NO-DISCHARGE ALTERNATIVE EVALUATION

Water Protection Program fact sheet
07/2016
Division of Environmental Quality Acting Director: Steve Feeler
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 able to achieve a no-discharge condition may solve certain challenges related to the treatment of pollutants and 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 fact sheet is intended to provide guidance and identify activities where a no-discharge alternative evaluation is required.

No-discharge alternatives are required to be evaluated during the various stages of the department’s 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 that 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.  Instances when the evaluation of no-discharge alternatives is required:

There are many examples of documentation that a community or consulting engineer can provide to demonstrate satisfactorily that 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 that accounts 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 to 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 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 that 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.

No Discharge Additional Justification Questions and Potential Documentation

Factors Considered

Evaluation and Questions

Potential Documentation

Land Availability

  • Evaluate & cost land available within 1.5 miles of the lagoon
  • Evaluate a long-term lease with a farmer
  • Capital cost estimate for piping and pumps
  • Evaluate increased application rates, requiring less land
  • Multiple application sites for optimal rate per farmer/crop
  • Public access areas with disinfection (e.g.golf courses, nature parks, etc…)
  • Geohydrological or soils report showing application rates
  • Copy of correspondence/ documentation with land owners regarding land for sale or lease
  • Provide address or plat map showing areas considered
  • County Soils Survey Maps consulted and application rates for the soils in the general area were provided
  • Show calculations for the amount of land necessary for the application rate and for lagoon storage.

Land Cost Expense

  • Evaluate land prices and availability farther from the site
  • Evaluate a long-term lease rather than land purchase
  • Salvage value of the land after 20 years
  • Capital cost estimate for piping and pumps
  • Evaluate long term upgrades of mechanical plant and new WQS vs. cost for land application (ie: mussel ammonia, bacteria, TP, TN)
  • Document recent land sales
  • Copy of correspondence/ documentation with land owners regarding land for sale or lease
  • 20-year life cycle of land application vs. mechanical plant

Easements/ Cost of Easements

  • Contact land owners for rights for an easement
  • Cost of the easement acquisition in comparison to continued discharging requirements
  • Condemnation consideration
  • Copy of correspondence/ documentation with land owners regarding easement rights
  • Document why the community is not willing to pursue condemnation (ie: council meeting minutes or letters )

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?
  • Capital cost estimate for piping and pumps
  • Copy of correspondence with land owners regarding land for sale or lease, not enough land available
  • Geohydrological reports
  • Soils maps and descriptions
  • Document land costs

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?
  • 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

  • Map
  • Detailed cost estimate for lift stations/ piping/ easements and connection
  • 20-year life cycle
  • Correspondence with other facility
  • Letter from the authority stating that the regional facility has no interest in taking flow from the new or expanded facility
  • Letter from municipality stating area is outside city limits and annexation would be required.
  • Funding from State Revolving Fund, which does not fund projects outside city limits

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?
  • Copy of the county/city ordinance
  • Council meeting minutes
  • 20 year life cycle

Leasing the land

  • Could controls built into the contract, such as the owner is required to use a certain percentage of the water annually?
  • How many land owners were contacted and what restrictions were presented?
  • Capital cost estimate for piping and pumps
  • 20-year life cycle of land cost
  • Long term leases, at least 20 years
  • Copy of correspondence/ documentation with land owners regarding land for sale or lease

Zoning Restrictions

  • Does the county ordinance specifically restrict land application, surface and subsurface?
  • Distance to neighboring county
  • Copy of the county ordinance
  • Council meeting minutes

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 (e.g. surface, LPP, drip)
  • Soils report, with maps and descriptions
  • Geohydrological Evaluation

Collapse Potential of Storage Facility

  • Evaluation of a liner or alternative site
  • Any additional information provided to Missouri Geological Survey, such as maps or additional soils work
  • Cost of installation of a liner
  • Map of other sites considered and their Geohydrological considerations

Subsurface application alternatives

  • What subsurface application alternatives were considered and why were they ruled out
  • Consider surface, LPP, drip
  • Alternatives analysis

High strength waste

  • Calculate the Plant Available Nitrogen (PAN) Calculation and/or Sodium Absorption Ratio
  • Soils loading rate
  • PAN result
  • Soils  report
  • Geohydrological Evaluation

Classified Stream buffer distance

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

  • Map
  • Geohydrological Evaluation
  • Soils report
  • Type and size of necessary vegetated buffer

Industrial components in wastewater

  • Calculate the Plant Available Nitrogen Calculation and/or Sodium Absorption Ratio

  • PAN result
  • Micronutrient concentration uptake
  • Soils  report, with test results, maps and descriptions
  • Geohydrological Evaluation

References: