HomeMy Public PortalAboutDraft Lower Meramec 208 Plan Update for Public Notice_1.31
Proposed Amendments to the 1978 St. Louis, Missouri
Water Quality Management 208 Plan
Lower Meramec River Basin
January 31, 2019
Prepared by
Metropolitan St. Louis Sewer District
Northeast Public Sewer District
Rock Creek Public Sewer District
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
i
Executive Summary
In 1978, pursuant to Section 208 of the Clean Water Act, East-West Gateway Council of
Governments (EWGCOG) completed the St. Louis, Missouri Regional Water Quality
Management Plan (hereinafter referred to at the 208 Plan). The goal of the 208 Plan was to
meet State water quality standards throughout entirety of St. Louis City and County, St. Charles
County, Franklin County, and Jefferson County. The 208 Plan also identified the Meramec River
as the region’s number one priority river, deserving protection as a drinking water source and
because it is biologically diverse and contains important habitat.
The 208 Plan recommended controls to address point and nonpoint sources of pollution and
residual waste management throughout the four-county planning area. Within the Lower
Meramec Basin, the plan called for a regional secondary treatment system in St. Louis County
near the confluence of the Meramec and Mississippi River. This regional facility was to be
managed by the Metropolitan St. Louis Sewer District (MSD) and provide services for the Lower
Meramec System, which consists of the Lower Meramec Basin (southern St. Louis County and
northern Jefferson County) and the entire Rock Creek Basin in Jefferson County. The 208 Plan
also recommended designating this facility a regional sludge processing center.
These recommendations were based on an evaluation of cost-effectiveness, water quality
effectiveness, management and institutional constraints, and environmental considerations.
Since 1978 however, the technical, economic, and environmental conditions have changed and
some of the original recommendations are no longer appropriate. The 208 Plan recognizes that
updates to the plan may be necessary noting that it “is not a static list of recommendations but
represents a dynamic and progressive policy for guiding future wastewater construction
activities.” Federal regulations (40 CFR 130.6) also allow plans to be updated to reflect
changing water quality conditions, results of implementation actions, new requirements, or to
remove conditions in prior conditional or partially-approved plans.
This report provides support for amending the 208 Plan to bring it into alignment with the current
situation in the Lower Meramec Basin. The analyses justify the following amendments:
It is more cost-effective to maintain existing facilities ($182 million) within the Lower
Meramec System than to construct a single regional WWTF ($476 million). Further, a
single regional WWTF is not necessary to meet state water quality standards in the
Lower Meramec River. Therefore, the Lower Meramec System should instead be served
by four WWTFs: Lower Meramec WWTF, Grand Glaize WWTF, Saline Creek Regional
WWTF, and Kimmswick WWTF.
Due to environmental and management considerations, it is not feasible for the Lower
Meramec WWTF to serve as a regional sludge processing center. The plan should be
revised to recognize that sludge processing for MSD facilities in the Lower Meramec
System will be addressed at the Bissell Point WWTF or Lemay WWTF; the Northeast
Public Sewer District and Rock Creek Public Sewer District will continue their current
management activities.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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Contents
Executive Summary ....................................................................................................................................... i
Introduction .......................................................................................................................................... 1 1.
1.1. Lower Meramec System ............................................................................................................ 2
1.2. MSD’s 201 Facility Plan for the Lower Meramec River Basin ................................................... 1
1.3. Report Objectives ...................................................................................................................... 1
System Updates in the Lower Meramec System ................................................................................ 3 2.
2.1. Metropolitan St. Louis Sewer District (MSD) ............................................................................. 3
2.1.1. Lower Meramec WWTF ............................................................................................... 3
2.1.2. Grand Glaize WWTF .................................................................................................... 4
2.1.3. Fenton WWTF .............................................................................................................. 4
2.1.4. Future Plans for MSD WWTFs in the Lower Meramec Basin ...................................... 5
2.1.5. Collection System Improvements ................................................................................. 5
2.2. Northeast Public Sewer District (NPSD) ................................................................................... 6
2.2.1. 2010 Facility Planning Efforts ....................................................................................... 6
2.2.2. Saline Creek Regional WWTF Construction and Upgrade History .............................. 7
2.2.3. Future Improvements ................................................................................................... 7
2.3. Rock Creek Public Sewer District (RCPSD) ............................................................................. 8
2.3.1. Historical Facility Planning Efforts and Improvements ................................................. 9
2.3.2. Future Improvements ................................................................................................... 9
Meramec River Water Quality Evaluation ......................................................................................... 10 3.
3.1. 208 Plan Water Quality Goals ................................................................................................. 10
3.2. Existing Water Quality Conditions ........................................................................................... 10
3.2.1. Lead ........................................................................................................................... 11
3.2.2. Bacteria ...................................................................................................................... 11
3.2.3. Ammonia .................................................................................................................... 12
3.3. WWTF Performance for Major Facilities Discharging into the Lower Meramec River ............ 14
3.3.1. Grand Glaize WWTF Performance ............................................................................ 14
3.3.2. Fenton WWTF Performance ...................................................................................... 14
3.3.3. Saline Creek Regional WWTF Performance ............................................................. 15
Proposed 208 Plan Amendments ..................................................................................................... 16 4.
4.1. Lower Meramec System Point Source Amendments ............................................................. 16
4.2. Lower Meramec Regional Center Sludge Management Amendments ................................... 18
4.2.1 MSD Sludge Management ......................................................................................... 18
4.2.2 NPSD Sludge Management ....................................................................................... 19
4.2.3 RCPSD Sludge Management .................................................................................... 19
4.3. Summary of Proposed Amendments ...................................................................................... 19
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
iv
Tables
Table 1. Proposed Permanent WWTFs in the Lower Meramec System. ................................................... 16
Table 2. Comparison between Costs to Implement Original 208 Point Source Recommendations
and Costs to Maintain Existing Facilities in the Lower Meramec System. ..................................... 17
Figures
Figure 1. 208 Planning Area for the St. Louis Region. ................................................................................. 1
Figure 2. Lower Meramec System as Identified in the 208 Plan and Interim WWTF Outfalls and
Tunnel Identified in 201 Plan. .......................................................................................................... 4
Figure 3. Average (Geometric Mean) Recreational Season (April – October) E. coli Levels in the
Meramec River at Paulina Hills (1997-2016). ................................................................................ 11
Figure 4. Distribution of Average (Geometric Mean) Recreational Season (April – October) E. coli
Levels by Flow Regime in the Meramec River at Paulina Hills (2005 – 2018). ............................. 12
Figure 5. Average Annual Ammonia in the Meramec River at Paulina Hills (1968 – 2018). ...................... 13
Figure 6. Average Annual Ammonia Levels in the Meramec River at Eureka (Upstream of the 201
Planning Area) and Paulina Hills (Downstream of Major WWTFs in the 201 Planning
Area)............................................................................................................................................... 13
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
1
Introduction 1.
Section 208 of the Clean Water Act (CWA) requires that Regional Water Quality Management
Plans be developed to control water pollution from point and nonpoint sources in a defined
geographic area. In 1975, the Governor of Missouri designated the East-West Gateway Council
of Governments (EWGCOG) as the agency responsible for preparing the Water Quality
Management Plan for the St. Louis area, including the City of St. Louis and the counties of
Franklin, Jefferson, St. Charles and St. Louis (Figure 1).
