Water Pollution: Information on the Use of Alternative Wastewater
Treatment Systems (Chapter Report, 09/26/94, GAO/RCED-94-109).

The costs of treating the nation's wastewater are huge and rapidly
rising. According to the Environmental Protection Agency (EPA) the cost
of municipalities' unmet needs for wastewater treatment facilities rose
about $17.7 billion from 1988 to 1992 and totaled $108 billion in 1992.
This report examines whether the wastewater treatment costs could be
reduced through the use of alternative treatment systems. GAO discusses
(1) cost-effective alternatives to conventional systems for collecting
and treating wastewater, (2) barriers limiting the use of these
alternatives, and (3) how EPA is addressing the development of future
technologies.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-94-109
     TITLE:  Water Pollution: Information on the Use of Alternative 
             Wastewater Treatment Systems
      DATE:  09/26/94
   SUBJECT:  Wastewater management
             Water pollution control
             Cost control
             Systems evaluation
             Environmental engineering
             Wastewater treatment
             State-administered programs
             Environmental policies
             Federal/state relations
IDENTIFIER:  EPA National Water Quality Inventory
             State Water Pollution Control Revolving Fund
             Village of Browns (IL)
             Garrett County (MD)
             Gloucester (MA)
             Monterey (VA)
             West Virginia
             Craigsville (VA)
             EPA Environmental Technology Initiative
             Superfund Innovative Technology Evaluation Program
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Investigations and Oversight,
Committee on Public Works and Transportation, House of
Representatives

September 1994

WATER POLLUTION - INFORMATION ON
THE USE OF ALTERNATIVE WASTEWATER
TREATMENT SYSTEMS

GAO/RCED-94-109

Alternative Wastewater Treatment Systems


Abbreviations
=============================================================== ABBREV

  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  I&A - innovative and alternative wastewater treatment technology
     (program)
  NACEPT - National Advisory Council for Environmental Policy and
     Technology
  ORD - Office of Research and Development
  QBS - qualification-based selection
  STEP - septic tank and effluent pump

Letter
=============================================================== LETTER


B-245465

September 26, 1994

The Honorable Robert A.  Borski
Chairman, Subcommittee on
 Investigations and Oversight
Committee on Public Works and
 Transportation
House of Representatives

Dear Mr.  Chairman: 

As requested, this report discusses whether wastewater treatment
costs could be reduced by using alternative treatment systems.  The
report addresses (1) whether there are cost-effective alternatives to
conventional systems for collecting and treating wastewater, (2)
whether barriers are limiting the use of these alternatives, and (3)
how EPA is addressing the development of future technologies. 

As arranged with your office, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to the appropriate congressional committees; the
Administrator, EPA; and the Director, Office of Management and
Budget.  We will make copies available to others upon request. 

Please call me at (202) 512-6111 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
I. 

Sincerely yours,

Peter F.  Guerrero
Director, Environmental
 Protection Issues


EXECUTIVE SUMMARY
============================================================ Chapter 0


   PURPOSE
---------------------------------------------------------- Chapter 0:1

The costs of treating the nation's wastewater are huge and rapidly
rising.  According to the Environmental Protection Agency (EPA), the
cost of municipalities' unmet needs for wastewater treatment
facilities rose about $17.7 billion from 1988 to 1992 and totaled
$108 billion in 1992.  Small communities' needs represent about 12
percent of municipalities' total needs, or about $13 billion. 

Concerned about the nation's ability to meet these needs, the
Chairman, Subcommittee on Investigations and Oversight, House
Committee on Public Works and Transportation, asked GAO whether the
costs of wastewater treatment could be reduced by using alternative
treatment systems.  Specifically, GAO agreed to determine (1) whether
there are cost-effective alternatives to conventional systems for
collecting and treating wastewater, (2) whether barriers are limiting
the use of these alternatives, and (3) how EPA is addressing the
development of future technologies. 


   BACKGROUND
---------------------------------------------------------- Chapter 0:2

During the 1970s and 1980s, EPA provided construction grants
authorized by the Clean Water Act to local governments for building
wastewater treatment facilities.  Under the 1987 amendments to the
act, the grant program was phased out and replaced by state revolving
funds, which provide loans to local governments.  As GAO reported in
1992 (see GAO/RCED-92-35), the revolving funds are an efficient
alternative to grants, but they will not suffice to finance the
nation's wastewater treatment needs, especially the needs of small
communities.  Also phased out was an EPA incentive program to promote
alternative technologies. 


   RESULTS IN BRIEF
---------------------------------------------------------- Chapter 0:3

Alternative systems for collecting and treating wastewater offer the
potential for cost savings in certain circumstances.  In such cases,
the alternatives may help communities--particularly small ones, which
have not been able to afford conventional treatment systems--meet
their wastewater treatment needs.  Alternative systems include (1)
alternative collection systems that use smaller-diameter pipe buried
at shallower depths than conventional sewer systems and (2) natural
treatment systems that utilize soil, vegetation, and aquatic
environments as a treatment and/or disposal medium, such as
constructed wetlands and land application.  Natural treatment systems
employ few mechanical parts, use little energy, and have lower
construction and operation and maintenance costs than conventional
treatment systems. 

While alternative systems may be cost-effective, there are barriers
to their use.  The primary barrier is a lack of knowledge on the part
of engineers and state and local officials about the alternatives'
applicability, performance, and cost.  Other barriers include (1)
financial disincentives within the private sector to designing and/or
constructing facilities that employ alternative systems and (2)
restrictive state and local codes and regulations. 

Hesitancy about using available alternative systems discourages the
private sector's investment in future cost-effective technology.  In
addition, EPA's funding for engineering research on wastewater
treatment has dropped over the past 15 years.  However, EPA is
considering undertaking three limited projects that would provide
additional information on alternative systems and ways to reduce
barriers to their use.  These projects would be a helpful start in
addressing the barriers to the use of alternative wastewater systems. 


   PRINCIPAL FINDINGS
---------------------------------------------------------- Chapter 0:4


      ALTERNATIVE SYSTEMS CAN
      SOMETIMES YIELD SUBSTANTIAL
      SAVINGS
-------------------------------------------------------- Chapter 0:4.1

Although the data are not available for a broad assessment of their
savings potential, some alternative systems have been shown to save
substantial amounts compared with conventional systems.  For example,
a West Virginia community using a vacuum collection system saved
about $920,000, or about 42 percent of the cost of a conventional
collection system that would have used larger and more expensive pipe
buried at greater depth than the vacuum collection system.  Also, a
small community in Virginia found that it could save about $334,000,
or over 65 percent, by constructing a wetland to treat its wastewater
instead of constructing a conventional wastewater treatment facility. 
EPA and state officials identified a number of communities where the
use of alternative systems had resulted in significant savings. 

The cost savings obtained through the use of alternative systems have
enabled some communities to afford wastewater treatment.  According
to state officials, reducing costs by 30 to 40 percent can make
wastewater treatment affordable for many small communities. 


      BARRIERS LIMIT THE USE OF
      ALTERNATIVE SYSTEMS
-------------------------------------------------------- Chapter 0:4.2

Alternative systems are sometimes avoided even when they offer
potentially substantial cost savings because of uncertainties about
their performance and/or costs.  For example, state and local
officials have been reluctant to invest in an alternative wastewater
system for a city in Massachusetts even though an engineering study
concluded that (1) despite the city's limiting soil conditions,
on-site treatment was viable for much of the city and (2) a system
using alternative technologies would cost only about one-half as much
as a conventional system.  Proponents of alternative wastewater
systems and skeptics agree that credible, up-to-date performance and
cost data are needed to reduce the uncertainties. 

The lack of credible performance data also heightens engineers'
concerns about financial liability and damage to their professional
reputation if a system fails to perform to design specifications.  In
addition, state and local codes and regulations can restrict or
prohibit the use of alternative systems because many were written
with conventional systems in mind.  Few states and localities have
(1) encouraged or required the use of alternative fee structures and
methods to share risk and liability among the municipality,
contractor, and engineer and/or (2) revised codes and regulations to
allow greater flexibility in the use of nonconventional systems. 

Two of the three projects EPA is considering for addressing these
barriers would begin to develop additional information about the
applicability, performance, and cost of alternative wastewater
systems.  The third project would develop recommendations for
addressing other barriers to the use of alternative systems.  These
projects are estimated to cost about $1.2 million. 


      BARRIERS IMPEDE THE
      DEVELOPMENT OF FUTURE
      TECHNOLOGIES
-------------------------------------------------------- Chapter 0:4.3

The private sector has invested relatively little in developing new
technologies, in part because members of the engineering, regulated,
and regulatory communities have been reluctant to accept alternative
systems.  Investment is further limited by the private sector's
uncertainty about what technologies will be needed to meet future
regulatory requirements.  A private foundation that conducts a large
share of the nation's wastewater treatment research and development
reports that it is able to undertake only about one-quarter of the
needed engineering research and development activities because of
funding constraints. 

The public sector's funding of wastewater treatment research and
development is also severely limited.  EPA's funding of research and
development for wastewater engineering activities has declined from a
peak of about $19 million in fiscal year 1979 to less than $1 million
in fiscal year 1993.  EPA officials said that current funding levels
have prevented the agency from keeping abreast of emerging
technologies. 

