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, 92nd Congress) as amended, 

Permit No. MO-0004847 

Owner: Thermal North America 

Address: 99 Summer Street, Suite 900, Boston, MA 02110 

Continuing Authority: Veolia Energy Kansas City, Inc. 

Address: 115 Grand Blvd., Kansas City, MO 64106 

Facility Name: Veolia Energy Kansas City, Inc. 

Facility Address: 115 Grand Blvd., Kansas City, MO 64106 

Legal Description: SW 1⁄4 Sec 32 T 50N R 33W Jackson County 

UTM Coordinates: X=363403, Y=4330696 

Receiving Stream: Missouri River (P) 

First Classified Stream and ID: Missouri River (P)(356) 

USGS Basin & Sub-watershed No.: 210300101-0301 

is authorized to discharge from the facility described herein, in accordance with the effluent limitations and monitoring requirements 

as set forth herein: 

FACILITY DESCRIPTION 

Outfall #001- Steam and Air Conditioning Supply – SIC #4961 and NAICS #221330 

Outfall #001 is non-contact cooling water. The water from the coolers flows into a series of discharge pipes that combine into an 84” 

diameter river water return pipe. This pipe travels underground back to the river where it is connected to a weir assembly. The purpose 

of the weir is to insure that the 84” discharge line stays full of water from the main plant to the weir to insure that there always a slight 

draw on the line. The water from the slag tanks is discharged to the plant sump pump system where it is pumped into the City of

Kansas City, Missouri’s combined sanitary sewer system. 

Design Flow is 153.67 MGD 

Average Flow: 7.60 MGD 

Maximum Flow: 82.00 MGD 

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. 

September 1, 2012 

Effective Date Sara Parker Pauley, Director, Department of Natural Resources 

 

June 30, 2014 

Expiration Date John Madras, Director, Water Protection Program
A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

PAGE NUMBER 2 of 4

PERMIT NUMBER MO-0004847

The permittee is authorized to discharge from 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 

EFFLUENT PARAMETER(S) 

UNITS 

FINAL EFFLUENT LIMITATIONS MONITORING REQUIREMENTS 

DAILY 

MAXIMUM 

WEEKLY 

AVERAGE 

MONTHLY 

AVERAGE 

MEASUREMENT SAMPLE 

FREQUENCY TYPE 

Outfall #001 

Flow (Effluent) 

Stream Flow (Note 1) 

Temperature (Stream) (Note 2) 

Temperature (Effluent) 

Δ Temperature (Note 3) 

Temperature Cap (Note 4) 

cfs 

cfs 

°F 

°F 

°F 

°F 

* 

* 

* 

* 

5°F 

90°F 

 

5°F 

90°F 

once/day 24-hr total 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

MONITORING REPORTS SHALL BE SUBMITTED MONTHLY; THE FIRST REPORT IS DUE OCTOBER 28, 2012. 

THERE SHALL BE NO DISCHARGE OF FLOATING SOLIDS OR VISIBLE FOAM IN OTHER THAN TRACE AMOUNTS. 

B. STANDARD CONDITIONS 

IN ADDITION TO SPECIFIED CONDITIONS STATED HEREIN, THIS PERMIT IS SUBJECT TO THE ATTACHED PART I 

STANDARD CONDITIONS DATED October 1, 1980 and August 15, 1994, AND HEREBY INCORPORATED AS THOUGH 

FULLY SET FORTH HEREIN. 

A. Effluent Limitations and Monitoring Requirements (continued) 

* - Monitoring requirement only. 

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow. 

Note 2: Temperature (Intake). It is recommended that if the Intake structure does not adequately provide a temperature of the 

receiving stream, then the facility should use the receiving stream’s ambient temperature. 

Note 3: ΔT = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts 

Where: 

Qs/4 = daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe = effluent’s flow in cfs. 

Ts = stream’s temperature (ambient/intake temperature). 

Te = effluent’s temperature. 

ΔT = amount in T °F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory mixing zone. 

Note 4: Tcap = [((Qs/4)Ts + QeTe)) / ((Qs/4) + Qe)] 

Where: 

Qs/4 = daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe = effluent’s flow in cfs. 

Ts = stream’s temperature (ambient/intake temperature). 

Te = effluent’s temperature. 

