HomeMy Public PortalAboutExhibit MSD 84L5 - Lower Meramec Wastewater Treatment FacilityExhibit MSD 84L5
STATE OF MISSOURI
DEPARTMENT OF NATURAL RESOURCES
MISSOURI CLEAN WATER COMMISSION
MISSOURI STATE OPERATING PERMIT
In compliance with the Missouri Clean Water Law, (Chapter 644 R.S. Mo. as amended, hereinafter, the Law), and the Federal Water
Pollution Control Act (Public Law 92-500, 92'd Congress) as amended,
Permit No.
Owner:
Address:
Continuing Authority:
Address:
Facility Name:
Facility Address:
Legal Description:
UTM Coordinates:
Receiving Stream:
First Classified Stream and ID:
USGS Basin & Sub -watershed No.:
MO-0127949
St. Louis Metropolitan Sewer District (MSD)
2350 Market Street, St. Louis, MO 63129
St. Louis Metropolitan Sewer District (MSD)
1000 Grand Glaize Parkway, St. Louis, MO 63103
MSD, Lower Meramec Wastewater Treatment Facility
7849 Fine Road, St. Louis, MO 63129
SE'/., SW1/4, Sec. 34, T43N, R6W, St. Louis County
X= 732290, Y= 4255337
See Page Two
See Page Two
See Page Two
is authorized to discharge from the facility described herein, in accordance with the effluent limitations and monitoring requirements
as set forth herein:
FACILITY DESCRIPTION
SEE PAGE TWO
This permit authorizes only wastewater discharges under the Missouri Clean Water Law and the National Pollutant Discharge
Elimination System; it does not apply to other regulated areas. This permit may be appealed in accordance with Section 644.051.6 of
the Law.
December 1.2012
Effective Date
March 30.2017
Sohn , Director. Water Protection Logjam
Page 2 of 9
Permit No. MO-0127949
FACILITY DESCRIPTION (continued):
Outfall #001 — POTW — SIC #4952
The use or operation of this facility shall be by or under the supervision of a Certified "A" Operator
Coarse screens, fine screens, primary sedimentation (with chemical addition, if necessary/Trickling filter/secondary clarifiers (with
chemical addition, if necessary): gravity thickeners, belt filter press with polymer system, odor control (with chemical addition, if
necessary)/Disinfection with sodium hypochlorite and de -chlorination with sodium bisulfite used during the recreational season:sludge
is land applied, land filled, incinerated, or composted.
Design population equivalent is 150,000
Design flow is 15 MGD
Design peak daily flow is 42 MGD
Actual flow is 12.74 MGD
Design sludge production is 4,380 dry tons/year.
Legal Description: Land Grant — 3051, St. Louis County
UTM Coordinates: X = 732202.932, Y = 4252721.686
Receiving Stream: Mississippi River (P)
First Classified Stream and ID: Mississippi River (P)
USGS Basin & Sub -watershed No.: (07140101-0603) (1707)
Outfall #002 — Stormwater runoff/no treatment
Legal Description: Land Grant - 3051. St. Louis County
UTM Coordinates: X = 732057.842, Y = 4254806.463
Receiving Stream: Unnamed tributary to Meramec River (U)
First Classified Stream and ID: Meramec River (P)
USGS Basin & Sub -watershed No.: (07140102-1004) (2183)
Outfall #003 — Stormwater runoff/no treatment
Discharge is located approximately 450 feet southwest of the effluent box at a headwall.
Legal Description: Land Grant — 50, St. Louis County
UTM Coorriinatec• X = 732377, Y = 4255441
Receiving Stream: Unnamed tributary to Meramec River (U)
First Classified Stream and ID: Meramec River (P)
USGS Basin & Sub -watershed No.: (07140102-1004) (2183)
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
PAGE NUMBER 3 of 9
PERMIT NUMBER MO-0127949
The permittee is authorized to discharge Rain outfall(s) with serial number(s) as specified in the application for this permit. The final effluent
limitations shall become effective upon issuance and remain in effect until expiration of the permit. Such discharges shall be controlled, limited and
monitored by the permittee as specified below:
OUTFALL NUMBER AND
FINAL EFFLUENT LIMITATIONS
MONITORING REQUIREMENTS
UNITS
EFFLUENT PARAMETER(S)
DAILY
WEEKLY
MONTHLY
MEASUREMENT SAMPLE
MAXIMUM
AVERAGE
AVERAGE
FREQUENCY TYPE
Outfall #001
Flow
MGD
*
*
once/day 24 hr. total
Temperature
aF
*
*
once/day grab
Carbonaceous Biochemical Oxygen
mg/L
60
40
once/week 24 hr. comp.**
Demands
Total Suspended Solids
mg/L
65
45
once/week 24 hr. comp.**
E. coil (Note 1)
#/100 nil
1030
206
once/week grab
pH — Units
SU
* * *
* * *
once/weekday grab
Ammonia as N
(April 1— Sept 30)
mg/L
*
*
once/week grab
(Oct 1— March 31)
*
*
Total Residual Chlorine (Note 2)
µg /L
325
163
twice/week grab
130ML
130ML
MONITORING REPORTS SHALL BE SUBMITTED
MONTHLY; THE FIRST
REPORT
IS DUE JANUARY 28.2013. THERE SHALL BE
NO DISCHARGE OF FLOATING SOLIDS OR
VISIBLE FOAM IN OTHER
THAN TRACE
AMOUNTS.
Chromium III, Total Recoverable
µg/L
*
*
once/quarter**** grab
Chromium VI, Dissolved
µg/L
*
once/quarter**** grab
Oi18t Grease
mg/L
15
10
once/quarter**** grab
Hardness
mg/L
*
*
once/quarter **** grab
MONITORING REPORTS SHALL BE SUBMITTED
QUARTERLY; THE
FIRST REPORT
IS DUE APRIL 28.2013.
Whole Effluent Toxicity (WET) test
% Survival
See Special Conditions #23
once/year 24 hr. composite**
MONITORING REPORTS SHALL BE SUBMITTED
ANNUALLY; THE FIRST
REPORT
IS DUE OCTOBER 28, 2013.
**
***
****
Monitoring requirement only.
A 24-hour composite sample is composed of at least 48 aliquots (subsamples) collected at 30 minute intervals by an automatic
sampling device.
pH is measured in pH units and is not to be averaged. The pH is limited to the range of 6.5-9.0 pH units.
See table below for quarterly sampling.
Note 1- Final limitations and monitoring requirements for E. coll are applicable only during the recreational season from April 1
through October 31. The Monthly Average Limit for E coli is expressed as a geometric mean. The Weekly Average for E. coli will
be expressed as a geometric mean if more than one (1) sample is collected during a calendar week (Sunday through Saturday).
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS (continued)
Note 2 - This permit contains a Total Residual Chlorine (TRC) limit.
(a)
Page 4 of 9
Permit No. MO-0127949
The monthly average effluent limit is below the minimum quantification level (MI) of the most common and practical EPA
approved CLTRC methods. The Department has determined the current acceptable NIL for total residual chlorine to be 0.13
mg/L when using the DPD Colorimetric Method #4500 — CL G. from Standard Methods for the Examination of Waters and
Wastewater. The permittee will conduct analyses in accordance with this method, or equivalent, and report actual analytical
values. Measured values greater than or equal to the minimum quantification level of 0.13 mgL will be considered
violations of the permit and values less than the minimum quantification level of 0.13 mg will be considered to be in
compliance with the permit limitation. The minimum quantification level does not authorize the discharge of chlorine in
excess of the effluent limits stated in the permit.
(b) Disinfection is required year-round unless the permit specifically states that "Final limitations and monitoring requirements
for E. coli are applicable only during the recreational season from April 1 through October 31." If your permit does not
require disinfection during the non -recreational months, do not chlorinate in those months.
(c) Do not chemically de -chlorinate if it is not needed to meet the limits in your permit.
(d) If no chlorine was used in a given sampling period, an actual analysis is not necessary. Simply report as "0 mg/L" TRC.
B. INFLUENT MONITORING REQUIREMENTS
The facility is required to meet a removal efficiency of 85% or more as a monthly average. The monitoring requirements shall become effective upon
issuance and remain in effect until expiration or the permit. To determine removal efficiencies, the influent wastewater shah be monitored by the
permittee as specified below:
SAMPLING LOCATION AND
PARAMETER(S)
UNITS
MONITORING REQUIREMENTS
).OASLREMENT FREQUENCY
SAMPLE TYPE
Influent
mg/L
mg/L
once quarter****
once/quarter****
24 hr. composite**
24 hr. composite**
Carbonaceous Biochemical Oxygen
Demands
Total Suspended Solids
MONITORING REPORTS SHALL BE SUBMITTED
QUARTERLY: THE FIRST REPORT IS DUE APRIL 28, 2013.
**** See table below for quarterly sampling.
Sample discharge at least once for the months of:
January, February, March (1st Quarter)
April, May, June (2nd Quarter)
July, August, September (3rd Quarter)
October, November, December (4th Quarter)
C. STANDARD CONDITIONS
Report is due:
April 28
July 28
October 28
January 28
IN ADDITION TO SPECIFIED CONDITIONS STATED HEREIN, THIS PERMIT IS SUBJECT TO THE ATTACHED Parts I, II, & III
STANDARD CONDITIONS DATED October 1. 1980 and August 15. 1994, AND HEREBY INCORPORATED AS THOUGH FULLY SET FORTH
HEREIN.
