Planning a Wastewater System Project - PUB2648

Steps in a Wastewater System Project

1. Hire an engineer.
2. Evaluate existing system and needed improvements.
3. Evaluate and select and alternative.
4. Hold a bond election.
5. Submit plans and applications.
6. Receive construction approval and initiate construction.
7. Complete construction.

This fact sheet provides wastewater system owners an overview of the steps generally involved in a wastewater infrastructure project. It is not a comprehensive description of every requirement.  A wastewater project starts with an evaluation of existing infrastructure, and identification and prioritization of needed improvements. All plans and reports to accomplish these tasks need to be signed and sealed by an engineer registered in the state of Missouri, so the first step is to hire an engineer.

Financial Assistance Opportunities for System Evaluation and Pre-Project Planning

Clean Water Engineering Report Grants grants are available for municipalities, counties, public sewer or water districts, political subdivisions or instrumentalities of the state with a population of less than 10,000. These grants offer funding for wastewater engineering costs incurred to prepare a facility plan or engineering report. Communities may be eligible to receive an 80% grant with a 20% recipient match, while disadvantaged communities may be eligible to receive a 90% grant with a 10% recipient match. Grant awards can be up to $50,000. This grant is for a new work product only. The department must approve eligibility of the engineering services and award the grant prior to work commencing.

Step 1. Hire an Engineer

All engineering reports, plans and specifications must be signed, sealed and dated by a Missouri professional engineer. The procurement of planning and design services is one of the most important steps in the design or upgrade of wastewater systems. The procurement of engineering services should be in accordance with sections 8.285 through 8.291, RSMo.

Qualifications-based selection is a recommended process to negotiate procurement of an engineering firm based on qualifications and competence relative to the work to be performed. Qualifications-based selection information is provided by the American Council of Engineering Companies. Failure to properly procure engineering services can lead to ineligibility for funding provided by the department and other government agencies. If a community intends to request funding assistance, the community is encouraged to contact the funding agency to ensure they have the latest requirements.

Professional engineers registered in Missouri can be found on the Missouri Division of Professional Registration website. The Rural Community Assistance Partnership offers tips to help small communities hire an engineer.

Step 2. Evaluate the Existing System and Needed Improvements

Evaluate the Facility: An engineering evaluation and report on existing facility infrastructure and needed improvements should be developed in order to prioritize and estimate costs for needed system improvement alternatives. The engineering report (also known as a facility plan) should include an evaluation of the community’s financial capabilities and rate structure to determine if the community can responsibly pay for the most practical alternative. The facility plan should include discussion, documentation and rationale indicating the preferred alternative is the most reasonable and sustainable option in accordance with 10 CSR 20-8.110. The engineering evaluation should anticipate future rules, such as updated ammonia criteria. Guidelines for facility plans, plans and specifications for construction authorization permits is available in the Clean Water State Revolving Fund Project Facility Plan Guidance.

Communities that intend to seek engineering reports, plans and specifications and construction funding assistance from state and federal funding agencies are encouraged to apply and coordinate early to reduce any duplication of effort and ensure specific funding program requirements are met during early planning stages. 

Antidegradation Review: If the community is going to build a new or expanded facility, an antidegradation report needs to be submitted to the department before submittal of a facility plan, engineering report or construction permit application. The antidegradation report often includes an alternatives analysis of the different treatment technologies the engineer evaluated and the community’s preferred alternative. If a facility is pursuing a no-discharge alternative, an antidegradation report is not required.

Evaluate Inflow and Infiltration: Sewers and treatment facilities are designed on expected average and maximum flows. Excess stormwater and groundwater entering the sewer system through inflow and infiltration deprives the system of its valuable capacity, puts a burden on operation and maintenance and reduces the life expectancy of the treatment facility. Sewer surcharging, back-ups and overflows are some of the effects of inflow and infiltration. The evaluation of inflow and infiltration can be accomplished through recording and analyzing flow measurements. Once the general location of inflow and infiltration sources within the collection system have been identified by flow monitoring, then smoke testing, heavy cleaning, dye testing and/or closed-circuit television can be used for a complete evaluation of the inflow and infiltration sources. Once the evaluation has been completed, prioritization of work and a detailed cost estimate for collection system rehabilitation can be determined. The U.S. Environmental Protection Agency offers a Guide for Estimating Infiltration and Inflow.