Over the past 2 years, EPA has taken steps to better target the
limited public and private funds for research and development.  In
1992, the agency created the Innovative Technology Council to serve
as an in-house advisory and advocacy group that coordinates EPA's
technology development activities.  Although the Council's plans are
not final, EPA is taking steps to (1) promote innovation in
technology, (2) strategically invest in promising technologies, and
(3) accelerate the use of these technologies. 


   AGENCY COMMENTS
---------------------------------------------------------- Chapter 0:5

GAO discussed its findings with officials of EPA's Office of Water
and Office of Research and Development, including the Director,
Office of Wastewater Management.  These officials generally agreed
with the information presented.  Specifically, they agreed with the
potential savings from the use of alternative wastewater treatment
systems and the barriers to their use and development.  These
officials also indicated that they planned to consider funding
projects that would begin to address these barriers.  As agreed, GAO
did not obtain written agency comments on a draft of this report. 


INTRODUCTION
============================================================ Chapter 1

The Federal Water Pollution Control Act Amendments of 1972 (Clean
Water Act) required the Environmental Protection Agency (EPA) and the
states to set limits on the discharge of pollutants into rivers,
lakes, and other bodies of water.  In addition to placing controls on
industry, the act required cities and towns to build and maintain
wastewater treatment plants that meet national standards for
discharged pollutants.  If these treatment requirements were not
sufficient, more stringent controls--such as advanced levels of
wastewater treatment--would be required in order to meet
water-quality-based standards. 

EPA has reported that, since 1972, progress made in controlling water
pollution under the technology-based approach has been considerable. 
According to EPA, the number of people served by improved levels of
wastewater treatment has risen significantly, and the health of many
rivers has been restored after sewage and industrial wastewater
treatment facilities have been constructed or upgraded.\1

Despite these improvements, some waters are still not suitable for
swimming or fishing.  EPA's 1988 National Water Quality Inventory
states that persistent pollution problems remain.  For example, out
of 519,412 river miles that were assessed, 158,081 miles (30 percent)
did not fully meet state water quality standards. 

The 1972 act created the Construction Grants Program and also
substantially increased federal financial support to local
governments for wastewater treatment projects.  For example, the act
set the maximum federal contributions for eligible projects at 75
percent of eligible construction costs.  Although federal wastewater
treatment grants were provided under previous legislation, the 1972
act increased federal grants significantly-- to a total of $18
billion for fiscal years 1972 through 1976. 

Concerns were raised in the 1980s about the efficiency of providing
federal grants to finance wastewater treatment.  For example, EPA
reported in 1984 that the availability of federal funds had
discouraged state and local governments from providing funding.  As a
result, the federal share of eligible project costs was reduced from
75 to 55 percent, and total appropriations for the Construction
Grants Program were gradually reduced. 

The Congress changed the federal role in the 1987 amendments to the
Clean Water Act by eliminating the Construction Grants Program and
creating the State Water Pollution Control Revolving Fund Program. 
This change was phased in, starting in fiscal year 1989.  Capital for
the state revolving funds is provided by federal funds and a
20-percent state match.  These revolving funds are operated by the
states and provide loans to local governments to finance wastewater
treatment and certain other water pollution projects; the repayment
of these loans replenishes the funds. 

According to EPA, the nation's total documented wastewater treatment
needs rose to $108 billion in 1992--about $17.7 billion more than in
1988.  However, the Congress authorized only $8.4 billion in the 1987
amendments to capitalize the state revolving funds for fiscal years
1989 through 1994.  Although some additional funds will be available
through the state matching funds, leveraging, and some other federal
and state grant and loan programs, these sources are too limited to
close the gap between local needs and available resources, as
discussed in our 1992 report on state revolving funds.\2


--------------------
\1 The Quality of Our Nation's Water:  A Summary of the 1988 National
Water Quality Inventory, EPA (Washington, D.C.:  May 1990). 

\2 As we stated in our report Water Pollution:  State Revolving Funds
Insufficient to Meet Wastewater Treatment Needs (GAO/RCED-92-35, Jan. 
27, 1992), state revolving funds are an efficient alternative to the
grants program for providing a subsidy to local governments. 


   WASTEWATER TREATMENT NEEDS OF
   SMALL COMMUNITIES
---------------------------------------------------------- Chapter 1:1

In our 1992 report, we noted that small communities did not receive a
fair proportion of the construction grants.  We also noted that
insufficient resources in the state revolving funds will affect small
communities disproportionately.  According to EPA's Administrator,
small communities have unmet wastewater treatment needs of over $13
billion, which represent about 12 percent of the nation's total
needs.  Many states reported that their revolving funds will not meet
the needs of small communities, and many of these states expect that
these unmet needs will have significant effects on health and the
environment. 

Small communities are unable to compete with large communities for
financing because, in making a loan, states (except for Wisconsin)
consider a community's ability to pay back a loan.  Because
per-household costs for wastewater treatment are higher in small
communities, which cannot achieve economies of scale, small
communities pose a greater credit risk.  When these high
per-household costs are combined with low per-capita income in small
communities, debt may be unsupportable at any interest rate. 


   INNOVATIVE AND ALTERNATIVE
   WASTEWATER TREATMENT
   TECHNOLOGIES
---------------------------------------------------------- Chapter 1:2

Wastewater treatment technologies are classified as innovative,
alternative, and conventional.  Innovative technologies are
considered cutting edge and not fully proven, while alternative
technologies are considered relatively more proven and have been used
or demonstrated.  Conventional collection and treatment technologies
collect wastewater in large gravity sewers, treat it centrally using
proven or established mechanical techniques, and discharge it
directly into surface water. 

In the 1972 Clean Water Act, the Congress promoted the development
and use of innovative and alternative wastewater treatment
technologies.  However, financial incentives were not added to
promote these cost-saving technologies until the 1977 amendments to
the Clean Water Act established the innovative and alternative
wastewater treatment technology (I&A) program. 

Under the 1977 amendments, the I&A program increased the federal
share for innovative and alternative technology projects from 75
percent of total costs (the federal share for conventional technology
projects) to 85 percent of total costs.  Starting in fiscal year
1985, the federal share for conventional technologies dropped to 55
percent and the federal share for innovative and alternative
technologies dropped to 75 percent.  In addition, as a kind of risk
insurance, the I&A program provided grants for up to 100 percent of
the cost of modifying or replacing new technologies that failed to
perform to their design standards. 

Under the 1987 amendments to the Clean Water Act, the I&A program was
terminated after fiscal year 1990; the Construction Grants Program
was also terminated after fiscal year 1990.  Although the state
revolving funds have replaced construction grants, the 1987
amendments made no distinction between the funding of innovative or
alternative technologies and conventional technologies under the
state revolving fund program. 

For fiscal years 1979 through 1987, about $4.4 billion was invested
in 600 innovative projects and 2,100 alternative projects under the
I&A program.  According to a 1989 EPA report to the Congress,\3 the
I&A program moved some alternative technologies--such as land
treatment of wastewater, land spreading of sludge, alternative
collection systems, and on- site systems--from relative obscurity to
more widespread acceptance and application. 

EPA has maintained a research and development program for wastewater
and sludge.  The research objective is to develop the technology and
methods necessary to ensure the most cost-effective and
environmentally sound management and disposal of wastewater and
sludge.  Wastewater and sludge research focuses on three areas:  (1)
municipal wastewater/sludge treatment, (2) urban wet-weather
discharges, and (3) industrial wastewater management.  EPA's
development of technology for treating municipal wastewater/sludge is
operated by the Office of Research and Development's (ORD) Risk
Reduction Engineering Laboratory in Cincinnati, Ohio. 


--------------------
\3 Effectiveness of the Innovative and Alternative Wastewater
Treatment Technology Program:  Report to Congress, EPA (Washington,
D.C.:  Sept.  1989). 


   OBJECTIVES, SCOPE, AND
   METHODOLOGY
---------------------------------------------------------- Chapter 1:3

In a June 4, 1992, letter, the Chairman, Subcommittee on
Investigations and Oversight, House Committee on Public Works and
Transportation, requested that we provide information on whether the
nation could reduce its wastewater treatment costs by using new or
unconventional methods.  Specifically, he asked us to determine (1)
whether there are cost-effective alternatives to conventional systems
for collecting and treating wastewater, (2) whether barriers are
limiting the use of these alternatives, and (3) how EPA is promoting
the development of future technologies. 

To address these objectives, we contacted the Illinois, Maryland,
Massachusetts, and Virginia environmental protection agencies and/or
health agencies.  We also contacted various local communities in
these states that are using or considering alternative systems,
including the Village of Browns, Illinois; Garrett County, Maryland;
Gloucester, Massachusetts; and Monterey, Virginia.  During these
contacts, we interviewed local officials from organizations such as
the mayor's office, the public works agency, the consulting
engineering firm, and citizen groups.  We also met with local Rural
Development Administration officials who are helping local
communities resolve their wastewater treatment problems. 

We attempted to identify states and communities that had been
successful in using alternative wastewater treatment systems and had
overcome existing barriers.  EPA officials referred us to the
agency's National Small Flows Clearinghouse in Morgantown, West
Virginia, because it had the most current knowledge on state and
community activities concerning alternative wastewater systems.  We
selected the above states and local communities because officials of
the National Small Flows Clearinghouse told us that these areas would
exemplify the successful use of alternative systems, barriers to
these systems, and ways of overcoming these barriers. 