Page 5 of 9
Permit No. MO-0127949
D. SPECIAL CONDITIONS
1. This permit may be reopened and modified, or alternatively revoked and reissued, to:
(a) Comply with any applicable effluent standard or limitation issued or approved under Sections 301(b)(2)(C) and (D),
304(b)(2), and 307(a) (2) of the CIean Water Act, if the effluent standard or limitation so issued or approved:
(1) contains different conditions or is otherwise more stringent than any effluent limitation in the permit; or
(2) controls any pollutant not limited in the permit.
(b) Incorporate new or modified effluent limitations or other conditions, if the result of a waste load allocation study, toxicity
test or other information indicates changes are necessary to assure compliance with Missouri's Water Quality Standards
(c) Incorporate new or modified effluent limitations or other conditions if, as the result of a watershed analysis, a Total
Maximum Daily Load (TMDL) limitation is developed for the receiving waters which are currently included in Missouri's
list of waters of the state not fully achieving the state's water quality standards, also called the 303(d) list.
(d) The permit as modified or reissued under this paragraph shall also contain any other requirements of the Clean Water Act
then applicable.
2. All outfalls must be clearly marked in the field.
3. The permittee is the facility with an area -wide management plan per 10 CSR 20-6.010(3)(B).
4. Water Quality Standards
(a) Discharges to waters of the state shall not cause a violation of water quality standards rule under 10 CSR 20-7.031,
including both specific and general criteria.
(b) General Criteria. The following general water quality criteria shall be applicable to all waters of the state at all times
including mixing zones. No water contaminant, by itself or in combination with other substances, shall prevent the waters
of the state from meeting the following conditions:
(1) Waters shall be free from substances in sufficient amounts to cause the formation of putrescent, unsightly or
harmful bottom deposits or prevent full maintenance of beneficial uses;
(2) Waters shall be free from oil, scum and floating debris in sufficient amounts to be unsightly or prevent full
maintenance of beneficial uses;
(3) Waters shall be free from substances in sufficient amounts to cause unsightly color or turbidity, offensive odor or
prevent full maintenance of beneficial uses;
(4) Waters shall be free from substances or conditions in sufficient amounts to result m toxicity to human, animal or
aquatic life.
(5) There shall be no significant human health hazard from incidental contact with the water;
(6) There shall be no acute toxicity to livestock or wildlife watering;
(7) Waters shall be free from physical, chemical or hydrologic changes that would impair the natural biological
community;
(8) Waters shall be free from used tires, car bodies, appliances, demolition debris, used vehicles or equipment and solid
waste as defined in Missouri's Solid Waste Law, section 260.200, RSMo, except as the use of such materials is
specifically permitted pursuant to section 260.200-260.247.
5. Changes in Discharges of Toxic Substances
The permittee shall notify the Director as soon as it knows or has reason to believe:
(a) That any activity has occurred or will occur which would result in the discharge of any toxic pollutant which is not limited
in the permit, if that discharge will exceed the highest of the following "notification levels:"
(1) One hundred micrograms per liter (100 µg/L);
(2) Two hundred micrograms per liter (200 µg/L) for acrolein and acrylonitrile; five hundred micrograms per liter (500
µg/L) for 2,5 dinitrophenol and for 2-methyl-4, 6-dinitrophenol; and one milligram per liter (1 mg/L) for antimony;
(3) Five (5) times the maximum concentration value reported for the pollutant in the permit application;
(4) The level established in Part A of the permit by the Director.
(b) That they have begun or expect to begin to use or manufacture as an intermediate or final product or byproduct any toxic
pollutant, which was not reported in the permit application.
6. Report as no -discharge when a discharge does not occur during the report period.
7. It is a violation of the Missouri Clean Water Law to fail to pay fees associated with this permit (644.055 RSMo).
Page 6 of 9
Permit No. MO-0127949
D. SPECIAL CONDITIONS (continued)
8. The permittee shall comply with any applicable requirements listed in 10 CSR 20-9, unless the facility has received written
notification that the Department has approved a modification to the requirements. The monitoring frequencies contained in this
permit shall not be construed by the permittee as a modification of the monitoring frequencies listed in 10 CSR 20-9. If a
modification of the monitoring frequencies listed in 10 CSR 20-9 is needed, the permittee shall submit a written request to the
Department for review and, if deemed necessary, approval.
9. The permittee shall continue to develop and implement, in accordance with the Consent Decree, a program for maintenance and
repair of the collection system. The permittee shall submit a report annually in November to the St. Louis Regional Office with
the Discharge and Monitoring reports which address measures taken to locate and eliminate sources of infiltration and inflow into
the collection system serving the facility.
10. The permittee shall report any substantial changes in the volume or character of pollutants being introduced to the POTW. The
approval to bypass may be modified or terminated when there is a substantial change in the volume or character of pollutants
being introduced to the POTW.
11. The permittee shall continue to implement a program for maintenance and repair of the collection system.
12. The SWPPP shall continue to do the following:
(a) Assess all storm water discharges associated with the facility. This must include a list of potential contaminants and an
annual estimate of amounts that will be used in the described activities.
(b) Listing of all specific Best Management Practices (BMPs) and a narrative explaining how BMPs will be implemented to
control and minimize the amount of potential contaminants that may enter storm water.
(c) Have an individual to be responsible for environmental matters.
(d) Provide training to all personnel involved in material handling and storage, and housekeeping of maintenance and cleaning
areas. Proof of training shall be submitted on request of DNR.
(e) Provide spill cleanup in the event that any stored pollutants are released in to the environment.
(f) Avoid track -out from any building where materials are contained.
(g) Maintain vegetation on all unpaved area to prevent erosion.
12. Permittee shall adhere to the following minimum Best Management Practices:
(a) Prevent the spillage or loss of fluids, oil, grease, fuel, etc. from vehicle maintenance, equipment cleaning, or warehouse
activities and thereby prevent the contamination of storm water from these substances.
(b) Provide collection facilities and arrange for proper disposal of waste products including but not limited to petroleum waste
products, and solvents.
(c) Provide good housekeeping practices on the site to keep solid waste from entry into waters of the state.
13. All paint, solvents, petroleum products and petroleum waste products (except fuels), and storage containers (such as drums, cans,
or cartons) shall be stored so that these materials are not exposed to storm water. Spill prevention, control, and or management
shall be provided sufficient to prevent any spills of these pollutants from entering a water of the state. Any containment system
used to implement this requirement shall be constructed of materials compatible with the substances contained and shall also
prevent the contamination of groundwater.
14. Bypasses are not authorized at this facility and are subject to 40 CFR 122.41(m). If a bypass occurs, the permittee shall report in
accordance to 40 CFR 122.41(m)(3)(1), and with Standard Condition Part I. Section B, subsection 2.b. Bypasses are to be
reported to the St. Louis Regional Office.
15. Substances, regulated by federal law under the Resource Conservation and Recovery Act (RCRA) and Comprehensive
Environmental Response, Compensation, and Liability Act (CERCLA), that are transported, stored, or used for maintenance,
cleaning or repair, shall be managed according to RCRA and CERCLA.
16. The permittee shall implement and enforce its approved pretreatment program in accordance with the requirements of 40 CFR
Part 403. The approved pretreatment program is hereby incorporated by reference.
Page 7 of 9
Permit No. MO-0127949
17. The permittee shall submit to the Department on or before September 301 of each year a report briefly describing its pretreatment
activities during the previous calendar year. At a minimum, the report shall include the following.
(a) An updated list of the Permittee's Industrial Users, including their names and addresses, or a list of deletions and additions
keyed to a previously submitted list. The Permittee shall provide a brief explanation of each deletion. This list shall identify
which Industrial Users are subject to categorical pretreatment Standards and specify which Standards are applicable to each
Industrial User. The list shall indicate which Industrial Users are subject to local standards that are more stringent than the
categorical Pretreatment Standards. The Permittee shall also list the Industrial Users that are subject only to local
Requirements;
(b) A summary of the status of Industrial User compliance over the reporting period;
(c) A summary of compliance and enforcement activities (including inspections) conducted by the Permittee during the reporting
period; and
(d) Any other relevant information requested by the Department.
18. Sewer Extension Authority
(a) The Department has approved the Sewer Extension Program for MSD to regulate and approve construction of sanitary
sewers that are tributary to this wastewater treatment plant.
(b) The approval of the Sewer Extension Program may be modified or revoked by the Department if the sewage collection,
transportation, and receiving treatment facility reach their respective design capacity, or if the Department determines that
this program is causing or contributing to chronic non-compliance of the receiving treatment facility, or if the permittee fails
to follow the terms and conditions of the submitted and approved program.
(c) The Sewer Extension Program Special Condition may be reopened and modified and reissued, or alternatively revoked to
incorporate new or modified conditions to the sewer construction permit authority, if information or regulation or statute
indicates changes are necessary to assure compliance with Missouri's Clean Water Law and associated regulations.
(d) If item b or item c of the Sewer Extension Program occurs, the permittee will be notified to any modification to this
operating permit.
(e) The Permittee, as part of their Sewer Extension Program, shall submit an annual report January 28's of each year, to the
Missouri Department of Natural Resources' St. Louis Regional Office. The report must provide the following: 1) list of the
name of the projects approved, and 2) the length of sewers and force mains and the capacity of lift stations constructed
under the sewer extension program. A summary of total flow at the treatment facility shall be included. Detailed project
information and data including design flows and inspection records shall be available for review upon request.
(f) The Sewer Extension Authority is valid the length of this operating permit. Upon renewal of the permit, the Sewer
Extension Authority for MSD- St. Louis will be reevaluated.
20. At least one sign shall appear on the fence on each side of each facility. Minimum wording shall be "SEWAGE TREATMENT
FACILITY — KEEP our, in letters at least 2 inches high.