Evaluate Rate Structure: During the system evaluation, the existing user rate/ revenue structure, potential infrastructure improvements and needed revenue for improvements will need to be evaluated. The department’s Financial Assistance Center can help systems evaluate and determine user rates. 

Evaluate Bylaws, Policies, Ordinances (etc.): Bylaws, policies and ordinances should prevent excess cost to the system in response to matters including non-remittance of customer fees, system failures, emergencies, etc. The department offers online editable examples of use ordinances and resolutions: Clean Water State Revolving Fund User Charge Ordinance and Clean Water State Revolving Fund Sewer Use Ordinance.

Identify Existing Debt:  Existing debt should be taken into consideration along with infrastructure improvement costs to determine project limitations and feasibility of improvements. Reserve accounts should exist for emergency equipment needs, debt service and operational maintenance needs. 

Determine Bonding Capacity: After the engineering evaluation and cost estimate for the system have been completed and improvement alternatives are identified, the system should identify their bonding capacity and limitations. If no current bonding capacity is available and the community is able to increase this capacity, the community should be ready to proceed with the bond election.  

Step 3: Evaluate and Select a Preferred Alternative   

The system uses the facility plan to select an improvement project. Critical long-term sustainability considerations include:

Long-Term Feasibility and the Permit Schedule of Compliance: The selected new wastewater treatment type should be able to meet the final effluent limits within the existing permit, as well as anticipate regulatory changes. Feel free to contact the department’s permitting staff for information about future regulatory changes that may potentially affect the system. If the most practical and appropriate treatment option will cause a substantial and widespread economic impact, the permittee may submit a permit modification application to the department requesting additional time in the Schedule of Compliance. The application for modification should include all supporting documentation showing that the selected treatment option is the most reasonable option for the community and will result in residential user rates that will not cause users to make unreasonable sacrifices in their essential lifestyle or spending patterns or undergo hardships in order to make the projected monthly payments for sewer services. (Please see Section 644.145 RSMo for further information.)

Consider Land Application Alternative: If a surface or sub-surface land application system is a viable option for the community, this type of treatment should be thoroughly considered in accordance with 10 CSR 20-6.010(4)(D)1. and 10 CSR 20-8.110(4)(C)8.G. The Missouri State Operating Permit for a land application system does not contain discharge effluent limits as there is no discharge to cause an impact on water quality. Therefore, a land application system is of value to the permittee when considering long-term costs associated with operation and maintenance, and future regulatory changes. Visit Evaluating Wastewater Treatment Alternatives for Small Communities With Lagoons - PUB2587 for more information.

Financial Assistance Opportunities for Construction Project Funding: Communities that intend to seek funding assistance from the agencies listed below are encouraged to apply and coordinate early. Financial assistance programs often have additional engineering, environmental and financial requirements the community must meet.

Step 4. Hold Bond Election

During the course of evaluating the current system and alternatives, the community should be ready to proceed with bond election to the extent funding of that type is available and necessary. Prior to the bond election, the community should make every attempt to advertise the need to pass the bond during the election. If the community is seeking state or federal financial assistance, contact the appropriate agency to learn about specific bond election requirements associated with each funding program. Expect the funding programs will require the community have a debt instrument (i.e., bonds) in place in order to be eligible for loans or grants.

Financial Assistance Opportunities for Construction

The Missouri Department of Natural Resources’ Financial Assistance Center provides funding to communities for certain water and wastewater infrastructure projects with the programs listed below.

• The Clean Water State Revolving Fund (SRF) Program is a partnership between EPA and Missouri to provide funding for capital improvement wastewater projects such as: building new publicly owned wastewater treatment plants; rebuilding, improving or upgrading publicly owned wastewater treatment plants; rehabilitation, replacement and new collection systems; lift stations; and water reuse, efficiency and conservations projects. The SRF program is primarily a subsidized loan program but grants may be available depending on annual appropriations by Congress.
  
  The SRF program offers loans with a 70% interest rate subsidy and loan term is typically 20 years, but may be up to 30 years. SRF applicants are required to submit an application that must be postmarked by Nov. 15 prior to the fiscal year for which SRF assistance is being sought for competitive evaluation with other applicants. Applications received after the deadline will still be considered for funding to the extent funds are available. Electronically transmitted applications are not accepted. The Missouri Clean Water Commission adopts an intended use plan, typically in early October, each year showing how the funds are intended to be allocated. Projects allocated funding in the plan still must meet the program requirements and the community undergoes a due diligence review for legal, institutional, managerial and financial capability prior to the department entering into a binding funding agreement for the project. Projects are funded once they are ready to proceed with construction.
   