We interviewed EPA officials at headquarters, several regional
offices, the agency's research laboratories in Cincinnati, and the
National Small Flows Clearinghouse, as well as other federal
officials at the Tennessee Valley Authority, the National Aeronautics
and Space Administration, the National Science Foundation, and the
Department of Energy.  We also interviewed officials from a number of
professional associations representing consulting engineers, water
pollution professionals, and equipment manufacturers, among others. 
These included the American Society of Civil Engineers, American
Consulting Engineers Council, Water Environment Federation, and
National Association of Towns and Townships. 

We also reviewed appropriate EPA documents, including EPA's technical
manuals and guidance on wastewater treatment technologies, EPA's
report to the Congress on the I&A program, and the available
literature on communities' experiences with alternative wastewater
treatment technologies. 

We conducted our review from January 1993 through July 1994 in
accordance with generally accepted government auditing standards. 


ALTERNATIVE WASTEWATER TREATMENT
AND COLLECTION SYSTEMS CAN YIELD
SUBSTANTIAL SAVINGS
============================================================ Chapter 2

Alternative wastewater treatment systems can provide lower-cost
treatment than conventional treatment systems, when applied in
appropriate situations.  Also, alternative collection systems can
save significant amounts over conventional gravity sewers,
particularly in small communities.  The cost savings associated with
alternative systems may allow communities that cannot afford
conventional facilities to effectively meet their wastewater
treatment needs. 


   USE AND DEVELOPMENT OF
   ALTERNATIVE SYSTEMS
---------------------------------------------------------- Chapter 2:1

Many alternative wastewater treatment systems are based on "natural"
systems, such as land application or artificial wetlands, which rely
on the environment's ability to treat wastewater.  Natural systems
employ few mechanical parts, use little energy, and have lower
construction and operation and maintenance costs than conventional
treatment systems. 

Alternative collection systems reduce the costs of construction by
allowing small-diameter pipes to be installed at shallow depths and
variable gradients not permitted by conventional gravity sewers.  In
comparison, conventional collection systems require larger pipes to
be buried at a minimum slope and greater depth.  Small communities
can save significant costs by selecting alternative collection
systems because the collection system can represent 70 to 90 percent
of a wastewater system's total construction costs. 

Major metropolitan areas and larger communities often use
conventional systems with large sewers and mechanized treatment
plants that employ biological, physical, or chemical processes. 
These mechanical systems are highly engineered, treat relatively
large quantities of wastewater in a small amount of space, and are
advantageous in urban areas where land is costly and/or unavailable. 
The use of conventional treatment and collection systems in sparsely
developed areas with relatively few users will produce higher
per-capita costs than the use of such systems in the densely
developed areas typical of large communities.  Conventional treatment
processes usually need more attention by operators and more energy
than natural systems do.  Mechanical systems also produce greater
quantities of sludge, which must be treated and disposed of, than
natural systems.  In the 1960s and 1970s, wastewater technology
focused on developing these large centralized systems. 

In the last 15 years or so, alternative wastewater treatment and
collection systems have been revived from the past and developed for
application.  Alternative natural systems use the assimilative
capacity of the local environment to remove pollutants from
wastewater.  Some alternative systems apply wastewater to the land,
where it interacts with soil and vegetation.  Other natural systems
use an aquatic environment, such as lagoons and constructed or
natural wetlands.  These natural treatment and collection systems can
provide the equivalent of secondary treatment.\1 Some organizations
are looking at industrial applications of alternative systems such as
constructed wetlands to remove heavy metals and nutrients from
industrial wastewater.  However, these systems are designed to treat
municipal wastewater in a manner that conforms to secondary treatment
standards and are best suited for areas of low- density development
and small communities. 

Natural systems generally require larger amounts of land than
mechanical systems but are simpler and usually much less costly to
operate.\2 Natural systems can cost less to construct, and their
facilities can require fewer and less-skilled staff to operate,
consume less energy, and produce less sludge than conventional
facilities.  Large communities can also use natural systems alone or
in combination with mechanical systems, but land requirements tend to
reduce the advantages of natural systems in densely developed areas. 

The selection of the appropriate wastewater treatment technology will
depend on many factors, such as the physical characteristics of the
site, the configuration of the community, the level of treatment
needed, and the characteristics of the wastewater.  For example, the
performance of a soil-based treatment system is affected by such
factors as the characteristics of the soil, the quantity of
wastewater applied, the climate, and the depth of the soil above the
groundwater. 

The remainder of this chapter discusses specific wastewater treatment
and collection systems and provides examples of these systems.  The
cost savings estimated for these examples were reported to us by the
individual communities using or planning to use these systems or were
reported in case studies prepared by the National Small Flows
Clearinghouse.  These examples were judgmentally selected and are not
meant to be representative of all cases where these systems have been
applied.  We did not verify the accuracy of the reported cost
savings. 


--------------------
\1 Secondary treatment is a level of treatment that removes at least
85 percent of several key conventional pollutants. 

\2 It's Your Choice:  A Guidebook for Local Officials on Small
Community Wastewater Management Options, EPA (Washington, D.C.: 
Sept.  1987). 


   ALTERNATIVE WASTEWATER
   TREATMENT SYSTEMS
---------------------------------------------------------- Chapter 2:2

Wastewater treatment systems can be categorized as on-site systems,
cluster systems, or centralized systems where effluent is collected
and treated at a central location.  On-site systems are individual
on-lot treatment systems.  Cluster systems are similar to centralized
systems, since both collect wastewater or effluent and transport it
to a treatment facility.  However, cluster systems are smaller and
handle wastewater for a neighborhood or a few homes rather then a
whole town or community.  Generally, wastewater treatment
technologies for small communities include natural treatment systems
as well as mechanical, conventional technologies. 


      ON-SITE TREATMENT SYSTEMS
-------------------------------------------------------- Chapter 2:2.1

About 25 percent of the U.S.  population lives in areas that use
individual on-site treatment systems.  On-site systems often consist
of a septic tank and a subsurface wastewater infiltration system. 
Septic tanks allow raw wastewater to flow through the tank at a rate
slow enough to remove heavy solids by settlement and grease by
floatation.  In addition, bacteria in the tanks break down some
solids. 

Where fewer than 50 households will be connected to each mile of
sewer, EPA suggests that communities look closely at on-site systems. 
Eliminating sewers can save a community significant costs because
sewers represent a significant portion of the total cost of
constructing a wastewater treatment system.  On the proper site, a
well designed, installed, and maintained on-site system can provide
years of low-cost, trouble-free service.  We reported in 1978 that
on-site septic systems can function as effectively and permanently as
centralized treatment facilities and are generally more
cost-effective.\3

Nevertheless, today, many older on-site systems are not performing
properly, allowing wastewater to bubble up in homeowners' yards or
back up into homes.  Such situations often create pressure on a
community to construct a costly centralized wastewater treatment
facility.  However, these problems are usually the result of poor
design or siting, inadequate construction, or poor maintenance.\4

Much of the land area in the United States does not have the drainage
characteristics or minimum percolation rates required for soil
absorption systems.  Also, areas with high groundwater tables are
inappropriate for these systems, since the shallow soil depth does
not allow for adequate purification of wastewater before it reaches
the groundwater.  Where soil absorption systems cannot be used,
alternative natural systems, such as sand filters or mound systems,
may be used. 

A sand filter--illustrated in figure 2.1--consists of a bed of
granular material through which the partially treated sewage flows. 
A mound system--illustrated in figure 2.2--raises the absorption
field above the natural soil by using a fill material that is
permeable.  Both mound systems and sand filters are suitable in areas
where the soil has a low permeability, where the groundwater table is
high, or where there is a shallow layer of natural soil.  These
systems are considerably more expensive than soil absorption systems. 

   Figure 2.1:  Sand Filter

   (See figure in printed
   edition.)

Notes:

Filters are used when the soil is too shallow or too permeable.

A bed of sand is built over a drainpipe that collects the wastewater
after it has been filtered.

Filters provide a high degree of treatment.

Treated wastewater goes to a drain field or to a stream or lake
(after disinfection).

Two types are used--an intermittent filter (wastewater travels
through the filter only once) and a recirculating filter (wastewater
goes through the filter several times).

Periodic maintenance is required and may include the occasional
removal and replacement of the top sand layer. 

Source:  It's Your Choice:  A Guidebook for Local Officials on Small
Community Wastewater Management Options, EPA (Washington, D.C.: 
Sept.  1987). 

   Figure 2.2:  Mound System

   (See figure in printed
   edition.)

Notes:

This system is used when the soil is too shallow for a standard
septic system.

Septic tank effluent is pumped into a drain field built into the
mound.

Sand fill and gravel are mounded on top of the natural soil to filter
the septic tank effluent before it reaches the natural soil. 

Source:  It's Your Choice. 

Georgetown, California, has been operating an on-site wastewater
management program since 1971.  Following extensive studies from 1978
through 1981, which compared the merits of on-site disposal systems
with those of both conventional and alternative forms of sewage
collection, treatment, and disposal, the Georgetown Divide Public
Utility District concluded that an on-site option was the most
desirable alternative despite earlier expectations that the growth in
population would lead to the construction of a centralized system. 
For each lot, the on-site management program calls for (1) an
evaluation of the soil and geology at the building site, (2) a design
for the system based on the site's evaluation, (3) managed and
inspected construction work, (4) scheduled maintenance and
surveillance of the system, and (5) chemical and biological sampling
of the watershed.  Currently, the district charges homeowners a
one-time design/inspection fee of $540 when they build their homes
and $12.50 per month thereafter. 


