mr. todd thomas elm hills park wwtf 500 northwest plaza ... · elm hills park wwtf 500 northwest...

Mr. Todd Thomas Elm Hills Utility Operating Company Elm Hills Park WWTF 500 Northwest Plaza Drive, Suite 500 St. Ann, MO 63074 RE: Elm Hills Park Wastewater System Improvements – Elm Hills Park Wastewater

Treatment Facility, MO0088382, Construction Permit No. CP0001900, Pettis County

Dear Mr. Thomas: The Missouri Department of Natural Resources, Water Protection Program has reviewed the plans and specifications submitted by 21 Design Group for the Elm Hills Utility Operating Co., Inc. Please find enclosed Construction Permit No. CP0001900. This permit will terminate 24 months from the date of issuance. In accordance with 10 CSR 20-6.010(4)(G), the Department may grant an extension only one time. If you believe that an extension is necessary, you must submit a request and a justification in writing for the extension at least 30 days prior to the permit expiration date. This construction permit does not supersede any requirements of the operating permit or enforcement actions. Nothing in this permit removes any obligations to comply with county or other local ordinances or restrictions. If you were adversely affected by this decision, you may be entitled to an appeal before the Administrative Hearing Commission (AHC) pursuant to 10 CSR 20-1.020 and Section 621.250, RSMo. To appeal, you must file a petition with the AHC within 30 days after the date this decision was mailed or the date it was delivered, whichever date was earlier. If any such petition is sent by registered mail or certified mail, it will be deemed filed on the date it is mailed; if it is sent by any method other than registered mail or certified mail, it will be deemed filed on the date it is received by the AHC. Contact information for the AHC is: Administrative Hearing Commission, United States Post Office Bldg., Third Floor, 131 West High Street, P.O. Box 1557, Jefferson City, MO 65102, Phone: 573-751-2422, Fax: 573-751-5018, and Website: ahc.mo.gov/.

http://ahc.mo.gov/

Mr. Todd Thomas Page Two If you have any questions concerning this matter, please contact Ms. Cailie Carlile, of the Water Protection Program, at 573-751-1714 or Missouri Department of Natural Resources, P.O. Box 176, Jefferson City, MO 65102. Thank you for your efforts to help ensure clean water in Missouri. Sincerely, WATER PROTECTION PROGRAM Refaat H. Mefrakis, P.E. Engineering Section Chief RHM: ccn Enclosures c: Mr. Ben Kuenzel, P.E., 21 Design Group Ms. Erin Meyer Heidolph, Water Protection Program Kansas City Regional Office

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page One

STATE OF MISSOURI

DEPARTMENT OF NATURAL RESOURCES

MISSOURI CLEAN WATER COMMISSION

CONSTRUCTION PERMIT

The Missouri Department of Natural Resources hereby issues a permit to:

Elm Hills Utility Operating Company 500 Northwest Plaza Dr., Suite 500

St. Ann, MO 63074

for the construction of (described facilities):

See attached.

Permit Conditions:

See attached.

Construction of such proposed facilities shall be in accordance with the provisions of the Missouri Clean Water Law, Chapter 644, RSMo, and regulation promulgated thereunder, or this permit may be revoked by the Department of Natural Resources (Department). As the Department does not examine structural features of design or the efficiency of mechanical equipment, the issuance of this permit does not include approval of these features. A representative of the Department may inspect the work covered by this permit during construction. Issuance of a permit to operate by the Department will be contingent on the work substantially adhering to the approved plans and specifications. This permit applies only to the construction of water pollution control components; it does not apply to other environmentally regulated areas. October 6, 2017

Effective Date Edward B. Galbraith, Director, Division of Environmental Quality October 5, 2019

Expiration Date Chris Wieberg, Director, Water Protection Program

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Two

CONSTRUCTION PERMIT

I. CONSTRUCTION DESCRIPTION

Proposed construction includes the addition of aeration units to the existing lagoon cell No. 1, a NitrOx Moving Bed Bioreactor (MBBR) after the existing first lagoon cell, installation of a pump station for recirculating flow, installing a drum filter after the MBBR, and installation of UV disinfection. The berm of lagoon cell one will be raised just over two feet (2’) to provide additional freeboard and flow equalization. The second and third cells of the existing lagoon system will be taken out of service. The design flow will be expanding from 24,425 gallons per day (gpd) to 34,900 gpd. The discharge location will also be moved from upstream of a lake to downstream of the lake, into the same receiving stream. The existing outfall pipe will be capped and abandoned. Lagoon effluent will gravity flow to the NitrOx MBBR system through approximately sixty-two (62) LF of eight inch (8”) D.I.P., then gravity flow to a pump tank through twenty (20) LF of eight-inch (8”) PVC. From the pump tank, effluent will either be pumped back to a concrete splash pad in lagoon cell #1 through approximately 400 LF of one and one-half inch (1 ½”) SDR 21 Class 200 PVC, or gravity flow through twenty-seven (27) LF of four-inch (4”) DIP to a cloth drum filter, and then to an ultraviolet disinfection system. Effluent will gravity flow from the disinfection system, through a new outfall line approximately 438 LF of eight inch (8”) SCH 40 PVC with two (2) manholes, to a concrete splash pad at the receiving stream. Sludge is returned from the drum filter to the lagoon through approximately 50 LF of one and one-half inch (1 ½”) SDR 21 Class 200 PVC.

II. COST ANALYSIS FOR COMPLIANCE

Pursuant to Section 644.145, RSMo, when issuing permits under this chapter that incorporate a new requirement for discharges from publicly owned combined or separate sanitary or storm sewer systems or publicly owned treatment works, or when enforcing provisions of this chapter or the Federal Water Pollution Control Act, 33 U.S.C. 1251 et seq., pertaining to any portion of a publicly owned combined or separate sanitary or storm sewer system or [publicly owned] treatment works, the Department of Natural Resources shall make a “finding of affordability” on the costs to be incurred and the impact of any rate changes on ratepayers upon which to base such permits and decisions, to the extent allowable under this chapter and the Federal Water Pollution Control Act. This process is completed through a cost analysis for compliance. Permits that do not include new requirements may be deemed affordable.

