malfunction of a system
Q immediately to the health department staff.
7) Repair any malfunctioning system br system not in
compliance according to the. direction of the
Orange County Health Department or the Division of
Environmental Management.
8) Pump tank according to maintenance agreement (only
for classes .II and IV)
9) Keep accurate inspection and operation reports and
records and submit these documents periodically to
the permitting agency.
O ORANGE COUNTY HEALTH DEPARTMENT - The health department
would be responsible for all of the following:
1) Inspect each system in the program periodically as
prescribed in the levels of service document.
n
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Inspection frequencies range from one to four
times a year.
2) Provide directions to the system owners for
repairs to malfunctioning systems and systems not
in compliance if the system is reparable in
accordance with rules set forth by the Orange
County Board of Health, the North Carolina
Division of Health Services, or the Division of
Environmental Management.
3) Provide education and technical assistance to all
system owners.
4) Pump each septic tank in classes I and III under
the program as needed or at a minimum of every
five years.
5) Provide the Division of Environmental Management
with inspection data collected by the health
department for remediation or enforcement.
11

V - SCOPE - The following systems would be included in the
O&M program initially. All systems would be included in
the program eventually, but this is a long range goal.
1) Any new class I, II, III, or IV system installed
after the effective date of the program.
2) Any existing class I, II, III, or IV system
repaired after the effective date.
3) Any system reinspected for performance. This
includes systems reinspected according to state
mandate and any system the staff is requested to
reinspect.
4) At a system owner's request, any system installed
prior to the effective date.
5) Existing systems would be surveyed as resources
allow. Priority would be given to systems in
areas where high failure rates or ages of the
system are of concern. Any system found to be
failing would be included in the program. Owners
of properly functioning systems would 'be provided
-with educational and technical assistance to
improve system performance and would be.given the
option of joining the program.
6) Systems in groups V and VI would be included into
the program in accordance with the memorandum of
agreement with DEM. Any new or existing system in
these classes would be included.
L
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IN
PROPOSED FUNDING MECHANISMS
O
A program such as the O&M program will necessitate additional
staff from its inception and will require expansion as more
systems are brought into the program. Along with additional
O staff, other major expenses that should be considered are
equipment, lab fees, and the pumping of class I and III
systems. The staff has explored several ways to fund the
program and achieve the goal.
The first alternative- would be a user fee system for all
Q owners of systems in the program. These fees would be paid
annually by the owner and hopefully could be collected
through the tax office through a special assessment on the
property. The fees .would be prorated based on the size and
class of the system. This system would be intensive on the
members of the program and the fees may have to be adjusted
O from time to time to meet the expenses of the program. A
disadvantage of this system is that a large group of citizens
in Orange County who rely on municipal water supplies would
directly benefit from the program without incurring any of
the financial burden of the program. The entire financial
burden would be placed on the system owners when in fact
O other citizens will realize benefits of the program through
better protection of both ground and surface waters.
The second alternative would be to fund the program from
general tax revenues. This mechanism would have each citizen
paying equitable amounts to fund the program. This method
4 would not be as.intensive on any one individual, and since
all members of the county will benefit from the program, the
cost burden of the program would be shared.
A third alternative that might be considered is a combination
of the first two. Certainly some of the costs of the program
0 will directly benefit the system owner by prolonging the'life
of the system, thus delaying the expense of repair or
replacement of the system. On the other hand, proper
operation and maintenance of the systems decreases the risks
of surface water and groundwater degradation as well as
direct contact with improperly treated sewage. These reduced
0 risks are a benefit to all citizens of the county, not just
system owners.
As cost calculations are not complete and county management
has not reviewed the program fully, it is premature to decide
which of these mechanisms is better. The staff will notify
O the board as soon as more complete details of funding are
known.
0 13

W
IMPLEMENTATION SCHEDULE FOR THE O&M PROGRAM
January, 1990: Start-up of the program. All new, repaired,
or reinspected systems in classes I -IV would be put under the
O&M program. Any system originally permitted through another
agency would be added as soon as the board of health gains
authority. At least one new field staff person would be
needed to begin training for the program.
July, 1990: Start inspections (biannual and quarterly) on
system classes II -IV. Register class V systems into the
program. Staff (field and clerical) would be increased
according to projection from first months' records.
January 1991: All routine inspections should be underway.
The process of sampling- effluent, streams, and monitor wells
should begin at this time.
January or July, 1992: Begin monthly inspections of classes
IV and V. -
0
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v
CONCLUSION
As discussed in its preliminary form, the proposed program
has been well received by various governing bodies and
agencies including OWASA, DEM, DHS, The Joint Chatham -Orange
Work Group (University Lake Watershed Study), and the Orange
County Planning Board. In fact many of these groups have
noted and discussed the need for a program of comprehensive
Q management for sewage. treatment and disposal systems. On
both the state and national level, there is a strong trend
towards initiation of local programs to address the
maintenance and operation of on -site septic systems. Wake
and Mecklenburg Counties have both instituted agreements with
DEM to allow for local monitoring of discharge and non
a discharge systems. The Orange County program will be a
comprehensive management program inclusive of DEM systems as
well as ground absorption and locally permitted on -site
systems.
Orange County residents, as well as those of neighboring
v counties and affected watersheds, will have much to gain from
such a program. I
-Septic systems will be installed, maintained, and
operated in a safe and sanitary manner within
design and operating criteria.
-There will be fewer mechanical failures and need
for repairs as well as systems with a longer
expected life.
-Effluent quality will improve and have less impact
on receiving surface and ground waters.
O
-The Orange County Health Department can better
design systems with input and feedback from the
program.
-System owners will be more aware of the importance
O of a properly operating sewage treatment_ and
disposal system.
-Overall it is expected that protection of public
health and the environment will be greatly
enhanced by such a program.
With increased development in Orange County, the problem with
sewage treatment and disposal systems must be addressed
before the problems become crises or before the consequences
become irreparable. Most governing boards in the county do
agree that some sort of oversight over performance of these
O systems must be developed. As boards of health have clear
statutory authority to develop such oversight by adopting
regulations, they are the logical board to proceed with such
a program.
15
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t� 4 O O 4 O O O O 4 O

C
APPENDIX F
IWE
i
E
Package Sewage' Plantse
Burden .. .
Unless state government acts
quickly to regulate small sewage
treatment plants, municipalities may
soon face significant financial
burdens and a loss of control over the
pace and direction of growth in their
communities.
Small sewage plants —known
commonly as package treatment
plants —consist of prefabricated
modular components that are used in
combination to meet different levels
of treatment. In recent years, they
br Senator William Golden
cost-effective for subdivision devel-
opment due to the high cost of build-
able lots and the attractive price of
marginal land previously considered
unbuildable.
The Local Impact
Package treatment plants are
undermining the already limited con-
trol many communities have over
growth and development. The
growth management plans of local
governments are based not only on
"If we do not regulate this
technology, our communities
may find themselves in serious
financial difficulties and their
quality of life threatened."
have become widely used to service
new residential and commercial
developments. The plants make it
possible to develop lots that pre-
viously would have been unbuildable
because the soil could not support a
septic system.
Package treatment technology is
not new, but it, is now considered
We►•mouth Senator William Golden is
the Senate chairman of the legislature's
Committee on Counties.
zoning laws but on building, health,
and environmental regulation as
well. Many communities have
assumed that certain land was not
buildable because it could not pass a
percolation test. However, if a pack-
age treatment plant is constructed.
this land becomes buildable, and
zoning may be rendered ineffective as
a planning tool for future g: :)wth
management.
The parts of the state where the
most package sewage treatment
plants have been proposed and built
are the same areas that have been
straining under the pressure of devel-
opment. These communities have
been struggling for years to provide
vital municipal services, such as
schools, roads, water, and police and
fire protection.
Package treatment plants can
place other financial burdens on
municipalities in the future. What
happens if a system breaks down? Is
the responsibility for maintenance
that of the developer or the property
owners? What if the developer goes
bankrupt or the corporation dis-
solves? In the end, the municipality
may have little choice but to pick up
much of the financial burden.
There also are unresolved health
and environmental issues. because
the systems are volume
than large sewage systems, they may
be disproportionately affected by
common household toxic products
such as pesticides, paint thinners,
and antibiotics. Since responsibility
for maintenance is often ambiguous,
no emergency procedures may be in
place if the plant breaks down and
raw sewage backs up into homes.
Local governments now have little
control over small sewage treatment
plants. Permits are issued by the state
Department of Environmental Qual-
ity Engineering, which in 1987
approved more than eighty systems.
DEQE's parent agency, the Execu-
tive Office of Environmental Affairs.
has recognized the problems posed
by this technology and has supported
continued nn page 19
16 The Municipal Forum
SuVVIwke.Vr- ? � 0 l: G N() -L _...._ .

Technology
Or Breakthrough.?
Groundwater protection is a
serious concern and a popular
election -year issue in Massachusetts.
Those who are truly concerned about
clean drinking water are actively
seeking ways to protect ground-
water. One solution is for state and
local governments to encourage the
private use of wastewater treatment
plants, a technology that is becoming
more widespread.
Small wastewater treatment plants
process gray water waste for disposal
at the site while conventional septic
systems do not —and the plants need
less space than a comparable septic
system. This technology protects the
environment while allowing building
at greater density. Such systems
make the development of larger pro-
jects possible -in unsewered areas and
make into developable property land
that was previously unbuildable due
to the limits of septic systems.
In the past ten years, the Massa-
chusetts Department of Environ-
mental Quality Engineering has
issued more than one hundred
groundwater discharge permits for
privately owned treatment plants.
This technology has been approved
for use by businesses, hotels, institu-
tions, and condominiums, so it is log-
ical that its application would be
extended to residential subdivisions.
As of this spring, at least twenty-
three permit applications for plants
in single-family subdivisions were
pending at the state level, although
Monica Staaf is the associate counsel
of the Homebuilders Association of
Massachusetts.
by Monica Staaf
only one plant —located in Ipswich,
Massachusetts —had been approved.
The department's Division of
Water Control supports small
wastewater -treatment plants. The
division recently characterized one
though the department ultimately
denied the permit application, a
homowners' trust is a workable and
legitimate entity.
Such' a trust is similar to a
condominium -owners' association.
"All communities and their
water supplies stand to benefit
from prop
technolog
treatment
er application
[package see
plants]."
proposed plant as having "the poten-
tial to produce an effluent far super-
ior to that produced by conventional
septic systems." Some local officials
and environmentalists, however,
have expressed concerns about local
control over development, long-term
maintenance of treatment plants,
and accountability for replacement
of worn-out plants.
The Homeowners' Trust
Some of these concerns erupted
during public hearings on the pro-
posed Willis Hill subdivision in Sud-
bury, Massachusetts. The project's
proponents, at the urging of the legal
staff of the Department of Environ-
mental Quality Engineering, pro-
posed the creation of a homeowners'
trust to maintain and repair the
wastewater treatment plant. Even
of this
UZU
All purchasers and subsequent pur-
chasers of a home in a single-family
subdivision would, by deed, become
members of the homeowners' trust.
Although each buyer would indivi-
dually own his or her own home and
lot, the trust would own and manage
the common area on which the
wastewater treatment plant would be
located. The homeowners' trust
would assess charges against each
individual owner to cover the costs of
maintaining and ultimately replacing
the treatment plant. The trust would
have the contractual authority to
impose liens on the homes of delin-
quent owners if necessary.
Home Rule
Loss of local control over develop-
ments is an emotionally charged
The Municipal Forum 17
.. l%l . � �� o •� S �l�Rvrt �• � 19

WA
X
ES
J
lA
YJ
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M
101
Burden ...
continued from page 16
I
a moratorium on residential use. The
agency is now in the process of pre-
paring a report that will assess the
environmental impact of the plains.
Nevertheless, while that impact
report is being prepared, DEQE is
continuing to consider permit
applications.
Legislation
I have cosponsored legislation
with Representative Lucile Hicks
(R-Wayland) to impose a morato-
rium on the granting of package
treatment permits by DEQE. This
moratorium would remain in effect
while the environmental affairs
impact report is being prepared.
DEQE should not be issuing permits
before it knows what -the effects of
those permits are likely to be, both on
municipalities as well as statewide.
After the impact report is issued, the
moratorium would be extended
another six months. During this
time, state and miunicipal officials
could review the report and develop
strategies to address the problem.
The legislation would protect the
financial interests of cities and towns
if a package treatment plant breaks
down by requiring developers to post
a bond to cover the cost of replacing
the facility.
The bill would also encourage
communities to exert local control
over the plants. Cities and towns
would be urged to set up committees
of municipal officials and private
citizens to recommend regulations
for adoption by the local boards of
health.
Package treatment plants are not
an inherently bad technology. They
offer municipalities a valuable tool i-
addressing the problem of sew
disposal and may offer alter -
for providing affordable ho-
encouraging industrial a•
vial development. Y
must be managed a
comprehensive
into considers
term and long -
not regulate thi.
communities may h.
serious financial diffic,
quality of life in jeoparn,
C�7

issue that is not grounded in fact.
Although 'title Five of the State
Environmental Code requires pro-
posed plants or septic systems with a
flow of 15,000 gallons or more to win
approval from the Department of
Environmental Quality Engineering,
all projects must still obtain local
approval. In other words, even if the
Division of Water Pollution Control
issues a groundwater discharge per-.
mit, the local board of health may
still withhold a disposal works con-
struction permit pursuant to local
regulations and Title Five. Clearly,
local boards of health have the
authority to promulgate their own
regulations pertaining to treatment
plants.
In addition, developments using
private treatment plants must obtain
approval from local planning
boards, conservation commissions,
building inspectors, and others.
Thus, municipalities will continue to
have substantial control over con-
struction projects despite the advent
of this technology and its eventual
use in single family subdivisions.
State control of groundwater dis-
charge permits complements rather
than replaces local approval and
home rule.
Ironically, some opponents of this
technology would deny home rule to
municipalities. There is a movement
to bar developments that use sewage
treatment plants from being built at a
density greater than what would be
technologically feasible using con-
ventional septic systems pursuant to
Title Five. - Septic systems - require
more area to percolate than sewage
treatment plants do. Such a law
would prevent any community from
encouraging cluster developments or
other types of affordable housing.
This unnecessary constraint is a blat-
ant attempt to discourage the use of
treatment plants by making them
economically unfeasible.