21. An Operation and Maintenance (0 & M) manual shall be maintained by the permittee and Houle available to the operator. The 0
& M manual shall include key operating procedures and a brief summary of the operation of the facility.
22. An all-weather access road shall be provided from a public right-of-way to the treatment facility.
23. Whole Effluent Toxicity (WET) Test shall be conducted as follows:
SUMMARY OF ACUTE WET TESTING FOR THIS PERMIT
OUTFALL
AEC
FREQUENCY
SAMPLE TYPE
MONTH
001
5.8 %
_ Once/year
_
24 hr. composite**
September
** A 24-hour composite sample is composed of 48 aliquots (subsamples) collected at 30 minute intervals by an automatic sampler.
Dilution Series
AEC%
= 5.8%
40.8%
20.4%
10.2%
5.1%
2.6%
(Control) 100% upstream,
if available
(Control) 100% Lab Water,
also called synthetic water
Page 8 of 9
Permit No. MO-0127949
D. SPECLAL CONDITIONS (continued)
(a) Test Schedule and Follow -Up Requirements
(1) Perform a MULTIPLE -dilution acute WET test in the months and at the frequency specified above. For tests
which are successfully passed, submit test results using the Department's WET test report form #MO-780-1899
along with complete copies of the test reports as received from the laboratory, including copies of chain -of -
custody forms within 30 calendar days of availability to the WATER PROTECTION PROGRAM, P.O. Box 176,
Jefferson City, MO 65102. If the effluent passes the test, do not repeat the test until the next test period.
(a) Chemical and physical analysis of the upstream control and effluent sample shall occur immediately upon
being received by the laboratory, prior to any manipulation of the effluent sample beyond preservation
methods consistent with federal guidelines for WET testing that are required to stabilize the sample during
shipping.
(b) Any and all chemical or physical analysis of the effluent sample performed in conjunction with the WET
test shall be performed at the 100% Effluent concentration in addition to analysis performed upon any other
effluent concentration.
(c) All chemical analyses included in the Missouri Department of Natural Resources WET test report form
#MO-780-1899 shall be performed and results shall be recorded in the appropriate field of the report form.
(2) The WET test will be considered a failure if mortality observed in effluent concentrations for either specie, equal
to or less than the AEC, is significantly different (at the 95% confidence level; p = 0.05) than that observed in the
upstream receiving -water control sample. Where upstream receiving water is not available, synthetic laboratory
control water may be used.
(3) All failing test results along with complete copies of the test reports as received from the laboratory,1NCLUDLNG
THOSE TESTS CONDUCTED UNDER CONDITION (3) BELOW, shall be reported to the WATER
PROTECTION PROGRAM, P.O. Box 176, Jefferson City, MO 65102 within 14 calendar days of the availability
of the results.
(4) If the effluent fails the test for BOTH test species, a multiple dilution test shall be performed for BOTH test
species within 30 calendar days and biweekly thereafter (for storm water, tests shall be performed on the next and
subsequent storm water discharges as they occur, but not less than 7 days apart) until one of the following
conditions are met: Note: Written request regarding single species multiple dilution accelerated testing will be
address by THE WATER PROTECTION PROGRAM on a case by case basis.
(i) THREE CONSECUTIVE MULTIPLE -DILUTION TESTS PASS. No further tests need to be performed
until next regularly scheduled test period.
(ii) A TOTAL OF THREE MULTIPLE -DILUTION TESTS FAIL.
(5) Follow-up tests do not negate an initial failed test.
(6) The permittee shall submit a summary of all test results for the test series along with complete copies of the test
reports as received from the laboratory to the WATER PROTECTION PROGRAM, P.O. Box 176, Jefferson City,
MO 65102 within 14 calendar days of the third failed test.
(7) Additionally, the following shall apply upon failure of the third follow up MULTIPLE DILUTION test The
permittee should contact THE WATER PROTECTION PROGRAM within 14 calendar days from availability of
the test results to ascertain as to whether a TIE or TRE is appropriate. If the permittee does not contact THE
WATER PROTECTION PROGRAM upon the third follow up test failure, a toxicity identification evaluation
(TIE) or toxicity reduction evaluation (TRE) is automatically triggered. The permittee shall submit a plan for
conducting a TIE or THE to the WATER PROTECTION PROGRAM within 60 calendar days of the date of the
automatic trigger or DNR's direction to perform either a TIE or TRE. This plan must be approved by DNR
before the TIE or THE is begun. A schedule for completing the TIE or TRE shall be established in the plan
approval.
(8) Upon DNR s approval, the TIE THE schedule may be modified if toxicity is intermittent during the TIE/TRE
investigations. A revised WET test schedule may be established by DNR for this period.
(9) If a previously completed TIE has clearly identified the cause of toxicity, additional TIEs will not be required as
long as effluent characteristics remain essentially unchanged and the permittee is proceeding according to a DNR
approved schedule to complete a TRE and reduce toxicity. Regularly scheduled WET testing as required in the
permit, without the follow-up requirements, will be required during this period.
(10) When WET test sampling is required to run over one DMR period, each DMR report shall contain a copy of the
Department's WET test report form that was generated during the reporting period.
(11) Submit a concise summary in tabular format of all WET test results with the annual report.
D. SPECIAL CONDITIONS (continued)
(b)
Page 9 of 9
Permit No. MO-0127949
Test Conditions
(1) Test Type: Acute Static non -renewal
(2) All tests, including repeat tests for previous failures, shall include both test species listed below unless approved
by the Department on a case by case basis.
(3) Test species: Ceriodaphnia dubia and Pimephales promelas (fathead minnow). Organisms used in WET testing
shall come from cultures reared for the purpose of conducting toxicity tests and cultured in a manner consistent
with the most current USEPA guidelines. All test animals shall be cultured as described in the most current
edition of Methods for Measuring the Acute Toxicity of Effluents and Receiving Waters to Freshwater and
Marine Organisms.
(4) Test period: 48 hours at the "Allowable Effluent Concentration" (AEC) specified above.
(5) Upstream receiving stream water shall be used as dilution water. If upstream water is unavailable or if mortality
in the upstream water exceeds 10%, "reconstituted" water will be used as dilution water. Procedures for
generating reconstituted water will be supplied by the MDNR upon request.
(6) Tests will be run with 100% receiving -stream water (if available), collected upstream of the outfall at a point
beyond any influence of the effluent, and reconstituted water.
(7) If reconstituted -water control mortality for a test species exceeds 10%, the entire test will be rerun.
(8) If upstream control mortality exceeds 10%, the entire test will be rerun using reconstituted water as the dilutant.
(9) Whole -effluent -toxicity test shall be consistent with the most current edition of Methods for Measuring the Acjte
Toxicity of Effluents and Receiving Waters to Freshwater and Marine Organisms
MSD, Lower Meramec WWTF
Page # 1
Missouri Department of Natural Resources
FACT SHEET
FOR THE PURPOSE OF RENEWAL
MO-0127949
MSD, LOWER MERAMEC WWTF
The Federal Water Pollution Control Act ("Clean Water Act" Section 402 Public Law 92-500 as amended) established the National
Pollution Discharge Elimination System (NPDES) permit program. This program regulates the discharge of pollutants from point
sources into the waters of the United States, and the release of storm water from certain point sources. All such discharges are
unlawful without a permit (Section 301 of the "Clean Water Act"). After a permit is obtained, a discharge not in compliance with all
permit terms and conditions is unlawful Missouri State Operating Permits (MSOPs) are issued by the Director of the Missouri
Department of Natural Resources (Department) under an approved program, operating in accordance with federal and state laws
(Federal "Clean Water Act" and "Missouri Clean Water Law" Section 644 as amended). MSOPs are issued for a period of five (5)
years unless otherwise specified.
As per [40 CFR Pan I24.8(a)] and [10 CSR 20-6.020(1)2.] a Factsheet shall be prepared to give pertinent information regarding the
applicable regulations, rationale for the development of effluent limitations and conditions, and the public participation process for the
Missouri State Operating Permit (operating permit) listed below.
A Factsheet is not an enforceable part of an operating permit.
This Factsheet is for a Major El
Part I — Facility Information
Facility Type: POTW
Facility SIC Code(s): 4952
Facility Description:
The Lower Meramec WWTF is a 15 MGD (42 MGD peak flow) secondary treatment plant. Average daily flow is 12.74 MGD. Flow
enters through coarse screens to a pump station and then to the fine screens, two with 15 MGD and one with 75 MGD capacity) in the
treatment plant. After going through the fme screens, flow inters two 90-foot diameter primary clarifiers, where chemical feed can be
used to enhance settlement. Primary sludge and grit are separated through two slurry cup grit units. The primary effluent is treated in
two 150-foot diameter trickling filters with approximately 271,000 cubic feet of volume. The trickling filter effluent enters two 150-
foot final clarifiers with approximately 2.13 million gallons. Final effluent is seasonally disinfected using sodium hypochlorite and
de -chlorinated using sodium bisulfate The effluent is discharged into the Mississippi River. Sludge is thickened in two 50-foot
diameter gravity thickeners, dewatered with two belt filter presses, and can be held in two sludge storage bins until disposed of.
Have any changes occurred at this facility or in the receiving water body that effects effluent limit derivation?
-No.