The St. Louis, Missouri
Regional Water Quality
Management Plan1 (hereinafter
referred to at the 208 Plan) was
subsequently completed in
1978. The objective of the 208
Plan was to ensure that the
water quality of rivers and
streams of the St. Louis area
meets state standards and that
the negative effects of growth
on water quality be kept to a
minimum. The 208 Plan also
identified the Meramec River as
the region’s number one priority
river and watershed area,
deserving protection as a
drinking water source and
because it is biologically diverse
and contains important habitat.
The 208 Plan proposed multiple
control alternatives, with each
alternative evaluated using four
major criteria: 1) cost-effectiveness, 2) water quality effectiveness, 3) management/institutional
constraints, and 4) environmental considerations. After evaluation against these criteria, the
best of the alternatives at the time was chosen as a goal for the region. The 208 Plan included a
mixture of structural and non-structural control alternatives to address point sources, nonpoint
sources, and residual waste (sludge) throughout the four county region, which are summarized
as follows:
Point sources – The 208 Plan delineated 40 service area recommendations across the
four county planning area and identified a number of secondary wastewater treatment
1 East-West Gateway Coordinating Council (EWGCOG). 1978. St. Louis, MIssouir Water Quality Management Plan: Areawide
Waste Treatment Management Study (208). St. Louis, Missouri. https://www.ewgateway.org/wp-content/uploads/2017/07/208Rpt-
Part1.pdf
Figure 1. 208 Planning Area for the St. Louis Region.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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facilities (WWTF) to serve as regional treatment facilities within each of the service
areas.
Nonpoint sources – The 208 Plan recommended nonpoint source control measures for
each of the four counties in the planning area. Controls addressed both individual home
treatment systems (septic systems) and urban stormwater runoff. Recommendations for
septic systems included design and operational guidelines and implementation
measures. Recommendations for urban stormwater runoff were divided into three
categories of control designed to address the quantity and quality aspects of urban
runoff. These include control of stormwater runoff, onsite detention, and urban
cleanliness programs.
Sludge management – The 208 Plan delineated 14 regional sludge processing centers
across the four county planning area.
Since the 208 Plan was completed in 1978, the technical, economic, and environmental
conditions have changed and some of the original recommendations are no longer appropriate.
This report and the proposed amendment address updates within the Lower Meramec System,
which is one of 40 areas defined by the 208 Plan. Information regarding the Lower Meramec
System, MSD’s 201 planning efforts, and objectives of the current report are discussed in the
remainder of this section.
1.1. Lower Meramec System
The Lower Meramec System is one of 40 service areas delineated within the St. Louis 208
planning region. The Lower Meramec System of the 208 Plan included the Lower Meramec
Basin (southern St. Louis County and northern Jefferson County) and the entire Rock Creek
Basin in Jefferson County (Figure 2). Plan recommendations within the Lower Meramec System
were intended to address pressing water quality issues of the time in the Meramec River.
The main recommendation of the 208 Plan for the Lower Meramec System was the construction
of a regional secondary treatment system in St. Louis County near the confluence of the
Meramec and Mississippi River (see pages 62 and 91 of the 208 Plan). The proposed Lower
Meramec facility was to be managed by the Metropolitan St. Louis Sewer District (MSD) and
provide sewer services via major interceptors for the entire Lower Meramec System. The 208
Plan also recommended that the facility serve as the regional processing center for St. Louis
and Jefferson counties (see pages 148-149 and 151 of the 208 Plan). Sludge processing would
include the use of dissolved air flotation, anaerobic digestion, and final disposal in twenty year
storage lagoons. The plan alternatively considered pumping and hauling residuals from the
regional treatment facility to MSD’s Lemay WWTF to be incinerated. However, this alternative
was ultimately rejected based on the preliminary economic analysis conducted at that time.
Recommendations for a single regional facility within the Lower Meramec System to be serviced
and managed by MSD never came to fruition. In 1977, MSD annexed the entirety of the St.
Louis County portion of the Lower Meramec River Basin into its service area. By charter, MSD
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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could not annex the Jefferson County portions of the Lower Meramec River Basin, so in 1979 it
was proposed that the northern Jefferson County’s newly-formed Northeast Public Sewer
District (NPSD) contract with MSD for treatment at the proposed regional treatment facility. A
similar suggestion was made for the newly-formed Rock Creek Public Sewer District (RCPSD)
and the City of Arnold. MSD currently accepts and treats flow from the Arnold Pump Station,
but not from NPSD or RCPSD due to cost considerations and institutional constraints.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
4
Figure 2. Lower Meramec System as Identified in the 208 Plan and Interim WWTF Outfalls and
Tunnel Identified in 201 Plan.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
1
1.2. MSD’s 201 Facility Plan for the Lower Meramec River Basin
In conjunction with the 208 Plan, MSD developed the 201 Facility Plan (hereinafter referred to
as the 201 Plan) for the Lower Meramec River Basin in September 19792 and updated the plan
in 19853. Consistent with the 208 Plan, the 201 Plan concluded that the most cost-effective
solution to improve water quality in the Lower Meramec Basin was through the consolidation of
wastewater treatment to one regional WWTF discharging to the Mississippi River with a major
interceptor serving the entire basin. However, for unexpressed reasons, the 201 area was
limited to the Lower Meramec Basin and did not include Rock Creek as called for in the 208
Plan. Additionally, the 201 Plan acknowledged that MSD has no legal or jurisdictional authority
for operation within Jefferson County. NPSD currently maintains authority over most of the
Lower Meramec Basin in Jefferson County.
In 1985 when the 201 Plan was updated, MSD recognized that construction of the regional
treatment facility and its associated collection system could take significantly longer than
anticipated because of decreases in federal funding, and therefore proposed interim solutions.
These interim solutions included the construction of three secondary treatment facilities, Grand
Glaize, Fenton, and Lower Meramec, within the St. Louis County area of the Lower Meramec
River Basin. The intent of the 201 Facility Plan was to phase out the interim treatment facilities
upon the construction of the regional facility and the Lower Meramec Tunnel (LMT), which was
to be completed in three distinct phases (Figure 2). MSD has since been implementing the 201
Facility Plan recommendations in the Lower Meramec Basin. Details regarding specific actions
and progress are discussed further in Section 2.1.
1.3. Report Objectives
As discussed above, the objective of the 208 Plan was to ensure that the water quality of rivers
and streams of the St. Louis area meets state standards and mitigate the negative effects of
population growth on water quality. Circumstances have changed since 1978 and construction
of a single regional treatment facility in the Lower Meramec Basin is no longer necessary to
achieve these objectives. Water quality in the Meramec River itself has generally improved and
point sources in the Basin currently meet all applicable discharge permit requirements.
Remaining water quality challenges in the Basin are primarily related to nonpoint source control
issues and cannot be remedied through further point source consolidation.
The original 208 Plan recognizes that updates to the plan may be necessary, noting that it “is
not a static list of recommendations but represents a dynamic and progressive policy for guiding
future wastewater construction activities.” Further, federal regulations (40 CFR 130.6(e)) allow
water quality management plans to be updated to reflect changing water quality conditions,
results of implementation actions, new requirements, or to remove conditions in prior conditional
or partially-approved plans. The process for amending the 208 Plan is included in Attachment A.
2 Metropolitan St. Louis Sewer District (MSD). 1979. Final 201 Facility Plan: Lower Meramec River Basin. St. Louis, MO. 462 pp.
3 Havens and Emerson, Inc. 1985. 201 Facility Plan Update: Lower Meramec River Basin. St Louis, MO. 193 pp.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
2
The purpose of this report is to amend the 208 Plan recommendation for the Lower Meramec
Basin and bring it into alignment with the current situation. The decision criteria used to
evaluate alternatives and develop recommendations in the original 208 Plan were
Cost-effectiveness,
Water quality effectiveness,
Management and institutional constraints, and
Environmental considerations.