Zoning
Another concern about small
treatment plants is that municipali-
ties that have mandated large -lot
zoning, citing Title Five constraints,
will now be forced to allow develop-
ment on every'square inch of avail-
able land. Since land can sustain
considerably more development
using treatment plants than using
conventional septic systems, the
environmental justifications for
large -lot zoning have become virtu-
ally obsolete. However, neither tech-
nological advances nor Title Five
dictates local zoning law. While com-
munities concerned about the acute
shortage of affordable housing in the
commonwealth may contemplate
revising their zoning bylaws to allow
- building at a greater density, nothing
compels them to do so.
Landowners' Rights
For years, municipalities have
reaped the benefits of free open space
and property taxes paid on unbuild-
able land without providing any ser-
vices to these property owners in
return. Some communities deliber-
ately kept this land unbuildable by
refusing to install a municipal sewer
system. After receiving so many
benefits, it is only fair that local
governments advance the right of
these long-suffering property owners
by allowing them to develop their
land.
Until all municipalities are willing
to expend the necessary funds to pro-
tect their water supplies by installing
tc•- :i sewer systems, privately owned
u: .ewater treatment plants will
rr--ain the best way to dispose of
%. tewater. Considering their excel -
track record at the Department
of Environmental Quality Engineer-
ir:_•:. is is inevitable that treatment
pints will be used increasingly in
apartment buildings, condomini-
urs, cluster developments, and,
eventually, single-family sub-
divisions.
Skeptics once shouted "Get a
hone!" at early automobile drivers.
A,. the world sped by, they continued
to jeer and resist progress. Similarly,
those who fear and oppose privately
owned treatment plants should
a,:cept the change gracefully and
l: srn the facts about this new tech-
nology. Municipalities should
z.-tively review and, if necessary,
_:vise their bylaws to accommodate
::nd make the best use of treatment
plants, rather than passively waiting
.or the state to dictate these deci-
ons. All communities and their
.rater supplies stand to benefit from
^roper application of this
technology.
561
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M
ICMA
lanagemcnt
Information
Service
VOLUME 171 NUMBER 4
APRIL 1985
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Number Title
14 Recycling Paper in City Nall
IS Water Conservation: A Small Town's Campaign
16 Integrating Inspectional Service
17 An Insurance Procurement Procedure
18 Dynamic Pay Planning for Small Cities
19 Organizing for Land Development Control —
A Tool for Economic Development
20 The Political Manager
21 uniform Ordinance Format
22 Determining the Effect of Local Economic Changes
Upon a Community
23 Success in Traffic Signal and Street Light
Maintenance
24 A Style Manual for Writing Memos to the Council
25 Efficient Processing of Minor Traffic Violations
26 A Study of Leaf Collection and Disposal Practices
in the Garden State
27 - Public Safety: An Option for Greenville?

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Wastewater
Management:
Alternative
Small Scale
Treatment Systems
In many communities, existing wastewater systems barely
can meet the needs of current customers. With recent cut-
backs in federal construction grant programs, many com-
munities cannot afford to build new public facilities or to
expand their existing systems. The lack of wastewater
service capacity can curtail the construction of new
housing. And a lack of available housing can affect local
economic development, since one criterion of business
location decisions is the availability of housing for
employees.
In the past, when a public sewer system was not
available the only practical alternative was to install
individual on -lot wastewater systems (septic systems).
But not all sites are physically suited for this type of
disposal system. If the number of developable sites is
limited, the cost of such sites will rise. In addition, the use
of on -lot wastewater systems requires large lot sizes (at
least 3/4 of an acre). The combination of these factors
tends to drive up housing costs.
Some private developers have relied on small
"package plants" to provide wastewater service for new
developments. Independent small scale systems can be a
cost-effective means of providing wastewater service.
Since fewer physical site constraints must be addressed
and smaller lot sizes can be allowed, using such
approaches can help reduce housing costs compared to
the use of septic systems for wastewater management.
Some communities have had bad experiences in the
past with small package plants and as a result have
objected to their use. But in recent years, variations of
small-scale wastewater treatment systems have been
applied successfully. These systems use various methods
to collect and treat wastewater, including some technolo-
gies not commonly applied in conventional wastewater
systems. The experience with these installations has
proven that the problems previously experienced with
small scale package plants can be avoided with proper
design and operation. In addition, the various systems
currently available are more adaptable to different site
conditions than are typical package plant.
This report is excerpted from a reference
handbook developed under 4 US. Department of
Housing and Urban Development contract
awarded to The Synectics Group, Inc. (TSG),
n3o 17th St., NW, Washington, DC and Roy F.
Weston, Weston Way, West Chester, PA. The
purpose of the handbook is to make communities
and developers more aware of the full range of
wastewater management options. Authors of the
handbook were: from WESTON, Kenneth C.
Wiswall, from TSG, Amy L. Marasco, Claire M.
Gesalman, and Maggi Elliott. The handbook is
titled: A Reference Handbook on Small -Scale
Wastewater Technology and is available from
TSG at the address shown above.
BASIC WASTEWATER MANAGEMENT CHOICES
The three basic options for providing wastewater service
in a community are to:
• Provide individual on -lot treatment systems for each
home;
• Collect the wastewater via an on -site collection sys-
tem that is tied into a public sewer system; or
• Provide an independent on -site collection and treat-
ment system.
Today, however, there are many technical alternatives
from which to choose in deciding how to collect and treat
wastewater. The various types of wastewater systems
that might -be considered are shown in Figure 1.
Water conservation systems (also shown in Figure 1)
can significantly reduce the amount of wastewater gener-
ated and thus affect the feasibility and cost of different
wastewater system alternatives. Reducing water use can
lower day -today operating costs for treatment chemicals,
utilities, etc., and may justify the use of smaller, less
expensive treatment facilities. Water conservation is
appropriate particularly in cases where existing facilities
have limited treatment capacity and/or total hydraulic
loading is critical (i.e., land application and subsurface
disposal systems). If a community is connected to a
regional sewer system, conservation measures can be
effective in reducing treatment charges, which are usually
based on the volume of sewage treated.
Disposing of wastewater using individual on -lot
treatment systems is a simple wastewater management
option. Most on -lot disposal systems (including the tradi-
tional septic tank and drainfield, as well as more recently
developed "alternative" systems) rely upon some form of
soil absorption system to dissipate wastewater effluent.
Therefore, certain minimum site conditions must exist for
these systems to function properly. Some sites are simply
not suitable for on -lot systems because of steep slopes,
poor soil conditions, or other problems.
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2 Management Information Service
FIGURE 1. Basic Wastewater Management Options
Treatment Systems
OinOn-Slte off -site
ovidf I I I Treatment I I Treatment
Systems Facilities
Surface
Water
Discharge
No Surface
Water
Conventional I Alternativeant I I Application I I Subsurface
ssal
Treatment Treatment
Facilities Facilities
Morshpond
Overioi
Lagoons I I Septic Tar k I I Flownd I I Systemsre I I
IR nd
Local and state regulations usually establish mini-
mum lot sizes when on -lot systems are used. This is done
to ensure that adequate space is provided for the soil
absorption system and to minimize chances of contami-
nation of groundwater resources. This generally reduces
the number of building lots that can be created on a given
parcel of land when compared with use of public sewer
systems or on -site small scale treatment systems.
Public sewer systems are not subject to the same
constraints. Since the wastewater is collected and then
treated at a central facility, large lot size requirements
mandated by local and state health codes do not apply. In
addition, the existence of marginal soils is not a limiting
factor for development in such cases. Although the initial -
expense of building a centralized collection and treatment
system is high, the higher possible densities can reduce
infrastructure costs per lot as compared to large lot
developments.
There are factors that discourage the use of public
sewer systems. In some cases, the cost of extending a line
to connect to a sewer system may be prohibitive. In other
cases, the capacity of the existing treatment system may
be limited, making it impossible to service additional
homes. Many communities have imposed sewer mora-
toria because of this situation.
If connection to a public sewer system is not feasible,
the installation of a small scale temporary or permanent
on -site collection and treatment facility might be con-
sidered. This will increase the up -front capital costs of the
project, but may prove more cost-effective for the
developer -than developing a site using on -lot disposal
systems. For some technologies, the feasibility of an on -
Collection Systems
Conventional 'Alternative..
Gravity Collection
Sewers Systems
Small eptic Tank Grinder Pump Vacuum
Diameter VESffluent Pump Pressure Sewers
avity Sewers assure Sewers I Sewers
Water Conservation (i.e.. wastewater reduction)
Water Wastewater Recycle/
Saving Separation Reuse
Devkm
site treatment system will depend on the existence of a
receiving stream for the surface water discharge of treated
effluent. The appropriate State Water Pollution Control
Agency would need to approve such discharge. If surface
water discharge is not acceptable, non -discharging sys-
tems, such as land application and subsurface disposal,
might be appropriate.
The following discussion briefly reviews the different
types of collection, treatment, and water conservation
systems available, and explains how they might be
applied in various combinations.
Wastewater Treatment Atternatives
The traditional, and most common, on -lot disposal sys-
tem is the septic system, which consists of a septic tank
and drainfield. The method of disposal is usually dictated
by prevailing site conditions. For example:
• Elevated sand mounds are used when shallow soils
or high groundwater conditions exist;
• Contour trench systems are used on steep slopes;
• Sand fill systems are used to replace soils of exces-
sively low or excessively high permeability; and
• Recirculating ' sand filters provide sufficient treat-
ment to allow surface discharge of the effluent when
site conditions do not allow subsurface disposal.
An aerobic tank can be substituted for the septic tank in .
conjunction with any of the above systems. Aerobic
tanks are self-contained miniature mechanical sewage
treatment plants capable of treating wastewater to a
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FIGURE 2. Technical Alternatives —Independent Small -Scale Treatment Systems
O
f — Minimum Requirement secondary Treatment —4 {-- Advanced Treatment Requirement I— "No Discharge"— j
Disinfection Discharge Requirement
101
M
f;,onventlonal
Treatment
systems
(i.e., package
plants, oxidation
ditches, RBCs,
trickling filters,
etc. Including
innovative and
tertiary
treatment
technologies)
Disinfection
Lagoons
(i.e.,
wastewater
stabilization
ponds and
Q aerated
lagoons) .
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Do]
EePft TasMrs .
(or Individual septic
tanks in. SDG and STEP
collection systems)
Tertiary Treatment
and/or Sand Filter
TertiaryTreatment
Overland Flow
Morshpond/Aquaculture
or Wetland System
Sand Filter
Recirculating
Sand Filter --
greater degree than septic tanks. Depending on local
regulations, direct surface water discharge may be
acceptable with aerobic tanks. If connection to a public
sewer system is possible, sewage can be collected and
conveyed to a central treatment facility. In most cases,
the treatment facility will be an activated sludge biological
treatment plant with a surface water discharge.
Independent small-scale treatment systems also can
be installed at the development site. Figure 2 depicts
various combinations of treatment and disposal systems
which represent three practical treatment alternatives:
conventional systems, lagoons, and community septic
tanks.
Conventional treatment systems. These include pre-
fabricated package plants and several variations of bio-
logical treatment plants that have been applied in small
scale operations (e.g., oxidation ditches, rotating biologi-
cal contactors, trickling filters, activated biological fil-
ters). All of these are mechanical treatment facilities and
require varying degrees of operation and maintenance
depending on the size and complexity of the system.
Conventional treatment systems typically provide
secondary treatment (85% removal of organic and solids
loading) and are usually allowed to discharge directly to
surface waters with disinfection. For advanced levels of
treatment, tertiary treatment processes (e.g., phosphorus
removal, nitrogen removal, and tertiary filtration) may
be required. Such requirements may be imposed to
Disinfection " Discharge
Disinfection Spray Irrigation
Subsurface Disposal
Disinfection Groundwater Rechari
or Direct Reuse
Disinfection I -I Discharge
Disinfection Spray
Disinfection
I Subsurface Disposal
protect sensitive fish habitats (e.g., trout streams) or
down -stream domestic water supplies.
Land application or subsurface disposal of treated
effluent also may be an option. The most common
method of land application is spray irrigation, where
treated effluent is applied to cropland, meadowland, or
wooded areas using agricultural -type sprinkler systems.
Subsurface disposal systems are large soil absorption
systems similar to the drainfields used in individual septic
systems. -These types of systems both require significant
amounts of land. When groundwater discharge (i.e., to
known drinking water supply aquifers) or direct reuse of
treated effluent is proposed, advanced levels of treatment
and disinfection are required.
Lagoons. These include wastewater stabilization ponds
and aerated lagoons. These systems provide a low cost
treatment alternative to conventional treatment facilities.
Their capital and operating costs are considerably less
than conventional treatment systems provided land costs
are reasonable. Their operation is relatively simple and
labor and energy requirements are modest.
A wastewater stabilization pond is a large impound-
ment where wastewater is treated much as it is in a
biological treatment plant, but without the benefit of
mechanically assisted aeration it requires more time
(longer detention times) and more space (up to an acre or
more). Aerated lagoons use mechanical aeration (usually
surface aerators) and therefore are more efficient than
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4 Management Informaflon Service
stabilization ponds, requiring less land and shorter deten-
tion periods.
Lagoons provide secondary treatment according to
the recent redefinition of secondary treatment by the U.S.
Environmental Protection Agency. Direct discharge of
lagoon effluent is normally acceptable.
When direct discharge is not acceptable, further
levels of treatment can be provided using relatively low
cost treatment technologies. In overland flow systems,
lagoon effluent is applied to slightly sloping grassed
areas, allowed to flow over the surface, then is collected
on the downslope side, disinfected, and discharged. The
process of overland flow removes much of the residual
nutrients and solids found in lagoon effluent, and can
provide crop irrigation at the same time.
Another method of treating lagoon effluent is to dis-
charge it to a marsh or wetland (natural or constructed).
The combination of aquatic plants and biota feed on the
nutrients in the effluent, while the residual solids settle
out and decompose. Most of the pathogens in the effluent
quickly die off naturally in the marsh/wetlands environ-
ment. If fish or plant harvesting is practical, wetlands can
be operated as aquaculture systems. Lagoon effluent can
also be spray irrigated; however, filtration may be neces-
sary to prevent clogging of spray nozzles.
Community septic tanks. These are primarily used in
conjunction with community subsurface disposal sys-
tems. This category also includes the use of individual
septic tanks used in small diameter gravity sewer and
septic tank effluent pump pressure collection systems
(described later), since the same pretreatment function is
provided. The combination of a community septic tank
and subsurface disposal system represents one of the
most cost-effective wastewater management options
available due to the low capital cost and the nominal
operation and maintenance requirements.