--------------------
\3 Community-Managed Septic Systems--A Viable Alternative to Sewage
Treatment Plants (CED-78-168, Nov.  3, 1978). 

\4 In our 1978 report, we noted on the cover summary that "Because of
inadequate controls over the design, installation, and operation,
septic systems have become unreliable and temporary."


      CLUSTER SYSTEMS AND LARGER
      CENTRALIZED TREATMENT
      FACILITIES
-------------------------------------------------------- Chapter 2:2.2

Cluster systems collect and transport wastewater to small
neighborhood treatment facilities.  Even where land is not suitable
for on-site systems, a useable site may not be too far away.  Cluster
systems may be economical where houses are too close together to use
on-site systems but too far away to connect with a larger collection
system.  The treatment methods associated with cluster systems are
often larger versions of on-site systems, such as septic tanks with
soil absorption systems or sand filters. 

Larger centralized treatment systems (as well as cluster systems) can
use soils, vegetation, and aquatic environments including constructed
wetlands, overland flow systems, slow-rate land application, and
lagoons. 


         CONSTRUCTED WETLANDS
------------------------------------------------------ Chapter 2:2.2.1

Wetlands/aquaculture/marsh systems can be used to further reduce the
pollutant levels from the effluent of another treatment process. 
Wetland systems can also treat raw or partially treated sewage. 
Figure 2.3 illustrates a constructed wetland. 

Constructed wetlands can produce significant savings for some small
communities.  In the early 1980s, the small town of Monterey,
Virginia, was required to upgrade its existing treatment facility to
secondary treatment by adding additional treatment processes. 
According to the Mayor of Monterey, the town's consulting engineer
estimated that adding a conventional treatment process would cost
about $500,000, which the town considered unaffordable because of its
low average household income.  With the assistance of the National
Aeronautics and Space Administration, which developed this technology
for potential future space applications, Monterey is completing a
subsurface wetland with bulrushes--a common aquatic plant--and a rock
filter process over a liner.  According to the Mayor, the wetland
uses little energy, requires little maintenance, and was constructed
for about $166,000.  Over 30 such systems have been financed by EPA's
I&A program through fiscal year 1990.  A number of states have been
experimenting with on-site wetlands to replace failing drain fields
or to work in conjunction with a drain field where soils would clog
or otherwise be unsuitable for treating wastewater. 

   Figure 2.3:  Constructed
   Wetland

   (See figure in printed
   edition.)

Notes:

Marsh plants (cattails, reeds, etc.) are grown in beds of soil or
gravel through which wastewater flows.

Wetlands are useful to further treat wastewater from a lagoon.

This is a low-cost system that needs minimal attention from an
operator.  Periodically, plants need to be checked and sometimes
harvested at the end of the growing season.

The system requires relatively less land than many land treatment
systems.

The system may be operated year-round in most climates. 

Source:  It's Your Choice. 


         OVERLAND FLOW SYSTEMS
------------------------------------------------------ Chapter 2:2.2.2

Other types of natural systems use land as well as vegetation for
treating wastewater.  One of these systems--called the overland flow
system--applies wastewater at the top of a gently sloping hill and
collects it at the bottom of the hill.  Figure 2.4 illustrates this
system. 

   Figure 2.4:  Overland Flow
   System

   (See figure in printed
   edition.)

Notes:

This system is well suited for rural areas with large amounts of
pasture or meadow land having tight soils.

Wastewater is applied at the top of a gently sloping grass-covered
hill and allowed to flow over the ground's surface to the bottom of
the hill, where it is collected, disinfected, and discharged.

The system is useful to further treat wastewater from a lagoon.

In cold climates, a storage lagoon capable of holding flows during
nonoperational periods is needed.

The system requires minimal attention; the operator should
periodically mow and remove the grass.  (The system may produce
marketable hay.)

Source:  It's Your Choice. 

Kenbridge, Virginia, was required to upgrade its existing treatment
plant to meet discharge requirements.  Initially, the facility plan
proposed an aerated lagoon.  The plan was later modified on the basis
of an evaluation of land treatment technologies.  Land adjacent to
the plant was found to be ideally suited to an overland flow system. 
An economic analysis showed that an overland flow system would cost
$88,000 per year compared with $168,800 per year for an aerated
lagoon system.  Some 57 communities have received grants from EPA to
construct overland flow systems. 


         SLOW-RATE LAND
         APPLICATION
------------------------------------------------------ Chapter 2:2.2.3

Slow-rate land application, or spray irrigation, is another
soil-based treatment method that applies effluent at a controlled
rate to a vegetated soil surface of moderate to slow permeability. 
The wastewater is used as a form of irrigation and is applied by
spraying or the flooding of furrows.  Figure 2.5 illustrates a spray
irrigation system. 

   Figure 2.5:  Spray Irrigation

   (See figure in printed
   edition.)

   Notes:

   This system does not generally
   discharge effluent into surface
   water.  Hence, it is
   particularly appropriate in
   areas where discharge
   regulations would require a
   costly facility.

   Sprinklers apply wastewater to
   cropland, woodland, golf
   courses, or other vegetated
   areas.

   The system can be used with
   lagoon effluent.

   The system is relatively simple
   to operate.  The sprinkler
   system needs regular
   maintenance, and the rate at
   which wastewater is applied
   must be adjusted to suit crops'
   needs.

   (See figure in printed
   edition.)

Source:  It's Your Choice. 

Craigsville, Virginia, had failing on-site septic systems and hired a
consulting engineering firm that proposed an advanced wastewater
treatment plant.  This plant would have discharged effluent into a
local river.  But because the costs of construction and operation
were so high, the system was never constructed.  Craigsville's sewage
disposal problems remained unresolved until a prison was constructed
adjacent to the town, and a wastewater treatment facility for both
the town and the prison was evaluated.  The treatment system that was
finally selected discharged no effluent into the local waterways. 
Instead, this system, which included primary treatment tanks and
aerated lagoons, disposed of effluent by slow-rate land treatment. 
The cost to treat each gallon of wastewater, computed on the basis of
the design flow, was half that of an advanced wastewater system. 
Through the I&A program, EPA provided grants to 312 communities that
chose a slow-rate treatment system.



         LAGOONS
------------------------------------------------------ Chapter 2:2.2.4

Another system using natural treatment processes is a lagoon.  A
lagoon refers to either a stabilization pond or an aerated
(oxygenated) lagoon.  Figure 2.6 illustrates a lagoon.  A
stabilization pond is simply a shallow impoundment in which
wastewater is treated by natural processes without the aid of
mechanical equipment or chemical additives.  An aerated lagoon is the
same except that it uses mechanical equipment to enhance the aeration
process. 

   Figure 2.6:  Lagoon

   (See figure in printed
   edition.)

   Notes:

   This system employs a low-cost
   and simple treatment method
   requiring only a part-time
   maintenance staff.

   The system is suitable for
   areas that do not have strict
   discharge regulations.

   Primary treatment is not
   generally required.

   The system may require
   watertight liners to protect
   groundwater.

   Some lagoons may qualify for
   equivalent secondary discharge
   standards.

   Stabilization ponds require
   about 1 acre for every 200
   people served.

   Aerated lagoons require only
   one-third to one-tenth as much
   land as stabilization ponds.

   Regardless of the type, several
   smaller lagoons in a series are
   better than one big lagoon.

   The system may eliminate the
   need for a higher level of
   treatment if the discharge from
   the lagoon is controlled. 
   Controlled release lagoons
   discharge only when streamflow
   is high.

   Total containment lagoons never
   discharge.  All wastewater
   evaporates.  They are used only
   in dry climates.

   Sludge collects at the bottom
   of the lagoon and may have to
   be removed and properly
   disposed of every 5 to 10
   years.

   (See figure in printed
   edition.)

Source:  It's Your Choice. 


   ALTERNATIVE WASTEWATER
   COLLECTION SYSTEMS
---------------------------------------------------------- Chapter 2:3

Centralized treatment, which requires a collection system, may be
necessary for areas where on-site systems will not work.  Selecting
the appropriate collection system is important because conventional
gravity sewers can account for 70 to 90 percent of the construction
costs of a conventional wastewater treatment system.  Although
conventional gravity sewers are costly, they may be advantageous
where homes are close together and where many households can share
the cost.  Figure 2.7 illustrates a conventional gravity sewer. 

   Figure 2.7:  Conventional
   Gravity Sewer

   (See figure in printed
   edition.)

Notes:

This system is appropriate in densely developed areas (100 or more
homes per mile of sewer, lots of 1/2 acre or less).

Untreated wastewater travels mainly by gravity through a system of
sewers and pumping stations.

The system is difficult and expensive to install; it must always
slope downhill.

Costly manholes are required for maintenance.

Infiltration and inflow (leaky sewers) may be significant.

The system can be used alone or combined with other collection
systems. 

Source:  It's Your Choice. 

Alternative collection systems are appropriate where 50 to 100
households will be connected to each mile of sewer, according to EPA. 
The savings associated with alternative collection systems for
appropriate small communities generally range from 25 percent to as
high as 90 percent of the cost of conventional gravity sewers,
according to an environmental engineer who was responsible for EPA's
I&A research program at its Risk Reduction Engineering Laboratory for
many years.  Alternative collection systems use pipes that are
smaller in diameter than conventional sewer pipes and cost less to
purchase.  In addition, the excavation costs for installing the pipes
are reduced because small-diameter pipes can be installed at
shallower depths.  The pipes can follow land contours and can be laid
with curving and variable gradients to avoid buildings and other
large objects.  In contrast, conventional gravity sewers must be
installed at a specific minimum slope that may require fairly deep
cuts in the terrain and expensive pump or lift stations to pump the
sewage to the desired elevation. 