Application Date: 08/31/2011
Expiration Date: 02/27/2012
Last Inspection: 03/16/2008
OUTFALL(S TABLE:
Non -Compliance
OL TF?.LL DESIGN FLOW
i (CFS)
TREATMENT LEVEL
EFFLUENT TYPE
DISTANCE TO
I CLASSIFIED SEGMENT (MI)
=001 1 23.25 - Secondary
Domestic — 0.0
#002 Varies None
I#003 Varies
Stormwater runoff ! — 0.56
None 1 Stormwater runoff
0.27
MSD, Lower Meramec WWTF
Page # 2
Outfall #001 — POTW — SIC #4952
Legal Description: Land Grant — 3051, St. Louis County
UTM Coordinates: X = 732203, Y = 4252722
Receiving Stream: Tributary to Mississippi River (P)
First Classified Stream and ID: Mississippi River (P)
USGS Basin & Sub -watershed No.: (07140101-0603) (1707)
Outfall #002 — Stormwater
Stormwater runoff/no treatment
Legal Description: Land Grant 0 3051, St. Louis County
UTM Coordinates: X = 732058, Y = 4254806
Receiving Stream: Tributary to Meramec River (U)
First Classified Stream and ID: Meramec River (P)
USGS Basin & Sub -watershed No.: (07140102-1004) (2183)
Outfall #003 — Stormwater
Stormwater runoff/no treatment
Discharge is located approximately 450 feet southwest of the effluent box at a headwall.
Legal Description: Land Grant — 50, St. Louis County
UTM Coordinates: X = 732025, Y = 4255441
Receiving Stream: Tributary to Meramec River (U)
First Classified Stream and ID: Meramec River (P)
USGS Basin & Sub -watershed No.: (07140102-1004) (2183)
Receivine Water Body's Water Ouality & Facility Performance History:
The New Lower Meramec WWTF went online in 2007. The Mississippi River has a TMDL for Chlordane and Polychlorinated
biphenyls, or PCBs. The Meramec River is listed on the 2008 303 (d) impaired streams list for Mill tailings, and the 2010 Water
Quality report for impaired streams for Lead and Bacteria. The Facility has had permit effluent limit exceedances for BOD and TSS
from March 2007 — August 2009. As of the last compliance inspection on March 16, 2008, the facility was still bypassing. However,
the facility states that by August 26, 2008, the modifications to the influent structure have reduced bypassing at this facility.
Comments:
The facility states that during some wet weather events, primary treated flows in excess of secondary treatment capacity are diverted
around secondary treatment, and recombined with secondary treated flows prior to discharge. All blended flow will be seasonally
disinfected beginning on April 1, 2012.
Part II — Operator Certification Requirements
As per [10 CSR 20-6.010(8) Terms and Conditions of a Permit], permittees shall operate and maintain facilities to comply with the
Missouri Clean Water Law and applicable permit conditions and regulations. Operators or supervisors of operations at regulated
wastewater treatment facilities shall be certified in accordance with [10 CSR 20-9.020(2)] and any other applicable state law or
regulation. As per [10 CSR 20-9.020(2)(A)], requirements for operation by certified personnel shall apply to all wastewater treatment
systems, if applicable, as listed below:
Check boxes below that are applicable to the facility;
• Owned or operated by or for:
• Municipalities
Each of the above entities are only applicable if they have a Population Equivalent greater than two hundred (200) and/or fifty (50) or
more service connections.
• Department required:
The Department requires this facility to retain the services of a certified
operator due to: size and treatment type of the facility
MSD, Lower Meramec WWfF
Page # 3
This facility currently requires an operator with an A Certification Level. Please see Appendix A • Classification. Modifications
made to the wastewater treatment facility may cause the classification to be modified.
Operator's Name: Todd V. Heller
Certification Number: 3 882
Certification Level: A
The listing of the operator above only signifies that staff drafting this operating permit have reviewed appropriate Department records
and determined that the name listed on the operating permit application has the correct and applicable Certification Level.
Part III — Receiving Stream Information
APPLICABLE DESIGNATIONS OF WATERS OF THE STATE:
As per Missouri's Effluent Regulations [10 CSR 20-7.015], the waters of the state are divided into the below listed seven (7)
categories. Each category lists effluent limitations for specific parameters, which are presented in each outfall's Effluent Limitation
Table and further discussed in the Derivation & Discussion of Limits section.
Missouri or Mississippi River [10 CSR 20-7.015(2)]:
All Other Waters [10 CSR 20-7.015(8)]:
10 CSR 20-7.031 Missouri Water Quality Standards, the Department defines the Clean Water Commission water quality objectives in
terms of "water uses to be maintained and the criteria to protect those uses." The receiving stream and or 16S classified receiving
stream's beneficial water uses to be maintained are located in the Receiving Stream Table located below in accordance with [10 CSR
20-7.031(3)].
RECEIVING STREAMS) TABLE:
WATER -BODY NAME
i
CLASS
WBID
, DESIGNATED USES*
12-DIGIT
MCEDU**
Mississippi River
P
!
1707
IRR' LWW, AQL, SCR,
DNCS. IND, WBC "B" ;
07140101-
0603
Ozark/Apple
/Joachim
Unnamed trib. to Meramec River
!
1:
----
General Criteria
07140102-
1004
Ozark'
Meramec
Meramec River
I
l
P
j
2183
j LWW, AQL, SCR, DWS. !
i IND. WBC "A" 1
07140102-
1004
Ozark
Meramec
* - Irrigation (IRR), Livestock & Wildiife Watering (LV 1V), Protection of Warm Water Aquatic Life and Human Health -Fish Consumption (AQL), Cool Water
Fishery(CLF), Cold Water Fishery (CDF), Whole Body Contact Recreation (WBC), Secondary Contact Recreation (SCR), Drinking Water Supply (DWS ), Industrial
(IND), Groundwater (GRW).
** - Ecological Drainage Unit
MSD, Lower Meramec WWTF
Page # 4
MIXING CONSIDERATIONS: Mississippi River (Mixing values derived using March 1, 2012 CORMIX model)
Regulatory Mixing Zone
According to 10 CSR 20-7.031, effluent discharged to the Mississippi River must meet chronic water quality criteria within
% mite downstream of an outfall structure. The CORMIX model was used to determine farfield effluent plume predictions
based on a design flow of 15 MGD and an outfall structure 6.5' wide and 1' tall.
Zone of Initial Dilution (Z.I.D.).
Regulations contained within 10 CSR 20-7.031 state that the Z.I.D. is 10% of the mixing zone flow and cannot exceed 10
times design flow of the facility.
RECEIVING STREAM(S) Low -FLOW VALUES TABLE:
RECEIVING STREAM (U, C, P)
Low-FLow VALUES (CFS)
1Q10
7Q10
30Q10
Mississippi River (P)
52,900
56,700
63,800
MIXING CONSIDERATIONS TABLE: Meramec River (using stream cause #07019000
MIXING ZONE (CFS)
[10 CSR 20-7.031(4)(B)(IIIXA)]
ZONE OF INITIAL DILUTION (CFS)
[10 CSR 20-7.031(4)(B)0II)(B)...1
7Q10
30Q10
1010
7Q10
3,815
3,846
376
381
Part IV — Rationale and Derivation of Effluent Limitations & Permit Conditions
ALTERNATIVE EVALUATIONS FOR NEW FACILITIES:
As per [10 CSR 20-7.015(4)(A)], discharges to losing streams shall be permitted only after other alternatives including land
application, discharges to a gaining stream and connection to a regional wastewater treatment facility have been evaluated and
determined to be unacceptable for environmental and/or economic reasons.
Not Applicable 15;
The facility does not discharge to a Losing Stream as defined by [10 CSR 20-2.010(36)] & [10 CSR 20-7.031(1)(N)], or is an existing
facility.
ANTI -BACKSLIDING:
A provision in the Federal Regulations [CWA §303(dX4); CWA §402(c); 40 CFR Part 122.44(I)] that requires a reissued permit to be
as stringent as the previous permit with some exceptions.
® - All limits in this operating permit are at least as protective as those previously established; therefore, backsliding does not apply.
ANTI -DEGRADATION:
In accordance with Missouri's Water Quality Standard [10 CSR 20-7.031(2)], the Department is to document by means of Anti -
degradation Review that the use of a water body's available assimilative capacity is justified. Degradation is justified by documenting
the socio-economic importance of a discharging activity after determining the necessity of the discharge.
- Renewal no degradation proposed and no further review necessary.
MSD, Lower MeramecVWUTF
Page # 5
AREA -WIDE WASTE TREATMENT MANAGEMENT & CO:VTLN LNG ALTHORrrY:
As per [10 CSR 20-6.010(3)(B)1, ...An applicant may utilize a lower preference continuing authority by submitting, as part of the
application, a statement waiving preferential status from each existing higher preference authority, providing the waiver does not
conflict with any area -wide management plan approved under section 208 of the Federal Clean Water Act or any other regional
sewage service and treatment plan approved for higher preference authority by the Department.
BIO-SOLIDS & SEWAGE SLUDGE:
Bio-solids are solid materials resulting from domestic wastewater treatment that meet federal and state criteria for beneficial uses (i.e.
fertilizer). Sewage sludge is solids, semi -solids, or liquid residue generated during the treatment of domestic sewage in a treatment
works; including but not limited to, domestic septage; scum or solids removed in primary, secondary, or advanced wastewater
treatment process; and a material derived from sewage sludge. Sewage sludge does not include ash generated during the firing of
sewage sludge in a sewage sludge incinerator or grit and screening generated during preliminary treatment of domestic sewage in a
treatment works. Additional information regarding bio-solids and sludge is located at the following web address:
httn:',Idnr.mo.gov/env/wpn/nub/index.html. items WQ422 through WQ449.
- Permittee land applies bio-solids in accordance with Standard Conditions III and a Department approved bio-solids management
plan.