If subsurface disposal is not feasible or desired, the
effluent from a community septic tank can be treated by
a recirculating sand filter, disinfected, and discharged.
Although the use of such a filter does require periodic
maintenance, operating costs are very reasonable.
Wastewater Collection Alternatives
The two major categories of collection systems shown in
Figure 1 are conventional gravity sewers and small-scale
or alternative collection systems. The conventional
gravity sewer has been the standard in collection system
design for over 100 years. These sewer systems rely on
gravity to transport sewage through a network of pipes
and generally are designed to minimize the need for
pumping facilities.
Gravity systems are relatively simple in design and
are very reliable. However, the cost of constructing
gravity sewers has escalated in recent years to the point
where many communities and private developers simply
cannot afford the initial capital investment. This has con-
tributed to the increasing use of small-scale collection
systems such as:
• Small diameter gravity sewers,
• Small diameter pressure sewers, and
• Vacuum sewers.
Small diameter gravity sewer systems use individual
septic tanks to pretreat the wastewater from homes
before it is discharged to the collector sewer. Since the
septic tank effluent is relatively free of the large solids
and grease that can clog sewer lines, the sewers can be
sized much smaller than in conventional systems. Small
diameter gravity sewer lateral lines are typically 4 inches
in diameter, whereas the standard minimum pipe size in
conventional gravity sewer systems is 8 inches.
Even smaller pipelines can be used in small diameter
pressure sewer systems. One type of system requires the
use of individual septic tanks, as in a small diameter
gravity sewer system, but uses small pumps to force the
septic effluent through lines as small as 11/2 inches in
diameter. This is referred to as a septic tank effluent
pump or STEP system. Since the wastewater is under
pressure, the lines can be laid at a minimum depth (just
below the frost line) following the natural grade. This
avoids the expense of making the deep cuts required in
gravity sewer systems.
In a grinder pump pressure sewer system, individual
pumps that grind the raw sewage are substituted for the
effluent pumps, eliminating the need for the individual
septic tanks. Otherwise, the design of the sewer system is
similar to the STEP system. Again, the cost of materials
and installation can be considerably less than for conven-
tional sewer systems.
Vacuum sewers use central vacuum stations to create
a vacuum throughout the collection system. The vacuum
draws the wastewater through the lines to a central
collection point. The sewer lines average 3 to 4 inches in
diameter and are generally buried relatively shallow
following natural terrain.
Grinder pump pressure sewers and vacuum sewers
can be used in conjunction with any treatment system
that would normally be associated with a conventional
sewer system. Small diameter gravity sewers and STEP
systems, on the other hand, would typically be used in
conjunction with a subsurface disposal system or recircu-
lating sand filter. Since the individual septic tanks pro-
vide sufficient pretreatment for these disposal methods,
no other treatment facilities are required. Although septic
tank effluent can also be treated by conventional methods,
it is unnecessary and will increase capital and operating
costs. Figure 3 shows typical combinations of treatment
and collection systems.
Water Conservation Methods
As mentioned earlier, water conservation methods can be
used to reduce wastewater flows which in turn can affect
the design of a wastewater system. The use of water
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Wastewater Management 5
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FIGURE 3. Typical Combinations of Collection and Treatment Systems
Collection Systems
Appropriate
Alternatives
Treatment Systems
• Conventional Gravity Sewers
Conventional
Treatment
System Direct Discharge
• Grinder Pump Pressure Sewers
orLalagoon
Application
• Vacuum Sewers Community. Subsurface
Septic Tanis3Disposal
• Small Diameter Gravity Sewers
Sand Fitter A Disinfection Discharge
• Septic Tank Effluent Pump
Pressure Sewers Conventional "
Treatment System i:t
Lagoon
saving devices, such as flow reducing showerheads and
water saving toilets, can reduce wastewater flows by as
much as 25 %.1 The separation of toilet waste (black -
water) from other domestic wastewater such as wash
water, shower water, kitchen wastes (greywater), etc. can
eliminate up to 40% of the total wastewater flow when a
waterless toilet system is used (e.g., .compost toilets).
When water conservation measures are applied, waste-
water flows should be monitored to verify that water use
is reduced.
If water supplies are extremely limited, wastewater
recycle or reuse might be considered. Treated effluent can
be reused for non -potable uses, or used to recharge
groundwater supplies. In unusual situations, wastewater
can be treated to such high levels that it can be totally
recycled for potable as well as non -potable uses. Recycling
can significantly increase the cost of the wastewater
system due to the higher levels of treatment required.
Innovative Uses of Small -Scale
Wastewater Systems
When treatment capacity is not immediately available at
existing public sewer facilities, it may be possible to use
interim wastewater facilities pending expansion of exist-
ing public facilities. Some municipalities require the
installation of dry sewers (i.e., sewers laid during con-
struction but not hooked up to the new homes; also
known as capped sewers) and individual on -lot septic
systems in new developments where sewer service is
expected to be available at some future date.
If the use of a small community treatment system is
allowed (e.g., a package plant and subsurface disposal
system) instead of individual septic systems the installed
sewers would serve a useful purpose rather than he idle.
Such an arrangement may work to the advantage of the
local sewer agency if the treatment capacity otherwise
committed to a development using a community treat-
ment system can be applied to meet pressing service
demands in other areas.
Another approach is to construct a private treatment
facility to intercept and treat a portion of existing sewage
flows from a public sewer system so that additional
capacity is available for new development located else-
where in the service area. This may apply to cases where
on -site treatment is not feasible at a particular proposed
development site, but is possible at other locations where
existing sewage flows might be intercepted. This concept
has been applied successfully in San Bernardino, Cali-
fornia,2 where it is referred to as "interdiction:' By treat-
ing 200,000 gallons of sewage per day from upstream ser-
vice areas, a developer was granted a guaranteed sewer
allocation in the public system to be used as his project
was built -out.
Still another method of redistributing available
treatment capacity is to trade sewer allotments from one

6 Management Information Service
location to another or to allow the sale and purchase of
treatment capacity rights among property owners in a
given service area. To maintain control over such
transactions, a public authority should coordinate these
transfers. The City of Houston administers such a
program under the recently adopted "Capital Recovery
Ordinance;' which allows landowners to sell up to 15%
of the sewage capacity allotted to a particular parcel.
APPROPRIATE USES OF
TRADITIONAL WASTEWATER SYSTEMS
The focus of this report is on independent small-scale
wastewater treatment systems, but there are situations
where on -lot systems or public sewer systems are more
appropriate. Very often, the most effective wastewater
management solution will involve a combination of tra-
ditional and non-traditional treatment options. This
section discusses the appropriate uses of on -lot and public
sewer systems and illustrates different approaches to
applying traditional technologies to provide cost-effective
wastewater service.
On -lot Systems
The term on -lot system as used in this discussion refers to
an individual home sewage disposal system. The most
common on -lot system is the septic system, which con-
sists of a septic tank and a drainfield. The septic tank
pretreats the wastewater (i.e., traps solids, oil, and
grease), and the gffluent is applied to a subsurface drain -
field where it is filtered as it percolates through the soil.
The septic system generally provides more than adequate
treatment of domestic wastewater for a relatively small
capital investment, and requires little maintenana*.:When
properly designed, installed, and maintained, these sys-
tems can be expected to perform reliably for 20 years or
more.
However, septic systems can be used only if the
proper site conditions exist. Conditions that might pre-
clude the use of a standard septic system include poorly
drained soils, shallow depth to an impermeable layer,
high groundwater, excessively permeable soils, and steep
slope. These constraints can be overcome in many cases
using alternative on -lot system designs such as aerobic
tanks, elevated sand mounds, contour distribution
trenches, sand fill systems, and recirculating sand filters.
Aerobic tanks are essentially very small package
treatment plants designed to provide the same type of
treatment as a full scale sewage treatment plant. Aerobic
tanks typically rely on mechanical equipment (i.e., pumps
and blowers) to achieve this level of treatment. Regula-
tory agencies may in some cases allcw subsurface dis-
posal of aerobic tank effluent where discharge of septic
tank effluent is not allowed. This might apply in cases
where excessively permeable soils or high groundwater
conditions exist. It may also be possible to discharge
aerobic tank effluent directly to a surface waterbody after
filtering and disinfecting the effluent. This option may
have to be considered if site conditions prohibit any form
of subsurface disposal.
Elevated sand mounds may be used with either
septic tanks or aerobic tanks when the depth of soil is
insufficient to provide adequate effluent renovation due
to the presence of a limiting zone (i.e., layer of soils or
rock with limited permeability) or high groundwater.
Very often a pump is required to distribute the effluent
since the mound is usually at a higher elevation than the
treatment tank.
Contour distribution trenches provide a means of
disposing of septic tank or aerobic tank effluent on sites
with steep slopes. In such systems, the drainfield is made
up of a series of trenches installed at different elevations
following the contours of the ground. Use of a small
effluent pump may be required when the trenches are
installed at a higher elevation than is the treatment tank.
Contour trench systems can be used on sites with slopes
up to 25 or 30 percent (a drop of 2.5-3.0 feet in 10 feet),
although local and state regulations may impose limits on
maximum slope regardless of the type of system used.
Sand fill systems are buried sand filters where sand
fill replaces soils that are either poorly drained or exces-
sively permeable. To provide adequate effluent renova-
tion, the sand fill must meet certain physical specifications
(e.g., particle size, clay content) usually set by local or
state regulations. The soils beneath a sand fill system
must be permeable enough to convey the filtered effluent
away from the surface. Recirculating sand filters operate
on the same principle as a sand fill system, except that the
filter is in a sealed container where the effluent is collected
and recirculated after it passes through the filter. The
recirculation of filtered effluent causes the wastewater to
pass through the sand filter several times, while in a sand
fill system it passes through once and is then discharged
to the ground. The final effluent from a recirculating
filter, being of relatively high quality, can be discharged
using conventional subsurface disposal systems in cases
where subsurface disposal might not otherwise be allowed
(e.g., excessively permeable soils, shallow groundwater,
shallow soils). In fact, with proper disinfection it may be
possible to discharge the effluent from a recirculating
sand filter above ground.
In cases where site conditions severely restrict any
form of surface or subsurface discharge, compost toilets,
holding tanks, and complete wastewater recycling sys-
tems might be considered. However, the high cost and
inconvenience of installing and operating these systems
usually discourages their widespread application.
Positive Features. The major advantages of using on -lot
disposal systems are that they are relatively inexpensive
and easy to install. However, when alternative on -lot
system designs are required to overcome unique site
constraints, the cost advantage of on -lot systems may
diminish. When appropriate site conditions exist, on -lot
systems represent a reliable method of wastewater dis-
posal serving residential development. However, great

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care mustbe taken to assure that they are properly
constructed and operated to prevent premature system
failure and possible health risks.
System Applicability. In cases where centralized sewer
systems are not available, on -lot systems may be the only
practical alternative. On -lot systems are particularly well
suited to isolated small developments (i.e., less than 20
dwelling units) where it is difficult to justify the invest-
ment required for small-scale collection and treatment
facilities.
Regulatory Requirements. When on -lot systems are
used, a minimum lot size is usually required. These
restrictions are intended to assure that adequate space is
available to support an on -lot system and in some cases
require that an area be provided for possible future
replacement of the system as well. Minimum lot sizes
prescribed on this basis typically range from 1/2 acre to 1
acre. Recently, -communities have become concerned with
the pdtential cumulative impacts (i.e., impact on ground-
water quality) associated with the widespread use of on -
lot sewage disposal systems.
Aside from lot size restrictions, local or state regula-
tions will usually include specific design criteria for on -lot
systems. However, specific technical guidance on certain
"alternative' on -lot systems may be lacking. In fact the
use of "non -conventional" or "unrecognized" on -lot sys-
tem designs may not be allowed due to the lack of the
appropriate design criteria.
Operational Requirements. On -lot treatment systems, as
a general rule; require very little maintenance. Notable
exceptions are aerobic tanks and recirculating sand
filters. Aerobic tanks require electrical power to operate
the pumps and blowers, and also require periodic main-
tenance and repair of mechanical equipment, as well as
routine sludge removal. Recirculating sand filters require
periodic cleaning and pump system maintenance. If disin-
fection systems are involved, chemical feed devices must
be periodically maintained. In systems relying on a con-
ventional septic tank and subsurface disposal methods,
the only routine maintenance required is the pumping out
of the septic tank every 3 or 4 years. Some communities
require annual or biennial inspections of the tank to
determine when pumping is needed. Of course, if an on -
lot system malfunctions, appropriate repairs must be
made. Complete drainfield failure may require the instal-
lation of an entirely new drainfield which can be very
costly.
Public Attitudes. In areas where public sewer systems
exist, citizens may feel that on -lot systems are inferior to
sewers due to the perception that problems (e.g., sewage
back-ups, odors) are more likely to occur with a septic
system.
In areas where on -lot systems have a documented
history of chronic malfunction negative public attitudes
are likely to exist. In some cases these problems can be
Wastewater Management 7
rectified through the use of alternative system designs
and improved management practices (e.g., routine sys-
tem inspection and tank pumping). In other cases the
physical characteristics of a particular area may be
unsuitable for on -lot systems. If negative attitudes exist it
may be difficult to gain local approval of new develop-
ments proposing the use of on -lot systems unless it can be
demonstrated that problems experienced in the past can
be prevented through the use of proper design and opera-
tion practices, or with use of different technologies.
Costs. Since the design of an on -lot system is dependent
on actual site conditions, it is difficult to provide exact
cost estimates. However, approximate capital and oper-
ating cost ranges are presented for the various on4ot
system alternatives discussed as a rough guide (Table 1).
Connection to Public Sewer Systems
Connection to a public sewer system involves tying -in to
the nearest interceptor or trunk line. The developer gen-
erally will bear the cost of installing the connecting line
and other facilities (e.g., pump stations) required to reach
the connection point and may pay a tap fee as well. The
construction and eventual ownership of the connection
facilities can be handled in several ways. The developer
may be totally responsible for the construction and
operation of these facilities, or they may be privately
built and then dedicated to the municipality or sewer
authority. In either case, the public agency should require
that the design and construction of the connection facili-
ties conform with design standards deemed appropriate
by the agency. This might also apply to the collector
sewers installed within the development.
Positive Features. The main advantage to treating waste-
water off -site (i.e., connecting to a public sewer system)
is that the developer and the future property owners (i.e.,
individual homeowners or community association) are
not responsible for the operation of a treatment facility.