The Department is not required to complete a cost analysis for compliance because the facility is not a combined or separate sanitary sewer system for a publically-owned treatment works.

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Three III. CONSTRUCTION PERMIT CONDITIONS

The permittee is authorized to construct subject to the following conditions:

1. This construction permit does not authorize discharge.

2. All construction shall be in accordance with the plans and specifications submitted by 21 Design Group on February 23, 2017 and revised September 12, 2017.

3. The Department must be contacted in writing prior to making any changes to the

approved plans and specifications that would directly or indirectly have an impact on the capacity, flow, system layout, or reliability of the proposed wastewater treatment facilities or any design parameter that is addressed by 10 CSR 20-8, in accordance with 10 CSR 20-8.110(8).

4. State and federal law does not permit bypassing of raw wastewater, therefore steps

must be taken to ensure that raw wastewater does not discharge during construction. If a sanitary sewer overflow or bypass occurs, report the appropriate information to the Department’s Kansas City Regional Office per 10 CSR 20-7.015(9)(E)2.

5. This construction permit is invalid for projects required to comply with the requirements

contained in 10 CSR 20-4, “Grants and Loans”

6. The wastewater treatment facility shall be located at least fifty feet (50’) from any dwelling or establishment.

7. The wastewater treatment facility shall be located above the twenty-five (25)-year flood level.

8. Wastewater treatment facility shall not be located within one hundred feet (100'), and preferably three hundred feet (300') of any water well or water supply structure.

9. Protection of drinking water supplies shall be in accordance with 10 CSR 20-8.120(10). “There shall be no physical connections between a public or private potable water supply system and a sewer, or appurtenance thereto which would permit the passage of any wastewater or polluted water into the potable supply. No water pipe shall pass through or come in contact with any part of a sewer manhole.”

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Four

10. Sewers in relation to water works structures shall meet the requirements of 10 CSR 23-3.010 with respect to minimum distances from public water supply wells or other water supply sources and structures.

A. Sewer mains shall be laid at least 10 feet horizontally from any existing or proposed

water main. The distances shall be measured edge-to-edge. In cases where it is not practical to maintain a 10 foot separation, the Department may allow a deviation on a case-by-case basis, if supported by data from the design engineer. Such a deviation may allow installation of the sewer closer to a water main, provided that the water main is in a separate trench or on an undisturbed earth shelf located on either side of the sewer and at an elevation so the bottom of the water main is at least 18 inches above the top of the sewer. If it is impossible to obtain proper horizontal and vertical separation as described above for sewers, the sewer must be constructed of slip-on or mechanical joint pipe or continuously encased and be pressure tested to 150 pounds per square inch to assure water tightness.

B. Manholes should be located at least 10 feet horizontally from any existing or

proposed water main.

C. Manholes shall be located with the top access at or above grade level.

D. Sewers crossing water mains shall be laid to provide a minimum vertical distance of 18 inches between the outside of the water main and the outside of the sewer. This shall be the case where the water main is either above or below the sewer. The crossing shall be arranged so that the sewer joints will be equidistant and as far as possible from the water main joints. Where a water main crosses under a sewer, adequate structural support shall be provided for the sewer to maintain line and grade. When it is impossible to obtain proper vertical separation as stipulated above, one of the following methods must be specified:

a. The sewer shall be designed and constructed equal to the water pipe and shall

be pressure tested to assure water tightness prior to backfilling; or

b. Either the water main or sewer line may be continuously encased or enclosed in a watertight carrier pipe which extends 10 feet on both sides of the crossing, measured perpendicular to the water main. The carrier pipe shall be of materials approved by the Department for use in water main construction.

11. In addition to the requirements for a construction permit, 10 CSR 20-6.200 requires land

disturbance activities of 1 acre or more to obtain a Missouri state operating permit to discharge stormwater. The permit requires best management practices sufficient to control runoff and sedimentation to protect waters of the state. Land disturbance permits will only be obtained by means of the Department’s ePermitting system available online at dnr.mo.gov/env/wpp/epermit/help.htm. See dnr.mo.gov/env/wpp/stormwater/sw-land-disturb-permits.htm for more information.

http://dnr.mo.gov/env/wpp/epermit/help.htm

http://dnr.mo.gov/env/wpp/stormwater/sw-land-disturb-permits.htm

http://dnr.mo.gov/env/wpp/stormwater/sw-land-disturb-permits.htm

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Five

12. A United States (U.S.) Army Corps of Engineers (COE) permit (404) and a Water Quality Certification (401) issued by the Department or permit waiver may be required for the activities described in this permit. This permit is not valid until these requirements are satisfied. If construction activity will disturb any land below the ordinary high water mark of jurisdictional waters of the U.S. then a 404/401 will be required. Since the COE makes determinations on what is jurisdictional, you must contact the COE to determine permitting requirements. You may call the Department’s Water Protection Program at 573-751-1300 for more information. See dnr.mo.gov/env/wpp/401/ for more information.

13. Upon completion of construction

A. The Elm Hills Utility Operating Company will become the continuing authority for operation, maintenance, and modernization of these facilities;

B. Submit the enclosed form Statement of Work Completed to the department in

accordance with 10 CSR 20-6.010(5)(D) and request the operating permit modification be issued; and

C. Submit an electronic copy of the as builts if the project was not constructed in

accordance with previously submitted plans and specifications. IV. REVIEW SUMMARY

1. CONSTRUCTION PURPOSE

The existing facility is currently in poor condition and in need of upgrades; the new owners are looking to improve the system. The facility is currently under enforcement for delinquent permit fees and failure to submit Discharge Monitoring Reports.