COMPLL& CE AND ENFORCEMENT:
Enforcement is the action taken by the Water Protection Program (11PP) to bring an entity into compliance with the Missouri Clean
Water Law, its implementing regulations, and or any terms and conditions of an operating permit. The primary purpose of the
enforcement activity in the \VPP is to resolve violations and return the entity to compliance.
Not Applicable ®;
The permittee. facility° is not currently under Water Protection Program enforcement action.
PRETREATMENT PROGRAM:
The reduction of the amount of pollutants, the elimination of pollutants, or the alteration of the nature of pollutant properties in
wastewater prior to or in lieu of discharging or otherwise introducing such pollutants into a Publicly Owned Treatment Works [40
CFR Part 403.3(q)].
Pretreatment programs are required at any POTW (or combination of POTW operated by the same authority) and/or municipality with
a total design flow greater than 5.0'MGD and receiving industrial wastes that interfere with or pass through the treatment works or are
otherwise subject to the pretreatment standards. Pretreatment programs can also be required at POTWs/municipals with a design flow
less than 5.0 MGD if needed to prevent interference with operations or pass through.
Several special conditions pertaining to the permittee's pretreatment program may be included in the permit, and are as follows:
• Implementation and enforcement of the program,
• Annual pretreatment report submittal,
• Submittal of list of industrial users,
• Technical evaluation of need to establish local limitations, and
• Submittal of the results of the evaluation
Applicable ®;
This permittee has an approved pretreatment program in accordance with the requirements of [40 CSR Part 4031 and [10 CSR 20-
6.100] and is expected to implement and enforce its approved program.
REASONABLE POTENTIAL ANALYSIS (RPA):
Federal regulation [40 CFR Part 122.44(d)(1)(i)] requires effluent limitations for all pollutants that are or may be discharged at a level
that will cause or have the reasonable potential to cause or contribute to an in -stream excursion above narrative or numeric water
quality standard.
In accordance with [40 CFR Part 122.44(d)(iii)] if the permit writer determines that any give pollutant has the reasonable potential to
cause, or contribute to an in -stream excursion above the WQS, the permit must contain effluent limits for that pollutant.
Applicable /1;
A RPA was conducted on appropriate parameters. Please see APPENDIX A — RPA RESULTS.
MSD, Lower Meramec WWTF
Page#6
REMOVAL EFFICIENCY:
Removal efficiency is a method by which the Federal Regulations define Secondary Treatment and Equivalent to Secondary
Treatment, which applies to Biochemical Oxygen Demand 5-day (GODS) and Total Suspended Solids (TSS) for Publicly Owned
Treatment Works (POTWs)/municipals.
Applicable ®;
Secondary Treatment is 65% removal [40 CFR Part 133.102(a)(3) & (bx3)].
SANITARY SEWER OVERFLOWS (SSO) AND INFLOW AND INFILTRATION (I&I):
Sanitary Sewer Overflows (SSOs) are defined as an untreated or partially treated sewage release are considered bypassing under state
regulation [10 CSR 20-2.010(11)] and should not be confused with the federal definition of bypass. SSO's have a variety of causes
including blockages, line breaks, and sewer defects that allow excess storm water and ground water to (1) enter and overload the
collection system, and (2) overload the treatment facility. Additionally, SSO's can be also be caused by lapses in sewer system
operation and maintenance, inadequate sewer design and construction, power failures, and vandalism. SSOs also include overflows
out of manholes and onto city streets, sidewalks, and other terrestrial locations.
Additionally, Missouri RSMo §644.026.1 mandates that the Department require proper maintenance and operation of treatment
facilities and sewer systems and proper disposal of residual waste from all such facilities.
- In accordance with Missouri RSMo §644.026.1.(15) and 40 CFR Part 122.41(e), the permittee is required to develop and/or
implement a program for maintenance and repair of the collection system and shall be required in this operating permit by either
means of a Special Condition or Schedule of Compliance. In addition, the Department considers the development of this program as
an implementation of this condition. Additionally, 40 CFI( Part 403.3 (o) defines a POTW to include any device and systems used in
the storage, treatment, recycling and reclamation of municipal sewage or industrial wastes of liquid nature. It also includes sewers,
pipes, and other conveyances only if they convey wastewater to a POTW Treatment Plant.
At this time, the Department recommends the US EPA's Guide for Evaluating Capacity, Management, Operation and Maintenance
(CMOM) Programs At Sanitary Sewer Collection Systems (Document # EPA 305-B-05-002). The CMOM identifies some of the
criteria used by the EPA to evaluate a collection system's management, operation, and maintenance and was intended for use by the
EPA, state, regulated community, and/or third party entities. The CMOM is applicable to small, medium, and large systems; both
public and privately owned; and both regional and satellite collection systems. The CMOM does not substitute far the Clean Water
Act, the Missouri Clean Water Law, and both federal and state regulations, as it is not a regulation.
STORM WATER POLLUTION PREVENTION PLAN (SWPPP):
In accordance with 40 CFR 122.44(k) Best Management Practices (BMPs) to control or abate the discharge of pollutants when: (1)
Authorized under section 304(e) of the Clean Water Act (CWA) for the control of toxic pollutants and hazardous substances from
ancillary industrial activities: (2) Authorized under section 402(p) of the CWA for the control of storm water discharges; (3) Numeric
effluent limitations are infeasible; or (4) the practices are reasonably necessary to achieve effluent limitations and standards or to carry
out the purposes and intent of the CWA.
In accordance with the EPA's Developing Your Stormwater Pollution Prevention Plan. A Guide for Industrial Operators, (Document
number EPA 833-B-09-002) [published by the United States Environmental Protection Agency (USEPA) in February 2009], BMPs
are measures or practices used to reduce the amount of pollution entering (regarding this operating permit) waters of the state. BMPs
may take the form of a process, activity, or physical structure.
Additionally in accordance with the Storm Water Management, a SWPPP is a series of steps and activities to (1) identify sources of
pollution or contamination, and (2) select and carry out actions which prevent or control the pollution of storm water discharges.
Applicable ®;
A SWPPP shall be developed and implemented for each site and shall incorporate required practices identified by the Department with
jurisdiction, incorporate erosion control practices specific to site conditions, and provide for maintenance and adherence to the plan.
All chemicals stored at the MSD — Lower Meramec facility are properly contained and all waste streams of the treatment process are
separated and properly disposed of. Best Management Practices have been implemented at the facility to prevent any pollutants or
waste streams from entering the stormwater sewer system. The facility also employs good housekeeping measure to ensure that the
facility is kept clean.
MSD, Lower Meramec WWTF
Page # 7
The facility conducts monthly, quarterly and yearly monitoring to observe the two stormwater outfalls during times of discharge. The
facility also conducts annual inspections. The process includes an inspection and review of all potential pollutants and all stormwater
BMPs. If BMPs are found to be ineffective they are updated or replaced.
WASTE -LOAD ALLOCATIONS (WLA) FOR LINIITS:
As per [10 CSR 20-2.010(78)], the amount of pollutant each discharger is allowed by the Department to release into a given stream
after the Department has determined total amount of pollutant that may be discharged into that stream without endangering its water
quality.
Applicable ®;
Waste -load allocations were calculated where applicable using water quality criteria or water quality model results and the dilution
equation below:
(Cs x Qs) + (Ce x Qe)
C = (EPAz505/2-90-001, Section 4.5.5)
(Qe + Qs)
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) and stream volume of flow at the edge of the mixing zone (VIZ). Acute wasteload allocations were determined using
applicable water quality criteria (CMC: criteria maximum concentration) and stream volume of flow at the edge of the zone of initial
dilution (ZID).
Water quality based maximum daily and average monthly effluent limitations were calculated using methods and procedures outlined
in I SEPA's "Technical Support Document For Water Quality -based Toxics Control" (EPA505:2-90-001).
Number of Samples "n":
Additionally, in accordance with the TSD for water quality -based permitting, effluent quality is determined by the underlying
distribution of daily values, which is determined by the Long Term Average (LTA) associated with a particular Wasteload Allocation
(WLA) and by the Coefficient of Variation (CV) of the effluent concentrations. Increasing or decreasing the monitoring frequency
does not affect this underlying distribution or treatment performance, which should be, at a minimum, be targeted to comply with the
values dictated by the WLA. Therefore, it is recommended that the actual planned frequency of monitoring normally be used to
determine the value of "n" for calculating the ANII.. However, in situations where monitoring frequency is once per month or less, a
higher value for "n" must be assumed for ANIL derivation purposes. Thus, the statistical procedure being employed using an assumed
number of samples is "n = 4" at a minimum. For Total Ammonia as Nitrogen, "n = 30" is used.
WLA MODELLNG:
There are two general types of effluent limitations, technology -based effluent limits (TBELs) and water quality based effluent limits
(WQBELs). If TBELs do not provide adequate protection for the receiving waters, then WQBEL must be used.
Not Applicable ®;
A WLA study was either not submitted or determined not applicable by Department staff.
WATER QUALITY STANDARDS:
Per [10 CSR 20-7.031(3)], General Criteria shall be applicable to all waters of the state at all times including mixing zones.
Additionally, [40 CFR 122.44(d)(1)] directs the Department to establish in each NPDES permit to include conditions to achieve water
quality established under Section 303 of the Clean Water Act, including State narrative criteria for water quality.
MSD, Lower Meramec 1NWrF
Page#8
WHOLE EFFLUENT TOXICITY (WET) TEST:
A WET test is a quantifiable method of determining if a discharge from a facility may be causing toxicity to aquatic Iife by itself, in
combination with or through synergistic responses when mixed with receiving stream water.