Operating an independent small-scale treatment facility
can be very costly, particularly if operational problems
develop. By connecting to a public sewer system, the
operational responsibilities of the developer and future
property owners are minimized. Such an arrangement is
usually desirable for homeowners, assuming that the tap
fees and treatment charges levied by the public agency
are reasonable. From the developer's perspective, an
advantage is the avoided cost of constructing a small-
scale treatment facility. This also eliminates the
developer's time and the technical and administrative
costs of 'obtaining the necessary permits and local
approvals when a new wastewater facility is proposed.
System Applicability. Off -site treatment is appropriate
when the proposed development is reasonably dose to an
existing interceptor or trunk line. Of course, the public
agency responsible for wastewater management must be
willing to accept the sewage. If the existing treatment

8 Management Information Service
TABLE 1. Approximate Cost Ranges for Individual On -Lot Sewage Disposal Systems
(Ail Costs Updated to 1984 $)
Septic Tank—Drainfield
Septic Tank —Sand Mound
Septic Tank —Serial Trenches
Septic Tank —Sand Fill
Septic Tank —Recirculating Sand Filter—Drainfleld
Septic Tank —Recirculating Sand Filter -Discharge
Aerobic Tank (in lieu of septic tank with any of the above)
Aerobic Tank —Discharge
Recycle/Reuse Systems
Compost Toilets
Greywater Treatment System
Holding Tank
Construction Cost
Annual O&M
(Installed)
Cost (slyr)
1,200-3,0000
10-30a
6,500-7,700a•b
35-700
2,800-5,9000
10-30a
3,000-4,200a•a
10-30a•a
4,700-6,300a
35-75a
4,200-5,700a•d
95-135c.d
(Add 1,700-3,6000
110-3003
to above estimates)
3,000-5,300e•f
190-450e,f
(Consult manufacturer)
—
(Consult manufacturer
—
200-6,500a
5-600
1,100-1,500e
3,900-7,9003
°Oregon Department of Environmental Qualm♦), December 1982. "Final Report -Oregon Experimental Systems Program;' Oregon DE9, Portland,
Oregon.
bAssuming pressurized distribution.
Assuming pressurized distribution is not required.
d Modification of estimate for recirculating sand filter with dralnfield, subtracting cost of drainfleld and adding cost of disinfection system and
outfoll line.
e Vermont Agency of Environmental Conservation, June 1978. "Rural Sewage Treatment in Vermont. Book 1: A Guide To The Alternatives;'
Vermont Natural Resources Council, Montpelier, Vermont.
f Modification of estimate for aerobic tank. adding cost of disinfection system and outfall line.
facility is overloaded or very close to design capacity new
connections may not be allowed. In other cases, treat-
ment capacity might be available but committed to other
future customers through service agreements, assignment
of sewer allotments, or other contractual agreements.
If treatment capacity is temporarily unavailable, it
may be practical to encourage installation of small-scale
treatment systems that can be abandoned as treatment
capacity becomes available. In one example, a developer
installed a small package plant and subsurface disposal
system to serve a professional office commercial develop-
ment near Downingtown, Pennsylvania, where a sewer
moratorium was in effect' Through an agreement with
the local sewer agency the development will be connected
as soon as a planned facility expansion is completed.
When the interim on -site treatment system is abandoned,
additional office units will be built on the land being used
for the subsurface disposal area.
In some situations, a long term sewer allotment may
be needed to serve a large scale development which will
be built -out over a period of several years. It probably
would not be practical to build an on -site treatment
facility to serve gradually increasing wastewater demand.
However, it may be possible to intercept and treat exist-
ing sewage flows approximately equal in volume to the
projected wastewater flows of the built -out project. This
would divert wastewater flows that would otherwise go
to the central treatment plant, thus making it possible for
the sewer agency to accept the sewage generated by the
new development as it is gradually built -out.
There are certain circumstances under which con-
nection to a public sewer system may not be the most
attractive alternative. If the public treatment system is
not well managed or is in poor operating condition, treat-
ment charges may be high. If major capital improve-
ments are planned (e.g., upgrading of treatment plant or
sewer repairs) significant increases in treatment fees can
be expected. Dramatic increases in service fees are less
likely with a financially stable sewer agency. If there is
doubt as to the technical or financial capability of the
operating agency, encouraging alternative treatment
methods should be considered.
Regulatory Requirements. The local sewer agency may
require that specific design and construction standards
for the collector lines and connection facilities be met
before accepting a proposed connection. In addition, the
developer, on behalf of the future property owners, may
be required to enter into a service agreement that defines
the services to be provided and establishes a basis for
charging a service fee. Many municipalities have sewer
use ordinances that impose restrictions on what can be
discharged to the public sewer system.
Operational Requirements. Operation of public sewer
treatment facilities is the responsibility of the public
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agency. The developer or a designated private operating
agent (e.g., private utility, contractor, or community
association) may be responsible for the maintenance of
collector lines and connection facilities such as sewer
extensions, pump stations, and force mains unless these
facilities are dedicated to the public agency. If all facilities
are dedicated to the municipality or local sewer agency
the developer and the future property owners will have
essentially no operational responsibilities except for the
obligation to comply with the applicable provisions of
sewer use ordinances or service agreements.
Public Attitudes. Attitudes toward the connection of
new developments to public sewer systems depend on
local circumstances. In communities where growth is
desirable such connections will generally be favored. In
fact, very often public sewer systems are built for the
purpose of supporting future growth. In areas where
existing sewer systems are overloaded or near design
capacity, new connections may be discouraged or even
prohibited under sewer moratoria. In cases where treat-
ment capacity is limited there may be considerable con-
troversy over the allotment of sewer hook-ups.
Costs. The service fees charged by public agencies may
or may not be a direct function of the actual costs of
operating the wastewater facilities; they vary widely
from one community to another. Treatment charges on
the order of $1.00 to $3.00 per thousand gallons of waste-
water treated are typical.
In addition to annual service fees, the public agency
may require an initial capital contribution (e.g., connec-
tion fee, facilities improvement fee, sewer allotment fee).
APPROPRIATE USES OF
INDEPENDENT SMALL-SCALE
TREATMENT SYSTEMS
This section describes several small-scale wastewater
treatment and disposal systems that can be installed at
the site of the subdivision or housing development it
serves. Systems discussed include a variety of "package"
treatment plants, lagoons, marshpond/wetland systems,
community septic tanks, sand filters, overland flow treat-
ment systems, land application systems, and subsurface
disposal systems.
Conventional Systems
Sewage treatment facilities are .usually required to pro-
vide a minimum level of treatment. The term "secondary
treatment" is commonly used to define this minimum
requirement and is usually measured in terms of the
degree to which certain pollutants are removed. Any
combination of processes that removes 75-85 percent of
the biochemical oxygen demand of "BOD" (a measure of
organic loading) and suspended solids is generally con-
sidered secondary treatment. After receiving this level of
treatment, the treated effluent can be disinfected and dis-
charged to a surface water body.
Any number of treatment systems can provide sec-
ondary treatment. Most are mechanical plants using
some form of biological treatment process, which for
purposes of this discussion are collectively referred to as
conventional treatment systems. Large-scale wastewater
treatment facilities are typically custom designed for a
particular application and constructed on -site. However,
for smaller facilities (i.e., treating less than 100,000
gallons per day), as would normally be required for a
moderately sized residential development (fewer than 400
homes), it is generally more economical to use prefabri-
cated or "package" plants which are available from a
number of manufacturers.
Package plants come in all sizes and shapes and most
use some variation of the activated sludge process used in
most custom-built municipal sewage treatment plants.
Typically, package plant sizes range from 10,000 gpd
(equivalent to 40 dwelling units) to 100,000 gpd (equiva-
lent to 400 dwelling units). Although they are relatively
simple in design and operation, package plants require
the close attention of a qualified operator to maintain an
acceptable level of performance. When properly operated
they can easily provide secondary treatment.
A smaller scale version of the package plant is the
aerobic tank, which also uses an activated sludge -type
treatment process, but is contained in a closed tank. The
tank is often buried below ground. Aerobic tank systems
typically range in size from 500 gpd to 10,000 gpd, and
can serve from 1 to 40 dwelling units. Greater numbers of
dwelling units can be served by using more than one
tank. Since aerobic tanks are essentially self-contained
treatment systems they generally require less operation
and maintenance attention than larger package plants.
However, frequent system inspections are necessary to
assure that acceptable treatment levels are maintained.
There are also several variations of conventional
treatment systems that may be appropriate in small-scale
applications. These include the oxidation ditch, rotating
biological contactor (RBC), activated bio-filter (ABF),
and sequencing batch reactor (SBR) processes. Although
these technologies are not yet widely used in small-scale
applications, they have been proven in full-scale applica-
tions and may offer distinct cost and operational advan-
tag� over more traditional treatment systems.
Oxidation ditch treatment systems typically use a
"racetrack" shaped aeration basin in which the waste-
water is aerated by a brush -type surface aerator. Oxida-
tion ditches have relatively long detention times, which
improve treatment efficiency and, at the same time,
reduce sludge production. These systems normally do
not require primary , clarification, which eliminates the
need for primary settling basins. (Note: many of these
advantages also apply to extended aeration -type package
plants). Oxidation ditch systems usually treat wastewater
flows of 100,000 gpd or more.
Rotating biological contactor treatment systems use
a "fixed growth" process in which the wastewater is
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TABLE 2. Typical Coat Ranges° (Conventional On -Site Treatment Systems)
10,000 gpd Capacity
100,000 gpd Capacity
Capital O&M
Capital
O&M
(S/gpd) ($/1000 gal.)
(S/gpd)
($/1000 gal.)
Secondary Treatmentb
Package Plant 5.00-7.00 2.00-3.00
2.00-3.00
.75-1.00
Aerobic Tank 4.00-6.00 1.00-2.00
—
—
Oxidation Ditch 15.00-20.00 2.00-3.00
4.00-6.00
.50-.75
Rotating Biological Contactor 5.00-10.00 2.00-4.00
2.00-5.00
.50-1.00
Activated Blo-Filter — —
4.00-6.00
1.50-2.00
Sequencing Batch Reactor — —
3.00-4.00
.50-1.00
Advanced Treatment
Chemical Addition 1.00-1.50 A0-.50
.50-4.00
AIJ-.50
Nltriflcation/Denitrification 3.00-4.00 .50-1.50
2.00-3.00
.50-1.50
Activated Carbon 2.00-4.00 .50-1.50
1.00-3.00
.50-1.50
Tertiary Filtration 1.50-3.00 .10-.25
.50-2.00
.10-.25
°AII cosh updated to 1984$; based on cost data from the following references:
1. U.S. EPA (1980). Innovative and Alternative Technology Assessment Manual, MCD-53.
2. U.S. EPA (1980). Construction Costs for Municipal Wastewater Treatment Plants, FRD-11.
3. U.S. HUD (19771 Package Wastewater Treatment Plant Descriptions, Performance, and Cost.
bCompiete system Including disinfection and discharge.
° Costs cited are in addition to base secondary treatment system.
treated by a biological film attached to rotating discs.
The rotation of the contactors first immerses the film into
the wastewater, where the microorganisms in the film
feed on the organics in the wastewater, the rotation then
exposes the film to the air where the microorganisms
absorb the oxygen they need to survive. This design
eliminates the need for supplemental aeration equipment
(i.e., blowers or surface aerators), which offers potential
energy cost savings. RBC treatment systems can provide
a consistently high level of treatment and are less
susceptible to process upset due to variations in hydraulic
and organic loading than are activated sludge processes.
A limited number of small-scale prefabricated RBC sys-
tems are available. These RBC package plants may be
applicable to smaller developments (1 to 200 dwelling
units). Full-scale RBC systems usually handle flows of
greater than 100,000 gpd (equivalent to 400 dwelling
units).
The Activated Bio-Filter (ABF) system also uses a
fixed growth treatment process. However, in this case the
wastewater flows through a tower made up of redwood
slats or plastic media. As with RBC systems, ABF treat-
ment systems require primary clarifiers to pretreat the
wastewater before it is applied to the bio-filter. Supple-
mental aeration systems may or may not be included.
ABF systems offer the same basic advantages as the RBC,
and like the RBC is available to a limited extent in
package plant form.
The Sequencing Batch Reactor (SBR), a relatively
recent development, is an activated sludge process oper-
ated on a batch basis where the aeration and final clarifi-
cation steps occur in the same tank. The SBR system is
claimed to require less operation and maintenance atten-
tion than conventional activated sludge systems. SBR
systems typically are applied to treat wastewater flows in
the range of 100,000 gpd to 5 MGD.
In some situations it may be necessary to provide
advanced levels of treatment (going beyond secondary
treatment) to comply with discharge permit conditions
set by regulatory agencies. This is normally accomplished
by modifying secondary treatment systems or by adding
supplemental treatment units to a secondary treatment
system. For example, if phosphorus removal is required,
chemicals can be added in the clarification process to
precipitate phosphorus containing compounds. If
ammonia removal is called for, activated sludge and fixed
growth processes can be modified so that ammonia is
biologically converted to nitrate. If total nitrogen limita-
tions are imposed, supplemental denitrification treatment
systems can be added to remove the nitrates. Activated
carbon adsorption systems might be considered if very
high organic removal levels are required. Tertiary filtra-
tion systems also can be used to produce a very high
quality effluent by filtering out residual suspended solids
and associated organics.
However, it must be noted that these advanced levels
of treatment have high initial capital costs as well as
operating costs (e.g., labor, chemicals). They also involve
relatively complex treatment processes that require a sig-
nificantly higher degree of operator skill than required
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for a typical secondary plant. Due to their operational
complexity, these systems are more vulnerable to process
upset and mechanical breakdown than the simpler
secondary treatment processes. For these reasons, ad-
vanced treatment systems are generally not recom-
mended for small-scale on -site treatment applications.
Such systems may be appropriate in special cases where
they prove to be the only cost-effective wastewater
management alternative; however, in these cases, care
should be taken to ensure that adequate operation and
maintenance is provided. It should be noted that land
application or subsurface disposal systems often can be
used in lieu of advanced treatment systems when stringent
discharge limitations exist.
Positive Features. The wastewater treatment methods
discussed above are considered proven technologies
capable of providing consistent levels of treatment. These
treatment system alternatives represent practical small-
scale applications of these technologies. These systems
are generally acceptable to regulatory agencies and
provide an effective means of wastewater treatment
when access to a public sewer system is not possible or
cost-effective.