These same criteria are applicable in the context of the current situation and support the need to
amend some of the original 208 Plan recommendations for the Lower Meramec Basin. It is
important to note that the proposed amendments in this report only address one point source
service area (identified as the Lower Meramec System in the 208 Plan) and one regional sludge
processing center (identified as the Lower Meramec Regional Center in the 208 Plan). The
proposed amendments do not impact point source, nonpoint source, or sludge management
recommendations for the remainder of the four-county planning area.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
3
System Updates in the Lower Meramec System 2.
Wastewater treatment and planning efforts of the three regional control authorities responsible
for the Lower Meramec System are discussed below. These include MSD, NPSD, and RCPSD.
2.1. Metropolitan St. Louis Sewer District (MSD)
MSD incorporated the entirety of the St. Louis County portion of the Lower Meramec River
Basin in 1977, inheriting hundreds of miles of sewers and over sixty treatment plants, most of
which were small, overburdened, and failing due to construction under limited to no regulation.
Much of the inherited collection system was old and inadequately sized for future development.
MSD shaped its goals for the Lower Meramec River Basin around rehabilitating, maintaining,
and improving this inherited collection system and eliminating numerous treatment plants.
Through the use of its sewer use ordinance, MSD has been able to regulate dischargers within
its service area in order to protect the sewer system, treatment processes, residuals
management processes, and receiving waters. MSD has a variety of regulatory abilities
including requiring connection to the MSD system, connection permitting, pretreatment limits,
effluent monitoring, and reporting requirements. These regulatory abilities have given MSD the
opportunity to eliminate nearly all of the inherited treatment plants and replace them with three
well operated treatment facilities, as well as to rehabilitate much of its collection system.
In 2012, MSD entered into a Consent Decree with the United States EPA (EPA), the state of
Missouri, and the Missouri Coalition for the Environment Foundation. In this Consent Decree,
MSD committed to spending $4.7 billion in order to make infrastructure improvements to the
sanitary and combined collection systems.4 The major improvements to MSD’s collection
system that the Consent Decree includes are inflow and infiltration (I/I) reduction remediation
projects, elimination of all constructed sanitary sewer overflows (SSOs), elimination of all known
SSOs, and elimination of building backups. These efforts have and will continue to make a
significant impact in ensuring that the Lower Meramec River Basin achieves Clean Water Act
goals.
Since the 1985 201 Plan update, MSD has constructed the three recommended WWTFs and
made significant progress with respect to maintaining and improving their sanitary sewer
collection systems. These activities, as well as planned future WWTF modifications, are
described below.
2.1.1. Lower Meramec WWTF
The Lower Meramec WWTF was constructed in 2007 with a design flow of 15 million gallons
per day (MGD) and a peak hour design capacity of 40 MGD. Currently, the facility has an
average dry weather daily flow of 11 MGD, which includes wastewater flows from the City of
Arnold, and discharges to the Mississippi River (Figure 2). MSD intends to expand the Lower
4 United States of America and the State of Missouri, and Missouri Coalition for the Environment Foundation v. Metropolitan St.
Louis Sewer District, No. 4:07-CV-1120-CEJ, The original Consent Decree required improvements over a twenty-three year period.
In 2018, the parties agreed to modify the duration of improvements to twenty-eight years.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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Meramec WWTF to accommodate additional flows from the Fenton WWTF when it is
eliminated. The Lower Meramec WWTF is currently served by a 31 square mile sanitary sewer
collection, consisting of approximately 1.75 million feet of public sewers and 34 active pump
stations owned and maintained by MSD.
The Lower Meramec WWTF uses sludge grit removal, gravity sludge thickeners, sludge belt
filter presses, and cake storage hoppers for sludge management, and produces approximately
2,000 dry tons of sludge annually. MSD currently hauls its sludge from the Lower Meramec
WWTF to MSD’s Bissell Point WWTF for incineration or to the IESI Champ Landfill to be
landfilled.
2.1.2. Grand Glaize WWTF
In an effort to improve wastewater treatment in the Lower Meramec River Basin, MSD
constructed the Grand Glaize WWTF in 1986 and expanded the facility in 2006. This expansion
resulted in an average design flow of 21 MGD and peak hour design capacity of 40 MGD. In
addition to the treatment capacity directly available, the facility can store influent flows above 40
MGD in its 49.7 million gallon wet weather storage lagoon. The Grand Glaize WWTF discharges
to the Meramec River (Figure 2). The Grand Glaize WWTF serves a 45 square mile sanitary
collection system consisting of approximately 3 million feet of public sewers, with pipe diameters
ranging from 6 to 54 inches. The collection system also includes 20 active pump stations owned
and maintained by MSD.
The Grand Glaize WWTF uses gravity sludge thickeners and belt filter presses for residuals
management and produces approximately 3,000 dry tons of sludge annually. MSD hauls its
residuals from Grand Glaize to MSD’s Bissell Point WWTF for incineration or to the IESI Champ
Landfill to be landfilled.
2.1.3. Fenton WWTF
The Fenton WWTF was constructed in 1987. This facility has a design flow of 6.75 MGD and
currently has an average dry weather daily flow of 4.85 MGD that discharges to the Meramec
River. The Fenton WWTF currently discharges to the Meramec River but MSD anticipates
taking it offline and sending flows to the Lower Meramec WWTF once Phase II of the LMT is
complete (Figure 2). The Fenton WWTF has a 19 square mile sanitary collection system
consisting of approximately 850,000 feet of public sewers. The Fenton collection system also
includes 21 active pump stations owned and maintained by MSD.
The Fenton WWTF uses a gravity sludge thickener and a sludge belt filter press for residuals
management and produces approximately 1,000 dry tons of sludge annually. MSD hauls its
residuals from the Fenton treatment facility to MSD’s Bissell Point treatment facility for
incineration or to the IESI Champ Landfill to be landfilled.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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2.1.4. Future Plans for MSD WWTFs in the Lower Meramec Basin
MSD plans to expand the Lower Meramec WWTF to accommodate future flows from the offline
Fenton WWTF. This expansion is scheduled to be completed in 2023. The Fenton WWTF
facility is currently scheduled to be taken offline in 2025 once the Phase II LMT extension is
complete.
The Grand Glaize WWTF will continue to operate, as the treatment facility has more than
enough capacity to accommodate future flows and has demonstrated continual high-quality
treatment. MSD is also planning to spend $2.75 million for additional flood protection
infrastructure, including earthen berms and a floodwall. This work is important for making the
Grand Glaize maintenance yard and treatment facilities more resilient to regional flooding
created by the Meramec River.
As described further herein (see Section 3.1.1), MSD is planning major improvements to its
sewer sludge incineration facilities at the Lemay WWTF and Bissell Point WWTF. MSD
estimates $340 million is needed to replace its sewer sludge incinerators with fluidized bed
incinerator technology that substantially reduces emissions. MSD estimates an additional $50
million is needed for pumping stations and piping needed to transport sludge from the Meramec
basin facilities to the Lemay WWTF.