2. FACILITY DESCRIPTION

The existing treatment facility consists of a three (3) cell, non-aerated lagoon. The effluent discharges into a Class C tributary of Flat Creek (8-20-13 MUDD V1.0). Flat Creek is also classified as a Class C Stream. The system serves a residential area of approximately 100 acres consisting of about 151 single family, duplex, mobile home, and multi-family residences. Proposed upgrades would add aeration to the lagoon and raise the lagoon berm, as well as add an MBBR system, drum filter, and UV disinfection.

3. COMPLIANCE PARAMETERS

This facility upgrade is being installed as a Demonstration Project because it is considered innovative technology. Extra monitoring for 18 months and a report at the end of 18 months to demonstrate one year of operation with six (6) months for start-up time is required to demonstrate the effectiveness of the new technology.

http://dnr.mo.gov/env/wpp/401/

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Six

The proposed project is expected to help the facility meet the following final effluent limits:

EFFLUENT PARAMETER(S) UNIT DAILY

MAXIMUM WEEKLY

AVERAGE MONTHLY AVERAGE

Flow mgd * * Biochemical Oxygen Demand5 mg/L 45 30 Total Suspended Solids mg/L 45 30 Ammonia as N (April 1 – Sept 30) (Oct 1 – Mar 31)

mg/L 2.5 5.2 1.0

2.0

E. coli (Apr 1 – Oct 31) #/100 mL 1030 206

EFFLUENT PARAMETER(S) UNIT MINIMUM MAXIMUM pH SU 6.5 9.0 * Monitoring requirement only

4. ANTIDEGRADATION

The Department has reviewed the antidegradation report for this facility and issued the Water Quality and Antidegradation Review dated March 15, 2017, due to the design flow expanding from 24,425 gpd to 34,900 gpd. See APPENDIX – ANTIDEGRADATION.

5. REVIEW of MAJOR TREATMENT DESIGN CRITERIA

The Elm Hills system serves 151 customers with no growth projected. US Census data show an average of 2.34 persons per household. To more accurately reflect the actual demographic, the applicant assumed 2.8 persons per household. Given the nature of the multi-family residential and leased property with small yards, water consumption rates will tend to be lower. Therefore, a rate of 82.5 gallons per day per person was used to calculate a design flow of 34,900 gpd. Average daily water usage (23,900 gpd) was also utilized to confirm the design flow rate.

Existing major components which will remain in use include the following:

• Lagoon Cell No. 1 – The influent is pumped into Lagoon Cell No. 1 by an existing

pump station on the treatment plant site. Lagoon Cell No. 1 is currently non-aerated and has a surface area of approximately 1.73 acres and a wastewater volume of 820,000 gallons. The berm of the lagoon will be raised about two feet. After the berm is raised, the cell will have 2 ft of freeboard, approximately 1.5 ft of operating depth, 2 ft of sludge depth, and a clay liner. The existing Lagoon Cells No. 2 and 3 will be closed. A closure plan will be submitted to the Kansas City Regional Office for review.

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Seven

Construction will cover the following items: • Two (2) AeroHub 8T aeration units will be installed in Lagoon Cell No. 1 before the

MBBR system to help eliminate the possibility of short circuiting. These aerators are being installed to reduce TSS and BOD, which would allow the MBBR system to eliminate the Ammonia more quickly. They will also provide a more consistent pollutant loading rate into the MBBR.

• Recirculation Tank – Construction of one recirculation tank to pump MBBR treated

wastewater back to Lagoon Cell No. 1 during periods of low flow. The structure will include an overflow weir gate that will allow the tank to discharge flow to the drum filter. The recirculation tank is 30 inches in diameter by seven feet (7’) total depth with a water level depth of 5.1 ft for a wastewater volume of approximately 190 gallons. The tank has one 5 HP submersible pump capable of 30 gpm at 78 ft TDH and 40 gpm at 70 ft TDH.

• Triplepoint Water Technologies, LLC NitrOxTM – The lagoon treated effluent will flow

by gravity through a recirculation tank and to the NitrOxTM system. The NitrOxTM system is capable of treating a design average flow of 34,900 gpd and a peak flow of 140,000 gpd. The system is composed of two tanks with each approximately 8 ft x 8 ft x 10 ft deep with a sidewater depth of 8 ft. Total volume of the two tanks is 7,660 gallons. The average flow hydraulic retention time is 5.3 hours and the peak flow hydraulic retention time is 1.3 hours. A modular floating insulating cover shall be installed in each tank. An electric immersion tank heater will be installed to maintain a minimum wastewater temperature of 5°C. Each tank shall be filled approximately 44% with HDPE media with a surface area of approximately 152 square ft per cubic ft and a protected surface area of approximately 113 square feet per cubic foot. Aeration by means of two tri-lobe positive displacement blowers each capable of supplying 180 scfm with 7.5 HP motors.

• Microscreen Drum Filter – Installation of one IN-EKO Microscreen Drum Filter Model 1FB. The unit will be in a tank that is 6 ft. x 3 ft. x 4 ft deep. The 1FB unit is capable of treating an average design flow of 182,596 gpd (8 L/s), which exceeds the expected peak flow for this facility. At the design average flow of 34,900 gpd, the flux rate will be 2.39 gpm/ft2. At the peak flow of 140,000 gpd, the flux rate will be 9.60 gpm/ft2. The unit has 18 media modules with a total filtration area of 20.15 ft2 and a submerged filtration area of 10.125 ft2. The filter media are constructed with 20 µm openings. The drum filter unit shall be supplied with a backwash assembly capable of delivering 40 gpm of water every 6 or 8 hours to 4 to 6 minutes. The backwash cleaning sequence will entail a water jet that rinses the system and push the debris into a sludge tank where it can be washed out via sludge pump back to Lagoon Cell No.1.