In the past, small-scale treatment facilities, specifi-
cally "package plants," acquired a poor reputation due to
poor performance. In most cases this poor performance
was due to inadequate operation and maintenance. Pack-
age plants are often incorrectly perceived to be self-
sufficient. When neglected, these plants will inevitably
malfunction. However, if properly maintained, these
plants can provide very reliable service. Adequate opera-
tion and maintenance can be provided with part-time
staff or by private service contract and does not require
full-time attention. The performance of these facilities
should be monitored daily or at least several times a week
so that operational problems can be detected early and
corrected.
Many prefabricated treatment systems are available.
Complete technical specifications and cost information
on any particular system can be easily obtained from the
manufacturer or authorized local distributors. Once
selected, a package plant can usually be installed on very
short notice.
System Applicability. Conventional treatment systems
usually are not affected by physical site constraints
(except for extreme slopes and floodplains) and generally
only require access to a receiving stream that can accept a
surface water discharge. Most conventional treatment
systems require relatively small amounts of land, although
buffer areas should be provided between the plant and
residential areas. In some cases the construction of new
treatment facilities may be restricted by existing sewer
service franchise agreements, local water and sewer
master plans, wastewater facility plans, or local zoning
ordinances.
In situations where interim treatment facilities are
required pending future connection to a public sewer
system, the use of package plant systems may be particu-
larly appropriate. Many package plants can be easily
disassembled and thus lend themselves well to such uses.
In most cases these plants can be transported to other
sites and reused and, therefore, have a high salvage
value.
Regulatory Requirements. The construction of discharg-
ing wastewater treatment facilities is generally regulated
by state pollution control agencies or state health depart-
ments. These agencies are normally responsible for set-
ting discharge limitations and issuing discharge permits
under the National Pollutant Discharge Elimination
System. In addition, most states have explicit design
standards that apply to the construction of any new
treatment system. If the treatment system is to be pri-
vately owned and operated, the approval of a state public
utility commission or public service commission is gener-
ally required.
Operational Requirements. The importance of providing
adequate operation and maintenance for a small-scale
treatment facility cannot be overemphasized. A full-time
operating staff is generally not required for facilities
treating less than 1 MGD. However, as stated earlier, it is
important to perform frequent inspections of the facility
to monitor its performance. In addition, a routine main-
tenance schedule should be used.
If part-time staffing is not feasible, small-scale treat-
ment facilities can be operated by private contractors
under service contracts. However, great care must be
taken to assure that the contractor is technically capable
and reliable. It may also be possible to enter into a similar
type of service contract with a nearby public sewer
agency that is willing to contract out its staff on a part-
time basis.
Public Attitudes. As mentioned earlier, small-scale pri-
vate wastewater facilities such as package plants may be
negatively perceived in some areas. There is often a fear
that the local government may be forced to take over the
operation of a private treatment facility if the private
operator neglects to operate the system properly. There
also may be a perception that private treatment facilities
are of substandard design and construction.
Local officials need to be assured that the proposed
facility will meet current standards of design and con-
struction and that specific measures will be taken to
assure adequate operation and maintenance. Such assur-
ances can be made through third party service agree-
ments giving the local government the right of approval
over matters affecting the performance of the facility, or
through the posting of a performance bond by the private
operator.
Costs. The cost of a small-scale treatment system will be
site specific. It will vary depending on the local cost of
labor, utilities and materials, and the competitiveness of
bids received on manufactured equipment. For this rea-
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TABLE 3. Weal Coat Ranges for Wastewater Lagoonsa WI Coats Updated to 4984 s)
10,000 gpd Capacity
100,000 gpd Capacity
Capital O&M
Capital O&M
$/gpd $/1000 gal.
$/gpd . $/1000 gal.
Stabilization Pondb 6.00-7.00 .75-1.00
2.00-4.00 .30-.50
Aerated Lagoonb 4.00-6.00 1.00-1.50
1.00-3.00 .40-.60
Polishing Ponds .50-1.00 —
.25-.50 —
Fiitrationa 3.00-6.00 1.00-2.00
1.00-2.00 .50-1.00
° Based on cost data from the following sources:
1. U.S. EPA (1980). Innovative and Alternative Technology Assessment Manual, MCD-53.
2. U.S. EPA (1980), Construction Costs for Municipal Wastewater Treatment Plants. FRD-11.
3. U.S. HUD (1977). Package Wastewater Treatment Plant Descriptions, Performance, and Cost.
bCompiete system Including disinfection and discharge.
c Costs cited are In addition to base cost for lagoon.
son, the cost figures cited are provided only for the
purpose of making relative comparisons and should not
be used for cost estimating purposes. Typical ranges of
capital and operating costs are presented in Table 2.
Lagoons
When used in the context of wastewater treatment, the
term lagoon generally refers to either a stabilization pond
or an aerated lagoon. In a stabilization pond, sewage is
treated by a natural process whereby bacteria and algae
feed on the organics in the wastewater. The bacteria and
algae cells eventually die and settle to the bottom of the
pond,' where further decomposition takes place through
the action of anaerobic bacteria.
Stabilization ponds represent a simpld, almost main-
tenance -free method of wastewater treatment. However,
to allow sufficient time for the various natural treatment
processes to take place, long detention times are required.
Detention times of 30 to 40 days are typical; even longer
detention times are required in cold weather. These long
detention times necessitate large storage volumes, which,
due to the shallow depth of this type of lagoon (4-5 feet),
require large amounts of land. As a rough approximation,
a half acre of pond surface area will be required for every
10,000 gallons per day of treatment capacity (i.e., a popu-
lation equivalent of about 200 persons per acre of pond).
Aerated lagoons, on the other hand, can assimilate
much higher organic loadings due to the aeration process
and therefore require shorter detention times-3 to 10
days in warm climates, 8 • to 20 days in cold climates.
Aerated lagoons can also be made deeper since air can be
artificially introduced at any depth, whereas stabilization
lagoons rely on natural reaeration processes (exchange of
oxygen between the air and the wastewater at the surface
of the pond) in which only a surface layer of wastewater
is aerated. The shorter detention times and greater depths
possible with aerated lagoons reduce the land require-
ments to 1/3 to 1/10 of that required for a stabilization
lagoon.
Wastewater lagoon systems are usually designed
with at least three separate cells connected in series. Nor-
mally, disinfection is required before final discharge, and
additional treatment (i.e., polishing ponds or filtration)
may be necessary if a high quality effluent is desired. In
cases where underlying soils are moderately permeable
and there is concern for groundwater quality, wastewater
lagoons may need to be lined using either synthetic liners
or imported day soils.
Positive Features. The main advantages of wastewater
lagoons are their low capital cost and their simple design
and operation. Very little mechanical equipment is
required and energy requirements are minimal. Both
stabilization ponds and aerated lagoons are relatively
insensitive to fluctuations in hydraulic and organic load-
ings and produce considerably less sludge than con-
ventional treatment systems.
System Applicability. Wastewater lagoons are best suited
to larger developments where sufficient land is available
to allow the construction of the impoundments while
maintaining reasonable buffer distances between the
lagoons and nearby residential land uses. Two hundred
(200) foot buffer zones are common. Obviously, land
availability is a key requirement; if land is at a premium,
a lagoon may not be appropriate.
Since there is generally some carryover of algae cells
in lagoon effluent it may be difficult to achieve the effluent
quality required for some receiving streams. Although
aerated lagoons will produce higher effluent quality than
stabilization ponds, they generally cannot match the
treatment levels achieved by many conventional treat-
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ment systems. Where such requirements exist, lagoon
effluent can be further treated using sand filters or polish-
ing ponds. It may be possible to modify restrictive dis-
charge limitations on this basis. If land is available, lagoon
effluent also can be disposed of by land application.
Regulatory Requirements. Wastewater lagoons may not
be capable of meeting stringent discharge requirements.
However, the recent issuance of new regulations by the
U.S. Environmental Protection Agency redefines waste-
water stabilization ponds as "secondary treatment".(4)
This redefinition makes the use of lagoons possible in
many cases where regulatory requirements previously
precluded consideration of this alternative.
Design standards that apply to the use of lagoons
vary from state to state. These standards may require
impermeable liners, post -treatment, and buffer zones. If
such standards apply, technical guidance should be
sought from the appropriate regulatory agency.
Operational Requirements. Due to their simple design,
wastewater lagoons have few operational needs. The
operation of a stabilization pond normally involves three
basic tasks: site maintenance, aquatic weed control, and
collection of influent and effluent samples. If the lagoon
is properly designed (i.e., is not overloaded or under -
loaded), control of unusual weed growth .(e.g., duckweed,
cattails, etc.) and other nuisance conditions (e.g., odors
caused by excessive algae growth) should require only
occasional attention. When such problems do occur, they
are relatively simple to correct by controlling water levels
in the lagoons or by chemical treatment. Other operation
and maintenance activities are routine and easily man-
aged by a part-time staff.
The maintenance of pumps and aeration equipment
will slightly increase the operational attention required,
but still should require no more than a part-time main-
tenance staff in most cases. Aside from these routine
maintenance tasks, the accumulation of sludge at the
bottom of the lagoon must be monitored and sludge
removed periodically (every 5 to 10 years). Although the
operational requirements are nominal, wastewater
lagoons must be frequently monitored and operational
adjustments made as warranted. If these minimum
requirements are not attended to, a lagoon can soon
become a significant nuisance.
Public Attitudes. The most commonly cited public objec-
tion to wastewater lagoons is that they emit foul odors.
These odors are caused by overloaded or underloaded
conditions. Overloading causes excessive algae growth,
which eventually interferes with the natural reaeration of
the wastewater and causes anaerobic (i.e., septic) condi-
tions. Underloading causes a change in the balance of
aquatic organisms, which increases oxygen demand and
reduces the oxygen generating capacity of the algae. This
also leads to anaerobic conditions and, therefore, odors.
These problems can be minimized through proper design
and simple corrective operational procedures. Spring
Wastewater Management 43
thaw can also cause odor problems for a brief period
of time.
Negative public attitudes are almost always asso-
ciated with aesthetic effects (e.g., odors, appearance,
etc.). Occasionally, concern for public safety (e.g., access
to small children) is cited. These problems can be greatly
mitigated, if not eliminated entirely, by maintaining
adequate buffers from residential uses and by providing
visual screens and perimeter fencing. Nonetheless, if the
proximity of a proposed lagoon to residential areas raises
serious concern about potential aesthetic effects, other
treatment options should be considered.
Costs. The cost of constructing a lagoon is heavily
dependent on excavation prices that vary significantly
from one location to another. Operating costs also vary
from place to place as a function of local labor and utility
costs. Therefore, the cost figures presented are intended
to be used only as a rough guide. Typical ranges of
capital and operating costs are provided in Table 3.
MarshpondMettand Systems
Marshpond and wetland treatment systems are some-
times used to polish the effluent from another treatment
process. However, this method can also be used to treat
raw or partially treated sewage. The use of marshponds
and wetlands to treat wastewater falls under the broad
definition of aquaculture; that is, the cultivation of
aquatic plants, animals, and microorganisms for the pur-
pose of producing food, fiber, or fertilizer. In wastewater
applications aquaculture systems perform the additional
function of removing certain wastewater constituents
such as suspended solids, biodegradable organics, nutri-
ents, and pathogenic organisms. Some aquatic plants
(e.g., water hyacinths) are even capable of removing
more exotic pollutants such as heavy metals and complex
organics.
A wetland is generally defined as land where the
water table is at or near the surface, or land that is under
water much of the time, which supports the growth of
certain kinds of water tolerant vegetation such as cattails,
bulrushes, reeds, cypress trees, willow trees, etc. Natural
forms of wetlands include marshes, swamps, peat bogs,
wet meadows, and cypress strands. Marshponds are gen-
erally shallow ponds which support the growth of vascu-
lar plants (e.g., water hyacinths and duckweed) and, in
some cases, finfish, crustaceans and shellfish. Very often,
wetland plants such as cattails and bulrushes are found
along maishpond shores. Marshponds, marshes, and
swamps usually will have some outlet that allows dis-
charge to surface water. However, in certain types of
wetlands, such as peat bogs, wet meadows, and cypress
domes, evapotranspiration and percolation through the
soil may be the only means of dissipating the volumes of
water applied.
When wastewater is applied to a marshpond or wet-
land, it is renovated by many of the same natural proc-
esses that take place in wastewater lagoons and overland
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14 Management Information Service
flow systems. Suspended solids in the wastewater settle
out, while soluble organics and nutrients are assimilated
by bacteria found on plant surfaces and in the bottom
sediments. Most pathogenic organisms die off naturally
due to the unfavorable environment. In addition, the
aquatic plants absorb limited quantities of nutrients,
heavy metals, and complex organics, which are ulti-
mately removed from the system when the plants are
harvested. It is interesting to note that the amount of
nutrients and organics removed by plant uptake is very
small compared to that removed by the bacteria attached
to the plant surfaces.
Wastewater can be applied either to existing natural
ponds and wetland areas, or artificial aquaculture sys-
tems can be created for wastewater treatment. When
natural areas are used, wastewater applications are gen-
erally limited to treated effluent that has undergone
secondary treatment. Artificial systems, on the other
hand, can be designed to accept wastewater with minimal
pretreatment (i.e., primary clarification, or just screen-
ing). Man-made pond and wetland systems are generally
more efficient treatment systems since they are designed
to allow control of hydraulic and organic loadings and to
facilitate maintenance and harvesting operations. Totally
enclosed wastewater aquaculture systems allow year-
round control of temperature and climate as well as
hydraulic and organic loading.
Land requirements for marshpond/wetland treat-
ment systems will vary depending on the wastewater's
strength and the application rate. Wetland systems can
require anywhere from one to ten acres for every 10,000
gpd of wastewater applied (i.e., for every 40 homes
served), whereas marshpond systems will generally
require from one -tenth acre to one acre of water surface
area for every 10,000 gpd of treatment capacity.
Positive Features. The main advantage to using marsh -
pond or wetland treatment systems is that they can pro-
vide very high levels of treatment with minimal use of
mechanical or chemical treatment methods. The creation
of a m�rshpond or wetland may enhance the aesthetic
value of a property and can be used to protect sensitive
shoreline areas. Another positive feature is that harvested
plants can be sold for animal feed or fertilizer. Use of
anaerobic digesters to produce methane gas from the
harvested plants has also been proposed (Hercules, CA;
San Diego, CA).