Three main classes of alternative sewers are small-diameter effluent
sewers, pressure sewers, and vacuum sewers.  These alternatives can
be used with conventional sewers or with other alternative sewers, as
discussed below. 


      SMALL-DIAMETER EFFLUENT
      SEWERS
-------------------------------------------------------- Chapter 2:3.1

Small-diameter effluent (or gravity) sewers use small-diameter pipes
and a septic tank at each home for primary treatment.  Although flow
in the pipes is accomplished by gravity, lines can be installed at a
lesser gradient than in conventional gravity sewers; therefore, less
excavation is required.  Figure 2.8 illustrates a small-diameter
effluent sewer.  According to EPA, 167 communities have received I&A
program grants to construct small-diameter effluent sewers.  One of
the communities, located in the Maysville area of Muskingum County,
Ohio, has some 770 households.  This area had many existing septic
tanks and drain fields that failed or were near failing.  A
conventional gravity sewer system was found to be too expensive
because of the low-density development.  A small-diameter effluent
sewer system was estimated by a National Small Flows Clearinghouse
study to cost about 35 percent less than the conventional gravity
sewer system. 

   Figure 2.8:  Small-Diameter
   Effluent Sewer

   (See figure in printed
   edition.)

Notes:

This system is appropriate in less densely developed areas (fewer
than 50 to 100 homes per mile of sewer, lots of 1/2 to 2 acres).

Septic tank effluent (water flowing out of septic tanks) travels
through a small-diameter plastic pipe.  Some homes may require a pump
to move the effluent.

The system can be installed at shallow depths and may follow the
land's contours; it can be "woven" around trees and buildings.

Septic tanks remove the solids; sewer clogging is generally not a
problem even in low spots.

Less costly cleanouts may be used in place of manholes.

A smaller and simpler treatment facility can be used.

Septic tanks should be pumped out every 3 to 5 years.

The system presents less possibility of infiltration and inflow.

The system can be used alone or combined with other collection
systems. 

Source:  It's Your Choice. 


      PRESSURE SEWERS
-------------------------------------------------------- Chapter 2:3.2

Pressure sewers could consist of either (1) a grinder pump that
grinds the solids present in wastewater into a slurry, much as a
garbage disposal unit grinds waste in a kitchen sink, or (2) a septic
tank and effluent pump (STEP) system.  Figure 2.9 illustrates a
grinder pump pressure sewer.  A grinder pump system may require more
sewer line cleaning and pump maintenance than a STEP system.  In a
STEP system, the septic tank holds the solids, grit, grease, and
other waste that could clog a pipeline.  Because wastewater is
treated in a septic tank, the treatment facility can be smaller and
simpler than would otherwise be needed.  Under the I&A program, EPA
has provided grants to 87 communities for constructing STEP systems
and 163 communities for constructing pressure sewers with grinder
pumps. 

   Figure 2.9:  Grinder Pump

   (See figure in printed
   edition.)

Notes:

This system is appropriate in the same areas as a septic tank
effluent sewer system.

The system is similar to a septic tank effluent sewer system except
that a grinder pump is used in place of a septic tank.

Grinder pumps have built-in cutter mechanisms that grind solids so
they do not clog sewers.

Operation and maintenance requirements are slightly higher than for a
septic tank effluent sewer system.

Power costs $10 to $20 per year.

The system can be used alone or combined with other collection
systems. 

Source:  It's Your Choice. 

One state is attempting to demonstrate that using the STEP system
could save costs for some of its small communities.  Illinois has
established a federal and state interagency coordinating committee to
find solutions to the problems of small rural communities with
failing private septic systems or deteriorating wastewater treatment
systems.  According to officials from the Illinois Environmental
Protection Agency, it is extremely difficult for a community with a
population of under 300 to afford a conventional wastewater
collection and treatment system because per-capita costs are too
high.  The Governor's Rural Affairs Council of Illinois estimated
that small communities could save about 25 to 40 percent in
construction costs by using an alternative collection system and that
savings would allow many of these small communities to correct their
wastewater problems. 

To demonstrate that alternative collection systems will work and will
lower costs, Illinois has selected a number of small communities that
have serious problems with their on-site septic systems and cannot
afford the conventional gravity sewers selected by consulting
engineers and identified in their facility plans.  For example, the
Village of Browns, Illinois, with a population of about 200, has
septic systems that are failing because of seasonally high
groundwater.  Consulting engineers for Browns have estimated that a
conventional sewer and lagoon treatment system would cost $1.3
million, whereas a STEP system with a comparable treatment system
would cost $965,000. 


      VACUUM SEWERS
-------------------------------------------------------- Chapter 2:3.3

Vacuum sewer systems move sewage by creating within the sewer lines a
vacuum or negative pressure that draws the waste to a common
collection tank.  Once in the collection tank, the wastewater is
pumped to a treatment facility.  Figure 2.10 illustrates a vacuum
sewer. 

   Figure 2.10:  Vacuum Sewer

   (See figure in printed
   edition.)

Notes:

This system is an option in areas that are flat.

The system conveys untreated wastewater by vacuum through a small
plastic pipe to a central station.  There, it is pumped to a
treatment facility.

Each home or group of homes is equipped with a vacuum valve rather
than a septic tank or grinder pump.

The system requires careful installation and skilled maintenance.

The system can be used alone or combined with other collection
systems. 

Source:  It's Your Choice. 

One vacuum collection system financed partially with grant funds from
EPA is in Cedar Rocks, West Virginia.  Before the vacuum collection
system was considered, a gravity collection system was designed.  The
lowest bid received for this system was $2.15 million in 1978.  A
vacuum collection system was then designed and constructed at an
actual cost of $1.23 million.  Under the I&A program, EPA awarded
grants to 41 communities for vacuum sewers. 


   VARIETY OF SYSTEMS IN GARRETT
   COUNTY, MARYLAND
---------------------------------------------------------- Chapter 2:4

Various treatment and collection systems--alternative and
conventional--can be mixed with each other to take advantage of each
system's positive features.  Garrett County, Maryland, is a rural
area where 60 percent of the people use individual septic systems;
the other 40 percent use a variety of systems managed by a sanitary
district for the county or a local town government.  For example,
variable-grade, small-diameter sewers with on-site septic tanks and
recirculating sand filters are used in the small communities of
Gorman and Crellin.  At Deep Creek Lake, the largest system uses
small-diameter pressure sewers with grinder pumps in combination with
larger gravity pipes and a conventional treatment plant.  The
Administrator of the sanitary district noted that communities in Deep
Creek Lake could not afford a conventional gravity system because of
the topography. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 2:5

Many small communities may not be able to afford the conventional
wastewater collection and treatment systems typical of large
metropolitan areas.  Fortunately, many alternative wastewater
collection and treatment systems are available and may be more
affordable.  A number of small communities have used these
technologies, and some have reported substantial cost savings over
conventional technology. 


BARRIERS TO THE USE OF ALTERNATIVE
SYSTEMS CAN BE REDUCED
============================================================ Chapter 3

A number of barriers impede the use of alternative wastewater
treatment and collection systems including

  a lack of knowledge about the alternatives' applicability,
     performance, and cost;

  financial disincentives within the private sector to design and/or
     construct facilities employing alternative systems; and

  restrictive state and local codes and regulations. 

EPA has an important role to play in addressing these barriers and
helping communities achieve the cost savings that are possible with
the use of the alternative systems. 


   EPA'S ROLE IN PROMOTING
   ALTERNATIVES HAS CHANGED
---------------------------------------------------------- Chapter 3:1

In the 1970s and 1980s, EPA vigorously promoted the wider use of
alternative systems.  These activities occurred primarily through the
innovative and alternative wastewater treatment technology program
and the technical transfer activities authorized under the Clean
Water Act.  However, these activities largely ceased when funds for
evaluating and disseminating the results of projects using these
systems were virtually eliminated with the termination of EPA's
Construction Grants Program.  As a result, information that is
critical to the use of alternative wastewater systems has not been
developed or disseminated to those who could use it. 

In its 1989 report to the Congress on the effectiveness of its I&A
program, EPA concluded that the program "has been tremendously
successful at promoting the development and application of more
cost-effective, environmentally sound wastewater treatment
technologies, especially in small communities."\1 However, the report
also acknowledged concerns about whether innovative and alternative
technologies would continue to be used once the I&A program ceased in
1990.  Specifically, the report cited concerns about the continuation
of (1) technology transfer activities, (2) guarantees to modify or
replace failing systems, and (3) the testing and demonstration of
promising new technologies.  To address some of these concerns, the
report recommended that EPA continue to (1) conduct, publish, and
distribute evaluations of the performance of innovative and
alternative wastewater technologies and (2) conduct technology
transfer and training seminars. 

