Pump and Haul Operating Permit Exemption - PUB2658

The Missouri Department of Natural Resources recognizes there are some circumstances where the use of onsite wastewater collection and treatment facilities are not practical or efficient, for which pumping and hauling to a permitted facility may be an alternative. However, there are a number of environmental and public health risks associated with pumping and hauling domestic and industrial process wastewater. These risks include overflowing storage structures causing an illegal discharge, accidental loss of wastewater before delivery to a permitted facility and improper disposal of wastewater. For these reasons, the department strongly encourages facilities to connect to a permitted facility or use an on-site wastewater treatment facility, and to consider pumping and hauling wastewater as a last resort only after all other options have been exhausted.

The purpose of this fact sheet is to explain the operating permit exemption requirements established in Code of State Regulations, 10 CSR 20-6.015(3)(B)12, for facilities using pump and haul practices. This fact sheet is not intended to address specific design criteria, nor is it meant to answer all of the hypothetical scenarios. If you have any questions concerning the pump and haul operating permit exemption, please contact the department's Water Protection Program.

The pump and haul operating permit exemption does not excuse any facility or person from complying with the Missouri Clean Water Law or any other federal, state or local laws. It is the facility owner’s responsibility to demonstrate to the department that the system is exempt.

Regardless if the facility is exempt from construction and operating permits, it will remain under the department’s jurisdictional authority throughout its lifespan. As described in 10 CSR 20-6.015(2)(B), nothing shall prevent the department from taking action to ensure facilities do not discharge into surface or groundwater, including requiring construction or operating permits for facilities that were normally exempt. The department may require permits to correct noncompliance, or when construction or operation and maintenance practices are not adequate.

This publication does not apply to facilities that fall under the jurisdiction of the Missouri Department of Health and Senior Services, On-site Wastewater Treatment Program or a local onsite wastewater authority, commonly the local health department. The department recommends reviewing the publication, Who Regulates Domestic Wastewater in Missouri? - PUB1296, for guidance in determining jurisdictional responsibility.

What is Domestic and Process Wastewater?

Domestic wastewater is defined in 10 CSR 20-2.010(26) as “wastewater (i.e., human sewage) originating primarily from the sanitary conveniences of residences, commercial buildings, factories, and institutions, including any water which may have infiltrated the sewers. Domestic wastewater excludes stormwater, animal waste, process waste, and other similar waste.”

Process wastes is defined in 10 CSR 20-6.015(1)(B)10, as “the waste, wastewater, sludges, biosolids and residuals originating from sanitary conveniences, or generated during manufacturing or processing, or results from the production or use of any raw material, intermediate product, finished product, by-product, or waste product and includes discharges from land application fields that occur as a result of the land application process.”

What is a No-discharge Facility?

As defined in 10 CSR 20-2.010(50), a no-discharge facility is “a facility designed, constructed, and operated to hold or irrigate, or otherwise dispose without discharge to surface or subsurface waters of the state, all process wastes and associated stormwater flows except for discharges that are caused by catastrophic and chronic storm events; any basin is sealed in accordance with 10 CSR 20-8, Minimum Design Standards; and no subsurface releases exist in violation of 10 CSR 20-7.015, Effluent Regulations, or section 577.155, RSMo.”

No-discharge Lagoons

The pump and haul operating permit exemption may be used for no-discharge lagoons that receive more than 3,000 gallons per day of domestic wastewater or any amount of industrial process wastewater, when the contents do not discharge from the lagoon, but instead are pumped and hauled to a permitted facility. The owner must have a written contract with the pumper-hauler and approval from the receiving facility that is able to receive the specific waste, as required by 10 CSR 20-6.015(3)(B)12. This exemption pertains to operating permits only.

Department-issued construction permits are required for all lagoons (earthen basins) that receive the following:

• Any amount of industrial process waste or
• When the calculated maximum daily flows of domestic wastewater for a facility operated under the same common promotional plan or within the same operating location is more than 3,000 gallons per day

Certain no-discharge lagoons that receive 3,000 gallons per day or less of domestic wastewater can be eligible for a construction and operating permit exemption. To learn more about that exemption, review the department's 3,000 Gallon Per Day or Less No-discharge Permit Exemption for Domestic Wastewater Design Guidance - PUB1319 fact sheet.

As described in 19 CSR 20-3.060(6)(D), the Missouri Department of Health and Senior Services, On-site Wastewater Treatment Program or the local on-site wastewater authority have jurisdictional responsibility for a single-family lagoon that serves no more than one single-family residence. The 3,000 gallons per day or less no-discharge lagoon permit exemption and the pump and haul operating permit exemption do not apply to those types of facilities. The department recommends contacting the Missouri Department of Health and Senior Services, Onsite Wastewater Treatment Program or the local onsite wastewater authority for their specific design and permitting requirements.

Holding Tanks

The pump and haul operating permit exemption is possible for holding tank(s) receiving the following:

• Any amount of industrial process waste or
• When the calculated maximum daily design flows of domestic wastewater for all holding tanks within a facility operated under the same common promotional plan or within the same operating location is more than 3,000 gallons per day, when the wastewater is pumped and hauled to a permitted facility that is able to receive it.

The owner must have a written contract with the pumper-hauler and approval from the receiving facility, as required by 10 CSR 20-6.015(3)(B)12. This requirement applies regardless if each holding tank receives less than 3,000 gallons per day of domestic wastewater or any amount of industrial processed waste. Holding tanks serving single-family residences are the jurisdiction of the Missouri Department of Health and Senior Services, Onsite Wastewater Treatment Program or the local onsite wastewater administrative authority and are not used in those calculations.

A construction permit is not required for holding tanks under the department’s jurisdiction as described in Missouri Revised Statutes section 644.051, RSMo, provided it is an engineered, pre-fabricated wastewater tank and installed according to manufacture’s specifications while following 10 CSR 20-8.  

As previously stated, the Missouri Department of Health and Senior Services, Onsite Wastewater Treatment Program or the local onsite wastewater administrative authority have jurisdictional authority for holding tanks serving single-family residences and for all holding tanks when the accumulated maximum daily flows of domestic wastewater within a facility operated under the same common promotional plan or operating location is less than or equal to 3,000 gallons. These facilities do not qualify for the pump and haul operating permit exemption.

What are the Approximate Operating Costs?

The approximate costs associated with operating a pump and haul facility can vary greatly throughout the state. The cost depends on numerous factors, including but not limited to, the following:

• Pumping frequency
• Accessibility
• Travel time
• Method of final treatment.

If a facility requires frequent pumping, the costs can be significant. Calculating the estimated cost of pumping the facility for its expected life should be part of the initial planning and not an afterthought. Over time, the cost of a wastewater treatment system may be less expensive than a pump and haul system.

Summary

The pump and haul operating permit exemption does not excuse any facility or person from complying with the Missouri Clean Water Law or any other federal, state or local laws. It is the facility owner’s responsibility to demonstrate to the department that the system is exempt.

As described in 10 CSR 20-6.015(2)(B), nothing shall prevent the department from taking action to ensure facilities do not discharge into surface or groundwater, including requiring construction or operating permits for facilities that were normally exempt. The department may require permits to correct noncompliance, or when construction or operation and maintenance practices are not adequate.

The department recognizes there are some circumstances where the use of other methods of wastewater collection and treatment are not practical or efficient. For those cases, pump and hauling may be an alternative. However, it is strongly recommended that the pump and haul option only be considered after all others have been exhausted.