2.1.5. Collection System Improvements
MSD has taken significant steps to study and characterize its collection system in order to
identify the best strategy to maintain and rehabilitate the collection system. In 2013, MSD
produced sewer system evaluation surveys (SSES) for the following watersheds: Fenton Creek,
Lower Meramec Sub Areas, Mattesse Creek, Fishpot Creek, Kiefer Creek, and Grand Glaize
Creek. These watersheds make up the entirety of the MSD service area portion of the Lower
Meramec River Basin. SSES reports were produced discussing the various aspects of the
collection system, including constructed SSO outfalls, known SSOs, building backups, gravity
sewers, pump stations, force mains, CCTV inspections, I/I evaluations, and flow and rainfall
monitoring,
MSD has made substantial efforts towards maintaining and rehabilitating its collection system.
The Capacity, Management, Operations and Maintenance (CMOM) Program Plan is a Consent
Decree requirement that allows MSD to better understand how its sewer system works under
various conditions, and identifies maintenance and improvements needed to achieve
established goals. The CMOM program has been in place since 2012. The goal of the CMOM
program is to preserve capital investment while minimizing building backups and non-capacity
SSOs. The CMOM program includes the following control measures: scheduled cleaning and
inspection of gravity sewers, especially for sewer lines with historic Fats, Oils, and Grease
(FOG) blockages; sewer lining to minimize root intrusion and I/I and to prevent structural
damage, SSOs, and building backups; manhole inspection, repair, rehabilitation, and
replacement; utilization of a computerized maintenance management system; recording,
investigating, and resolving customer complaints to correct system problems; CCTV of sewer
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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lines and manholes to rate the condition; pump station inspections, maintenance, repair, and
testing; scheduled force main visual and non-destructive testing; and proactive inspection of
FOG generating facilities and source investigation of excessive FOG in sewer lines. These
CMOM control measures have target service levels for MSD to maintain, all of which have been
consistently met since the program was implemented.
2.2. Northeast Public Sewer District (NPSD)
NPSD was established in 1979 under the provisions of Chapter 204 of the Missouri Revised
Statutes and is governed by a five member Board of Trustees appointed by the Jefferson
County, Missouri government. The day-to-day operations of NPSD are managed by the
Executive Director. As a Chapter 204 Sewer District, NPSD does not levy taxes and receives
income from user fees and connection fees. NPSD covers 42.8 square miles of northern
Jefferson County, serving over 12,000 customers. NPSD operates and maintains a collection
system consisting of 161.5 miles of gravity sanitary sewer, 49 pump stations, 29.78 miles of
force mains, 4,948 manholes, and 298 lampholes.
In 1980, the service area of NPSD contained five privately owned sewer companies and 80
permitted wastewater disposal systems. In 1980, and reaffirmed in 1991, NPSD signed a
management agreement designating NPSD as a Management Agency for the Northeast
Facility Planning Area (FPA) with the boundaries of the FPA conterminous with the boundaries
of NPSD. This designation made NPSD responsible for the planning, design, construction,
acquisition, operation and maintenance of any public wastewater system with the NPSD
service area. In 2015, NPSD was granted Level 2 Continuing Authority classification by the
Missouri Clean Water Commission, which permits NPSD to provided sewage collection and
service on a regional basis within the NPSD service area. NPSD is currently the only Level 2
Continuing Authority in the Lower Meramec Basin.
Today, there is one privately owned sewer company (Missouri American Water Company), and
14 permitted wastewater disposal systems in the NPSD service area. Four (4) of these
permitted systems are NPSD facilities, and NPSD also has a no-discharge pump and haul site.
2.2.1. 2010 Facility Planning Efforts
NPSD completed a comprehensive Facility Plan for the entire collection and treatment system
in 2010, with an amendment in 2013. The Facility Plan identified NPSD’s future wastewater
needs and identified improvements that will support growth within the service boundaries. The
Facility Plan recommended the Saline Creek WWTF become a regional facility for NPSD. The
plant was designed for an average daily flow of 4 MGD and a peak daily flow of 10 MGD.
Provisions were made in the plant design to accommodate expanding capacity to an average
daily flow of 8 MGD and a peak daily flow of 20 MGD by adding additional process equipment.
The Facility Plan also recommended to re-rate the Saline Creek Regional WWTF as follows:
1. Design Average Daily Flow = 6.56 MGD
2. Design Maximum Flow = 17.97 MGD
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
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3. Organic Loading BOD5 = 11,341 lb/d
4. Total Suspended Solids Loading TSS = 12,203 lb/d
2.2.2. Saline Creek Regional WWTF Construction and Upgrade History
The Saline Creek Regional WWTF was constructed in two phases with the headworks and
overflow basin completed in 2004, and the remainder of the existing facility including lab
building, oxidation ditch, clarifiers and UV disinfection system completed in 2009. The WWTF
was constructed adjacent to the old Ron Rog plant, which itself was converted to a temporary
aerobic digester for the Saline Creek Regional WWTF. In 2017 construction was completed on
a new blower building, electrical improvements to the headworks facility to comply with NEC
(NFPA 70) Class I, Division 1 requirements, and a new perforated plate screen. The Saline
Creek WWTF discharges to the Meramec River (Figure 2).
Biosolids from NPSD’s satellite WWTFs are transported to the Saline Creek Regional WWTF
for processing and final disposal. The Saline Creek Regional WWTF has an aerobic digester
which is a recycled plant from the old Ron Rog WWTF adjacent to Saline Creek Regional
WWTF and two (2) biosolids holding ponds. Biosolids are land applied annually by a
contractor on fields near Byrnes Mill, MO. The aerobic digester was intended to be a
temporary facility until a more in-depth study for improvements to NPSD’s biosolids process
could be completed.
The Biosolids Facility Plan was completed in February 2014 and NPSD conducted pilot studies
on several different types of equipment as part of the development of the plan. The
recommendation of the Biosolids Facility Plan was to construct a new aerobic digester with a
membrane thickener and continue land application. NPSD applied for a SRF loan ($5 million)
to fund most of the cost of the Biosolids project with the remainder to be funded by NPSD’s
capital improvement fund. NPSD’s biosolids project was included in the FY 2019 Intended Use
Plan approved by the Missouri Clean Water Commission on October 18, 2018 as a $5 million
loan. The project is in final design with anticipated bidding in Spring 2019. The total capital
cost of the biosolids project will be approximately $6.4 million.
Between May 2012 and May 2015 NPSD completed $9.75 million in work to eliminate known
sources of I/I and regionalize the service area by eliminating eight of NPSD’s wastewater
treatment facilities. The flow from seven of these eliminated facilities was redirected to the
Saline Creek Regional WWTF, and the flow from the remaining facility was redirected to the
collection and treatment system of the RPCSD. Approximately $9.3 million of this expenditure
was funded by a loan from the State Revolving Fund (SRF) program, with the remainder
funded by NPSD revenue. Some of the work completed during this time period provides
improved access to the public sewer system for unsewered areas of NPSD’s service area.
2.2.3. Future Improvements
In addition to the planned biosolids project, NPSD has begun efforts to evaluate and improve
their collection system to eliminate sources of I/I, eliminate sanitary sewer overflows and
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
8
enhance customer service reliability. While the 2010 Facility Plan improved parts of the
collection system and removed I/I, this work concentrated on the interceptors of NPSD’s
collection system. With that work completed, NPSD can concentrate on the collection sewer
mains. As NPSD inspects the system, needed improvements will be added to NPSD’s capital
improvement planning. At this time, it is anticipated that the work identified by NPSD’s
systemic inspection program will be completed on a pay-as-you-go basis as funding is
available.
In addition to NPSD’s planning for its existing assets, NPSD is working to improve
management of wastewater on a watershed basis. Many areas of NPSD’s territory are not
served by public sewers. They are either served by on-site (septic) systems or private
treatment facilities. NPSD works with MDNR, Jefferson County and residents to facilitate
extending public sewer service to these areas. The introduction of the use of SSIAs is one step
that aids in the process of extending public sewers to areas with on-site systems by providing a
financing mechanism for the construction. NPSD believes that their current efforts and future
planning are the best way to regionally manage wastewater collection and treatment in its
service area and improve water quality.
