Navigating Enforcement and Funding
The City of Moscow Mills, with GBA’s support, undertook a critical wastewater compliance project to consolidate treatment operations, upgrade system components, and correct collection inefficiencies. Through targeted improvements and strategic funding, the project brought the city’s facilities into
regulatory compliance, enhancing operational efficiency and supporting future growth.
Background & Project Genesis
In the early 2000s, the City of Moscow Mills, Missouri, invested in significant infrastructure expansion, including roads, sewers and water systems, anticipating accelerated growth. However, due to the economic recession, the expected development failed to materialize, leaving portions of the infrastructure underutilized. This mismatch between infrastructure capacity and actual demand led to operational inefficiencies within the city’s two wastewater treatment plants, particularly at the newly constructed Crooked Creek Wastewater Treatment Facility. With insufficient inflow, the Crooked Creek Facility and the Northwest Wastewater Treatment Facility struggled to maintain treatment efficacy, resulting in persistent violations of Biochemical Oxygen Demand (BOD), Total Suspended Solids (TSS) and ammonia limits.
Initial Response & Legal Support
In 2011, both wastewater treatment plants faced inspections by the Environmental Protection Agency (EPA), and subsequent citations revealed multiple effluent violations. This led to a formal Notice of Potential Violation, which escalated to a Notice of Violation from the Missouri Department of Natural Resources (MDNR) by May 2012.
Recognizing the gravity of these compliance issues, the city hired an environmental attorney, which allowed Moscow Mills to better navigate the intricate legal landscape and avoid further penalties. This partnership became essential as the city worked toward a legally binding compliance plan with the EPA, requiring a series of corrective actions to bring its wastewater treatment systems into compliance.
Compliance Plan & Funding Acquisition
To meet compliance mandates, Moscow Mills entered an agreement of consent with the EPA, committing to a six-year plan to put the facilities into compliance with effluent limits. This compliance plan outlined a series of capital improvements, upgrades and regulatory measures designed to bring both the Crooked Creek and Northwest treatment plants up to standard.
Securing adequate funding became a priority, and in 2018, the city was awarded a State Revolving Fund (SRF) loan to support capital improvement expenses. Additionally, an Engineering Report Grant from MDNR, covering approximately 50% of study costs, was leveraged to fund a Sanitary Sewer Evaluation Study (SSES). The city’s proactive approach to funding helped minimize the financial impact on the community while addressing compliance needs.
Technical & Operational Improvements
The project’s primary objective was to restructure Moscow Mills’ wastewater treatment operations by optimizing the Crooked Creek facility and decommissioning the older Northwest treatment plant. This solution involved the following key improvements:
1. Wastewater Treatment Facility Reconfiguration
A comprehensive reconfiguration was implemented, whereby wastewater from the Northwest plant was redirected to the Crooked Creek facility. This required installing a new lift station and force main to transport sewage effectively, bringing Crooked Creek’s inflow closer to its optimal operational range. One cell of the Northwest lagoon was repurposed as an Extraneous Flow Holding Basin (EFHB).
2. System Upgrades and Repairs
Smaller, targeted improvements, such as upgrading blowers and adding a baffle curtain, were introduced to enhance process control. These adjustments helped align the capacity at Crooked Creek with current demand and improved treatment efficiency.
3. Collection System Enhancements
Improvements were also made to the collection system, including lining of the corroded City Hall lift station and manhole repairs. These improvements minimized extraneous flow, enhancing the system’s overall resilience.
Environmental & Administrative Compliance
The SRF rules require adherence to specific technical standards, such as the American Iron and Steel (AIS) provisions, which mandate that all iron and steel products used in the project be domestically produced and certified. This requirement applied to various components, including fittings, pipes and fencing, necessitating careful selection and verification of materials from AIS-certified manufacturers.
One key lesson learned was the importance of early coordination with MDNR. Regular consultations with MDNR allowed GBA and the city to align project approaches with regulatory expectations, thereby avoiding costly setbacks during project execution.
Challenges Faced
Despite meticulous planning, the project encountered challenges with the selected contractor. Due to competitive bidding requirements, Moscow Mills was obligated to accept the lowest bid, which ultimately led to unforeseen issues. The contractor lacked experience with SRF requirements and required extensive oversight to ensure regulatory standards were met, necessitating near full-time construction observation by GBA’s team. The city’s additional expenditure on construction observation effectively offset the savings from choosing the lowest bid, highlighting the critical importance of evaluating both cost and contractor qualifications in public works projects.
Moreover, unforeseen site conditions, such as undocumented septic tank effluent pump (STEP) systems, required real-time problem-solving. These STEP systems, found in existing easements, complicated the installation of new pipelines. GBA’s team worked closely with the contractor to locate and navigate around these assets, minimizing disruptions to residents.
Lessons Learned
The project highlighted critical lessons in contractor qualifications, interagency coordination and resource optimization. Ensuring all project personnel understood SRF rules and regulatory requirements proved essential. In hindsight, more rigorous reference checks could have been beneficial. Close coordination with MDNR early in the project was essential for securing direction and alignment, while proactive communication and thorough documentation enabled the city to receive a one-year extension despite setbacks.
Additionally, balancing EPA and MDNR’s differing expectations required strategic negotiation. The city also leveraged external resources, like the Missouri Rural Water Association’s free rate study service, helping to offset costs and support compliance efforts.
Final Outcomes and Impact
The project concluded with the successful integration of Moscow Mills’ wastewater treatment operations. Following more rigorous financial evaluation by MDNR, half of the SRF loan was converted to a grant, freeing up revenue that the city used on other needed sewer projects. By consolidating treatment at the Crooked Creek facility and addressing longstanding compliance issues, the city now benefits from a streamlined wastewater system with improved treatment performance and regulatory adherence. The upgrades have not only brought the facilities within acceptable effluent limits but also positioned Moscow Mills for future growth and development.
Rebecca Howley
Rebecca Howley has over 25 years of experience, all with GBA, developing solutions to meet client goals in evaluating and designing storm and sanitary sewer systems for small and large organizations. Her technical responsibilities include hydraulic modeling of gravity and pressure systems, designing sewers and lift stations, analyzing data and recommending cost-effective methods to improve collection system and treatment performance. Her approach to project management is to form a collaborative team of experts to perform efficiently and closely track performance, budget and schedule.