Applicable ®;
Under the federal Clean Water Act (CWA) §101(a)(3), requiring WET testing is reasonably appropriate for site -specific Missouri
State Operating Permits for discharges to waters of the state issued under the National Pollutant Discharge Elimination System
(NPDES). WET testing is also required by 40 CFR 122.44(d)(1). WET testing ensures that the provisions in the 10 CSR 20-
6.010(8)(A)7. and the Water Quality Standards 10 CSR 20-7.031(3)(D),(F),(G),(1)2.A & B are being met. Under [10 CSR 20-
6.010(8)(A)4], the Department may require other terms and conditions that it deems necessary to assure compliance with the Clean
Water Act and related regulations of the Missouri Clean Water Commission. In addition the following MCWL apply: §§§644.051.3
requires the Department to set permit conditions that comply with the MCWL and CWA; 644.051.4 specifically references toxicity as
an item we must consider in writing permits (along with water quality -based effluent limits, pretreatment, etc...); and 644.051.5 is the
basic authority to require testing conditions. WET test will be required by all facilities meeting the following criteria:
® Facility is a designated Major.
40 CFR 122.41(M) - BYPASSES:
The federal Clean Water Act (CWA), Section 402 prohibits wastewater dischargers from "bypassing" untreated or partially treated
sewage (wastewater) beyond the head -works. A bypass, which includes blending, is defined as an intentional diversion of waste
streams from any portion of a treatment facility, [40 CFR 122.41(mX1Xi)]. Additionally, Missouri regulation 10 CSR 20-2.010(11)
defines a bypass as the diversion of wastewater from any portion of wastewater treatment facility or sewer system to waters of the
state. Only under exceptional and specified limitations do the federal regulations allow for a facility to bypass some or all of the flow
from its treatment process. Bypasses are prohibited by the CWA unless a permittee can meet all of the criteria listed in 40 CFR
122.41(mX4)(i)(A), (B), & (C). Any bypasses from this facility are subject to the reporting required in 40 CFR 122.41(1)(6) and per
Missouri's Standard Conditions 1, Section B, part 2.b. Additionally, Anticipated Bypasses include bypasses from peak flow basins or
similar devices designed for peak wet weather flows.
- This facility does bypass. Any bypasses from this facility are subject to the reporting required in 40 CFR 122.41(1)(6) and per
Missouri's Standard Conditions I, Section B, part 2.b. Additionally, Anticipated Bypasses include bypasses from peak wet weather
flows.
303(d) Lisr & TOTAL MAXIMUM DAILY LOAD (TMDL):
Section 303(d) of the federal Clean Water Act requires that each state identify waters that are not meeting water quality standards and
for which adequate water pollution controls have not been required. Water quality standards protect such beneficial uses of water as
whole body contact (such as swimming), maintaining fish and other aquatic life, and providing drinking water for people, livestock
and wildlife. The 303(d) list helps state and federal agencies keep track of waters that are impaired but not addressed by normal water
pollution control programs.
A TMDL is a calculation of the maximum amount of a given pollutant that a body of water can absorb before its water quality is
affected. If a water body is determined to be impaired as listed on the 303(d) list, then a watershed management plan will be
developed that shall include the TMDL calculation
Applicable ®;
Mississippi River from St. Louis County to Mississippi County is listed on the 2012 Missouri 303(d) List for Lead and Zinc from the
Herculaneum lead smelter, and E. colt from point and non -point sources.
MSD, Lower Meramec WWfF
Page #
Part V — Effluent Limits Determination
Outfall #001 — Main Facility Outfall
Effluent limitations derived and established in the below Effluent Limitations Table are based on current operations of the facility.
Future permit action due to facility modification may contain new operating permit terms and conditions that supersede the terms and
conditions, including effluent limitations, of this operating permit
EFFLUENT LIAIITATIONS TABLE:
I. BASS DAILY ;
PARAMETER UNIT FOR I MAXIMUM
I Laurs i
WEEKLY
AVERAGE
MONTHLY HLY
AVERAGE
?l1ODITIED
PREVIOUS PERMIT
LIM£rATIONS
FLOW j GPD 1 *
*
NO
*±*
CBOD5 MG/L 3
60
40
NO
60/40
TSS
MG/L 1
65
45
NO
65 45
PH
- SU
1 I 6.5-9.0
6.5-9.0
YES
6.0-9.0
.AMMON1A AS \
(APR::. t—SEPT30)
NK1,1
2 i *
*
NO
*/*
A_A MONtA AS N
(OcT 1—MARCH 31)
MC;L
2 *
*
NO
ESCHERICHIACOLI
**
2
1030
206
YES
FECAL
CoLIFORM
1000/400
CE ORIINR, TOTAL RESIDUAL
µgot 2
335
163
YES
0.19/0.09 MG/L
OIL & GREASE (MG.L)
mail: i 2,3
15
10 NO
15/10
CHROMR M III, TOTAL
RECOVERABLE
ug i
2,3
*
* NO
*pi,
Clown! VI, DISSOLVED µg.'L
2,3
°
" No */*
HARDNESS DNESS mad,
2,3
i
* I NO */*
WHOLE EFFLUENT TOXICITY °ro 11
(WET) TEST Survival 1
Please see WET Test in the Derivation and Discussion
Section below.
* - Monitoring requirement only.
- of colonies• 0mL; the Monthly Average for E. coif is a geometric mean.
Basis for Limitations Codes:
1. State or Federal RegulationiLaw
2. Water Quality Standard (includes RPA)
3. Water Quality Based Ettluent Limits
4. Lagoon Policy
5. Ammonia Policy
6. Antidegradation Review
7, Antidegradation Policy
8. Water Quality Model
9. Best Professional Judgment
10. TMDL or Permit in lieu of TI•1DL
1 I. WET Test Policy
OI TFALL #001— DERIVATION AND DISCUSSION OF LIMITS:
• 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.
• Carbonaceous Biochemical Oxvsen Demand (CBOD). Effluent limitations from the previous state operating permit have
been reassessed and verified that they are still protective of the receiving stream's Water Quality. Therefore, effluent limitations
have been retained from previous state operating permit. As establish in the 2002 WQRS and is achievable by the facility.
• Total Suspended Solids (TSS). Effluent limitations from the previous state operating permit have been reassessed and verified
that they are still protective of the receiving stream's Water Quality. Therefore, effluent limitations have been retained from
previous state operating permit. As establish in the 2002 WQRS and is achievable by the facility.
• RH. pH shall be maintained in the range from (6.5 — 9.0) standard units [10 CSR 20.7.015(8)(B)2.]
MSD, Lower Meramec VWVTF
Page # 10
Total Ammonia Nitrogen. A reasonable potential analysis was conducted for Total Ammonia Nitrogen and found to have no
reasonable potential to pollute at this time. Therefore, a monitoring only requirement will be retained in this permit.
• Escherichia coli (E. coli). Monthly average of 206 per 100 ml as a geometric mean and Weekly Average of 1030 during the
recreational season (April 1— October 31), to protect designated uses of the receiving stream, as per 10 CSR 20-7.031(4XC).
Weekly Average effluent variability will be evaluated in development of a future effluent limit. An effluent limit for both monthly
average and weekly average is required by 40 CFR 122.45(d).
Total Residual Chlorine (TRC). Warm -water Protection of Aquatic Life CCC = 10 µg/L, CMC = 19 µg/L [10 CSR 20-7.031,
Table A]. Background TRC = 0.0 rig/L. Design flow, 23.25 cfs. Mixing zone, 3,846 cfs. Zone of initial dilution, 204 cfs.
Chronic WLA: Ca = ((23.25 + 3,846)10 — (0.0.3,846))/23.25
C. = 1,664 µg1L
Acute WLA: = ((23.25 + 376)19 — (0.0 * 376))/23.25
Ce = 326 µg/L
LTA. = 1664 (0.527) = 877 µg/L [CV = 0.6, 99"' Percentile]
LTA. = 326 (0.321) =105 µg/L [CV = 0.6, 99th Percentile]
Use most protective number of LTA. or LTA..
MDL = 105 (3.11) = 325 µg/L (0.33mg/L) [CV = 0.6, 99th Percentile]
AML =105 (1.55) = 163 µgfL (0.16 mg/L) [CV = 0.6, 95a' Percentile, n = 4]
Total Residual Chlorine effluent limits of 0.19 mg/L daily maximum, 0.09 mg/L monthly average are recommended if
chlorine is used as a disinfectant. Standard compliance language for TRC, including the minimum level (ML), should be
included in the permit.
• Oil & Grease. Conventional pollutant, effluent limitation for protection of aquatic life; 10 mg/L monthly average, 15 mg/L daily
maximum.
• Dissolved Oxygen. The Department has evaluated the D.O. monitoring data from the previous permit cycle and determined that
future monitoring of D.O. may be useful, however, this NPDES permit does not require D.O. monitoring due to the lack of
potential future stream modeling efforts. Furthermore, exceedances of the D.O. water quality standard associated with this
discharge have not been demonstrated.
▪ Metals. RPA was conducted for Cadmium, Cyanide, Copper, Lead, Nickel, Zinc, Silver, Iron, Mercury, and Arsenic.
No Reasonable Potential exists for these pollutants. Therefore, limits for these metals will not be included in the
permit.
• Chromium. Data did not exist on the DMR for this facility. Therefore, a monitoring only requirement will be maintained in the
permit.
• WET Test. WET Testing schedules and intervals are established in accordance with the Department's Permit Manual; Section
5.2 Effluent Limits / WET Testing for Compliance Bio-monitoring. It is recommended that WET testing be conducted during the
period of lowest stream flow.