2.3. Rock Creek Public Sewer District (RCPSD)
RCPSD was established on August 7, 1979 under the provisions of Chapter 204 of the Missouri
Revised Statutes and is governed by a five member board of trustees appointed by the
Jefferson County, Missouri government. The day-to-day operations of RCPSD are managed by
the RCPSD Administrator. As a Chapter 204 Sewer District, RCPSD does not levy taxes and
receives income from user fees and connection fees. RCPSD was designated the management
agency for the Rock Creek drainage area as a result of the 208 Plan. RCPSD had accepted this
responsibility by an agreement signed in March 1980.
RCPSD currently owns and operates the Kimmswick WWTF which services the Rock Creek
Basins and includes the cities of Arnold, High Ridge, House Springs, Kimmswick and Imperial.
RCPSD area contains approximately 32 square miles or approximately 20,750 acres. The
RCPSD area is divided into four service areas: Imperial/Kimmswick, New Towne, Seckman
Valley, and West Elm Place. RCPSD operates and maintains a collection system consisting of
150 miles of gravity sewer lines, six pump stations, five miles of force main, 5,000 manholes,
and 65 grease traps for commercial customers.
RCPSD also owns and operates the Kimmswick WWTF. The facility is a four basin sequencing
batch reactor system with UV disinfection and three aerobic sludge digesters. It has a design
flow of 4.8 MGD and discharges directly to the Mississippi River. RCPSD also collects sewer
flows from the Pomme Creek watershed in Arnold and sends them to MSD’s Lower Meramec
WWTF.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
9
2.3.1. Historical Facility Planning Efforts and Improvements
Since being established in 1979, RCPSD has worked to improve wastewater treatment and
eliminate and regionalize small treatment facilities throughout the Rock Creek Basin. Historical
facility planning efforts in 1983, 1985, 1993, 2000, and 2009 have focused on cost-effectively
consolidating existing facilities while meeting discharge permit requirements.
The Kimmswick WWTF was constructed in 2003 to facilitate regionalization in the watershed. At
the time, RCPSD evaluated the cost to build the new treatment facility against the cost to
construct sewers and pump to MSD, as outlined in the original 208 Plan. RCPSD found that the
new facility was the most cost effective alternative (Table ). Construction of the new facility lead
to the elimination of nine smaller WWTFs in the basin.
Table 1. Estimated RCPSD Treatment Alternative Construction Costs (in 2000 Dollars).
Project RCPSD Cost
Original 208 Plan Recommendation - Connect to MSD
Original 208 Plan Recommendation – Connect to MSD $26.2 million
Construct Kimmswick WWTF $16.7 million
Source: Don Daniel, RCPSD District Administrator
In 2009, new permit requirements for disinfection, potential future treatment and collection
system improvements, and significant inflow and infiltration reduction challenges necessitated
phased upgrades to the Kimmswick WWTF. Upgrades included the addition of a UV disinfection
system and the addition of mixers within the existing sequencing batch reactor to achieve partial
nutrient removal in Phase 1. Phase 1 also included improvements to the collection system
including elimination of two pump stations, several creek bank stabilizations, sewer relocations,
the closure of the Seckman School Lagoon, a significant inflow and infiltration investigation, and
manhole lining and rehabilitation. Phase 2 improvements include plans for two additional
sequencing batch reactors and the addition of a deep bed sand filter to achieve high level BOD,
TSS and nutrient removal.
2.3.2. Future Improvements
RCPSD is currently working through a Facility Plan Amendment in the FY 2019 and have
identified approximately $26.5 million in capital improvements at the WWTF. Projects include
new influent screens, influent pump replacement, and capacity and disinfection improvements to
accommodate future expanded flows. These projects will continue to be refined as the Facility
Plan Amendment is developed.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
10
Meramec River Water Quality Evaluation 3.
Since 1978, water quality impacts caused by WWTFs have been eliminated in the Lower
Meramec Basin. However, the Meramec River remains a high priority area in need of
improvement from other pollutant sources. A summary of the original 208 Plan water quality
goals, existing water quality conditions, and WWTF performance is provided below.
3.1. 208 Plan Water Quality Goals
Three different approaches to water pollution control were defined and evaluated for the original
208 Plan. Each approach or level of pollution control was predicted to produce different water
quality in the study area at a different cost. The three levels of water quality used in the 208
Plan in ascending order of stringency are summarized below:
Level 1 – Provided for the secondary treatment of point sources and a continuation of
existing practices and controls for nonpoint sources;
Level 2 – Required the control of point and nonpoint sources necessary to meet the
State of Missouri’s water quality standards; and
Level 3 – Called for more stringent control of point and nonpoint sources of pollution in
order to meet the water quality goals developed during the 208 study. This included
establishing a new criterion of 0.05 mg/L for phosphate and new, more stringent criteria
for fecal coliform and ammonia than were proposed by the State at the time the plan was
developed.
As part of the 208 planning process, control strategies and their costs were developed for each
water quality level. Results of this analysis were presented to the public at workshops held in
1977. Workshop participants overwhelmingly chose Level 2 water quality, which was
subsequently selected as the target for the 208 Plan. In essence, the goal of the 208 Plan was
to implement a combination of point and nonpoint source controls such that the rivers and
streams of the St. Louis area meet Missouri’s water quality standards. Water quality standards
consist of three basic elements: 1) designated uses (e.g., recreation, aquatic life, public water
supply), 2) numeric and narrative water quality criteria to protect designated uses by limiting
chemical constituents that may be present in the water body, and 3) an antidegradation policy to
maintain and protect existing uses and high quality waters.
3.2. Existing Water Quality Conditions
Section 303(d) and 305(b) of the CWA require each state to report to EPA on the status of their
waters every two years. Waters that do not meet water quality standards and for which
adequate water pollution controls have not been required are included on the state’s 303(d) List.
Missouri’s 2018 303(d) List of impaired waters identifies the Lower Meramec River as impaired
for both lead in sediment and bacteria (Escherichia coli or E. coli). There are currently no other
identified 303(d) impairments in the Meramec River. Additional information regarding existing
lead and E. coli levels in the Meramec River is included below. Because total ammonia nitrogen
(ammonia) is a common pollutant discharged by WWTFs and Missouri’s water quality criteria for
ammonia will likely become more stringent in the near future, an analysis of historic and current
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
11
ammonia levels in the Meramec River is also included. Data used for this analysis were
obtained from United States Geological Survey (USGS) monitoring stations at Paulina Hills
(07019280) and Eureka (07019000). Paulina Hills is downstream of all major point discharges.
Eureka is located upstream of the Lower Meramec basin system.
3.2.1. Lead
The most likely source of lead impairments to the Meramec River is old lead belt tailings. The
Meramec River region is a former lead producing area with over 200 years of lead mining
pollution. EPA and the U.S. Army Corps of Engineers (USACE) currently serve on a task force
to facilitate the cleanup, restoration, and remediation efforts on the Meramec River5. DNR
concluded that the Fenton WWTF, Grand Glaize WWTF, and Saline Creek WWTF were not a
source of lead or the impairment.6
3.2.2. Bacteria
E. coli data collected in the Meramec River at Paulina Hills (USGS station 07019280) since
1997 supports MDNR’s findings that the Meramec River is impaired for bacteria. The E. coli
criterion on the Meramec River is 126 cfu/100 mL, which is expressed as a recreational season
(April – October) geomean. Since 1997, the E. coli criterion has been exceeded at this location
six times (Figure 3).
