NO-DISCHARGE ALTERNATIVE EVALUATION

Water Protection Program fact sheet
08/2019
Division of Environmental Quality Director: Ed Galbraith
PUB02665

The Missouri Clean Water Law is intended to conserve, protect, maintain and improve the quality of the state’s waters. Preventing or eliminating discharges to the state’s waters satisfies this goal in the most direct manner. The goal of the federal Clean Water Act is the elimination of all discharges. Thus, wastewater treatment systems that are able to achieve a no-discharge condition may solve certain challenges related to the treatment of pollutants and may alleviate concerns about changing contaminant obligations in the future.

While a no-discharge system may not be a feasible alternative for every system, in many instances a no-discharge alternative has not been considered because there is a lack of specific guidance regarding the evaluation of this option. This provides guidance and identifies activities where a no-discharge alternative evaluation is required.

No-discharge alternatives are required to be evaluated during the various stages of the Missouri Department of Natural Resources’ antidegradation, construction permit and operating permit review processes. No-discharge alternatives include surface land application, subsurface land application, and connection to a regional treatment facility. The requirement for a no-discharge alternative evaluation ensures communities review durable long-term wastewater treatment options that might prove beneficial in the face of economic challenges and possible future changes in water quality standards. No-discharge alternative evaluations must be well documented, and recommendations regarding feasibility must be sufficiently justified.

The following are requirements and other considerations for no-discharge alternatives:

There are many examples of documentation a community or consulting engineer can provide to demonstrate satisfactorily no-discharge systems have been appropriately considered. A few commonly used factors are discussed below:

There are areas in the state where the existing geology makes the placement of a land application system challenging, but there are a number of existing land application systems that have overcome those challenges and are functioning well. Thus, the evaluation of no-discharge alternatives is a site-specific evaluation accounting for the geology, hydrology, community preferences and other considerations as communities plan for their future.

Proper evaluation of no-discharge systems will provide communities the necessary information when considering the option of land application, particularly as these communities face current and future wastewater commitments.

The matrix below provides a brief description of evaluation factors and the appropriate documentation for each factor. It is not a comprehensive list of site considerations, but is intended as a guide to assist communities in evaluating no-discharge alternatives. Communities should not rely solely on this document when making treatment technology decisions. The use of each of these evaluation factors should promote consistency and improved decision-making among communities, consulting engineers, and department staff as no-discharge alternatives are evaluated.

The following are terms used in the attached matrix:

Please note that the matrix assumes an application rate of 24 inches per year for surface land application. It is important to consult with a professional engineer in selecting a treatment technology, because RSMo 327.181.2 requires all design of buildings, structures, products, machines, processes and systems that can affect the health, safety and welfare of the public be designed by a professional engineer.

Additional Justification Questions for Demonstrating that No Discharge is not Feasible.

Factors Considered

Evaluation and Questions

Land Availability

  • Evaluate anad cost land available within 1.5 miles of the lagoon.
  • Evaluate a long-term lease with a farmer.
  • Provide a capital cost estimate for piping and pumps.
  • Evaluate increased application rates, requiring less land.
  • Evaluate multiple application sites for optimal rate per farmer/crop.
  • Evaluate public access areas with disinfection. For example: golf courses, nature parks, etc.

Land Cost Expense

  • Evaluate land prices and availability farther from the site.
  • Evaluate a long-term lease rather than land purchase.
  • Determine salvage value of the land after 20 years.
  • What is the capital cost estimate for piping and pumps?
  • Evaluate long-term upgrades of mechanical plant and new water quality standards vs. cost for land application. For example: mussel ammonia, bacteria, total phosphorus, total nitrogen.

Easements/Cost of Easements

  • Contact land owners for rights for an easement.
  • What is the cost of the easement acquisition in comparison to continued discharging requirements?
  • Consideration for condemning.

Size of Wastewater Flows

If flows are under 200,000 gpd:

  • Can application rates be increased?
  • Can the facility do seasonal discharge or seasonal application?
  • Can the facility buy property or lease multiple locations?
  • What is the capital cost estimate for piping and pumps?

Regional Connection

  • What is the distance to the closest municipality’s line or other facility’s line?
  • Is there any planning/zoning in the area regarding development and services?
  • What is the capital cost estimate for piping and pumps to regionalize?
  • Does the regional facility have the capacity to treat effluent and if not what would it cost to upgrade the regional facility?

Suitability of Site in Proximity of Neighboring Sites

  • Can buffer distances be increased to reduce neighbor noticing?
  • Are there other steps/considerations that can be made?
  • Change the method of application, avoiding center pivots and/or spray.
  • Drip or subsurface irrigation?

Leasing the Land

  • Could controls be built into the contract, such as requiring the owner to use a certain percentage of the water annually?
  • How many land owners were contacted and what restrictions were presented?
  • What is the capital cost estimate for piping and pumps?

Zoning Restrictions

  • Does the county ordinance specifically restrict land application, both for surface and subsurface?
  • What is the distance to a neighboring county?

Unsuitability of Soils

  • Was a soils report completed, including map information?
  • Does the soils report reflect the proposed area?
  • Is it cost-effective to bring in additional soils?
  • Can the application rate be decreased?
  • Is there a different method of application available? For example: surface, low press pipe systemand and drip.

Collapse Potential of Storage Facility

  • Evaluation of a liner or alternative site.
  • Is there any additional information provided to Missouri Geological Survey, such as maps or additional soils work.

Subsurface Application Alternatives

  • What subsurface application alternatives were considered and why were they ruled out?
  • Consider surface, low pressure pipe systemand and drip.

High Strength Waste

  • Calculate the plant available nitrogen calculation and/or sodium absorption ratio.
  • What is the soils loading rate?

Classified Stream Buffer Distance

  • Installation of vegetated buffer to reduce buffer distance.
  • Higher application rate requiring less land, which increases buffer distance.

Industrial Components in Wastewater

  • Calculate the plant available nitrogen calculation and/or sodium absorption ratio.

References: