No-discharge Alternative Evaluation - PUB2665

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 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 guarantees 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:

• An antidegradation analysis is required for all new facilities, all expanding facilities and for the introduction of any new pollutants of concern. Missouri’s Antidegradation Implementation Procedures Section II B Review of Alternatives to Degradation requires applicants to conduct an evaluation of alternatives to a proposed discharge to determine whether or not the discharge is necessary, that is, to examine if reasonable alternatives exist to prevent significant degradation. Land application is one of the alternatives that may be considered depending upon applicability. Refer to the No Discharge Evaluation, Form--MO 780-2805, for guidance on evaluating non-discharging options.
• Regional connection is a requirement in some operating permits; 10 CSR 20-6.010(8)(A) requires a facility located within the service area of a Level 1, Level 2 or Level 3 Continuing Authority facility with an area-wide management plan to connect within the time frame allotted by the continuing authority with its notice of connection availability.
• A facility plan is required for projects involving wastewater treatment facilities requiring a construction permit and all facilities pursuing financing through the Missouri State Revolving Fund. The facility plan requires an examination of long-term growth and financial commitments in the community and requires a discussion of the alternatives evaluated, including no-discharge alternatives. A fully developed facility plan should evaluate multiple types of no-discharge alternatives. See 10 CSR 20-8.110(5)(E)3 and 10 CSR 20-6.010(4)(A)5.
• When applicable, a no-discharge option is considered in the cost analysis for compliance for all permitting or enforcement decisions that include new environmental requirements on publicly owned facilities. RSMo 644.145.4 requires the department to make a finding of affordability on costs to be incurred to meet a new environmental requirement. One of the criteria for making a finding is to evaluate the overall costs and environmental benefits of control technologies.

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:

• Geohydrologic Evaluation. This is a free service provided by the department’s Missouri Geological Survey. Team members will look at both the lagoon/storage basin site and the proposed application sites being considered, provided they have owner’s permission to be on the land. Communities can request this evaluation directly without going through their consulting engineer. To request a geohydrologic evaluation visit the department’s Geologic Evaluation Data Gateway Exchange (GeoEDGE) website.
• Soils Report. A County Soils Report is a report provided by the Natural Resources Conservation Service. While this report provides excellent information, in many cases a site-specific soils evaluation will need to be conducted to determine appropriate siting locations and hydraulic loading rates. A soils report is required for all proposed subsurface soil dispersal systems to determine the soils loading rate. Additionally, a soils report is required for proposed surface land application systems desiring to land apply greater than 24 inches per year. A site-specific soils report is prepared by a qualified soil scientist. It describes the soils present, and the application or loading rates for the given situation. The Summary of Soils Report for Land Application of Treated Wastewater, Form 780-2696 can be used to summarize the soils report.
• Regionalization. Regarding regionalization, appropriate correspondence may be provided. This would include a letter from an existing higher preference authority waiving preferential status where service is not available, in accordance with 10 CSR 20-6.010(2), or if capacity is not available.

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 team members as no-discharge alternatives are evaluated.

The following are terms used in the attached matrix:

• Capital cost is the cost for the equipment, construction and land necessary to construct an operable no- discharge system.
• Life cycle cost is the estimated cost of the project over a defined period, usually 20 years, and includes repayment of the capital cost loan, interest, operation and maintenance cost, and expected replacement of equipment during the project lifetime. In operating permits, the Cost of Compliance Analysis uses a life cycle cost estimate based on 30 years as the funding agencies have the ability to issue longer loans. Unless a community has secured funding for a 30-year loan, it is standard practice for life cycle cost estimates to be completed on a 20-year term.
• Correspondence includes letters from the community or the consulting engineer regarding availability, proximity and location of suitable land and the reasonable cost of such the land. A community that contacts multiple landowners demonstrates every effort was made to evaluate a no-discharge alternative rather than limiting the results to one landowner and their opinion. Correspondence could also include copies of proposed leases or discussions of purchases or easements. A community may choose not to select no-discharge because of the lack of voluntary sellers, but the no-discharge alternative should be considered and presented based on the reasonable cost of the land.

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.

References:

• Affordability Analysis, Missouri Revised Statutes 644.145
• Missouri Regulation 10 CSR 20-6.010
• Missouri Regulation 10 CSR 20-7.031(3)
• Antidegradation Implementation Procedure
• Missouri Regulation 10 CSR 20-8.110
• Facility Plan Guidance for Wastewater Treatment Facilities - PUB2416
• Engineering Report Guidance for Collection System - PUB2415
• Ammonia Criteria: New EPA Recommended Criteria - PUB2481
• Evaluating Wastewater Treatment Alternatives for Small Communities with Lagoons - PUB2587
• University of Missouri Extension Managing Nitrogen to Protect Water Quality, G9218
• Wastewater Irrigation Frequently Asked Questions - PUB2668
• Antidegradation: Regionalization and No-Discharge Evaluation MO 780-2805
• Request a geohydrologic evaluation at GeoEDGE
• Summary of Soils Report for Land Application of Treated Wastewater MO 780-2696