Figure 3. Average (Geometric Mean) Recreational Season (April – October) E. coli Levels in the
Meramec River at Paulina Hills (1997-2016).
At the time the 208 Plan was developed, WWTFs were considered a significant source of
bacteria. However, since then most treatment facilities in the Lower Meramec Basin have been
either been eliminated or are required to disinfect. This suggests that high bacteria levels in the
Meramec River are primarily a result of nonpoint sources in the watershed. This finding is
supported by data from Paulina. Recent E. coli data (collected since 2005) from the Paulina
Hills station were grouped and summarized by the following flow regimes:
5 https://www.epa.gov/urbanwaterspartners/urban-waters-and-meramec-and-big-rivers-missouri
6 See fact sheets for Missouri State Operating Permits MO-0086126, MO-0101362, and MO-0128490.
1
10
100
1,000
1997199819992000200120022003200420052006200720082009201020112012201320142015201620172018Recreational Season E. coli Geomean (cfu/100 mL)E. coli criterion = 126 cfu/100 mL
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
12
High Flows: 0 to 10% flow exceedance
Moist Conditions: >10 to 40% flow exceedance
Mid-Range Flows: >40 to 60% flow exceedance
Dry Conditions: >60 to 90% flow exceedance
Low Flows: >90% flow exceedance
The data show that bacteria levels and the flow regime are positively correlated (Figure 4). This
relationship is most apparent during high flow conditions, which has an E. coli recreational
season geometric mean of 398 cfu/100 mL during these wet weather conditions. E. coli levels
in all other flow regimes range from 40 to 83 cfu/100 mL, which are below the criterion of 126
cfu/100 mL. Because the high flow regime is dominated by stormwater runoff, nonpoint sources
are likely the primary source of bacteria during this condition.
Figure 4. Distribution of Average (Geometric Mean) Recreational Season (April – October) E. coli
Levels by Flow Regime in the Meramec River at Paulina Hills (2005 – 2018).
3.2.3. Ammonia
Since 1968, average ammonia levels in the Meramec River at the Paulina Hills station have
consistently remained below EPA’s new recommendations7 for summer (April – September) and
winter (October – March) water quality criteria of 0.7 and 2.3 milligrams per liter (mg/L),
respectively, which are based on a pH of 7.8 and assume a summer temperature of 26°C and a
winter temperature of 6°C (Figure 5). During this period, average summer ammonia levels have
been below 0.1 mg/L and average winter levels have been below 0.2 mg/L. There is no clear,
long-term trend in ammonia levels at the Paulina Hills station.
7 EPA’s 2013 ammonia criteria recommendations are based on new toxicity data which demonstrate that some organisms,
particularly some species of gill-breathing snails and freshwater mussels, are more sensitive to ammonia than other organisms in
the national toxicity dataset used in previous criteria recommendations (EPA 2013). Depending on pH and temperature
assumptions, the revised recommendations represent a decrease of 50% or more for existing ammonia criteria.
40 53 65
83
398
0
50
100
150
200
250
300
350
400
450
Low Flows Dry
Conditions
Mid‐Range
Flows
Moist
Conditions
High FlowsE. coli (cfu/100 mL)
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
13
Figure 5. Average Annual Ammonia in the Meramec River at Paulina Hills (1968 – 2018).
Since 2009, average ammonia levels at the Paulina Hills station dropped by approximately 50%
and 75% during the summer and winter seasons, respectively. The net result of these changes
was that ammonia returned to background levels measured at the upstream Eureka station
(Figure 6). This reduction is likely attributable to upgrades made at the Grand Glaize WWTF
during the period. However, reduced ammonia levels may also be partly attributable to
improvements at the NPSD Saline Creek Regional WWTF, which completed its second phase
of construction in 2009.
Figure 6. Average Annual Ammonia Levels in the Meramec River at Eureka (Upstream of the 201
Planning Area) and Paulina Hills (Downstream of Major WWTFs in the 201 Planning Area).
0.0
0.1
1.0
10.0
19681970197219741976197819801982198419861988199019921994199619982000200220042006200820102012201420162018Ammonia-N (mg/L)Winter Summer 2013 EPA Winter Chronic 2013 EPA Summer Chronic
2013 EPA Recommended Winter Criteria = 2.3 mg/L (pH =7.8 and temperature = 6°C)
2013 EPA RecommendedSummer Chronic Criteria = 0.7 mg/L (pH =7.8 and temperature = 26°C)
0.04
0.06
0.03
0.03
0.12
0.03
0.00
0.02
0.04
0.06
0.08
0.10
0.12
0.14
Eureka (1979‐2015) Paulina Hills (1968‐
2008)
Paulina Hills (2009‐
2018)Ammonia‐N (mg/L)Summer Winter
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
14
3.3. WWTF Performance for Major Facilities Discharging into the Lower
Meramec River
In the 1970s, discharges from point sources were directly attributed to elevated levels of
phosphorus and fecal coliform in the Meramec River. At that time, the Lower Meramec Basin
was serviced by numerous lagoons and septic systems, which did not meet secondary
treatment standards or require disinfection. Effluent quality was generally insufficient to meet
water quality standards. Since this time, most of these facilities and septic tanks have been
consolidated into a small number of major secondary treatment facilities with disinfection. Major
facilities that discharge to the lower Meramec River include MSD’s Grand Glaize WWTF, and
Fenton WWTF, and NPSD’s Saline Creek Regional WWTF. All three of these facilities typically
meet their National Pollutant Discharge Elimination System (NPDES) permit requirements,
which were designed to protect water quality standards.
3.3.1. Grand Glaize WWTF Performance
The Grand Glaize WWTF (MO-0101362) uses a treatment process that includes equalization,
coarse screening, influent pumping, fine screening, grit removal, primary clarification, aeration,
secondary clarification, and disinfection during the recreation season. This treatment process
has been well operated since the facility’s expansion in 2007. Over the past decade, both BOD
and TSS effluent concentrations have consistently achieved minimum average monthly removal
requirement. High wet weather flows significantly affect BOD and TSS removal, so continual
achievement of the average monthly removal indicates the Grand Glaize WWTF’s ongoing
exceptional performance.
Since final ammonia effluent limits came into effect in 2010, the Grand Glaize WWTF has never
exceeded daily maximum or monthly average ammonia effluent limits. E. coli effluent limits were
consistently achieved. In 2018, the National Association of Clean Water Agencies gave the
Grand Glaize WWTF a Gold Peak Performance Award.
3.3.2. Fenton WWTF Performance
The Fenton WWTF (MO-0086126) uses a treatment process of fine screening, influent
pumping, grit removal, primary clarification, aeration, secondary clarification, and disinfection
during the recreation season. In the past five years, there has been one exceedance of E. coli
limits in May 2017, which occurred during a period of historic flooding and flows into the plant
that exceeded the rated capacity of the disinfection equipment. There was one exceedance of
lead effluent limits in December 2013. It is anticipated that the Fenton WWTF will be taken
offline in 2025 and the Fenton influent flow will be sent to the Lower Meramec WWTF. In 2018,
the National Association of Clean Water Agencies gave the Fenton WWTF a Platinum Peak
Performance Award.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
15
3.3.3. Saline Creek Regional WWTF Performance
The Saline Creek Regional WWTF (MO-0128490) currently features a multi-channel oxidation
ditch with biological nutrient reduction capabilities, two secondary clarifiers, and UV disinfection.