• Rural Sewer Grants are offered to communities of less than 10,000 population, public water supply districts, and public sewer districts that must meet more stringent operation permit requirements or are expanding the system to provide service to areas without sewers. The maximum grant amount is the lesser of 50% of the eligible project cost or $1,400 times the number of service connections. When the grant is to fund a collection system, the maximum grant is based on the number of new service connections. Grants are capped at $500,000.
   
• Small Borrower Loan is a state-funded program with a $100,000 loan limit available to communities or public water districts with a population under 1,000. This loan does not require bonding capacity and provides up to a 70% interest rate subsidy.
   
• 40% State Construction Grants are currently not available.

U.S. Department of Agriculture Rural Development has loans and grants help very small, financially distressed rural communities finance extend and improve water and waste treatment facilities that serve local households and businesses. For more information, contact the USDA- Rural Development Missouri office at 573-876-0976. 

Missouri Department of Economic Development’s Community Development Block Grant (CDBG) offers grants to small Missouri communities to improve local facilities, address critical health and safety concerns, and develop a greater capacity for growth. For more information, contact the Missouri Department of Economic Development at 573-751-3600.

Step 5.  Submit Plans and Applications

Ensure the facility is up to date on annual permit fees: A facility’s annual permit fees need to be paid prior to any review of applications by the department. 

Submit Facility Plan: The department’s general engineering report guidance and facility plan guidance is available on the Wastewater Construction Permitting webpage. Questions regarding current information on funding options for inclusion in a facility plan should be directed to the appropriate agency because funding availability and requirements may change with time.

Apply for Construction Permit: A construction permit from the department is necessary prior to the start of work. All information for construction permitting is available on the department's website. The Wastewater Engineering - Wastewater Guidelines and Standards Document is an excellent resource that provides step-by-step guidance on obtaining a construction permit with or without department funding.

Apply for a Renewal or Modification of Current Missouri State Operating Permit: For existing facilities, an application for renewal or modification of the NPDES Missouri State Operating Permit should be submitted with the construction permit application. The renewed or modified permit must be put on public notice prior to issuance of the construction permit. Renewal applications are due to the department 180 days before expiration of the current permit.

Updated financial information using the department’s financial questionnaire must be submitted with the renewal or modification request. This information allows the department to determine if the permit’s schedule of compliance is adequate based on the community’s current financial situation. The more information a community provides, the more accurate and site-specific the department is able to draft the schedule of compliance. The application for modification and the financial questionnaire is available on the department's website.

Step 6. Receive Construction Approval and Initiate Construction

A construction permit is issued in accordance with 10 CSR 20-6.010(4)(G). Construction permits are issued for a minimum of one year, but up to 24 months may be approved depending on the project. If the community determines more time is needed to complete the project, the community can ask for an extension. The time extension needs to be submitted to the department at least 30 days prior to the expiration of the construction permit. Only one extension per construction permit can be awarded to a project. If the permittee fails to submit a request for extension before the construction permit expires, a new construction permit will need to be obtained and the associated fees paid to the department.

Construction of the selected wastewater treatment facility will take place during this time. If the community has received Clean Water SRF funding, construction should be completed in a timely manner and will be subject to at least quarterly inspection by the department.

Step 7.  Complete Construction

A statement of work should be submitted to the department by the engineer when the construction is complete, in accordance with 10 CSR 20-6.010(5)(D), together with any necessary documentation that is required if the department provided funding for the project. A new or modified Missouri State Operating Permit will be issued at that time reflecting the new treatment type and the appropriate effluent limits.

Where to Find Help

Each department regional office is staffed with a community services coordinator. The community services team offers assistance to local governments responsible for environmental protection in their communities such as answering questions and providing one-on-one assistance on specific environmental issues, helping communities find resources such as technical assistance, grants and loans and training, and assisting small, technically- and financially-challenged communities with developing a comprehensive plan to address current and future environmental needs.  Visit the department’s Water Protection Program Financial Assistance Center webpage or call 800-361-4827.