• Disinfection –

o Non-Contact Ultraviolet (UV) – A closed channel, gravity flow, low pressure high intensity UV non-contact disinfection system capable of treating a peak flow of 170,000 gpd while delivering a minimum UV intensity of 30 mJ/cm2 with an expected ultraviolet transmissivity of 65% or greater. The enclosed UV system consists of one non-contact UV reactor unit with 8 lamps.

Elm Hills Park Wastewater System Improvements Permit No. CP0001900 Elm Hills Park WWTF, MO-0088382 Page Eight

o Each lamp rack will be equipped with an LED indicator to identify the operating condition of each lamp on the lamp rack. There will also be a display for UV intensity and the system will be wired through a cellular monitoring system.

o Emergency Power – The operator has a portable generator that the UV system can be plugged into during power outages. Additionally, if the system had an electrical issue, valving is in place to store the discharge in the lagoon until the system is repaired.

• Flow Measurement – Installation of accurate flow measurement devices will give the

treatment facility a means of improved data analysis. o Electromagnetic Meter – An effluent Siemens Magnetic Flow Meter, Model

5100 shall measure the secondary treated and disinfected wastewater prior to discharge at Outfall No. 001.

6. OPERATING PERMIT MODIFICATION

Operating permit MO-0088382 will require a modification to reflect the construction activities. The operating permit modification was public noticed from June 9, 2017 to July 10, 2017 and no comments were received. Upon construction completion submit the enclosed form Statement of Work Completed to the department in accordance with 10 CSR 20-6.010(5)(D) and request the operating permit modification be issued.

Cailie Carlile, P.E. Engineering Section [email protected]

APPENDIX – ANTIDEGRADATION

Appendix – Antidegradation Page 2


Water Quality and Antidegradation Review

For the Protection of Water Quality and Determination of Effluent Limits for Discharge to Tributary to Flat Creek

by

Elm Hills Park Wastewater Treatment Facility

March 2017


Table of Contents 1. FACILITY INFORMATION ........................................................................................................ 5 2. WATER QUALITY INFORMATION ............................................................................................ 5 2.1. WATER QUALITY HISTORY: ................................................................................................... 5 3. RECEIVING WATERBODY INFORMATION................................................................................. 6 4. GENERAL COMMENTS ........................................................................................................... 6 5. ANTIDEGRADATION REVIEW INFORMATION ........................................................................... 6 5.1. TIER DETERMINATION ........................................................................................................... 6 TABLE 1. POLLUTANTS OF CONCERN AND TIER DETERMINATION .................................................... 7 5.2. EXISTING WATER QUALITY ................................................................................................... 7 5.3. NO DISCHARGE EVALUATION ................................................................................................ 7 5.4 LOSING STREAM ALTERATIVE DISCHARGE LOCATION .............................................................. 8 5.5. DEMONSTRATION OF INSIGNIFICANCE .................................................................................... 8 TABLE 2. NET CHANGE IN LOADINGS BASED UPON CURRENT AND PROPOSED PERMIT LIMITS. ......... 8 5.6. DEMONSTRATION OF NECESSITY AND SOCIAL AND ECONOMIC IMPORTANCE .......................... 9 6. GENERAL ASSUMPTIONS OF THE WATER QUALITY AND ANTIDEGRADATION REVIEW .............. 9 7. MIXING CONSIDERATIONS ..................................................................................................... 9 8. PERMIT LIMITS AND MONITORING INFORMATION ................................................................... 9 TABLE 3. EFFLUENT LIMITS FOR OUTFALL #001 ........................................................................... 10 9. RECEIVING WATER MONITORING REQUIREMENTS ................................................................ 10 10. DERIVATION AND DISCUSSION OF LIMITS ............................................................................. 10 10.1. OUTFALL #001 – MAIN FACILITY OUTFALL ......................................................................... 11 10.2. LIMIT DERIVATION .............................................................................................................. 11 11. ANTIDEGRADATION REVIEW PRELIMINARY DETERMINATION ............................................... 12 APPENDIX A: MAP OF DISCHARGE LOCATION .............................................................................. 13 APPENDIX B: NATURAL HERITAGE REVIEW .................................................................................. 14 APPENDIX C: ANTIDEGRADATION REVIEW SUMMARY ATTACHMENTS .......................................... 16


1. FACILITY INFORMATION FACILITY NAME: Elm Hills Park WWTF NPDES #: MO-0088382 FACILITY TYPE/DESCRIPTION: FACILITY TYPE: NON-POTW – Residential Subdivision – SIC #4952 FACILITY DESCRIPTION: The applicant’s proposed treatment facility is to add a Moving Bed Bioreactor (MBBR) after the existing first lagoon cell, install a pump station for recirculating flow, install a drum filter after the MBBR, and install UV disinfection. The berm of lagoon cell one will be raised to provide additional flow equalization. The second and third cells of the existing lagoon system will be taken out of service. The design flow will be expanding from 24,425 gallons per day (gpd) to 34,900 gpd. The discharge location will also be moved from upstream of a lake to downstream of the lake. COUNTY: Pettis UTM COORDINATES: X= 478670 / Y= 4279909 12- DIGIT HUC: 10300103-0301 LEGAL DESCRIPTION: NW ¼, NW ¼, Section 21, T45N, R21W

EDU*: Central Plains Blackwater / Lamine ECOREGION: Osage Plains / Ozark Highlands

* - Ecological Drainage Unit 2. WATER QUALITY INFORMATION In accordance with Missouri’s Water Quality Standard [10 CSR 20-7.031(3)] and federal antidegradation policy at Title 40 Code of Federal Regulation (CFR) Section 131.12 (a), the Missouri Department of Natural Resources (MDNR) developed a statewide antidegradation policy and corresponding procedures to implement the policy. A proposed discharge to a water body will be required to undergo a level of Antidegradation Review which documents that the use of a water body’s available assimilative capacity is justified. Effective August 30, 2008, and revised July 13, 2016, a facility is required to use Missouri’s Antidegradation Implementation Procedure (AIP) for new and expanded wastewater discharges.

