Updated Mar 20, 2023

This post and comments at Brown County Matters.

I encourage concerned citizens to view the Water Quality Study presentation. It is only 23 minutes.

The study itself is available in the appendix.

Unless county elected officials direct otherwise, no public meeting that would allow citizens to ask questions regarding the plan and study is scheduled. However, elected and appointed state and federal officials will respond to questions. Documentation regarding their respective project review and approval processes on the applications for funding, are subject to the Freedom of Information Act (FOIA) and can also be obtained by citizens.

BLUF. The scope of the proposed projects for the Bean Blossom Area is not supported by all the facts and other available information relevant to the issues.

Key Points

Water Quality and The Major source of E-coli. Despite claims to the contrary in the strategic plan, the water study identifies that E-coli from pastureland, “AND NOT” failing septic systems (the prevailing BCRSD narrative), is recognized as the major source of E-coli.

Not So!  Claim  (below) identified in the Wastewater Strategic Plan, April 2022, Executive Summary, pg iv.

Conflicting position – Watershed Study:

• • There were 22 total samples. Of the five (5) samples that tested high for human-caused E.coli, only two BB10, BB12, exceeded the state standard. (Figure 28, pg. 64.)
  • It was stated that samples detected pharmaceutical and hair care products indicating human contamination. However ….
    • Regarding the detection of pharmaceuticals in the water, this topic was covered in the Brown County Democrat – STREAM SAMPLING: Where’s the contamination coming from? By Sara Clifford – 1/28/20. The information included in the article states: “The highest detections in surface waters are often associated with municipal wastewater treatment plant outfalls.” Would this be true for functioning septic systems as well, e.g., an effective septic system will not treat pharmaceuticals?
  • Figure 33 details that pastureland loads more E.coli to Brown County streams than other sources under all modeled septic failure modeling scenarios. Only if 100% of documented septic system failures are failing do they contribute a significant volume of E.colito the entirety of Brown County.”
    • Note: There are no documented failures and a “significant volume” is not the majority (see graph below).

Watershed Study – Model
Sources of E-Coli: Yellow Pasteurland; Green – septic systems

This conclusion has been a consistent finding in studies from throughout the State. Only “5” water samples in the targeted area identified the majority of E-coli as being human-caused. No additional analysis was provided as to how many septic systems may be contributing to the problem in these areas. Per the Pareto principle, 80% of the problems could be due to 20% of the causes supporting more cost-effective solutions.

• • Lake Monroe Watershed
    • E-coli levels in all the 2020 Lake Monroe samples were well below the state standard of 235 CFU/100 ml (CFU = colony forming units of bacteria). …. The South Fork (Jackson County) sub-watershed appears to be the largest contributor of E. coli.
  • Indiana Water Quality 
    • In a recent report, “the major cause” of E-coli IS NOT due to the possibility of failed septic system – it’s agricultural runoff from industries that are in compliance with federal and state laws and regulations. “IDEM said combined sewer overflows, untreated stormwater and wastewater that discharges to nearby streams, rivers and other water bodies were the largest sources of E. coli bacteria, one of the impairments cited to the EPA.”
    • Mar 31, 2022. Indiana ranks highest in nation for miles of polluted waterways, report finds
    • “According to the report, a major contributor to water pollution is manure and fertilizer runoff from farms. This causes the concentration of E. coli and nutrients that promote bacterial growth in waterways. “
    • Watershed Coordinator Maggie Sullivan, who works at the nonprofit Friends of Lake Monroe, said Lake Monroe suffers from nutrient contamination. Lake Monroe also has streams that feed into the lake which have elevated levels of E. coli, but levels in the lake are well below state standards. “Our biggest concern right now is harmful algal blooms,” Sullivan said. 

• Records and Useful Life of a Septic System. The video also identifies what is “speculated”  to be an “average useful life” of a septic system along with the lack of records in the Health Department, to conclude that an “estimated” 76% (2,200 systems) need repair or replacement. No documentation of inspections by the Health Department of the suspected properties was referenced to support the claim as to inadequate systems.
  • Was the “estimated” not documented failure rate overstated to influence the modeling (see above graph)?
  • Sweetwater Lake. (Watershed Study, pg. 26). “There are 550 homes around Sweetwater Lake, which represent the largest concentration of residential septic systems in the watershed.  “Failures”  were identified as being caused by “abuse, lack of maintenance, or grandfathered installations.”  No evidence of any “significant threats to water quality resulting from septic systems.”
  • Note that “potential” for problems was identified but nothing to indicate existing septic management practices would not continue to be effective.
  • Of the 550 homes, what would the BCRSD estimate to be the failure rate given “available records” and “useful life.”

Indefinite Useful Life. Conventional septic systems are designed to operate indefinitely if properly maintained.” (EPA 932-F-99-075). Presby Systems has also identified that a well-designed and maintained system can have an indefinite life. The county is flexible in approving Presby systems to accommodate site-related challenges that support repairs/replacements for existing homes. Pump and Haul is another approved option in some circumstances. A non-statistically valid survey with 113 responses was referenced as supporting the need for repairs/replacements of the existing system. It is unknown if needed actions may have already been completed.

Soils. The water study also identifies that county soils are “very limited in their ability to drain and treat the wastewater produced by a septic system. The State of Indiana has identified the criteria for soils and requires soil testing before a septic permit is granted by the county. I assume the county is in compliance with State guidance and statutes. This fact as to indefinite life is not referenced in the study.   Presby Systems (approved by the State and County), identify that their septic systems “treat wastewater before it is released into the ground and claim their “technology removes up to 98% of wastewater contaminants, recycling clean water into the environment and recharging natural water supplies.”

Economic RISK to Residents. It is unknown at this time if the BCRSD can identify (now or at a future date) a  higher standard for approving septic permits than what is allowed by the State and county. Given the relative power of an RSD that includes making decisions independent of elected officials, the allegations by the BCRSD regarding soils and the useful life of a septic system should be clearly documented and posted on the main page of the county website. The purpose is to prevent/mitigate any possible class-action lawsuits so that existing and prospective new residents can be aware of the potential risks posed by the BCRSD associated with owning property in Brown County.

Additional Comments

https://browncountyregionalsewerdistrict.wordpress.com/strategic-plan/

Helmsburg and Lake Lemon Corridor. The justification of sewer service in Helmsburg west to Lake Lemon is supported with valid justifications to include community support.

Bean Blossom Corridor. I continue to question the assumptions, data, and level of analysis used to support the scope of “solutions” identified for the Helmsburg and east to Bean Blossom and Woodland Lake corridor.

Economic Development. The intent for providing sewer service in the Bean Blossom area has always included the desire by a few for economic development. This has been reinforced by elected officials and the current BCRSD Board president, who has acknowledged his commercial interests in the area. Economic development-related analysis to include any adverse effects on the low to moderate-income level residents was not covered within the scope of the current projects.

Conclusion.  I would encourage concerned citizens to review the videos. The published plan and study provide the supporting detail. A public hearing is required before the applications for project funding are submitted. The RSDs have to allow for citizen input at the hearings. Input can be ignored. The Hearing is recorded which will provide more testimony to be considered by state and federal officials.