Approval Process for Innovative Technology - PUB2453

This document provides the department’s approval process for new or innovative wastewater technologies. For the purpose of this document, the definition for new or innovative wastewater technologies, which mirrors the definition for innovative technology provided in section 644.051.12, RSMo, is as follows:

Innovative technology for wastewater treatment means a completely new and generally unproven technology in the type and method of its application that bench testing or theory suggest has environmental, efficiency and cost benefits beyond the standard technologies.

The department encourages new methods and equipment for the treatment of wastewater and supports their development or use. While new treatment methods and equipment are encouraged, their efficacy must be demonstrated. This is typically accomplished by providing a theoretical overview of the technology, performing bench or pilot scale testing and by demonstrating a full-scale system. An overview of this approval process is provided herein. The applicant is encouraged to contact the department’s Water Protection Program before developing data to be used to demonstrate a new technology intended for use in Missouri.

Small-Scale Pilot Project for Innovative Technologies

The department may allow a temporary small-scale pilot project to obtain data to demonstrate expected performance of a proposed technology. These projects are to be installed such that the discharge is returned to and treated by the existing treatment facility. Projects must be approved by the department before initiating testing. A written request with a test plan must be submitted to the department in order to obtain the approval for the pilot test. The request must contain the following information.

The Test Plan - The testing to demonstrate the innovative technology’s efficacy must include, but may not be limited to, the following considerations:

• The impact of seasonal conditions on the technology (e.g., one year of data).
• If the demonstration is not in Missouri, data must be collected to demonstrate performance in the range of climatic conditions experienced in Missouri.
• The impact of variable flow rates and concentrations on the technology (e.g., hydraulic rates, pollutant concentrations, design flow, peak flow, low flow, etc.).
• The parameters that will be examined to demonstrate the technology’s efficacy.
• The test methods to be employed to generate the needed data for the engineering evaluation.
• The frequency and type of sampling (e.g., 24-hour composites, grabs, weekly frequency, diurnal considerations, etc.) to be used.
• The quality assurance/quality control (QA/QC) procedures to be employed to ensure valid test results are produced.
• The qualifications and affiliation of principal investigators should be provided.

The test plan should be submitted to the department’s Water Protection Program for review before initiating testing efforts. Communication with the department during the course of the project is encouraged.

After obtaining written project approval from the department, the project is exempt from obtaining a construction permit. Pilot project installations may be used for up to one year and the evaluation requirement specifics are as stated above. These installations are considered temporary and project requirements must be coordinated with the Water Protection Program’s Operating Permits Section to ensure water quality is protected. The applicant may submit a written request with justification for a time extension to the department. The department will review and may approve an extension period for up to one additional year.

Full-Scale Demonstration Project for Innovative Technologies

In order to determine if the new process or equipment meets department standards, the results of a comprehensive, full-scale demonstration of the technology must be provided. Three successful demonstration projects are required before advancing a technology out of an innovative status.

Before initiating an innovative or new technology demonstration project, the applicant is required to submit the appropriate permit applications and antidegradation evaluation. The application must include the purpose of the project, a description of the innovative technology, the scientific basis for the technology, and the anticipated benefits of the technology. If the process or equipment are to be demonstrated outside of Missouri, it must be demonstrated in a climate substantially the same as Missouri’s for it to be acceptable to the department.

The operating permit for a facility performing a full-scale demonstration project will contain additional requirements.  The monitoring frequency may be increased (e.g., every two weeks at designated locations), additional monitoring locations may be added (e.g., intermediate locations within the process), and monitoring additional parameters may be required (e.g., related to chemical and/or biological characteristics). A Demonstration Project Report requirement will also be added for facilities performing a demonstration project. After the innovative technology has been successfully demonstrated (typically after one year), monitoring requirements may be adjusted to a more typical scenario for that facility’s design flow.

The Demonstration Project Report - Upon completion of the demonstration project, a report that presents the findings of the testing and engineering evaluation must be prepared. The report should include, but may not be limited to the following:

• The facility description (including facility drawing or schematic) including the design parameters, calculations and all assumptions used in implementing the innovative technology employed for the demonstration.
• A description of the demonstration project testing procedures and engineering evaluation methodology should be provided.
• A summary of results should be presented which demonstrates the efficacy of the technology.
• A discussion of the demonstration findings should be provided.
• All analytical data, including QA/QC data, should be available for review upon request.
• If the demonstration is not performed in Missouri, data must be provided to show performance in the range of climatic conditions experienced in Missouri and the effluent is in the range of Missouri’s Water Quality Standards.

The department recommends the applicant review 10 CSR 20-8.110, Engineering – Reports, Plans, and Specifications, for assistance in determining the types of information relevant to the Demonstration Project Report.

The department may approve innovative technologies or equipment in accordance with 10 CSR 20-6.010(5)(E) and 10 CSR 20-8.110(6), under the following conditions:

• The operational reliability and effectiveness of the process or device has been demonstrated at various operating conditions (e.g., including its design flow of similar waste loading and peak flow conditions, seasonal impact, diurnal effects, etc.) at three separate installations for a minimum period of one year.
• An engineering evaluation was performed in a climate substantially the same as Missouri’s, demonstrating the technology has environmental, efficiency, and cost benefits. The documentation must verify consistent performance as designed for treatment of pollutants of concern. A copy of the evaluation must be made available to the department. The evaluation shall have been performed in accordance with good engineering practices and the sampling and analyses must have been performed in accordance with department-approved methods provided in 10 CSR 20-7.015.
• If a technology is in use outside Missouri, in a climate substantially the same as Missouri’s, it may be used as the demonstration of the technology if supporting information is provided to the department.

The department may require the innovative technology demonstration be performed by an independent third party. Resumes of the principal investigators may also be requested.