2.1. WATER QUALITY HISTORY: The receiving stream flows for one mile until it reaches Flat Creek (C) (865). Flat Creek has a TMDL for sediment which is available at http://dnr.mo.gov/env/wpp/tmdl/docs/0865-flat-ck-tmdl.pdf. The main source of sediment is believed to be runoff from agricultural nonpoint sources. Wasteload allocations (WLA) for TSS in the TMDL are set as the lesser of current permit limits or technology based effluent limits (TBELs). Waste load allocations for TSS for Elm Hills Park in the TMDL are the permit limits at the time the TMDL was issued of 120 mg/L weekly average and 80 mg/L monthly average with a design flow of 58,617 gpd. A review of Discharge Monitoring Report history from March 2012 through November 2016 indicated three exceedances for BOD (Jun 2016, Mar 2016, Mar 2012) and one exceedance for TSS (Mar 2012). DMRs were not received for nine months in 2016 (only received for March and June). This facility’s actual flow exceeds its design flow due to the lagoon being over-connected. The existing operating permit established a four year schedule to comply with new ammonia and E. coli limits. Upgrades will also correct the flow issues. The facility is currently under enforcement for delinquent permit fees.

OUTFALL DESIGN FLOW (CFS) TREATMENT LEVEL RECEIVING WATERBODY DISTANCE TO

CLASSIFIED SEGMENT (MI)

001 0.054 Secondary Tributary to Flat Creek Direct Discharge

Flat Creek 1.0 mile to TMDL Stream

http://dnr.mo.gov/env/wpp/tmdl/docs/0865-flat-ck-tmdl.pdf


3. RECEIVING WATERBODY INFORMATION

WATERBODY NAME CLASS WBID LOW-FLOW VALUES (CFS) DESIGNATED USES** 1Q10 7Q10 30Q10

Tributary to Flat Creek (8-20-13 MUDD V1.0) C 3960 0.0 0.0 0.0 AQL, HHP, IRR, LWW, SCR,

WBC(B), General Criteria

Flat Creek C 865 0.0 0.0 0.1 AQL, HHP, IRR, LWW, SCR, WBC(B), General Criteria

** Irrigation (IRR), Livestock & Wildlife Watering (LWW), Protection of Warm Water Aquatic Life (AQL), Human Health Protection (HHP), Cool Water Fishery (CLF), Cold Water Fishery (CDF), Whole Body Contact Recreation – Category A (WBC-A), Whole Body Contact Recreation – Category B (WBC-B), Secondary Contact Recreation (SCR), Drinking Water Supply (DWS), Industrial (IND), Groundwater (GRW).

RECEIVING WATER BODY SEGMENT #1: Tributary to Flat Creek Upper end segment* UTM coordinates: X= 478670 / Y= 4279909 (Outfall) Lower end segment* UTM coordinates: X= 479574 / Y= 4279041 (tributary meets Flat Creek) *Segment is the portion of the stream where discharge occurs. Segment is used to track changes in assimilative capacity and is bound at a minimum by existing sources and confluences with other significant water bodies. 4. GENERAL COMMENTS 21 Design Group prepared, on behalf of Elm Hills Utility Operating Company, Inc., the Elm Hills Park Antidegradation Report dated November 2016. Applicant elected to determine that discharge of all pollutants of concern (POC) is non-degrading or insignificant to the receiving stream. This analysis was conducted to fulfill the requirements of the AIP. Information that was provided by the applicant in the submitted report and summary forms in Appendix C was used to develop this review document. A Missouri Department of Conservation Natural Heritage Review Report was obtained by the applicant (see Appendix B); MDC found no record or records of wildlife preserves, critical habitats, or state or federal endangered-list species records within one mile of the site. The confluence of the tributary where effluent is discharged and Flat Creek is approximately 1 mile downstream. This portion of Flat Creek is considered a significant example of a high quality, Central Plains, warm water – small river. Project activities should prevent soil erosion, water pollution and in-stream activities that modify or diminish aquatic habitats. The Natural Heritage review also notes that the U.S. Fish and Wildlife Service should be contacted if any trees need to be removed for the project in order to protect Indiana bats and Northern long-eared bats. 5. ANTIDEGRADATION REVIEW INFORMATION The following is a review of the Elm Hills Park Antidegradation Report dated November 2016.

5.1. TIER DETERMINATION Below is a list of pollutants of concern reasonably expected to be in the discharge (see Appendix C). Pollutants of concern are defined as those pollutants “proposed for discharge that affects beneficial use(s) in waters of the state. POCs include pollutants that create conditions unfavorable to beneficial uses in the water body receiving the discharge or proposed to receive the discharge.” (AIP, Page 7). Tier 2 is assumed for all POCs; however, tier determinations were not necessary with maintenance of mass loading determinations (see Appendix C).


TABLE 1. POLLUTANTS OF CONCERN AND TIER DETERMINATION POLLUTANTS OF CONCERN TIER DEGRADATION COMMENT

BOD5/DO 2 Insignificant Total Suspended Solids (TSS) ** Insignificant

Ammonia 2 Insignificant pH *** Insignificant Permit limits applied

Escherichia coli (E. coli) 2 Insignificant * Tier assumed. Tier determination not possible: ** No in-stream standards for these parameters. *** Standards for these parameters are ranges The following Antidegradation Review Summary attachments in Appendix C were used by the applicant: For pollutants of concern, the attachments are:

Attachment B, Tier 2 with minimal degradation.