® Acute
® No less than ONCE/YEAR:
® Facility is designated as a Major facility or has a design flow >>> 1.0 MGD.
® Facility continuously or routinely exceeds their design flow.
MSD, Lower Meramec WWTF
Page # 11
Part VI — Finding of Affordability
Pursuant to Section 644.145, RSMo., the Department is required to determine whether a permit or decision is affordable and makes a
finding of affordability for certain permitting and enforcement decisions. This requirement applies to discharges from combined or
separate sanitary sewer systems or publically-owned treatment works.
® Applicable; The Department is required to determine findings of affordability because the permit applies to a combined or
separate sanitary sewer system for a publically-owned treatment works.
Finding of affordability - The Department has made a reasonable search for empirical data indicating the permit is affordable. The
search consisted of a review of Department records that might contain economic data on the community, a review of information
provided by the applicant as part of the application, and public comments received in response to public notices of this draft permit. If
the empirical cost data was used by the permit writer, this data may consist of median household income, any other ongoing projects
that the Department has knowledge, and other demographic financial information that the community provided as contemplated by
Section 644. 145.3. See Appendix C — Affordability Analysis
Part VII — Administrative Requirements
On the basis of preliminary staff review and the application of applicable standards and regulations, the Department, as administrative
agent for the ytissouri Clean Water Commission, proposes to issue a permit(s) subject to certain effluent limitations, schedules, and
special conditions contained herein and within the operating permit. The proposed determinations are tentative pending public
comment.
PERMIT SYNCHRONIZATION:
The Department of Natural Resources is currently undergoing a synchronization process for operating permits. Permits are normally
issued on a five-year term, but to achieve synchronization many permits will need to be issued for less than the full five years allowed
by regulation. The intent is that all permits within a watershed will move through the Watershed Based Management (WB 1) cycle
together will all expire in the same fiscal year. This will allow further streamlining by placing multiple permits within a smaller
geographic area on public notice simultaneously, thereby reducing repeated administrative efforts. This will also allow the
Department to explore a watershed based permitting effort at some point in the future.
PUBLIC NOTICE:
The Department shall give public notice that a draft permit has been prepared and its issuance is pending. Additionally, public notice
will be issued if a public hearing is to be held because of a significant degree of interest in and water quality concerns related to a draft
permit. No public notice is required when a request for a permit modification or termination is denied; however, the requester and
permiee must be notified of the denial in writing.
The Department must issue public notice of a pending operating permit or of a new or reissued statewide general permit. The public
comment period is the length of time not less than 30 days following the date of the public notice which interested persons may submit
written comments about the proposed permit.
For persons wanting to submit comments regarding this proposed operating permit, then please refer to the Public Notice page located
at the front of this draft operating permit. The Public Notice page gives direction on how and where to submit appropriate comments.
- The Public Notice period for this operating permit was from August 10, 2012 to September 10, 2012. Responses to the Public
Notice of this operating permit warrant the modification of effluent limits and/or the terms and conditions of this permit. The
comments and responses are summarized below:
• MSD requested to correction of several typographical errors contained in the draft permit and the fact sheet. These errors
have been corrected.
• MSD requested the legal description and UTM coordinates for each outfall location be changed. However, no documentation
was submitted to support the requested changes. Therefore, the data was retained in the permit and fact sheet.
• MSD requested the 30-minute interval be removed from the 24-hour sampling frequency in the draft permit. This request
could not be granted. There must be an interval in order for the sample to be composite. Since no other alternative was
proposed the sampling frequency was retained in the permit.
• MSD requested the removal of Dissolved Oxygen limits from the draft permit. The Department reevaluated the D.O.
monitoring data from the previous permit cycle and determined that future monitoring of D.O. may be useful; however
the D.O. monitoring requirement will be removed from the permit due to the lack of potential future stream modeling efforts.
MSD requested the minimum sampling requirement table be removed from the draft permit to prevent redundancy. This
table was removed from the permit.
MSD, Lower Meramec WWTF
Page # 12
• MSD requested that the stormwater monitoring requirement be removed from the draft permit due to the development of a
facility SWPPP. Therefore, this condition was removed from the permit.
• MSD requested special condition #3 be removed from the draft permit. Since special condition does not apply to this facility
it was removed from the permit.
MSD requested special condition #4 in the draft permit, regarding Water Quality Standards, be changed to include "To the
extent required by law." At this time the Department wishes to maintain the language as written in the draft permit. In the
future if the Department and various stakeholders groups determine a path forward regarding this issue the permittee retains
the option to apply for a modification.
• MSD requested the removed of special conditions #9, #15 and #21 from the draft permit. Standard condition #21 was a
repeat of special condition #15 and was removed from the permit. Special condition #9 and #15 will be retained in the
permit. These conditions are standard conditions in all permits.
MSD requested that the wording contained in special condition #13 be changed. However, upon further review the
Department determined to remove the condition from the draft permit.
MSD requested the removal of special condition #20 in the draft permit. After reevaluating this condition the Department
changed the wording to better reflect this facility.
MSD requested that the A.E.C. % be changed to reflect the current permit A.E.0 %. The March 2012 Cormix Study
conducted by Geosyntec Consultants, submitted for the New Lower Meramec Wastewater Treatment Plant outfall to the
Mississippi River defines the allowable effluent concentration as follows:
AEC = Qe/(Qs+Qe), where Qe = 23.25 cfs and Qs = 7Q10 ZID = 381 cfs
= 23.25/(381+23.25)
=5.8%
Therefore the A.E.C% was retained in the permit at 5.8%.
• MSD requested the distances of each outfall to the classified segments be changed. The Department reevaluated this data.
The distances of each outfall to the classified segments were updated in the fact sheet to reflect the appropriate distances.
• MSD requested the facility performance history section of the fact sheet language be changed from "As of the last
compliance inspection on March 16, 2008, the facility was still bypassing" to "The bypassing noted during the compliance
inspection on March 16, 2008, was corrected by August 26, 2008. The Department notes the efforts to fix bypassing at this
facility. However, the requested language was not incorporated into the fact sheet. The fact was modified to include the
following statement; "The facility states that modifications to the influent structure pipe have reduced bypassing.
• MSD requested that the TRC values be recalculated. These values were recalculated. The new values were incorporated into
the draft permit and fact sheet.
DATE OF FACT SHEET: (01/23/2012, 07/12/2012, 07/13/2012, 10/09/2012)
COMPLETED BY:
HILLARY CLARK, ENVIRONMENTAL SPECIALIST III
NPDES PERMITS UNIT
PERMITTING AND ENGINEERING SECTION
WATER PROTECTION PROGRAM
(573) 751-7326
HILLARY.CLARKapNR.MO.GOV
MSD, Lower Meramec VOMIT
Page # 13
Appendices
A - CLASSIFICATION V4 ORKSHEET:
ITEM -
POINT$ POSSIBLE
POINTS
ASSIGNED
Maximum Population Equivalent (P.D.) served (Max 10 pts.)
1 pt. ' 10,000 PE or major fraction
t_e.eof.
10
Maximai : 10 pt Design Flow (avg. day) or peak month; use greater ! 1 pt.. MGD or major fraction
(Max 10 pts.) j thereof.
10
EFFLUENT DISCHARGE RECEIVP G WATER SENSITIVITY
Missouri or Mississippi River
0
0
All other stream discharges except to losing steams and stream
reaches supporting whole body contact
Discharge to lake or reservoir outside of designated whole body
contact recreational area
2
Discharge to losing stream, or stream, lake or reservoir area
supporting w o1e body contact recreation.
Z
3
PRELIMI\ARY TREATMENT-Ileadworks
i
Screening and/or comminution 3 I 3
I
Grit removal 3 ; 3
Plant pumping of ntain flow (lift station at the headworks) I 3 G 3
PRIMARY TREATMENT
Primary clarifiers I 5
I
5
Combined sedimentation/digestion i 5
Chemical addition (except chlorine, enzymes) 4
REQUIRED LABORATORY CONTROL — performed by plant personnel (highest level only)
Push — button or visual methods for Kmplc test such as pH, 1 3
Settleable solids
Additionai procedures such as DO, COD, BOD, titatioris, solids, I S
volatile content
More advanced determinations such as BOD seeding pr oceezes, 7
fecal coliform, nutrients, total oils, phenols, etc.
Highly sophisticated inst-umentation, such as atomic absorption and 10
gas ehromatograph
10
ALTERNATIVE FATE OF EFFITIEN"T
Direct reuse or recycle of effluent
6
Land Disposal — low rate
3
High rate
5
Overland flow
4
Total from page ONE (1)
---- . 47 ..