System Applicability. Marshpond and wetland treat-
ment systems are applicable particularly when direct
stream discharge is either prohibited or restricted for
water quality reasons. In such cases, an existing or man-
made marshpond or wetland can be used to polish the
effluent from another treatment system, such as a pack-
age plant or lagoon, producing a discharge of nearly the
same quality as would be expected from a natural pond
or wetland. If regulatory agencies allow the application
of partially treated wastewater to a pond or wetland, it
may be possible to eliminate mechanical treatment facili-
ties altogether (except for screens and comminutors).
If natural ponds or wetlands are used they must be
reasonably close to the property served. If artificial sys-
tems are used, an adequate amount of land must be avail-
able (see discussion of land requirements above), and the
site must be suitable for such use (i.e., soils need to be
relatively impermeable and must support the growth of
rooted aquatic plants). Systems using water hyacinths are
best suited to milder climates, whereas duckweed, cattails
and bulrushes are more tolerant of colder climates. The
design and construction of an artificial marshpond or
wetland requires great care and should not be attempted
without the advice of an expert in aquatic ecosystems.
Regulatory Requirements. The acceptability of this
method of treatment will vary from state to state. Many
regulatory agencies have serious reservations regarding
the treatment of raw or partially treated sewage by
marshpond or wetland systems; however, several states
have accepted the discharge of secondary plant and
lagoon effluent to such systems (California, Mississippi,
Florida, Texas, Michigan). Disinfection generally is re-
quired, especially when natural ponds or wetland areas
are involved. Although it can be argued that pathogenic
organisms are destroyed in the natural environment cre-
ated by a marshpond or wetland, regulatory agencies
often mandate disinfection. When disinfection is required,
chlorination is the commonly used method. To minimize
the harmful effect on the plants and biota in marshpond
and wetland systems, the wastewater should be dechlori-
nated before being applied to the system. This can be
accomplished by installing a holding basin which allows
the residual chlorine to dissipate, generally in less than 24
hours.
Any discharging marshpond or wetland treatment
system will have to comply with state and federal dis-
charge requirements and will need a discharge permit.
Periodic testing of effluent quality will also be required in
most cases.
Operational Requirements. Once the vegetation is estab-
lished, the operation of a marshpond or wetland requires
very little attention. Depending on the organic loading
being applied, plant harvesting may or may not be re-
quired. Most artificial systems operate at higher loading
rates and will require periodic harvesting, perhaps two or
three times a year. The harvesting of cattails and other
tall emergent plants is normally accomplished using com-
mon mowing equipment. Artificial wetland systems usu-
ally are constructed in long narrow trenches to facilitate
mowing from the bank. The harvesting of floating aquatic
plants may require the use of special equipment (e.g.,
dredging equipment or mechanical harvesters) or tempo-
rary pond draining.
Routine maintenance of mechanical equipment (e.g.,
pretreatment facilities, pumps, and pipe distribution sys-
tems) when such equipment is used. If disinfection facili-
ties exist, frequent inspections are required and sufficient
chemical supplies must be maintained. Except for pre-
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TABLE 4. Typical Cost Ranges
Marshpond/Wetland Systemsa
(All Costs Updated to 4984 $)
(Treatment Capacity .1-1.0 MGD)
Capital Costb Operating Cost
($/gpd) ($/1000 gal.)
.Marshpond .50-2.00 .10-.50
Wetland .25-1.00 .10-.30
Pretreatment 4.00-3.00 .50-1.00
Disinfection° .75-1.00 .20-.30
°Costs based on actual cost data from several known installa-
tions (Hercules, CA; Martinez, CA; Vermontville, MI; Houghton
Lake, MI)
bNot including land cost.
Including dechlorinatlon holding pond.
treatment and pumping equipment, marshpond and wet-
land systems have essentially no energy requirements. As
mentioned earlier, periodic water quality samples may be
specified by a discharge permit. Such testing will be rela-
tively infrequent in most cases and can probably be
handled by a private testing laboratory -at nominal cost.
Public Attitudes. There may be considerable public
objection to proposals involving wastewater discharge to
existing natural wetlands or ponds due to the perceived
potential effect on natural habitats. In some cases any
wastewater discharge, even treated effluent, may be
unacceptable. The current uses of the water body (e.g.,
fishing, shellfishing, waterfowl refuge, etc.) will affect the
level of public objections. It is much less likely that
objections will be encountered when artificial marshpond
and wetland treatment systems are proposed, provided
natural habitats are not disturbed. In fact, the creation of
new wetland areas may be perceived as an asset.
When there is public concern for potential environ-
mental impacts associated with the use of marshpond or
wetland treatment systems, these effects should be
weighed against those associated with other treatment
alternatives, such as the risk of malfunction of a mechan-
ical treatment plant or the disturbance of natural habitat
involved in the construction of a sewer outfall.
Costs. Due to the variety of design and site conditions
that might apply in different cases, the cost of construct-
ing and operating a marshpond or wetland treatment
system will vary greatly. Since the land requirements are
significant, land cost will be an important factor.
Typical cost ranges are presented in Table 4 as a
rough guide. This cost information is based on data from
a limited number of installed marshpond/wetland treat-
ment systems. The typical size of these systems ranges
from 100,000 gpd to 1 MGD, which can serve from 400
to 4,000 homes.
Wastewater Management 15
Community Septic Tanks
Community septic tanks are larger versions of the tanks
used in individual on -lot septic systems. The basic design
of a community septic tank is similar to that of a standard
on -lot septic tank and its treatment function is the same:
to trap solids, oil, and grease. A septic tank will typically
remove up to 75 percent of the suspended solids and oil
and grease in raw sewage and will reduce the organic
loading (i.e., BOD) by about one half.5 The treatment
efficiency of a septic tank can be improved significantly
by using a two compartment tank which reduces the risk
of solids and floating oil and grease escaping through the
outlet. The same effect can be accomplished by installing
two tanks in series.
Pre -cast septic tanks usually are available from local
suppliers in sizes up to 2,500 gallons (which can typically
serve up to four or five dwelling units). If larger treatment
capacities are required, the septic tanks will most likely
have to be constructed in place using pre -cast sections or
poured -in -place concrete.
Positive Features. The major assets of a community
septic tank are its simple construction and its nominal
operation and maintenance requirements. The lack of
moving parts and mechanical equipment eliminates the
need for many routine maintenance chores and there is
usually no electrical power requirement. Community
septic tanks are relatively easy to install and much less
expensive than conventional treatment plants and
lagoons.
System Applicability. Community septic tanks are almost
always used in conjunction with a subsurface disposal
system. Because septic tank effluent quality does not
meet secondary treatment requirements, the effluent can-
not be discharged to surface water without further treat-
ment. In addition, the foul odors often associated with
septic wastes makes surface discharge inappropriate in
most cases.
By discharging septic tank effluent to a subsurface
drainfield, these problems are avoided. This method of
disposal is the same as that used in an on -lot septic sys-
tem and is a generally accepted practice. However, since
larger volumes of wastewater are involved when com-
munity septic tanks are used, great care must be taken in
designing the septic tank. For example, additional storage
capacity may be necessary to compensate for peak flow
surges.
Although community septic tanks normally are used
to treat raw sewage, they can also be used to receive
effluent from small diameter gravity sewers or septic tank
effluent pump pressure sewer systems. When such systems
discharge to a subsurface disposal system the community
septic tank provides a margin of safety by trapping any
excess solids, oil, and grease that might have overflowed
from the individual septic tanks in the collection system.
This protects the drainfield from premature clogging.
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16 Management Information Service
Regulatory Requirements. State regulations sometimes
include specific provisions for the use of large community
septic tanks. Very often, specification for larger than
normal septic tanks will be addressed in codes regulating
on -lot disposal systems. Where such standards do not
exist, technical guidance pertaining to the design and
construction of community septic tanks may be available
from other states. Since the basic design of a septic tank is
relatively straightforward, the primary concern of regu-
latory agencies will relate to the structural integrity of the
tank itself. Regardless of specific local requirements, the
design of any large community septic tank should be
certified by a licensed professional engineer.
The use of community septic tanks in conjunction
with subsurface disposal systems may not be acceptable
to some state and local regulatory agencies. This is usu-
ally due to reservations concerning potential ground-
water impacts (i.e., elevated nitrate concentrations) and
operational problems. In fact, these systems require care-
ful design and construction and are sensitive to hydraulic
overloading. There have been cases where such systems
have failed due to poor design and construction practices.
However, the state of art is well enough established that
these systems can be properly applied with appropriate
regulatory guidance and supervision.
Public Attitudes. There may be some local reluctance to
accept a community septic tank as a treatment system
because septic tanks often are associated with foul odors
and sewage back-ups based on experiences with on -lot
septic systems. In fact, these problems usually result from
the homeowner's failure to provide required routine
maintenance (i.e., periodic pumping of the tank). Such
problems would not normally be expected with a com-
munity septic system since regular maintenance would be
the responsibility of a public agency or private manage-
ment agency.
Costs. The cost of a community septic tank will depend
entirely on the availability of pre -cast tanks and the pre-
vailing cost of labor and materials in a particular region.
Local suppliers and contractors should be contacted for
prices.
Sand Filters
The use of filtration to provide higher levels of treatment
was mentioned in the discussion of conventional treat-
ment systems and lagoons. Filtration also can be used to
treat septic tank effluent to produce a higher quality dis-
charge. The type of filter normally used for this purpose
is an intermittent sand filter, which can be either open or
buried. A recently developed variation of the intermittent
sand filter is the recirculating sand filter. In this variation,
most of the discharge from the sand filter is diverted to a
recirculation tank where it mixes with incoming septic
tank effluent and is reapplied to the filter. This has the
effect of diluting the wastewater applied to the filter and
it improves filter performance and reduces clogging.
Septic tank effluent is applied in intermittent doses
at a specific loading rate that determines the size of the
filter required. The loading rate for a buried sand filter is
generally less than 1.0 gallon/square foot/day, while the
loading rate for an open sand filter can be as high as 10.0
gal./sq. ft./day. A recirculating filter normally operates
in the range of 2.0 to 3.0 gal. /sq. ft. /day. The size of the
filter (i.e., the surface area) required is determined by
dividing the design flow by the appropriate loading rate.
The performance of a sand filter is sensitive to loading
rate. Overloaded filters will be prone to clogging and will
require frequent cleaning. Clogging of the filter may also
be a problem if the solids concentration in the septic tank
effluent is higher than normal (i.e., greater than 75 mg/1).
Positive Features. Sand filters are an effective and relia-
ble method of upgrading septic tank effluent to meet
secondary, or better, treatment standards. Sand filters not
only remove suspended solids but also reduce organic
loading and reduce nitrogen levels through nitrification
and denitrification. The types of filters normally used in
such applications (i.e., intermittent sand filters) are rela-
tively simple in design and easy to operate.
Buried sand filters are essentially maintenance free,
although they may become clogged after several years
use and require resting or chemical treatment. To mini-
mize clogging, lower loading rates are generally recom-
mended for this type of filter. This, however, means that
larger filter sizes are needed compared to open and recir-
culating filters. Despite the added cost of materials (i.e.,
sand, gravel, and pipe), buried sand filters are often more
cost-effective than other types of filters since they gener-
ally do not require concrete enclosures.
Open sand filters can be operated at much higher
loading rates than buried filters, but they require frequent
maintenance to sustain peak performance. The surface
layer of sand must be periodically scraped clean as it
becomes clogged with solids. Recirculating sand filters
operate at somewhat lower loading rates and require less
maintenance than conventional open filters. Recirculat-
ing filters thus have the advantage of being capable of
handling relatively high loading rates without requiring
much operator attention.
System Applicability. The use of a sand filter may be
appropriate where site conditions are not conducive to
subsurface disposal of septic tank effluent. Because of the
high quality effluent produced, regulatory agencies often
allow subsurface disposal of sand filter effluent where
groundwater protection concerns prevent disposal of
septic tank effluent. In other situations subsurface dis-
posal of any kind may be infeasible due to impermeable
soils, shallow bedrock, or very steep slopes. In such cases
it may be possible to discharge septic tank effluent to
surface water (i.e., streams, lakes, rivers) after sand filter
treatment. This may prove to be more cost-effective than
using conventional secondary treatment methods (e.g.,
mechanical treatment plants). If the sand filter effluent is
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TABLE S. Typical Cost Ranges
Sand Filters° (All Costs Updated to 4984 S)
Capital Costb
($/gpd)
Buried Sand Filter 3.00-8.00
Open Sand Filter 3.00-6.00
Recirculating Sand Filter 6.00-40.00
Cost estimates by Roy F. Weston. Inc.
b Costs apply to small Installations (less than 10.000 gpd); costs
do not include the cost of pretreatment or disinfection
facilities.
discharged to surface water, disinfection will probably be
required.
Regulatory Requirements. Filtration is a commonly
accepted wastewater treatment practice. Most states have
design standards for sand filters but these usually apply
to large-scale facilities. Since the same basic design prin-
ciples apply, regulatory agencies generally will accept
simplified designs for smaller applications. Although the
design of a sand filter is relatively- straightforward,
specifications regarding loading rate and the physical
characteristics of the sand used (i.e., effective particle
size, particle size distribution, etc.) will vary from state to
state.
Operating Requirements. As mentioned earlier, buried
sand filters require little or no maintenance, while open
sand filters require considerably more attention to pre-
vent the surface layers of sand from becoming clogged.
Recirculating sand filters require periodic inspection and
occasional cleaning but demand much less operator
attention than conventional open filters (one or two
hours per week for a recirculating filter compared to at
least 8 hours per week for an open filter, each serving 20
to 30 homes).
The maintenance of a sand filter does not require
any special training or skills. The primary maintenance
chores include keeping the surface of the sand filter clean
and keeping distribution piping clear of obstructions. The
only other direct operational requirements relate to main-
tenance of pumping units and occasional adjustment of
dosing rates. Although not related directly to the opera-
tion of the sand filter, it is important to assure that the
septic tanks ahead of the filters are properly maintained
(i.e., periodic pumping of solids). Regular septic tank
maintenance prevents excessive solids loading to the
filter, which can lead to filter surface clogging.
Public Attitudes. Since sand filters produce a relatively
high quality effluent, there is generally no adverse public
reaction to their use. Odors and other nuisance problems
can develop if a sand filter is not properly maintained.
Wastewater Management V
Ponding of effluent on the filter surface due to overload-
ing or inadequate cleaning can cause septic conditions to
develop and may contribute to problems with flies and
mosquitos. Excessive weed growth on the surface of a
filter can be unsightly and will reduce the filters effec-
tiveness. All of these problems can be avoided through
proper maintenance.