5.2. EXISTING WATER QUALITY No existing water quality data were submitted as part of this review. All POCs were considered to be Tier 2 in the absence of existing water quality. One other discharger has a point source that flows into the same waterbody as Elm Hills Park WWTF. Don's Truck Towing and Truck Wash Inc. (MOG750046) has reported no discharge from May 2015 through December 2016.

5.3. NO DISCHARGE EVALUATION According to 10 CSR 20-6.010 (4)(D), reports for the purpose of constructing a waste water treatment facility shall consider the feasibility of constructing and operating a no discharge facility. Missouri’s antidegradation implementation procedures specify that if the proposed activity does not result in significant degradation then a demonstration of necessity (i.e., alternatives analysis) and a determination of social and economic importance are not required. For this reason, the no discharge evaluation should be submitted with the engineering report or facility plan for the purpose of obtaining a construction permit. The facility did submit information evaluating a no discharge alternative of irrigation of a golf course. The cost would include sludge removal from the lagoons to create volume for pre-treatment prior to irrigation. This alternative would have been difficult due to land restrictions, and being a publicly used area it would require disinfection and strategizing irrigation timing. An estimated present worth cost for the irrigation system was more than 120% of the cost of the proposed Moving Bed Bioreactor System. The facility also evaluated pumping the wastewater to a nearby City, but stated that the city had become unwilling to discuss a contract for the connection and therefore, the option was no longer feasible. The owners also considered regionalization. There was a meeting with the department to discuss ways the owner, CSWR, could help solve the problems of the many clustered wastewater discharges in the area. The cost to connect all these facilities by CSWR would increase the rates for the existing customer base. They determined that the only feasible approach would have been to force the neighboring facilities to connect at their own cost. CSWR will entertain letting others connect in the future, but for the size of potential customers, it is currently cost prohibitive for CSWR to pay for those improvements to extend the existing system.


5.4 LOSING STREAM ALTERATIVE DISCHARGE LOCATION

Under 10 CSR 20-7.015(4) (A), discharges to losing stream shall be permitted only after other alternatives including land application, discharge to gaining stream and connection to a regional facility have been evaluated and determined to be unacceptable for environmental and/or economic reasons. The facility does not discharge to a losing stream segment and will not discharge within two miles of a losing stream segment.

5.5. DEMONSTRATION OF INSIGNIFICANCE In Section II.A of the Missouri’s Antidegradation Rule and Implementation Procedure, a demonstration of insignificance of the discharge requires the applicant to show a reduction, or maintenance of loading, i.e., no change in ambient water quality concentrations in the receiving waters. As demonstrated in the Elm Hills Park Antidegradation Report dated November 2016, Table 2 below summarizes the results of current loading based on the current permit final effluent limit concentrations and proposed loadings based on the proposed permit concentrations. TABLE 2. NET CHANGE IN LOADINGS BASED UPON CURRENT AND PROPOSED PERMIT LIMITS.

Pollutants of Concern

Current Max Daily/ Average Weekly

at 24,425 gpd

Proposed Max Daily/ Average Weekly

at 34,900 gpd Net

change (lb/day)

Percent Change limit

(mg/L) loading (lb/day)

limit (mg/L)

loading (lb/day)

BOD5 (AWL) 65 13.2 45 13.1 -0.14 -1.1% TSS (AWL) 120 24.5 45 13.1 -11.35 -46.4% Ammonia summer 3.6 0.73 2.5 0.73 0.00 0.0% Ammonia winter 7.5 1.53 5.2 1.53 0.00 0.0% pH (SI Units) 6.5-9.0* Not Applicable E. coli Regulatory limits apply* Not Applicable

Pollutants of Concern

Current Average Monthly

at 24,425 gpd

Proposed Average Monthly

at 34,900 gpd Net

change (lb/day)

Percent Change limit


limit (mg/L)

loading (lb/day)

BOD5 45 9.2 30 8.7 -0.43 -4.7% TSS 80 16.3 30 8.7 -7.57 -46.4% Ammonia summer 1.4 0.29 1.0 0.29 0.00 0.0% Ammonia winter 2.9 0.59 2.0 0.59 0.00 0.0% pH (SI Units) 6.5-9.0* Not Applicable E. coli Regulatory limits apply* Not Applicable

* See Derivation and Discussion of Limits, Section 10. AWL = average weekly limit. Calculation of mass loading is done as follows:

Current design flow (Qd) = 0.024425 MGD. Proposed Effluent design flow (Qe) = 0.0349 MGD. Unit conversion: 1 mg/L = 8.34 lbs/million gallons limit = current or proposed limit expressed in concentration (mg/L)

Load (lbs/day) = Mass conversion * limit * Qd

Example: 8.34 (lbs/MG)/(mg/L) * 65 mg/L * 0.024425 MGD = 13.2 lbs/day


5.6. DEMONSTRATION OF NECESSITY AND SOCIAL AND ECONOMIC IMPORTANCE Missouri’s antidegradation implementation procedures specify that if the proposed activity does not result in significant degradation then a demonstration of necessity (i.e., alternatives analysis) and a determination of social and economic importance are not required. Thus, the Tier 2 Review is not required. 6. GENERAL ASSUMPTIONS OF THE WATER QUALITY AND ANTIDEGRADATION REVIEW 1. A Water Quality and Antidegradation Review (WQAR) assumes that [10 CSR 20-6.010(3)

Continuing Authorities and 10 CSR 20-6.010(4) (D), consideration for no discharge] has been or will be addressed in a Missouri State Operating Permit or Construction Permit Application.

2. A WQAR does not indicate approval or disapproval of alternative analysis as per [10 CSR 20-7.015(4) Losing Streams], and/or any section of the effluent regulations.

3. Changes to Federal and State Regulations made after the drafting of this WQAR may alter Water Quality Based Effluent Limits (WQBEL).