While EPA has continued a limited number of these technology transfer
efforts, EPA's research and development funding for wastewater
treatment engineering has been severely reduced from about $19
million in fiscal year 1979 to $880,000 in fiscal year 1993.  (See
fig.  3.1.) As a result, virtually no evaluation work has been done,
most of EPA's technical manuals are outdated (many are based on
research done in the 1970s), and few technology transfer and training
seminars have been held.  Furthermore, officials of EPA's Office of
Research and Development (ORD) told us that the virtual elimination
of ORD's wastewater treatment budget has caused the agency to lose
much of its expertise in innovative and alternative technologies. 
According to these officials, the agency may no longer be able to
keep abreast of new developments, much less evaluate them and
disseminate information about them. 

   Figure 3.1:  Funding for
   Municipal Wastewater
   Engineering Research

   (See figure in printed
   edition.)

Note:  The amount for 1982 includes $3.8 million carried over from
the prior year.  Figures for all years do not include research on the
land application of watewater performed by EPA's laboratory in Ada,
Oklahoma, during the 1970s and ending in the 1980s. 

Source:  ORD's Risk Reduction Engineering Laboratory. 

Although ORD officials maintain that their wastewater budget need not
be restored to the 1970s' levels, they believe that some restoration
is needed if the agency wishes to retain minimal expertise in current
treatment technologies.  Some of the officials we spoke to from EPA,
from state and local entities, and from wastewater treatment,
engineering, and rural and environmental associations--including both
advocates and skeptics--agree that the loss of EPA's technology
transfer activities hinders the wider use of alternative
technologies.  A critical component of these activities was EPA's
independent evaluation of alternative technologies, publication of
technical manuals reflecting these evaluations, and dissemination of
this information through workshops and training seminars. 

In 1993, action was taken that may reverse the declining level of
attention that EPA has been able to give to these alternative
technologies.  The Congress funded the administration's
"Environmental Technology Initiative" for EPA to accelerate the
development and use of innovative environmental technologies.  EPA
plans to focus, in part, on reducing barriers to innovation and the
use of new technologies and on creating incentives in federal and
state regulations for the development and use of innovative
technologies.\2 The initiative is being funded at $36 million for
fiscal year 1994.  As discussed later in this chapter, EPA staff have
developed proposals to use a portion of these funds to address
barriers to the use of alternative wastewater technology. 


--------------------
\1 Effectiveness of the Innovative and Alternative Wastewater
Treatment Technology Program:  Report to Congress, EPA (Washington,
D.C.:  Sept.  1989). 

\2 Chapter 4 contains a discussion of this initiative. 


   INFORMATION IS NEEDED ON THE
   ALTERNATIVES' APPLICABILITY,
   PERFORMANCE, AND COST
---------------------------------------------------------- Chapter 3:2

The absence of comprehensive and current information on alternative
wastewater systems' applicability, performance, and cost is a primary
barrier to the greater use of these systems.  Engineers remain
largely unfamiliar with the treatment alternatives, according to
officials from the Water Environment Federation, in part because
these alternatives were given little or no attention in engineering
school courses until recently.  Also, according to the Chief of EPA's
Municipal Technology Branch, state regulators who are unfamiliar with
alternative technologies are less likely to approve their use. 

Even when engineers, municipal officials, and regulators have a basic
familiarity with alternative technologies, they may have reservations
and/or questions about their applicability, performance, or costs. 
Although EPA's former I&A program was successful in expanding the use
of these technologies, it also funded a number of systems that did
not perform up to expectations or realize anticipated savings.  As a
result, some state and local officials and engineers continue to have
reservations about choosing alternative technologies.  Even though
EPA attempted to address these concerns by issuing informational
manuals and conducting workshops, most of these activities ended.  If
such questions are left unresolved, it is unlikely that systems using
alternative technologies will be selected. 

For example, a Gloucester, Massachusetts, citizens' group advocates
the use of on-site treatment alternatives for the city.  The group
maintains that despite some siting difficulties, a variety of
alternative treatment technologies can be used in lieu of connecting
the city's entire population to the city's treatment plant.  The
group argues that the level of treatment would be superior to, and
significantly less expensive than, that provided by the city's
treatment plant, which provides only primary treatment.  The group
supports its position by pointing to an engineering firm's revised
facility plan that examined alternatives and concluded that they are
feasible.  The engineering firm estimated the capital cost of
alternative technologies for different areas of the city at about
$13.6 million compared with the capital costs of conventional sewers
estimated at about $25.2 million.  The group also invited a National
Small Flows Clearinghouse engineer to assess the situation; the
engineer concluded that a mix of on-site and other alternative
technologies could meet the city's wastewater treatment needs. 

In contrast, the city's former mayor, the city's project engineer,
and the state's Director of the Division of Water Pollution Control,
Department of Environmental Protection, maintain that Gloucester's
soil conditions preclude the widespread use of on-site alternatives. 
Specifically, these officials cite the city's high water table and
underlying rock formations as factors precluding on-site treatment
alternatives. 

In February 1993, Gloucester agreed to a compromise and signed an
agreement with the state under which the city will install either
conventional sewers or alternative collection systems with connecting
septic tanks for various areas of North Gloucester by specific dates
(the latest date being Feb.  1, 1997) and assess the feasibility of
using alternative on-site systems for the remaining unsewered areas
of the city.  According to the city's former mayor and project
engineer, this assessment will consist of experimenting with four
pilot on-site alternatives to obtain data on their applicability and
performance.  Under the agreement, Gloucester must have finished
constructing wastewater treatment system(s) in the areas that could
use on-site systems by December 31, 1998. 

Questions about alternative treatment systems' applicability and
performance also surfaced in our discussions with other state
regulators.  In Virginia, for example, state Health Department and
Water Control Board officials questioned the natural treatment
systems' ability to satisfactorily meet new, increasingly stringent
discharge limits for some pollutants, such as nitrogen and ammonia. 
An Illinois Department of Public Health official told us that soil
conditions and/or population density in much of the state precludes
the use of on-site treatment alternatives.  Some advocates of
alternatives maintain, however, that if the proper site and
technology are selected, alternatives can be used in most
circumstances where poor soil conditions are a concern. 

Questions have also arisen about how much money can be saved by using
alternative wastewater technologies.  Even some who believe that
alternatives can perform in a wide variety of circumstances question
whether the alternatives will produce significant savings or any
savings under certain circumstances.  For example, Virginia Health
Department and Water Control Board officials said that because these
systems require extensive land, they may not save costs where land is
expensive.  An Illinois Environmental Protection Agency official said
that cost savings of 30 to 40 percent, estimated by others as
achievable by using alternative collection systems, were too high for
many communities in Illinois because of its flat terrain. 
Nevertheless, he noted that a community located in hilly terrain had
constructed an alternative collection system that saved about 50
percent of the cost of a conventional system.  He acknowledged that,
if realized, savings of 30 to 40 percent could make wastewater
treatment affordable for many small communities not serviced by
sewers. 

Sometimes, the examples cited in the debate are from projects that
were designed and constructed years ago and do not reflect
technological advances that have improved the alternatives'
performance and cost savings.  For example, pumps used in early STEP
systems were prone to corrosion and failure and were difficult and
expensive to operate and repair.  Nevertheless, advances in pump
design and manufacturing have resulted in a reliable,
energy-efficient pump that is easy to maintain and repair, according
to EPA officials in ORD and the Office of Water. 

The debate over alternatives' applicability, performance, and cost
stems from a lack of comprehensive and up-to-date information on the
alternatives.  Those advocating the wider use of alternatives support
their position by citing specific examples where alternatives are
performing well and saved significant costs.  Skeptics, however,
point to cases where the technologies failed to realize performance
and/or cost-savings expectations. 

Advocates of alternative wastewater treatment technologies and
skeptics agree that more comprehensive and current performance and
cost data are needed to resolve questions about these technologies. 
Most of the officials from EPA, state and local governments, and
engineering firms we spoke with agreed that an independent third
party should examine existing systems that use alternative
technologies, analyze how well they perform under varied
circumstances, and verify their actual design, construction, and
operation and maintenance costs.  Some said that this analysis should
include a study of the lessons learned from alternative systems that
did not meet expectations. 


   CONCERNS ABOUT LIABILITY AND
   ENGINEERING FEES POSE BARRIERS
---------------------------------------------------------- Chapter 3:3

As we have reported in the past, consulting engineers, state
regulators, and local officials wish to minimize the possibility that
a system could fail to meet expected performance and/or cost
parameters.  Engineers wish to avoid potential damage to their
professional reputations and/or possible financial liability for
designing such a system; regulators are reluctant to approve a system
that may not be able to perform reliably; and local officials wish to
avoid the fiscal and political ramifications of selecting such a
system.  These concerns, we believe, are also mutually reinforcing. 
Local officials and engineers are reluctant to select an alternative
if they believe it will not be approved by regulators.  Regulators
are reluctant to approve a system if it is not clear who will be
liable or if resources will not be available to modify or replace a
system that fails to meet the parameters of its design. 

The I&A program had a "modification and replacement" provision
designed to allay these types of concerns.  The program did so by
providing grants for up to 100 percent of the cost to modify or
replace innovative and alternative wastewater systems that failed to
perform according to the parameters of their design.  There is no
similar mechanism in the current state revolving fund program that
supports communities' wastewater projects. 

Because of concerns about these issues, the Associated General
Contractors of America and the American Consulting Engineers Council
established a task force to examine innovative steps to assign
construction risks.  The task force's report concluded that the
traditional approach of resolving liability issues after unforeseen
conditions are found or unexpected events occur is costly and
dispute-prone.\3 When these disputes occur, relationships between
parties can become adversarial and result in costly delays to
projects, especially when the courts are asked to resolve liability
issues.  In contrast, the task force noted that allocating and
managing risks up front with all the involved parties can reduce both
costly delays and disputes.  The report also stated that although
some aspects of risk-sharing have been around for years, they are
just now becoming more widely used. 