Costs. The major capital cost components in the con-
struction of a sand filter include the concrete, sand, and
gravel. The cost of these materials is subject to local
pricing. The approximate cost ranges for different types
of sand filter systems given in Table 5 are presented as a
rough guide. Local material costs must be confirmed
before an accurate cost estimate can be made.
Operating cost is mainly related to labor cost, which
varies widely among locations. Labor requirements range
from almost nothing for a buried sand filter to 50-100
hours per year for a recirculating filter, and 300-500
hours per year for a conventional open filter. If pumping
is required, electrical power costs must be considered.
Power costs will generally be nominal because of the rela-
tively small size of the pumps typically used.
Overland Flow
In an overland flow system, wastewater is applied at the
top of a gently sloping hill and flows over the surface of
the ground to the bottom of the hill where it is collected,
disinfected, and discharged. The suspended solids in the
wastewater settle out and lodge on the surface vegetation
where they eventually decompose. The organic matter
and nutrients in the wastewater are consumed by soil
bacteria and absorbed by plant root systems. These
natural processes produce an effluent that generally
exceeds secondary treatment requirements.
Overland flow systems have been used to treat raw
sewage as well as wastewater lagoon effluent and have
proven to be an effective treatment method in both appli-
cations. When raw sewage is treated, only limited pre-
treatment (i.e., screening) is required. When lagoon
effluent is treated, there may be significant carryover of
algae cells, which tend to remain suspended in the waste-
water as it flows over the surface. This in turn contributes
to high suspended solids concentrations in the effluent.
However, more effective algae removal usually results if
the system is operated at a lower loading rate.
Positive Features. Overland flow provides a relatively
high level of treatment with minimal use of mechanical
equipment. Due to its simple design, this treatment sys-
tem is low in capital cost and has nominal operation and
maintenance requirements. It has the added advantage of
producing a crop (e.g., hay) that can be harvested and
sold to supplement wastewater operations revenue.
System Applicability. Certain site characteristics must be
present to use an overland flow system. The overland
flow plots must have a slope of 2 to 8 percent and should
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TABLE 6. Typlcai Cost Ranges for Overland
Flow Systems° (AIL Costs Updated to 1984 S)
10,000 gpd 100,000 gpd
Capacity Capacity
Capital Costb 5.00-10.00 1.00-2.00
(Slgpd)
Operating Costb 4.00-2.00 .25-.50
($i1000 gal.)
° Based on cost data from the following sources:
1. U.S. EPA (1980). Innovative and Alternative Technology
Assessment Manual, MCD-53.
2. U.S. EPA (1980). Construction Costs for Municipal Waste.
water Treatment Plants, FRD-11.
3. U.S. HUD (1977), Package Wastewater Treatment Plant
Descriptions. Performance and Cost.
bComplete system Including disinfection and discharge;
capital costs do not Include land costs.
be 100 to 300 feet in length in the downslope direction.
Although a site can be terraced to provide the proper
slope, the natural terrain should not be very flat or steep.
The soils beneath the overland flow plots should be rela-
tively impermeable so that the wastewater does not seep
into the ground and possibly contaminate groundwater.
At the same time, the top soil should be capable of sup-
porting the growth of perennial moisture tolerant grasses.
Overland flow systems are best suited to rural or
semi -Waal areas where large plots of pasture land or
meadow land exist. (There also may be a greater demand
for the harvested hay in such areas.) Milder climates are
preferable since they allow year-round operation of the
system. Where year-round operation is not possible,
storage lagoons capable of holding flows during the non-
operational periods must be provided.
The amount of land required to construct an over-
land flow system depends on the type of waste treated. If
screened raw sewage is applied, roughly one acre of over-
land flow plots should be provided for every 10,000 gpd
(i.e., 40 homes) of treatment capacity, whereas only half
an acre is required for every 10,000 gpd of lagoon effluent
applied.
Regulatory Requirements. Although overland flow
treatment systems have been approved in many states
(Arkansas, Louisiana, Mississippi, Texas, Oklahoma,
Florida, Illinois, North Dakota, and Nebraska), regula-
tory agencies may be reluctant to accept this method of
wastewater treatment, particularly when raw wastewater
is to be applied.
In many cases specific design standards will not exist
and every new application will require special review. It
may be helpful to consider overland flow systems under
the category of wastewater irrigation, which is accepted
in most states. The major difference between overland
flow and conventional wastewater irrigation is that in
overland flow systems the wastewater is applied at a
higher rate (up to 16 inches per week compared to 1 or 2
inches per week for a typical spray irrigation system).
The higher application rates are possible because most of
the wastewater applied to an overland flow system runs
off the site and is collected, disinfected, and discharged,
whereas in a wastewater irrigation system all the applied
wastewater is either evaporated or absorbed by the soil.
Operational Requirements. The operational demands of
an overland flow system are nominal. Once the desired
operating schedule is established (i.e., the rate and dura-
tion of wastewater application) operation is fairly rou-
tine, although daily attention is required. Automatic
timed pump controls can be used to eliminate the daily
chore of turning the system on and off. In any case,
highly skilled operators are not required. In fact, a back-
ground in farming is more helpful than experience in
wastewater treatment.
Public Attitudes. The general public and local officials
may express reservations about applying raw wastewater,
or even lagoon effluent, to an open field. One common
concern is that humans may be exposed to pathogens.
Although off -site pathogen transport may be possible
with spray -type irrigation systems via the dispersion of
an aerosol -like mist, such transport is not likely in
overland flow systems where the wastewater is applied
directly to the ground. Of course, site access should be
restricted by fencing to prevent direct contact with the
wastewater prior to disinfection.
Costs. Typical capital and operating cost ranges for over-
land flow systems are provided in Table 6. It should be
kept in mind that this cost information is based on some-
what limited operating experience and is only a general
indication of cost ranges.
Land Application By Spray Irrigation
Land application of wastewater generally involves irriga-
tion using treated wastewater effluent. Although partially
treated wastewater can also be applied to the land, most
state regulatory agencies require that wastewater receive
at least secondary treatment before land application. The
most common type of land application is spray irriga-
tion. In a spray irrigation system the effluent is applied
using sprinklers or spray nozzles. The sprinklers can be
fixed in place or mounted on a movable pipeline. The
latter is often used in agricultural applications. Drip irri-
gation systems, such as those typically used in orchard
irrigation, can also be used to apply wastewater but may
require higher levels of treatment to remove solids which
might clog the small discharge outlets. By the time the
wastewater percolates deep into the soil, it has become
nearly drinking water quality. For this reason land appli-
cation systems are often referred to as "living filters:'
As in any irrigation system, the rate at which the
irrigation water (i.e., effluent) is applied depends on the
weather, the stage of plant growth, and soil drainage
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characteristics. Since the wastewater cannot be applied
continuously there must be provision for storing the
treated effluent for periods of up to 90 days. This storage
is usually provided by large holding lagoons. When con-
ditions are right for irrigation, the effluent is pumped
through a network of pipelines to the various fields or
parcels to be irrigated. Woodland areas are generally less
sensitive to the rate at which wastewater is applied. In
fact, in some cases, wastewater effluent has been applied
to woodlands year-round, even in freezing conditions.
For this reason less storage is required for woodland land
application systems.
Land requirements for land application systems (i.e.,
spray irrigation) will be a function of soil characteristics,
the type of vegetation to which the wastewater is applied,
and crop production objectives. In the production of cash
crops (e.g., corn, soybeans, alfalfa, etc.), the rate at
which wastewater is applied must be controlled to main-
tain ideal soil moisture conditions. On the other hand, if
wastewater disposal is the primary goal, the only limiting
factor is the soirs capacity to absorb the applied waste-
water. The higher the application rate, the less the land
requirement will be. When wastewater disposal is the
main objective, application rates of up to 2 inches per
week may be possible, and land requirements will range
from 2 to 10 acres for every 10,000 gpd of wastewater
applied. If crop production is the main objective, the
average application rates over the typical growing season
will be much lower, and 5 to 10 times as much land will
be required.
The selection of a cover crop depends not only on
the crop production objective, but also on the waste-
water treatment objective. If nutrient removal is re-
quired, forage crops such as coastal bermuda grass, reed
canary grass, fescue, and alfalfa will be the most effec-
tive. When nutrient removal is not a critical requirement,
and it is desirable to maximize application rates, water
tolerant perennial grasses or forest crops will serve best.
Positive Features. Treating wastewater by land applica-
tion is one of the most environmentally sound waste-
water treatment methods known. It is effective in purify-
ing the wastewater and it recovers nutrients from the
wastewater and recharges groundwater resources. In
fact, in some cases groundwater recharge may be the
primary objective.
Land application systems are relatively simple in
design and operation and have nominal energy require-
ments. Energy requirements may be significant, however,
if the effluent has to be pumped for long distances or over
high elevations.
If cash crops (e.g., feed corn, soybeans, nursery
products, etc.) are produced, supplemental operating
income can be realized. Effluent can also be used to irri-
gate landscaped areas such as parks and golf courses. In
such cases the water bill savings can be significant.
System Applicability. Land application systems are often
applied as a last resort when surface discharge is not
Wastewater Management V
possible. Land application often is chosen as an alterna-
tive to costly advanced treatment systems when stringent
discharge requirements are imposed. In some cases, land
application is used only part of the year to meet seasonal
discharge requirements (e.g., nitrogen and phosphorus
limitations imposed during summer low -flow periods). In
other cases, land application of wastewater effluent may
be dictated by the demand for irrigation water or by the
need to replenish depleted groundwater reserves.
Land application feasibility is affected by site suit-
ability. Soils should be loamy and well -drained. Milder
climates are preferable, although land application sys-
tems have been successfully used in colder climates.
Woodland areas often are effective land application
sites, particularly in colder climates. Although forest crops
are not as effective as forage and field crops in removing
nitrogen, other treatment mechanisms, similar to those
occuring in overland flow systems, can be expected to
take place in the heavy ground cover typical of woodland
areas. The use of wastewater irrigation can be particu-
larly well -suited to silvicultural operations (e.g., com-
mercial tree arms and small-scale foresting operations).
Regulatory Requirements. Standards pertaining to the
design and operation of land application vary from state
to state. Most states require some pretreatment of the
wastewater. Disinfection of the wastewater before land
application will often be required. Regardless of the treat-
ment level and disinfection provided, wastewater irriga-
tion of crops intended for human consumption is gener-
ally prohibited by public health codes.
State regulations governing the use of land applica-
tion systems typically include effluent storage require-
ments (i.e., holding capacity required during wet weather
periods and winter months when effluent cannot be
applied) and buffer zone requirements (i.e., setback
distances and screening requirements).
Extensive site testing, involving soils evaluations
and groundwater sampling, will usually be required. Per-
mit applications often have to be supported by detailed
technical assessments of site suitability. If a proposed
land application plan becomes controversial, the review
and approval process can be delayed, and additional
technical studies may be required.
Operational Requirements. The operation of a land
application system consists of three basic elements: pump
maintenance, line maintenance, and crop management.
Pump maintenance involves routine preventive mainte-
nance (lubrication, inspection, etc.) and equipment repair
as needed. With permanently installed irrigation systems,
line maintenance is nominal (i.e., occasional flushing of
lines and draining of the lines at the end of the season).
Spray nozzles may become clogged with solids from time
to time, but generally should not present a major main-
tenance problem. If spray nozzle clogging becomes a
chronic problem, sprinkler modifications or additional
effluent pretreatment (e.g., screening or filtration) may
be required.
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20 Management Information Service
Crop management probably is the most important
operational requirement in this type of system. The rate
at which the wastewater is applied must be regulated to
match crop requirements and the soil's drainage proper-
ties. Application rates must be constantly adjusted to suit
changing climate and weather conditions. System opera-
tors should have experience in agricultural operations. In
fact, local farmers may be an invaluable resource in
determining the most appropriate crop management
techniques to be applied.
Public Attitudes. There may be some public objection to
land application of wastewater because of perceived
public health risks. This is largely a function of the
proximity of the proposed land application site to resi-
dential areas. The more isolated the site, the less likely it
is to generate public concern. If a land application site is
near residential properties, the site should be adequately
screened (e.g., by dense woods) and fenced to restrict
access. Considering that in most cases the wastewater has
undergone at least secondary treatment, there should be
no odor problems or other aesthetic or nuisance problems.
Costs. Typical capital costs (not including land) and
operating costs are presented in Table 7. These costs are a
rough guide. Obviously, land costs will be significant for
this type of treatment system. One way to avoid the cost
of land purchase is to enter into an agreement with local
farmers under which they agree to allow wastewater to
be applied to their land. It may be possible to sell the
effluent as an irrigation water supply. In estimating
operating costs,.projected income from the sale of effluent
or crops should be used to offset operating expenses.
Subsurface Disposal
The use of subsurface disposal systems in individual
home sewage disposal systems (i.e., septic systems) was
discussed earlier. The same type of system can be used to
dispose of effluent from larger community treatment sys-
tems. The basic principle is the same: effluent is distrib-
uted through a network of pipes installed in underground
stone -filled beds or trenches and is absorbed by the sur-
rounding soils. As the effluent percolates through the
soil, it is treated by a number of natural treatment
processes.
The soil acts as a filter by trapping particulate matter
(i.e., suspended solids) that cannot pass through the small
soil pores. This filtering action is enhanced by a biologi-
cal clogging mat that usually forms at the soil -gravel
interface in a drainfield. Many other waste constituents
were attracted by the electrical charge on soil particles
and remain attached (i.e., absorbed) to the soil. Phos-
phates, for example, are readily absorbed by fine -
textured, organic soils (i.e., clay soils and loam soils).
Organic matter in the effluent (measured as BOD) is bio-
logically decomposed by bacteria that thrive in the clog-
ging mat and in the soils just below the mat. Most of the
bacteria and viruses in the wastewater, which may or
may not be pathogenic (i.e., capable of transmitting
disease), are retained by the clogging mat and in the soil
below, where they are either consumed by soil microor-
ganisms or eventually die off.
Generally finer texture soils with smaller particle
sizes are more effective in removing pathogens and phos-
phates. Fine -textured soils also can retain ammonium to a
limited extent. The treatment efficiency of fine -textured
soils is due to the chemical activity of the soil particles
and the longer contact times resulting when the waste-
water has to flow through the smaller pores.
