The Missouri Department of Natural Resources requires all facilities undergoing the antidegradation or construction permitting processes to evaluate a no-discharge wastewater treatment facility alternative. The Missouri Clean Water Law is intended to conserve, protect, maintain and improve the quality of Missouri’s waters. In addition, the goal of the federal Clean Water Act is eliminating all discharges. Therefore, the department encourages wastewater treatment systems to achieve no-discharge.

Water quality standards and effluent limitations will only become more stringent in the future. While a no-discharge system may not be feasible for every wastewater system, it must be evaluated during the department’s antidegradation, construction permit and operating permit review processes.

Permitting

A common misperception is that a no-discharge wastewater treatment facility does not require an operating permit. However, a Missouri State Operating Permit is required for all systems that disperse more than 3,000 gallons per day into the soil within the same operating location. It is very important that the system operates correctly as a no-discharge system. Failure to do so is a violation of the Missouri Clean Water Law and may result in enforcement action. These operating permits contain reporting requirements and conditions to be met. Please read through the permit carefully.

Permit requirements include math calculations. To determine math calculations, the No-Discharge Operator Math guidance can help. 

Master General Permit

Master general permits, as opposed to site-specific permits, are issued to multiple locations where activities are similar enough to be covered by a single set of requirements. Master general permit MO-G823000  is for no-discharge, private, domestic wastewater treatment facilities with design flows of less than 50,000 gallons per day. Refer to the Applicability section of MO-G823000 for more details.

Site Specific Permit

Most no-discharge MSOPs are site specific and reflect the unique site of the no-discharge facility and land application area.

Permit Exemption

Discharge Facility Categories

No-discharge facilities may fall into one of three categories: regionalization, surface land application or subsurface soil dispersal systems. More details about each category and additional information is available below.

Regionalization

Regionalization can range from physically connecting to another wastewater system or consolidating two or more treatment facilities, to administrative solutions, such as cooperative purchasing, contract billing or shared operator employment. Physically connecting to another wastewater system reduces the number of discharges to waters of the state because only the discharging wastewater treatment facilities are required to have a Missouri State Operating Permit (MSOP). 

Typically, regionalization decreases the operation and maintenance portion of user raters. Larger wastewater systems have greater technical, managerial and financial capabilities in general. This leads to quicker response during emergencies and a better position to finance capital improvement projects.

Barriers to regionalization include local opinion, geography and large upfront capital costs. Local issues could be improved upon with open communication with neighboring systems. In remote rural areas, the geographic distance between wastewater systems may be too great for a physical connection. In these instances, administrative solutions should be considered. Where physical connection or consolidation is assessed, large upfront capital construction costs are often necessary.  The department's State Revolving Fund loan program awards additional priority points for regionalization projects. A low-interest State Revolving Fund loan could help finance construction projects. More information on the State Revolving Fund loan program can be found on the department's Wastewater Financial Assistance webpage.

Regionalization is a complex process and not feasible for every system, but it could be a cost-effective approach for some. In addition, a regional connection is a requirement in some MSOPs; 10 CSR 20-6.010(8)(A) requires a facility located within the service area of a Level 1, Level 2 or Level 3 Authority facility with an area-wide management plan to connect within the timeframe allotted by continuing authority with is notice of connection availability.

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