MSD, Lower Meramec VWVTF
Page#t4
APPENDIX A - CLASSIFICATION WORI{SHEET (CONTINUED):
ITEM
Ponca Possma
POnvrs
ASSIGNED
VARIATION IN RAW WASTE (highest level only) (DMR exceedances and Design Flow exceedances)
Variation do not exceed those normally or typically expected
0
Recurring deviations or excessive variations of 100 to 200 % in
strength and/or flow
2
2
Recurring deviations or excessive variations of more than 200 % in
strength and/or flow
4
Raw wastes subject to toxic waste discharge
6
SECONDARY TREATMENT
Trickling filter and other fixed film media with secondary clarifiers
10
10
Activated sludge with secondary clarifiers (including extended
aeration and oxidation ditches)
15
Stabilization ponds without aeration
5
Aerated lagoon
8
Advanced Waste Treatment Polishing Pond
2
Chemical/physical — without secondary
15
Chemical/physical — following secondary
10
Biological or chemical/biological
12
Carbon regeneration
4
DISINFECTION
Chlorination or comparable
5
5
Dechlorination
2
2
On -site generation of disinfectant (except UV light)
5
UV light
4
SOLIDS HANDLING - SLUDGE
Solids Handling Thickening
5
5
Anaerobic digestion
10 '
Aerobic digestion
6
Evaporative sludge drying
2
Mechanical dewatering
8
8
Solids reduction (incineration, wet oxidation)
12
Land application
6
Total from page TWO (2)
--
32
Total from page ONE (1)
—
47
Grand Total
—
79
® - A: 71 points and greater
❑ - B: 51 points — 70 points
❑ - C: 26 points — 50 points
❑ - D: 0 points — 25 points
MSC). Lower Meramec MNTF
Page # 15
APPENDIX B - RPA RESULTS:
Parameter
CMC*
RWC
Acute*
CCC*
RWC
Chronic*
Range
m min
CV***
off'
RP
Yes/No
Total Ammonia as Nitrogen
(Summer) mg/L
12.10
1.12 1
1.50
0.10
12 ! 15.2.0.600
0.999
4.693
NO
Total Ammonia as Nitrogen
(Winter) mg/L
12.1
1.12
3.10
0.10
13 1
15.1.`0.100
1.05
4.714
NO
Iron. Total Recoverable
1000 ;
22.26
1000
2.26
18
675/60
0.547
2.253
NO
Mercury, Total Recoverable
2.40
0.03
0.50
0.00
16
0.600/.050
0.924
3.660
NO
Arsenic Total Recoverable
20.00
0.33
20.00
0.03
18
8.0/1.0
0.736
2.842
NO
Cadmium, Total Recoverable
• 10.61
0.89
0.47
0.09
18
9.0/0.05
1.811
6.779
NO
Copper, Total Recoverable
27.90
0.26
17.44
0.03
18
11/3.0 i 0.317
1.635
NO
Lead, Total Recoverable
207.31
0.84
8.08
0.09
18
20/0.15 0.745
2.871
NO
Nickel. Total Recoverable
872.36
1.84
96.98
0.19
18
40'3.0
0.827
3.145
NO
Zinc, Total Recoverable
222.85
4.66
222.85
0.47
17 128/15.0 0.610
2.488
NO
Silver, Total Recoverable 13.36
2.21
N/A N/A
18 1 30/1.0 , 1.407
5.250 ' NO
NIA - Not Applicable
* - Units are (µg .) unless otherwise noted.
** - If the number of samples is 10 or greater, then the CV value must be used in the WQBEL for the applicable constituent.
*** - Coefficient of Variation (CV) is calculated by dividing the Standard Deviation of the sample set by the Mean of the same
sample set.
RWC - Receiving Water Concentration. It is the concentration of a toxicant or the parameter toxicity in the receiving water after
mixing (if applicable).
n - Is the number of samples.
CIF - Multiplying Factor. 99% Confidence Level and 99% Probability Basis.
RP - Reasonable Potential. It is where an effluent is projected or calculated to cause an excursion above a water quality standard
based on a number of factors including, as a minimum, the four factors listed in 40 CFR 122.44(d)(1)(ii).
Reasonable Potential Analysis is conducted as per (TSD, EPA/505/2-90-001, Section 3.3.2). A more detailed version including
calculations of this RPA is available upon request.
MSD, Lower Meramec WWTF
Page # 16
APPENDIX C — AFFORDABILITY ANALYSIS:
Missouri Department of Natural Resources
Water Protection Program
Affordability Determination and Finding
(In accordance with RSMo 644.145)
Operating Permit Renewal
MSD-Lower Meramec Wastewater Treatment Plant
MO-0127949
Section 644.145 RSMo requires DNR to make a "finding of affordability" when "issuing permits under" or "enforcing provisions of'
state or federal clean water laws "pertaining to any portion of a combined or separate sanitary sewer system or publicly -owned
treatment works."
Description:
POTW — SIC #4952
Coarse screens, fine screens, primary sedimentation (with chemical addition, if necessary/Trickling filter/secondary clarifiers (with
chemical addition, if necessary)/ gravity thickeners, belt filter press with polymer system, odor control (with chemical addition, if
necessary)/Disinfection with sodium hypochlorite and de -chlorination with sodium bisulfite used during the recreational season/sludge
is land applied, land filled, incinerated, composted, or used in land application.
Design population equivalent is 150,000
Design flow is 15 MGD
Design peak daily flow is 42 MGD
Actual flow is 12.74 MGD
Design sludge production is 4,380 dry tons/year.
Receiving Stream: Mississippi River (P)
First Classified Stream and ID: Mississippi River (P)
USGS Basin & Sub -watershed No.: (07140101-0603) (1707)
Residential Connections: 20,290
Commercial Connections: 896
Total Connections: 21,186
New Permit Requirements or Requirements Now Being Enforced:
This is a renewal of an operating permit with no new or expanded conditions. This permit has less monitoring requirements in it than
the previous permit. The facility has demonstrated its ability to meet these permit limits. Discharge Monitoring Reports (DMRs)
provide data that support the Department's finding that this facility is capable of meeting the final effluent limitations with no new
cost.
All wastewater treatment facilities will experience a bypass if rainfall intensity is high enough, but facilities are required to maintain
their collection systems so as to minimize bypasses to the extent practicable. This facility bypassed only 3 times in the past five years,
with no water quality impacts noted.
MSD, Lower Meramec UVWfF
Page # 17
Range of Anticipated Costs Associated with Complying with Requirements:
This is a modification of an operating permit with no new or expanded conditions that does not involve any significant costs for the
permittee.
(1) A community's financial capability and ability to raise or secure necessary funding;
This is a renewal for an operating permit with no new or expanded conditions and does not involve any significant costs for the
permittee. The community has no need to secure funding or require changes to the rate structure. Therefore, the community shall
incur no new costs and financial capability exists.
(2) Affordability of pollution control options for the individuals or households of the community;
(3)
This is a renewal for an operating permit with no new or expanded conditions, thus maintaining existing pollution control options.
Therefore, no rate increase to individuals or households of the community is required to achieve the pollution control conditions
of this permit.
An evaluation of the overall costs and environmental benefits of the control technologies;
This is a renewal for an operating permit with no new or expanded conditions, thus maintaining existing overall costs and
environmental benefits. There will be no new costs or environmental benefits of control technologies unless the facility initiates
technology upgrades.
(4) An inclusion of ways to reduce economic impacts on distressed populations in the community, including but not limited to
low and fixed income populations. This requirement includes but is not limited to:
(a) Allowing adequate time in implementation schedules to mitigate potential adverse impacts on distressed populations
resulting from the costs of the improvements and taking into consideration local community economic considerations;
and
(b) Allowing for reasonable accommodations for regulated entities when inflexible standards and fines would impose a
disproportionate financial hardship in light of the environmental benefits to be gained;
(5)
This is a renewal for an operating permit with no new or expanded conditions, thus no implementation schedule is required. No
improvements are necessary, resulting in no new economic impacts on distressed populations and no other new cost burden.
The facility has demonstrated the ability to comply with the conditions in the permit, avoiding any violations or fines that would
result in financial hardships.
An assessment of other community investments relating to environmental improvements;
This is a renewal for an operating permit with no new environmental improvements; therefore, it will not affect the timing or
funding of other community investments.
(6) An assessment of factors set forth in the United States Environmental Protection Agency's guidance, including but not
limited to the "Combined Sewer Overflow Guidance for Financial Capability Assessment and Schedule Development"
that may ease the cost burdens of implementing wet weather control plans, including but not limited to small system
considerations, the attainability of water quality standards, and the development of wet weather standards;
See Section (2) of this analysis for the residential indicator as outlined in the above -referenced EPA guidance.
This is a renewal for an operating permit with no new or expanded conditions. Existing efforts to control combined sewer
overflows and wet weather flows at the facility are sufficient to meet the requirements of this permit. No new cost burden exists.
MSD, Lower Meramec WW1F
Page#18
(7)
An assessment of any other relevant local community economic condition.
This is a renewal for an operating permit with no new or expanded conditions. It creates no new cost burden that could be
affected by local economic conditions.
St. Louis's population has decreased 19.51% from 1990 to 2010. In terms of economic strength, St. Louis County is average when
compared to other counties in the State. The percentage of labor force is 78% below the State average, the per capita wealth' is
67% above the State average and the per capita income is 70% above the State's average.
In terms of retail sales, St. Louis County has gained retail customers from surrounding counties and the County residents spend
more than the state average on retail goods and services. The buying power index of St. Louis County residents is better than
average compared to the rest of the regional econoniy2.
Conclusion and Finding
This is a renewal for an operating permit with no new or expanded conditions. The facility is currently capable of meeting the permit
requirements. No new cost burden exists. Also, the facility states that the removal of authorization for bypasses at outran #002 does
not require capital improvements.
All wastewater treatment facilities will experience a bypass if rainfall intensity is high enough, but facilities are required to maintain
their collection systems so as to minimize bypasses to the extent practicable. This facility bypassed only 3 times in the past five years,
with no water quality impacts noted.
As a result of reviewing the above criteria, the Department hereby finds that the action described above will result in low or no burden
with regard to the community's overall financial capability and low or no financial impact for most individual customers/households.
1 Per capita wealth is calculated by taking a sum of appraised value of residential property, mobile homes and motor vehicles and this sum is then
divided by County population.
2 http://www.missourieconomy.org/pdfs/wc wia retail _trade analysis.pdf