Besides concerns about liability, engineers also face financial
disincentives in designing lower-cost alternative systems, according
to several sources, including the American Consulting Engineers
Council.  Design fees are usually derived from "cost-curves"
developed by EPA and the American Society of Civil Engineers.\4 Under
these cost curves, engineers' fees are calculated as a percentage of
net construction costs, and lower-cost construction projects carry a
higher-percentage award.  Using the society's cost curves, an
engineer's fee would be about 7.5 percent of the construction costs
for a $1 million plant and about 6.4 percent of the construction
costs for a $5 million plant.  However, even with the
higher-percentage fee for the lower-cost project, the engineers'
actual compensation is higher for the high-cost project.  Design fees
would be about $320,000 for the $5 million facility compared with
about $75,000 for the $1 million facility.  This problem is
exacerbated because alternative plants frequently require more time
to design than traditional systems because site-specific
considerations must be taken into account. 

Despite the prevailing fee structure, some engineers may be motivated
to take on lower-cost design projects.  However, communities may not
be able to readily identify these engineers.  To increase the
opportunity for communities to hire engineers who are qualified and
motivated to design lower-cost systems, the American Consulting
Engineers Council generally favors the use of qualification-based
selection (QBS).  Under QBS, communities do not initially select
engineers on the basis of fees but instead screen consulting
engineers' bids on the basis of predetermined qualification factors,
such as experience with similar projects, and of engineers' ability
to work within time constraints.  The engineers meeting these
qualifications are then interviewed and ranked against the factors. 
At this point, the highest-ranked engineer is invited to further
discuss the scope of work, and only then are fees negotiated.  If the
negotiation process fails to yield satisfactorily mutual agreements,
the second-highest-ranked engineer is invited to negotiations, and so
on.  Wisconsin and New Mexico--two states that encourage or require
QBS--report great satisfaction with the process, as do consulting
engineers and municipalities. 


--------------------
\3 This 1990 report is entitled Owner's Guide to Saving Money by Risk
Allocation. 

\4 Although consulting engineers are not required to use a fee
structure based on a project's total costs, EPA's cost curves were
used under the agency's Construction Grants Program to derive
allowable design costs, and their use remains widespread. 


   STATE AND LOCAL CODES AND
   REGULATIONS ARE RESTRICTIVE
---------------------------------------------------------- Chapter 3:4

State and local codes and regulations can restrict or actually
prohibit the use of alternative technologies because many codes
contain specifications that apply to conventional technologies.  For
example, several states' codes and regulations require sewers to have
manholes spaced at a set number of feet and require pipes to be
buried at a given depth.  However, alternative sewers do not need
manholes or deep burial, and constructing them to meet these
specifications would negate much of their cost-effectiveness. 
Similarly, Illinois's code requires basement drains to flow into
sewer lines, but compliance with this requirement could overwhelm
proposed small-diameter sewer systems. 

Some states have recognized that their codes were written with
conventional technologies in mind and are addressing the issue. 
Several states are updating codes to allow greater flexibility in the
use of alternative technologies.  The following are illustrations: 

  Wisconsin's on-site domestic wastewater regulatory agency is
     currently revising the state's code for privately owned sewage
     systems and making it a performance-based code that will promote
     flexibility and innovation in the design of alternative
     technologies. 

  Massachusetts is also drafting new codes for on-site systems, in
     part to allow for more flexibility in the use of alternative
     technologies.  These new codes are intended to clarify the
     process for approving and using alternative technologies, ensure
     that on-site systems are properly operated and maintained, and
     provide information to municipal officials to help them
     determine which alternative systems are appropriate for their
     community. 

In addition, Washington State has established guidelines for the use
of a number of alternative on-site systems through the state's
On-Site Sewage Technical Review Committee.  This committee develops
guidelines for the use of new on-site technologies, which local
health agencies then use in issuing permits for the new technologies. 
In addition, the National On-Site Wastewater Recycling Association is
currently working with the Water Environment Federation to develop a
model national on-site wastewater treatment code that will encourage
the use of alternative technologies by moving from prescriptive,
technology-based standards to performance-based standards. 

EPA's requirements can also discourage the use of alternative
technologies.  EPA's Chief of the Municipal Technology Branch stated
that when EPA (or a state) directs a community to build a treatment
facility within a tight time frame, the community and the consulting
engineer may select a conventional system to avoid the additional
time that may be required to design and receive approval for an
alternative system. 


   EPA MAY ADDRESS BARRIERS
---------------------------------------------------------- Chapter 3:5

Although the Director of EPA's Office of Wastewater Management
acknowledged the value of (1) evaluating the applicability,
performance, and cost of projects employing alternative technologies
and (2) publishing and updating technical manuals reflecting the
results of these evaluations, he was concerned that limited resources
would preclude the Office from undertaking activities that were not
mandated by the Clean Water Act.  Subsequently, EPA's Office of Water
proposed three limited projects to address barriers to the use of
innovative and alternative wastewater treatment technologies. 
According to the Chief of the Municipal Technology Branch, EPA may
decide to propose funding these projects with the agency's fiscal
year 1995 appropriation for its Environmental Technology Initiative,
which EPA expects to be somewhat higher than the $36 million
appropriated for the initiative in fiscal year 1994. 

Two of the three projects would develop and publish information on
the applicability, performance, and cost of alternative wastewater
treatment technologies.  One project would gather information on
technologies that have had "technology assessments" or evaluations
completed but not disseminated.  Under this project, EPA would
determine the proper methods to package and disseminate this
information.  The second project would analyze the performance of
technologies from the I&A program that have not yet been seriously
reviewed.  EPA estimates the cost of completing these two projects at
$650,000. 

The goal of the third project would be to recommend approaches to
reduce or eliminate impediments to the use of innovative and
alternative wastewater treatment technologies that communities
finance through the state revolving funds program.  The Chief of
EPA's Municipal Technology Branch said that EPA could take actions on
the basis of this project's recommendations to address such barriers
as liability, engineering fees, and restrictive codes.  The
recommendations would be based on an assessment of barriers to the
selection of these technologies.  EPA estimated the cost of this
project at $500,000. 


   CONCLUSIONS
---------------------------------------------------------- Chapter 3:6

Alternative wastewater collection and treatment systems may cost less
than conventional systems and may present some communities with
affordable options for adequate wastewater treatment.  Nevertheless,
barriers to the full use of these systems need to be addressed if the
systems are to be used as frequently as may be warranted by site
conditions and cost-saving considerations. 

The projects that EPA is considering funding would be a helpful start
in addressing these barriers and could be initiated for a very small
portion of the total investment that EPA anticipates it will be
making in the development of environmental technology.  Most
importantly, the proposed projects would begin to address the need
for credible, current performance and cost data.  This is an area
that EPA is well situated to address, given its past and current
involvement with wastewater treatment systems. 


OBSTACLES HINDER THE DEVELOPMENT
OF NEW TECHNOLOGIES
============================================================ Chapter 4

Technological advancements are needed to cut the cost of achieving
environmental goals.  However, many believe research and development
on advanced technology to be inadequate.  The private sector can be
understandably hesitant to invest in developing unproven
technologies, given the reluctance of many in the engineering,
regulated, and regulatory communities to accept alternative
technologies.  Uncertainties about future regulatory requirements
have discouraged long-term investments in new technologies.  Federal
budget constraints have also limited investments, as the curtailment
of EPA's research on wastewater treatment technology has shown. 
Nevertheless, additional federal investment is now planned through
EPA's Environmental Technology Initiative. 


   DEVELOPMENT OF TECHNOLOGY COULD
   REDUCE FUTURE COSTS OF
   WASTEWATER TREATMENT
---------------------------------------------------------- Chapter 4:1

The market opportunities for lower-cost wastewater collection and
treatment technologies are significant.  EPA estimated the nation's
wastewater treatment needs at $108 billion in 1992; of this sum, $95
billion is needed by medium-sized and large communities.  These needs
include upgrading facilities to meet current secondary or advanced
treatment requirements, addressing combined sewer overflow problems,
and repairing and replacing aging sewers. 

Water quality professionals believe that research and development
could reduce these costs.  They pointed out that large-scale
wastewater treatment technology has not fundamentally changed over
the past several decades and speculated that new technologies could
help the nation meet its wastewater treatment needs more
cost-effectively.  Other professionals cited a growing consensus
about the merits of reducing or preventing pollution at its source
rather than treating it at "the end of the pipe" and suggested that
research and development investments should be concentrated in
technologies for preventing rather than treating pollution.  Both of
these areas would appear to be fruitful to pursue because each
presents a set of opportunities with market potential. 


   CURRENT LEVELS OF RESEARCH AND
   DEVELOPMENT ARE CONSIDERED
   INADEQUATE
---------------------------------------------------------- Chapter 4:2

Although projects are currently being funded by EPA, other federal
agencies,\1 equipment manufacturers, foundations, and academia, EPA
and water quality organizations said that current research and
development activities are inadequate to meet the future needs of
both large and small communities.  They also said that these efforts
are not well coordinated and, therefore, may not be targeted to meet
the nation's most pressing or long-term needs. 