Ideally, aerobic conditions should exist in the drain -
field to promote the oxidation of organic matter and
prevent excessive buildup of the clogging mat. To assure
this, the soils should be well drained and unsaturated
(i.e., not inundated with effluent or natural ground-
water). This also precludes short-circuiting that may
occur through the larger pore spaces when the soil is
saturated. The septic tank effluent should travel through
at least four feet of unsaturated soil to provide adequate
wastewater renovation.
The treatment efficiency and longevity of a soil
absorption system is a function of many factors
including:
• The soil's ability to transmit water;
• The depth of unsaturated soil available;
• The texture, organic content, and chemical activity
of the soil;
• The rate at which effluent is applied; and
• The wastewater characteristics of the effluent from
the septic tank or other pretreatment units.
All of these factors should be taken into account
when designing a subsurface disposal system.
The standard drainfield, as described above, relies
on the effluent flowing through the distribution network
by gravity. This tends to heavily load the upper portions
of the drainfield and underutilize the rest of the absorp-
tion area. This, in turn, can lead to an excessive build-up
of the clogging mat, reducing the total absorption capac-
ity of the drainfield.
Theoretically, a more even loading of the entire
absorption area would result in greater treatment effi-
ciency and longer drainfield life. Dosing and pressurized
distribution are two methods of achieving this. Dosing
involves collecting a pre -determined volume of treated
effluent and discharging it in a single dose to the drain -
field. This can be done using a siphon device and dosing
chamber. By periodically discharging a large volume of
effluent to the drainfield, the entire absorption area is
utilized, thus maximizing treatment efficiency. An added
benefit is that the intermittent periods of no discharge
allow the drainfield to drain and be exposed to air. This
promotes oxidation of organic matter and prevents the
excessive growth of anaerobic organisms, which can pro-
duce impermeable gums and films capable of sealing the
infiltrative surfaces of the drainfield.
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Wastewater Management 24
TABLE 7. Typical Cost Ranges for Land Application Systems° (Spray Irrigation Systems)
(All Costs Updated to 1984 S)
.01 MGD Treatment Capacity 1 MGD Treatment Capacity
Capital Cost Operating Cost Capital Cost Operating Cost
(S/gpd) ($/1000 gal.) (S/gpd) ($/1000 gal.)
Spray Irrigation
Systemb 3.00-6.00 .50-1.00 4.00-3.00 .10-.30
a Cost Information based on data presented in the following publications:
1. U.S. EPA (1980) Innovative and Alternative Technology Assessment Manual, MCD-53.
2. U.S. EPA (1980) Construction Costs for Municipal Wastewater Treatment Plants, FRD-11.
3. U.S. HUD (1977) Package Wastewater Treatment Plant Descriptions, Performance, and Cost.
b Low rate (.5-4 Inches per week) application rate; not Including cost of pretreatment facilities, storage lagoons, and land.
Another form of dosing can be achieved using a
pressure dosing or pressure distribution system. This in-
volves pumping effluent through a network of small
diameter perforated pipes in periodic doses. As with a
siphon dosing device, the frequency of dosing is deter-
mined by the storage volume. The normal operating
pressures in the distribution network are relatively low,
typically 1 to 2 pounds per square inch. Pressure distribu=
lion is generally recommended with community subsur-
face disposal systems to assure even distribution in the
typically large absorption areas.
The practice of alternating drainfields also is gener-
ally recommended. Dividing the soil absorption system
into more than one field to allow alternate use of the
individual fields over extended periods of time can extend
the life of the absorption system. Alternating operation
of the fields permits part of the system to rest periodically
so that the infiltrative surface can be rejuvenated natu-
rally through biodegradation of the clogging mat. The
resting field also acts as a standby unit that can be put
into immediate service if a failure occurs in the other part
of the system.
Alternating systems commonly consist of two fields.
Common practice is to switch fields on a semi-annual or
annual schedule by means of a diversion valve. A pres-
sure dosing system can also be adapted to operate with
alternating drainfields.
Special care should be taken when considering the
use of alternating fields in sandy soils. In such soils the
use of alternating beds may increase the chance of
groundwater contamination because of the loss of treat-
ment efficiency when the clogging mat is decomposed
after resting. Nonetheless, in most cases the practice of
using alternating drainfields is recommended.
The amount of infiltrative surface required for a sub-
surface disposal has traditionally been determined on the
basis of a percolation test. Despite its widespread use, the
percolation test may not be a valid indicator of absorp-
tion area requirements. The percolation test measures the
hydraulic conductivity of the soil under saturated flow
conditions using clean water. This obviously does not
simulate conditions in an operating drainfield. The devel-
opment of a biological clogging mat usually precludes the
existence of saturated flow conditions. More importantly,
the effective infiltration rate will, in most cases, be largely
determined by the resistance of the clogging mat and not
the permeability of the soil. The resistance of the clogging
mat depends on the thickness and composition of the
mat, the hydrostatic pressure exerted by the ponding of
effluent, and the texture properties of the underlying soil.
Although the rate at which effluent will be absorbed
is not a direct function of a soil's percolation rate, soil
texture can affect the rate and degree of clogging mat
development which in turn will determine the effective
infiltration rate. The loading rate or effluent application
rate should therefore be determined on the basis of soil
texture rather than on the soil's "perc rate:'
Some studies have shown that systems installed in
soils with higher perc rates often fail more often than
systems installed in poorer soils. This is apparently
caused by undersizing of the systems, since the high perc
rate allowed loading rates that exceeded the infiltration
capacity of the clogging mat ° This supports the argu-
ment that absorption areas should be sized on the basis of
the infiltrative capacity of the clogging mat, rather than
the permeability of the soil. In sandy loam type soils
1000-2000 square feet of absorption area would be re-
quired for every 1000 gpd of septic tank effluent applied
(i.e., for every three or four homes), whereas 3500 to
7000 square feet per 1000 gpd would be required in clay
soils (i.e., greater than 40% clay content).
When sizing a subsurface disposal system, adequate
area should be provided not only for the drainfield itself,
but also for a buffer zone surrounding the drainfield to
facilitate lateral movement of effluent and evapo-
transpiration. The buffer zone should be grass covered
and heavily planted with shrubs and small trees to
enhance evapotranspiration. Any existing trees in this
area should be preserved. No buildings, swimming pools,
patios, sidewalks, or paved areas should be allowed in
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22 Management Information Service
the buffer zone. Surface drainage should be directed
away from the drainfield and buffer zone. An additional
area equal to the total area of the drainfield and buffer
zone should be set aside for future system replacement.
When alternating drainfields are used, the total absorp-
tion area should be twice that for a single drainfield;
however, loading rates in the high end of the range can be
used to calculate absorption area requirements.
Positive Features. Subsurface disposal systems provide
an effective means of disposing wastewater effluent with-
out risk of direct human contact. This is a distinct advan-
tage over surface discharge and land application. Also,
since the system is below ground it is not affected by wet
or cold weather conditions as are land application sys-
tems. An added advantage is that the subsurface disposal
system site can be used for other purposes such as open
space, recreational areas, etc.
Subsurface disposal systems require minimal opera-
tion and maintenance attention and generally provide a
high level of effluent renovation. However, while soil
absorption systems are effective at removing suspended
solids, organic matter, bacteria, and viruses, they are
relatively ineffective at removing nitrates. Nitrates are
created from the ammonia in septic tank effluent through
the nitrification process (the conversion of ammonia to
nitrate by nitrifying bacteria), which takes place under
aerobic conditions in the drainfield. Nitrates, being very
soluble and not readily absorbed, leach through the soil
and present the potential of contaminating- groundwater.
This presents a problem if nitrate concentrations approach
45 parts per million.
Subsurface disposal systems also accomplish ground-
water recharge, which may be very important in areas
where groundwater depletion is a concern. Of course,
whenever groundwater recharge is proposed, potential
effects on groundwater quality should be carefully
evaluated.
System Applicability. The use of subsurface disposal sys-
tems might be considered when surface discharge and
land application options are infeasible or undesirable.
They are well suited where septic tank effluent collection
systems are planned. Treated effluent from other treat-
ment systems also can be disposed of in subsurface dis-
posal systems. In fact, it may be possible to use smaller
absorption areas since clogging of infiltrative surfaces is
less likely with higher quality effluent. In some cases,
higher levels of pretreatment may be required to protect
groundwater quality.
Site constraints may preclude or limit the use of sub-
surface disposal systems. Certain soil properties (i.e., soil
depth, soil type, structure, permeability, hydraulic con-
ductivity, etc.) are required for this type of treatment
system to function properly. The underlying soils should
not be saturated by natural groundwater at any time dur-
ing the year, and the site should not be too steep. To some
degree site limitations can be overcome using an alternate
design (e.g., elevated sand mound, sandfill systems, con-
tour trench systems, etc.), as described in the discussion
on Individual On -Lot Systems.
It is generally recommended that subsurface disposal
systems not be installed in soils that have been disturbed
(i.e., urban land or fill land), since the soil may be com-
pacted and soil pores can be clogged.
Given these potential site constraints, the feasibility
of using subsurface disposal systems will often be deter-
mined by availability of a suitable site. The actual land
requirements will vary depending on soil conditions; gen-
erally a subsurface disposal area will require 500 to 2000
square feet of land for every dwelling unit served (includ-
ing the absorption area and buffer zone).
Most of the experience with subsurface disposal sys-
tems has been with individual on -lot sewage disposal
systems. The limited experience with larger subsurface
disposal systems (i.e., serving 50 to 100 homes or more)
suggests that greater care must be taken in designing and
sizing the system in order to prevent hydraulic overload-
ing of the absorption area. There are, however, several
examples to indicate that such systems can perform reli-
ably if properly designed (Westboro, Wisconsin; Cuyler,
New York; Avery, Idaho; Calder, Idaho).
Regulatory Requirements. Regulations governing the use
of subsurface disposal systems, if they exist, will often be
found in individual septic system codes. Several states
(e.g., Pennsylvania) have adopted specific regulations
dealing with the construction of community subsurface
disposal systems. Requirements regarding loading rates,
site limitations, and system design will vary from state to
state, and from one community to another. Depending
on the size of the system, regulatory requirements may be
dictated by a local agency (e.g., township or county
health department).
Normally, these systems do not require discharge
permits, although very often local or state design and
operating permits will be necessary. If there is a potential
for degradation of groundwater quality, groundwater
monitoring may be required.
Operational Requirements. Once installed, a subsurface
disposal system requires little operation and maintenance
attention. Aside from the periodic switching of a diverter
valve (with alternating drainfields), most of the opera-
tional requirements are associated with pretreatment and
pumping facilities. The maintenance of pretreatment
facilities is especially important. To prevent premature
clogging of the absorption area, a consistent effluent
quality must be maintained.
The requirement for consistent effluent quality
favors the use of septic tanks for pretreatment since con-
ventional treatment systems (i.e., mechanical treatment
plants) are vulnerable to occasional upsets that could
cause significant damage to the absorption area. Sub-
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surface disposal is generally not recommended for dis-
posing lagoon effluent since the algae in the effluent will
quickly clog the drainfield.
Even in cases where adequate pretreatment is pro-
vided, the absorption area may eventually become
clogged to the point where the system's treatment capac-
ity is severely limited. In such cases the absorptive
capacity of the field can often be rejuvenated by resting
the field for six months to a year. Chemical treatments
(e.g., hydrogen peroxide treatment), which oxidize the
biological clogging mat, sometimes can rejuvenate an
absorption area.
Public Attitudes. There may be some reservations con-
cerning the performance and reliability of subsurface dis-
posal systems. This particularly may apply in areas
where there is a history of individual septic system fail-
ures and people assume that the larger systems will be
just as likely to fail as the small individual systems.
Actually most on -lot systems fail due to one of three
factors: poor siting and design, poor construction, and
lack of maintenance. Assuming that a community system
is properly designed, constructed, and operated, the
probability of system failure is very small. The public
needs to be convinced that such systems will be built and
operated much like a public treatment facility. The sys-
tem will be subject to a more intensive regulatory review
than applies to individual home sewage disposal systems.
Assessing the effect of such systems on groundwater
quality may require extensive field studies and technical
evaluations. The potential for effects is a function of the
quantity of wastewater discharged, the proximity to
drinking water aquifers, and the size of the aquifer. In
most cases, the quantity of effluent discharged is so small
in relation to the volume of the groundwater aquifer, that
the effect on groundwater quality will be negligible. Of
course, it should be kept in mind that the effluent from a
subsurface disposal system normally does not contain
toxic substances, although nitrates, which are generally
present, may have health impacts in high enough
concentrations.
Costs. The cost of constructing a subsurface disposal
system will be determined largely by the local cost of
excavation and materials (sand, gravel, pipe, etc.).
Therefore, cost estimates should be based on quotes from
local contractors and suppliers. Capital costs typically
Wastewater Management 23
will be in the range of $3.00 to $5.00 per gpd of capacity
for a standard drainfield.
Operating costs associated with the direct mainte-
nance of the subsurface disposal system will be negligible
compared to the cost of operating the associated pretreat-
ment and pumping systems.
SUMMARY
As the costs of constructing, operating, and maintaining
public sewer systems increases, a growing number of
local governments must seek alternative methods to pro-
vide for wastewater treatment and collection. This report
has presented information on viable small scale waste-
water treatment technologies, including the use of
lagoons,' recirculating sand filters, community septic
tanks, marshpond aquaculture systems, and overland
flow systems. Local officials interested in further infor-
mation on the use of such treatment systems and/or
related collection systems may wish to contact U.S.
Environmental Protection Agency Innovative and Alter-
native Technology project staff in the Office of Water,
Washington, D.C.
REFERENCES
1. U.S. EPA, March 1981. Flow Reduction, Methods, Analysis
Procedures, Examples.
2. Presentation at the 1984 National Association of Home -
builders Convention, Houston, Texas, January 1984; Dana
Ripley, Allied Engineers Inc., San Ramon, California,
"What to Do When Local Governments Won't Provide
Public Services;'
3. Interview with Steven Chamberlin, Rouse -Chamberlin
Associates, Exton, Pennsylvania, March 13, 1984.
4. The Bureau of National Affairs, Inc. (September 28,1984).
Sewage Treatment Construction Grants Manual. News and
Developments, BNA, Washington, D.C.
5. Roy F. Weston, Inc. (1982). Innovative and Alternative
Technology Guide for On -Site Wastewater Disposal Sys-
tems in Sussex Co., NJ; Sussex County Planning Depart-
ment, Newton, NJ.
6. Hill, D. E. and Frink, C. R. (1980). "Septic System Longev-
ity Increased by Improved Design;' Journal of the Water
Pollution Control Federation, Vol. 52, No. 8, August 1980.
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