The facility used to consist of two separate treatment plants with a separate outfall – the Ron
Rog site and the Highway 141 site. The Highway 141 plant was eliminated in 2013 and
replaced with a lift station sending all effluent to the Ron Rog site now referred to as the Saline
Creek Regional WWTF. Since 2013, there have been no permit limit exceedances. Although
nutrient removal is not currently required at the facility, it can be operated to remove nitrogen
and phosphorus biologically.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
16
Proposed 208 Plan Amendments 4.
As discussed in Section 1, the original 208 Plan made recommendations regarding point
source, nonpoint source, and sludge management alternatives across the four-county planning
area. These recommendations were based on an evaluation of cost-effectiveness, water quality
effectiveness, management and institutional constraints, and environmental considerations.
Technical and economic considerations have changed since the 1978 analysis and the original
208 Plan point source and sludge management alternatives for the Lower Meramec Basin are
not necessary for meeting the overall planning objectives. The 208 Plan recognizes that
updates to the plan may be necessary noting that it “is not a static list of recommendations but
represents a dynamic and progressive policy for guiding future wastewater construction
activities.”
The purpose of this section is to identify changes necessary to amend the 208 Plan
recommendations and bring it into alignment with the current situation in the Lower Meramec
Basin. The proposed changes in this report only address one point source service area
(identified as the Lower Meramec System in the 208 Plan) and one regional sludge processing
center (identified as the Lower Meramec Regional Center in the 208 Plan), but do not impact
point source, nonpoint source, or sludge management recommendations for the remainder of
the four-county planning area.
4.1. Lower Meramec System Point Source Amendments
The existing 208 Plan calls for MSD to serve as the designated management agency of a
regional treatment facility to provide sewer services via major interceptors for the Lower
Meramec area (southern St. Louis County and northern Jefferson County) and the entire Rock
Creek Basin in Jefferson County. At the time the 208 Plan was developed, the construction of
separate facilities within this area was considered impractical from both a technical and
economic standpoint. Technical and economic considerations have evolved since 1978 and it is
currently more practical to make the existing major facilities permanent. Also, only NPSD is a
Level 2 Continuing Authority whereas MSD and RCPSD are Level 3 Continuing Authorities.
Therefore, the 208 Plan recommendations should be amended to state that the Lower Meramec
System will be served by four WWTFs and their designated management agencies (Table 2).
Table 1. Proposed Permanent WWTFs in the Lower Meramec System.
Treatment Facility Service Area Management
Agency
Lower Meramec WWTF Lower Meramec (St. Louis County)* MSD
Grand Glaize WWTF Grand Glaize (St. Louis County) MSD
Saline Creek Regional WWTF Lower Meramec (Jefferson County) NPSD
Kimmswick WWTF Rock Creek (Jefferson County) RCPSD
*Includes serving portions of the City of Arnold and RCPSD (Pomme Creek Watershed) in Jefferson County.
Amending the 208 Plan to maintain the four major WWTFs within the Lower Meramec System
will not impact water quality standards attainment. Unlike in 1978, there are currently no known
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
17
impairments in Meramec River that are attributable to WWTF discharges, and the existing
WWTFs are producing high quality effluent that meets existing NPDES permit conditions.
Additionally, both the Lower Meramec WWTF and the Kimmswick WWTF discharge directly to
the Mississippi River with no impact to the Meramec River. Therefore, from a water quality
perspective, there is little difference between the original 208 Plan and this proposed
amendment.
In addition to the Continuing Authority and jurisdictional issues, the overriding consideration for
maintaining separate WWTFs in the Lower Meramec System is cost-effectiveness. Each of the
three estimated 20-year present worth costs to for implementing the original 208
recommendations (connecting to the Lower Meramec WWTF) and maintaining their existing
facilities. Implementing the original 208 recommendations would include constructing the Phase
III Lower Meramec Tunnel, expanding the Lower Meramec WWTF, and decommissioning parts
or all of the Grand Glaize, Saline Creek, and Kimmswick WWTFs. The combined estimated cost
to implement these projects is approximately $476 million (Table 2). By comparison, capital
projects to maintain the existing facilities would include those to replace aging equipment at the
Grand Glaize WWTF, improve biosolids handling at the Saline Creek Regional WWTF, and
implement preliminary improvements identified for the Kimmswick WWTF. The combined
estimated cost to implement these projects is approximately $182 million (Table 2).
Table 2. Comparison between Costs to Implement Original 208 Point Source Recommendations
and Costs to Maintain Existing Facilities in the Lower Meramec System.
Estimated 20-Year Present Worth Cost to Implement Original 208 Recommendations
(in 2018 dollars)1
Cost Component MSD NPSD RCPSD Total
Phase III Lower Meramec Tunnel $134,900,000 -- -- $134,900,000
Phase III Lower Meramec WWTF Expansion $117,400,000 -- -- $117,400,000
Grand Glaize WWTF Decommissioning $2,000,000 -- -- $2,000,000
O&M Present Worth $73,300,000 -- -- $73,300,000
Cost of Tunnels to Connect to Lower
Meramec System -- $65,600,000 $40,900,000 $106,500,000
Cost of Lower Meramec WWTF Upgrades -- $18,900,000 $22,700,000 $41,600,000
Total Cost to Implement 208
Recommendations $327,600,000 $84,500,000 $63,600,000 $475,700,000
Estimated 20-Year Present Worth Cost to Maintain Existing Facilities
(in 2018 dollars)1
Cost Component
MSD
Grand Glaize
WWTF
NPSD
Saline Creek
Regional
WWTF
RCPSD
Kimmswick
WWTF
Total
Capital Improvements $19,500,000 $6,400,000 $26,500,000 $52,400,000
O&M Present Worth $73,300,000 $10,700,000 $45,100,000 $129,100,000
Total Cost to Maintain Existing Facilities $92,800,000 $17,100,000 $71,600,000 $181,500,000
1. 20‐year present worth based on an inflation rate of 2.5%
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
18
4.2. Lower Meramec Regional Center Sludge Management Amendments
The existing 208 Plan recommended designating the Lower Meramec WWTF as a regional
sludge processing center. Alternatives, including transporting the sludge to the Lemay WWTF
for incineration, were determined to be more expensive and ultimately ruled out of consideration
for this reason. However, more recent analyses and activities in the watershed indicate that the
original recommendation is no longer applicable. The 208 Plan recommendations should be
amended to state that MSD, NPSD, and RCPSD will be responsible for sludge management at
their respective facilities, as discussed below.
4.2.1 MSD Sludge Management
In the Lower Meramec Basin, sludge from the Grand Glaize WWTF and Lower Meramec WWTF
is currently thickened and hauled off-site for incineration and/or landfill disposal. Sludge from
MSD facilities outside of the Lower Meramec Basin are currently incinerated at the Bissell Point
WWTF or Lemay WWTF. In 2018, MSD evaluated four potential future sludge management
alternatives8. Alternatives included the following:
1) Locating all incineration activities at the Bissell Point WWTF,
2) Retaining incineration facilities at the Bissell Point WWTF and constructing new facilities
at the Lower Meramec WWTF to handle sludge from the Lower Meramec and Grand
Glaize WWTFs,
3) Retaining incineration facilities at the Bissell Point WWTF and constructing new facilities
at the Lower Meramec WWTF and Grand Glaize WWTFs to handle sludge from MSD’s
facilities in the Lower Meramec Basin, and
4) Retaining incineration facilities at the Bissell Point and Lemay WWTFs. The Lemay
WWTF would accept sludge from the Grand Glaize and Lower Meramec WWTFs.