The Director of the Water Environment Research Foundation\2 --the
organization that currently conducts a large share of the research
and development on wastewater treatment--noted that the foundation's
annual survey of subscribers' needs identifies a yearly need of $20
million for research on wastewater treatment but that the
foundation's current funding totals about $5 million annually. 
Although the President of the Water and Wastewater Equipment
Manufacturers' Association stated that the industry spends 3 to 4
percent of about $1 billion in sales on research and development, the
primary focus of these efforts is to refine existing technologies to
meet customers' short-term needs rather than to pursue significant
technological advancements.  According to the Deputy Director of the
Office of Research and Development's (ORD) Risk Reduction Engineering
Laboratory in Cincinnati, Ohio, EPA's current funding levels are not
adequate even to keep EPA's staff abreast of emerging technologies,
much less to support or conduct basic research and development on
more cost-effective wastewater treatment technologies. 


--------------------
\1 Other federal agencies, including the National Aeronautics and
Space Administration, Tennessee Valley Authority, Department of
Energy, and National Science Foundation, also support a limited
number of wastewater treatment research and development projects. 

\2 This foundation is funded primarily through voluntary
subscriptions from publicly owned treatment plants and, to a lesser
extent, corporate subscribers.  It also receives about $500,000
annually from EPA.  The foundation's parent organization is the Water
Environment Federation--a nonprofit entity that represents a wide
range of water quality professionals. 


      DISINCENTIVES LIMIT
      INVESTMENT BY PRIVATE SECTOR
-------------------------------------------------------- Chapter 4:2.1

Equipment manufacturers are understandably hesitant to make
significant investments in research and development for higher-risk,
cutting-edge technologies because many within the engineering,
regulated, and regulatory communities are reluctant to accept new
technologies.  Several of the National Advisory Council for
Environmental Policy and Technology's (NACEPT)\3 findings support
these concerns.  For example, (1) regulators and the permitting
process often create barriers to the use of innovative technologies,
(2) regulatory uncertainties inhibit the development of innovative
environmental technologies, and (3) venture capitalists are reluctant
to invest in environmental technology demonstration projects without
knowing if regulators will approve or permit new technologies.\4

Private-sector funding for researching and developing wastewater
treatment technologies is also limited by financial constraints
because most of the industry's firms are small corporations that
cannot sustain the long-term investments required to develop new
technologies.  Furthermore, manufacturers fear that if a technology
they develop fails, they will be held liable, their firms'
reputations will be damaged, and they will lose future business
opportunities. 


--------------------
\3 NACEPT is a public advisory committee providing extramural policy
information and advice to EPA. 

\4 Improving Technology Diffusion for Environmental Protection: 
Report and Recommendations of the Technology Innovation and Economics
Committee, NACEPT (Oct.  1992). 


      EPA GIVES LOW PRIORITY TO
      WASTEWATER TREATMENT
      RESEARCH AND DEVELOPMENT
-------------------------------------------------------- Chapter 4:2.2

EPA's funding for engineering research on wastewater treatment
dropped considerably from the late 1970s (as discussed in ch.  3). 
ORD officials stated that the budget reductions reflected a change in
the agency's research priorities.  Nearly half of ORD's funding in
fiscal year 1992 ($315 million) was directed toward multimedia
efforts--primarily research on ecological effects--and nearly a third
of the funding was set aside for the Air and Radiation Program.  ORD
also targeted pollution prevention as a high priority.  As noted in
ORD's April 1993 Strategic Issue Plan for Wastewater and Sludge,
funding for this area would not allow EPA to conduct research on new
cost-effective wastewater technologies for small communities.  Also,
research on new cost-effective wastewater treatment technologies for
larger municipalities was not a priority. 

The decline in EPA's wastewater research reflects a trend.  Over the
last decade, EPA's overall research and development budget has been
reduced substantially.  For example, in fiscal year 1983, research
represented over 15 percent of EPA's total budget; in fiscal year
1994, this level has dropped to about 5 percent. 


   BARRIERS TO DEVELOPING
   TECHNOLOGIES EXTEND ACROSS
   MEDIA PROGRAMS
---------------------------------------------------------- Chapter 4:3

The barriers to research and development discussed above have limited
the development not only of wastewater treatment technologies but
also of innovative technologies in other media programs, as EPA and
others have noted.  EPA has acknowledged these barriers within
specific programs and has developed initiatives to address them
within individual media programs. 

For example, in response to the need for technologies to clean up
hazardous waste, EPA was mandated by the Congress to establish the
Superfund Innovative Technology Evaluation Program.  In addition, EPA
created the Technology Innovation Office to support the
commercialization of innovative Superfund technologies.  Similarly,
as we recently reported, EPA has taken some action to address
barriers to developing new technologies for treating drinking
water.\5


--------------------
\5 See Drinking Water:  Stronger Efforts Essential for Small
Communities to Comply With Standards (GAO/RCED-94-40, Mar.  9, 1994). 


   INITIATIVES ARE UNDER WAY TO
   ADDRESS BARRIERS TO INNOVATION
   IN TECHNOLOGY
---------------------------------------------------------- Chapter 4:4

Rather than addressing these barriers on a program-by-program basis,
EPA has received suggestions for a comprehensive, agencywide
approach.  For example, because the barriers to developing
environmental technology cut across programs for different media,
NACEPT concluded that EPA should address these barriers
systematically through a comprehensive agencywide effort.  Among
other things, NACEPT recommended that EPA involve the providers,
regulators, and users of environmental technology to help EPA (1)
identify the most critical technology development needs and (2)
identify and reduce the barriers to the wider use of innovative
technologies.  The administration's recent National Performance
Review report also recommended that EPA increase private sector
partnerships to accelerate the development of innovative technologies
through improvements in the regulatory and statutory climate.\6

EPA has acknowledged the need to play an expanded role in reducing
these barriers and has some efforts under way.  In 1992, EPA created
an Innovative Technology Council to serve as an in-house advisory and
advocacy group to coordinate the agency's fragmented activities for
developing innovative technologies.  The Council is currently
drafting a strategic plan that centers on the four following
objectives:  (1) adapting EPA's policy, regulatory, and compliance
framework to promote innovation; (2) strengthening the capacity of
technology developers and users to succeed in environmental
technology innovation; (3) strategically investing EPA's funds in the
development and commercialization of promising new technologies; and
(4) accelerating the diffusion of innovative technologies at home and
abroad. 

To meet these objectives, the Council has developed the five
following basic operating principles for the agency to pursue:  (1)
maximum consultation with stakeholders; (2) coordination with
federal, state, and local agencies; (3) partnership and collaboration
with the private sector and academia to reduce the risk to innovators
in the market for environmental technologies (through public-private
partnerships, collaborative and cofunded research, and support for
testing and demonstrating innovative technologies to provide credible
documentation of their performance); (4) cleaner technology (focusing
on reducing pollution before it is generated), not just control
technology; and (5) measurement of progress in bringing innovative
technologies to bear in solving the nation's pressing environmental
problems. 

In addition, the administration proposed the "Environmental
Technology Initiative." In his State of the Union address in February
1993, the President stated that the purpose of the initiative is to
develop and deploy environmental technologies to improve the quality
of the environment and to enhance the economic standing of the United
States in the world marketplace.  The Congress responded by providing
EPA with $36 million in fiscal year 1994 (with a further increase
anticipated by EPA for fiscal year 1995) to fund the Environmental
Technology Initiative.  EPA has made its Innovative Technology
Council responsible for recommending specific uses for these funds. 

The Senate Appropriations Committee supported this funding, in part,
out of concern that the United States may lose its ability to compete
effectively in the growing international market for environmental
technologies.\7 The Committee supported funding of the initiative to
(1) recommend effective public and private partnership arrangements
for the development of environmental technology, (2) develop
approaches for the commercialization and diffusion of environmental
technologies developed with federal funds, and (3) identify economic
and regulatory barriers and incentives to the development,
deployment, and trade in environmental technologies.  However, the
Senate Appropriations Committee expressed concern about EPA's plans
for accomplishing these objectives and directed EPA not to expend
funds on the initiative until it submits a strategy and detailed
spending plan, subject to approval by the House and Senate Committees
on Appropriations.  Similarly, the House Appropriations Committee,
concerned because EPA did not have clearly defined plans for the
initiative, directed EPA to submit quarterly status reports.  EPA was
further directed to inform the Committee of all expenditures for the
initiative. 

As of September 1994, the Committees had approved all projects in
EPA's spending plan for fiscal year 1994, and EPA was soliciting
proposals for the initiative for fiscal year 1995. 


--------------------
\6 From Red Tape to Results:  Creating A Government That Works Better
and Costs Less, Report of the National Performance Review (Sept.  7,
1993). 

\7 According to a 1992 Organization for Economic Cooperation and
Development report, by 2000, the international market for
environmental technologies is expected to approach $300 billion.  The
report also stated that the United States invests only 0.5 percent of
its government research and development funds in environmental
objectives, whereas many European nations spend four or more times
this percentage. 


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I


   RESOURCES, COMMUNITY, AND
   ECONOMIC DEVELOPMENT DIVISION,
   WASHINGTON, D.C. 
--------------------------------------------------------- Appendix I:1

Bernice Steinhardt, Associate Director
Charles Adams, Assistant Director
Steve Elstein, Assistant Director
Gregory Kosarin, Evaluator-in-Charge
Ronald Morgan, Senior Evaluator
Beverly Norwood, Staff Evaluator