4. Effluent limitations derived from Federal or Missouri State Regulations (FSR) may be WQBEL or Effluent Limit Guidelines (ELG).

5. WQBEL supersede ELG only when they are more stringent. Mass limits derived from technology based limits are still appropriate.

6. A WQAR does not allow discharges to waters of the state, and shall not be construed as a National Pollution Discharge Elimination System or Missouri State Operating Permit to discharge or a permit to construct, modify, or upgrade.

7. Limitations and other requirements in a WQAR may change as Water Quality Standards, Methodology, and Implementation procedures change.

8. Nothing in this WQAR removes any obligations to comply with county or other local ordinances or restrictions.

9. If the proposed treatment technology is not covered in 10 CSR 20-8 Design Guides, the treatment process may be considered a new technology. As a new technology, the permittee will need to work with the review engineer to ensure equipment is sized properly. The operating permit may contain additional requirements to evaluate the effectiveness of the technology once the facility is in operation. This Antidegradation Review is based on the information provided by the facility and is not a comprehensive review of the proposed treatment technology. If the review engineer determines the proposed technology will not consistently meet proposed effluent limits, the permittee will be required to revise their Antidegradation Report.

7. MIXING CONSIDERATIONS

Mixing Zone (MZ): Not Allowed [10 CSR 20-7.031(5)(A)4.B.(I)(a)]. Zone of Initial Dilution (ZID): Not Allowed [10 CSR 20-7.031(5)(A)4.B.(I)(b)]

8. PERMIT LIMITS AND MONITORING INFORMATION WASTELOAD ALLOCATION STUDY CONDUCTED (Y OR N): N USE ATTAINABILITY

ANALYSIS CONDUCTED (Y OR N): N WHOLE BODY CONTACT USE RETAINED (Y OR N): Y

OUTFALL #001

WET TEST (Y OR N): N FREQUENCY: N/A AEC: N/A METHOD: N/A


TABLE 3. EFFLUENT LIMITS FOR OUTFALL #001

PARAMETER UNITS DAILY MAXIMUM

WEEKLY AVERAGE

MONTHLY AVERAGE

BASIS FOR LIMIT

(NOTE 2)

MONITORING FREQUENCY

FLOW MGD * * FSR Once/Month BOD5 (MG/L) MG/L 45 30 NDEL Once/Month TSS (MG/L) MG/L 45 30 NDEL Once/Month

PH (S.U.) SU 6.5 – 9.0 6.5 – 9.0 FSR Once/Month AMMONIA AS N (MG/L)

(APRIL1 – SEPT 30) MG/L 2.5 1.0 NDEL Once/Month

AMMONIA AS N (MG/L) (OCT 1 – MAR 31) MG/L 5.2 2.0 NDEL Once/Month

ESCHERICHIA COLIFORM (E. COLI) NOTE 1 1030** 206** FSR Once/Month NOTE 1 – COLONIES/100 ML NOTE 2– WATER QUALITY-BASED EFFLUENT LIMITATION – WQBEL; OR NO DEGRADATION EFFLUENT LIMIT – NDEL; OR FEDERAL/STATE REGULATION – FSR. ALSO, PLEASE SEE THE GENERAL ASSUMPTIONS OF THE WQAR #4 & #5. * Monitoring requirements only. ** The Monthly Average for E. coli shall be reported as a Geometric Mean. 9. RECEIVING WATER MONITORING REQUIREMENTS

No receiving water monitoring requirements recommended at this time.

10. DERIVATION AND DISCUSSION OF LIMITS Wasteload allocations and limits were calculated using two methods: 1) Water quality-based – Using water quality criteria or water quality model results and the dilution equation below:

( ) ( )( )se

eess

QQQCQCC

+×+×

= (EPA/505/2-90-001, Section 4.5.5)

Where C = downstream concentration Cs = upstream concentration Qs = upstream flow Ce = effluent concentration Qe = effluent flow Chronic wasteload allocations were determined using applicable chronic water quality criteria (CCC: criteria continuous concentration). Acute wasteload allocations were determined using applicable water quality criteria (CMC: criteria maximum concentration). Water quality-based maximum daily and average monthly effluent limitations were calculated using methods and procedures outlined in USEPA’s “Technical Support Document For Water Quality-based Toxics Control” (EPA/505/2-90-001). Chronic wasteload allocations (WLAc) were determined using applicable chronic water quality criteria (CCC: criteria continuous concentration) and upstream stream flow without mixing considerations. Acute wasteload allocations are only determined in the absence of applicable chronic criteria.


10.1. OUTFALL #001 – MAIN FACILITY OUTFALL

10.2. LIMIT DERIVATION • Flow. In accordance with [40 CFR Part 122.44(i)(1)(ii)] the volume of effluent discharged from each

outfall is needed to assure compliance with permitted effluent limitations. If the permittee is unable to obtain effluent flow, then it is the responsibility of the permittee to inform the department, which may require the submittal of an operating permit modification.

• Biochemical Oxygen Demand (BOD5). BOD5 limits of 30 mg/L monthly average, 45 mg/L average

weekly. These are the same as the technology-based secondary limitations at 10 CSR 20-7.015(8). The table below shows that the expanded loading will be reduced as compared to the current permitted loading. This demonstration of insignificance satisfies the requirements of the AIP. These limitations are non-degrading and protective of existing water quality.

Current Proposed

% Change in Loading Flow

(ft3/s) limit


Flow (ft3/s)

limit (mg/L)

loading (lb/day)

Average Weekly 0.038 65 13.2 0.054 45 13.1 -1.10% Average Monthly 0.038 45 9.2 0.054 30 8.7 -4.70%

There is a demonstrated reduction in loading in the above table; therefore, no dissolved oxygen analysis is needed to show that the proposed expanded loading is insignificant because existing water quality should improve with the proposed discharge. Therefore, staff considers the effluent limitations of 45 mg/L as the average weekly and 30 mg/L as the monthly average protective of aquatic life.