Incinerators at Bissell Point would provide redundancy for sludge produced at the Grand
Glaize and Lower Meramec WWTFs.
MSD concluded that Alternative 4 was the most environmentally sustainable and socially
feasible future course of action. This cost between the alternatives was not statistically different,
but Alternative 4 provided MSD with the most certainty with respect to unexpected increases in
future capital or operational costs. Per the Second Material Amendment to the Consent Decree,
the incinerators at both Bissell Point and Lemay WWTFs will be upgraded from multiple hearth
incinerators to fluidized bed incinerators by 2026, which will result in a yearly reduction of 2,109
tons of air emissions.
Alternative 4 assumes that sludge from the Grand Glaize and Lower Meramec WWTFs may
initially be hauled, but eventually will be transported to the Lemay WWTF via force main.
Transportation of raw sludge via hauling will be phased out of use because hauling has potential
for both spills and odor complaints. Landfilling of raw sludge will only be used minimally.
8 Metropolitan St. Louis Sewer District (MSD). 2018. Solids Handling Technical Memorandum, Fluidized Bed Incinerators. Project
12565. St. Louis, MO. 24 pp.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
19
The 208 Plan should be amended to state that MSD will manage sludge generated at the Grand
Glaize and Lower Meramec WWTFs at the Lemay WWTF, as described above in alternative 4.
4.2.2 NPSD Sludge Management
Biosolids from NPSD’s satellite WWTFs are transported to the Saline Creek Regional WWTF
for processing and final disposal. The Saline Creek Regional WWTF has an aerobic digester
which is a recycled plant from the old Ron Rog WWTF adjacent to Saline Creek Regional
WWTF and two (2) biosolids holding ponds. Biosolids are land applied annually by a
contractor on fields near Byrnes Mill, Missouri. As described in Section 2.2.2, NPSD is in the
process of construction a new aerobic digester with a membrane thickener and will continue
land application. The 208 Plan should be amended to state that NPSD will continue the
current activities.
4.2.3 RCPSD Sludge Management
In previous facility planning efforts, RCPSD evaluated the cost to haul sludge to MSD’s facilities
against the cost to retain a contract hauler and land apply them. RCPSD found that the cost to
land apply was approximately half the cost to dispose of them at MSD ($0.07 per gallon versus
$0.17 per gallon). RCPSD selected the most cost effective alternative and currently land applies
residual sludge in accordance with their NPDES permit and MDNR-approved biosolids
management plan. The 208 Plan should be amended to state that RCPSD will continue the
current activities.
4.3. Summary of Proposed Amendments
This report provides support for amending the 208 Plan to bring it into alignment with the current
situation in the Lower Meramec Basin. The analyses support the following amendments:
It is more cost-effective to maintain existing facilities ($182 million) within the Lower
Meramec System than to construct a single regional WWTF ($476 million). Further, a
single regional WWTF is not necessary to meet state water quality standards in the
Lower Meramec River. Therefore, the Lower Meramec System should instead be served
by four WWTFs: Lower Meramec WWTF, Grand Glaize WWTF, Saline Creek Regional
WWTF, and Kimmswick WWTF.
Due to environmental and management considerations, it is not feasible for the Lower
Meramec WWTF to serve as a regional sludge processing center. The plan should be
revised to recognize that sludge processing for MSD facilities in the Lower Meramec
System will be addressed at the Bissell Point WWTF or Lemay WWTF; the Northeast
Public Sewer District and Rock Creek Public Sewer District will continue their current
management activities.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
A - 1
ATTACHMENT A
Process and Proposed Schedule for Amending the 208 Plan
State regulations do not currently specify a process or requirements for amending existing 208
plans. According to federal regulations (40 CFR 130.6(f)), updated water quality management
plan sections must be consistent with all other parts of the plan. The updates must also be
certified by the Governor (or Governor’s designee before being sent to EPA for approval.
In the fall of 2015, the EWGCOG met with MDNR, EPA Region 7, and NPSD to identify a
process for amending the plan in accordance with the federal regulations. From these
discussions, EWGCOG prepared a detailed Process to Amend 208 Water Quality Management
Plan. In general, the process stipulates that the requesting agencies (MSD, NPSD, RCPSD) will
prepare a documentation report (this document) and amendment request and, with EWGCOG’s
support, submit it to the Missouri Clean Water Commission (CWC) for their approval following a
public notice period. The CWC shall consider recommendations on the proposal from MDNR
and hold a public hearing before submitting final recommendations to the Governor or
appropriate designee. The detailed process identified by the EWGCOG is outlined below. The
proposed schedule for amending the 208 Plan recommendations, through the vote by the CWC
to take action on the plan, is included in Figure A-1.
EWGCOG Process for Amending 2018 Plan Recommendations
1. Applicant(s) notify EWGCOG of their interest in an amendment to the 1978 208 Water
Quality Management Plan.
2. Applicant(s) communicate with interested parties including and MDNR and receives
feedback concerning proposed amendment.
3. Applicant(s) prepare documentation report supporting proposed amendment.
4. While Applicant(s) are preparing their documentation report, EWGCOG considers
request and can prepare a background report (if needed) with recommendation and
letter.
5. Applicant(s) sends draft documentation report to MDNR Engineering Section, Water
Pollution Control Branch of Water Protection Program for feedback.
Applicant(s) receives feedback and makes adjustments, if necessary.
6. Applicant(s) hold public meeting
Schedule meeting.
Post meeting announcement and request/documentation on Applicant(s) website.
Comment period should begin at time of announcement and end 7 days after public
meeting.
Publicize meeting announcement.
Public meeting held and feedback on proposed amendment is solicited.
Meeting documentation is assembled – announcement, where publicized, meeting sign-
in sheet and notes and comments received.
Proposed Amendment to the 1978 St. Louis,
Missouri Water Quality Management 208 Plan
A - 2
7. Applicant(s) prepare packet including: letter requesting amendment to plan;
documentation report; and public meeting information.
8. Applicant(s) send packet to EWGCOG and to Clean Water Commission.
9. EWGCOG sends letter of recommendation to Clean Water Commission. EWG’s
background report (if needed) will be attached.
MISSOURI CLEAN WATER COMMISSION ACTIONS
1. MDNR receives request letter and packet from Applicant(s).
2. MDNR receives EWG recommendation letter with background report (if needed).
3. MDNR/Clean Water Commission places request on Clean Water Commission meeting
schedule and identify public hearing/comment period.
4. Clean Water Commission meeting with request on Agenda, as information item.
5. Clean Water Commission holds public hearing about request from MSD.
6. Clean Water Commission meeting with request as action item on Agenda.
7. At this meeting, MDNR will make recommendation to Clean Water Commission on
request.
8. Clean Water Commission will take action on request to amend 208 Plan.
9. MDNR staff drafts document to record Commission’s recommendation and asks them to
sign.
10. MDNR staff prepares memo to Governor requesting action to amend 208 Plan and
attaches Commission’s recommendation.
GOVERNOR ACTIONS
1. Governor reviews recommendations from Clean Water Commission/MDNR and issues
208 Plan certification and sends to EPA Region 7 for review and approval.
EPA ACTIONS
1. EPA reviews certification and takes action.
2. EPA communicates with MDNR on their action.
3. MDNR informs MSD.
Proposed Amendment to the 1978 St. Louis, Missouri Water Quality Management 208 Plan A - 3 Figure A-1. Proposed Process and Schedule for Amending the 208 Plan.