• Total Suspended Solids (TSS). 30 mg/L monthly average, 45 mg/L average weekly limit. These are the same as the technology-based secondary limitations at 10 CSR 20-7.015(8). The table below shows that the expanded loading will be reduced as compared to the current permitted loading. This demonstration of insignificance satisfies the requirements of the AIP. These limitations are non-degrading and protective of existing water quality.

Current Proposed

% Change in Loading Flow

(ft3/s) limit


Flow (ft3/s)

limit (mg/L)

loading (lb/day)

Average Weekly 0.038 120 24.5 0.054 45 13.1 -46.40% Average Monthly 0.038 80 16.3 0.054 30 8.7 -46.40%

The TMDL for sediment for Flat Creek notes that, based on the assessment of sources, point sources do not contribute to water quality impairment relative to sediment impacts on stream biology. Thus, the WLAs are zero percentage net reduction in sediment load. Facilities’ WLAs are set at the current permit limits and conditions. The TSS WLA for Elm Hills Park was set at the lagoon permit limits at the time the TMDL was issued of 120 mg/L weekly average and 80 mg/L monthly average. The TMDL notes that the TSS WLA for Mechanical waste water treatment facilities is a weekly average of 45 mg/L and a monthly average of 30 mg/L. These limits are the same as the applicant’s proposed non-degrading effluent limits.

• pH. – 6.5-9.0 SU. Technology based effluent limitations of 6.0-9.0 SU [10 CSR 20-7.015] are not protective of the Water Quality Standard, which states that water contaminants shall not cause pH to be outside the range of 6.5-9.0 SU. No mixing zone is allowed due to the classification of the receiving stream, therefore the water quality standard must be met at the outfall.


• Total Ammonia Nitrogen. Non-degrading limits for summer of 2.5 mg/L daily max and 1.0 mg/L monthly average and for winter of 5.2 mg/L daily max and 2.0 mg/L monthly average. The existing operating permit for this facility has interim monitoring only for ammonia and water quality-based final limits which become effective October 1, 2019 and remain in effect until the expiration of the permit. The final ammonia limits in the existing operating permit for summer are 3.6 mg/L daily max and 1.4 mg/L monthly average and for winter are 7.5 mg/L daily max and 2.9 mg/L monthly average. As noted in Table 2, the proposed Ammonia as N effluent limits result in maintenance of loading (0% change) and are non-degrading: Notice to Permittee: On August 22, 2013, the Environmental Protection Agency (EPA) published a notice in the Federal Register announcing the final national recommended ambient water quality criteria for protection of aquatic life from the effects of ammonia in freshwater. The EPA's guidance, Final Aquatic Life Ambient Water Quality Criteria for Ammonia – Fresh Water 2013, is not a rule, nor automatically part of a state's water quality standards. States must adopt new ammonia criteria consistent with EPA’s published ammonia criteria into their water quality standards that protect aquatic life in water.

The Water Protection Program (WPP) is providing this notice to inform permittees that EPA’s published ammonia criteria for aquatic life protection is lower than the current Missouri criteria. The Department has begun discussions about how these new criteria will be implemented. WPP is suggesting that all permittees consider the lower ammonia criteria and adjust the proposed alternative’s treatment design if they so choose. Consideration of the future ammonia criteria at this time could avoid a near-future upgrade. More information about the new ammonia criteria for aquatic life protection may be found at: http://dnr.mo.gov/pubs/pub2481.htm.

• Escherichia coli (E. coli). Monthly average of 206 per 100 mL as a geometric mean and Daily

Maximum of 1030 during the recreational season (April 1 – October 31), to protect Whole Body Contact Recreation (B) designated use of the receiving stream, as per 10 CSR 20-7.031(5)(C) and 10 CSR 20-7.015 (9)(B)1.A.. An effluent limit for both monthly average and daily maximum is required by 40 CFR 122.45(d). Per the effluent regulations the E. coli sampling/monitoring frequency shall be set to match the monitoring frequency of wastewater and sludge sampling program for the receiving water category in 7.015(1)(B)3. during the recreational season (April 1 – October 31), with compliance to be determined by calculating the geometric mean of all samples collected during the reporting period (samples collected during the calendar month for the monthly average). The daily maximum requirement is consistent with EPA federal regulation 40 CFR 122.45(d). Please see GENERAL ASSUMPTIONS OF THE WQAR #7

11. ANTIDEGRADATION REVIEW PRELIMINARY DETERMINATION The proposed facility discharge will result in no degradation of the segment identified in the Tributary to Flat Creek. Per the requirements of the AIP, the effluent limits in this review were developed to be protective of designated uses and to retain the remaining assimilative capacity in the receiving water body. MDNR has determined that the submitted review is sufficient and meets the requirements of the AIP. No further analysis is needed for this discharge. Reviewer: Cailie Carlile, P.E. Date: 03/09/2017 Unit Chief: John Rustige, P.E.

http://dnr.mo.gov/pubs/pub2481.htm


Appendix A: Map of Discharge Location

New Discharge Location Existing

Discharge Location


Appendix B: Natural Heritage Review


Appendix C: Antidegradation Review Summary Attachments The attachments that follow contain summary information provided by the applicant, Elm Hills Utility Operating Company, Inc. MDNR staff determined that changes must be made to the information contained within these attachments. The following were modified and can be found within the MDNR WQAR:

1) Water Quality Review Assistance Form: a. The form has “Upgrade (No Expansion)” checked, but “Expansion” should have been

checked. 2) Attachment B:

a. The new loads and percent load reductions in Item 10 list incorrect values. The correct new loads and percent reductions for BOD, TSS, and Ammonia are in Table 2 of this WQAR.

mr. todd thomas elm hills park wwtf 500 northwest plaza ... · elm hills park wwtf 500 northwest...

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