Tcap = temperature of the receiving stream at the end of the regulatory mixing zone. 
 Page 3 of 4 

 Permit No. MO-0004847 

C. 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 Clean 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. 

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. Permittee will cease discharge by connection to a facility with an area-wide management plan per 10 CSR 20-6.010(3)(B) 

within 90 days of notice of its availability. 

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 in 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. Report as no-discharge when a discharge does not occur during the report period. 

 6. 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. 

 

 
 Page 4 of 4 

 Permit No. MO-0004847 

C. SPECIAL CONDITIONS (cont). 

 7. It is a violation of the Missouri Clean Water Law to fail to pay fees associated with this permit (644.055 RSMo). 

 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. Cooling Water Intake. 

 This permit may be reopened and modified, or alternatively revoked and reissued to: incorporate new or modified 

 requirements applicable to existing cooling water intake structures under Section 316(b) of the Clean Water Act. In the event 

 that, it is necessary for this permit to be reopened and modified, or alternatively revoked and reissued, permittee shall comply 

 with any such new or modified requirements or standards applicable to existing cooling water intake structures under 316(b) 

 of the Clean Water Act. Until such time that the 316(b) Phase II is promulgated, the permittee is required to continue operate 

 intake structures as indicated in the approved 1980 and subsequent 2007 impingement studies. 

10. There shall be no discharge of polychlorinated biphenyl compounds. 

11. Any pesticides discharge from any point source shall comply with the requirements of Federal Insecticide, Fungicide and 

 Rodenticide Act, act as amended (7 U.S.C. 136 et.seq.) and the use of such pesticides shall be in a manner consistent with its 

 label. 

12. Except for any untreated overflow from facilities designed, constructed and operated to treat the volume of material storage 

 runoff and construction runoff which is associated with a 10-year, 24-hour rainfall event; discharges resulting from material 

 storage runoff and construction runoff shall comply with the following limitations: 

a) Total suspended solids shall not exceed 50 mg/L at any time. 

b) The pH shall not be less than 6.5 standard units nor greater than 9.0 standard units at any time. 

13. The discharge monitoring reports shall contain the results of all sampling, not just representative values. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 2

Missouri Department of Natural Resources 

FACT SHEET

FOR THE PURPOSE OF RENEWAL 

OF

MO-0004847 

VEOLIA ENERGY KANSAS CITY, INC.

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 Part 124.8(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 an Industrial Facility. 

Part I – Facility Information 

Facility Type: IND 

Facility SIC Code(s): 4961 

Facility Description: 

This permit, originally issued on February 16, 2007, was modified on May 18, 2011 to change the names of the facility, owner, and 

continuing authority. The facility name has changed from Trigen Kansas City Energy – Grand Avenue Station to Veolia Energy 

Kansas City, Inc. The owner’s name has changed from Trigen Kansas City District Energy Corp. to Thermal North America, and the 

continuing authority name has changed from Trigen Kansas City Energy Corp. to Veolia Energy Kansas City, Inc. No other portions

of this permit has been addressed or modified. 

The Veolia Energy Kansas City, Inc. supplies 185 psig steam into a downtown distribution system, which services Truman Medical 

Center, Cargill Soybean and Biodiesel plant and National Starch Corn plant with steam demands and the downtown areas’ customers

with building heating. The plant also supplies 33° F chilled water into a downtown distribution system, which services the area’s 

customers with building cooling. 

The facility’s Pump House is comprised of three sections. The first section was built in the early 1900s and is currently abandoned in 

place. To the east of the 1900 section is the 1929 addition. The 1929 section houses pumps No. 3, 4, 5 and 6. Pumps No. 3, 4 and 5 are 

high volume, low pressure pumps capable of pumping 2.7 million gallons/hour. Pump No. 6 is rated at 0.24 million gallons/hr. and is 

used when plant flow requirements are lower than pumps 3, 4, and 5’s pumping curves allow. Pumps No. 3, 4 and 5 have suction 

hoods and take their suction from the suction bays which are 43 feet deep as measured from the floor of the pump house. USGS places 

the floor of these suction bays at +2.33’ which is above the USGS Station Gage datum of elevation 706.4’ above sea level. 

To the east of the 1929 addition are the 1939 addition which houses pumps No. 1 and 2. No. 2 pump is a high volume, low pressure 

pump capable of moving 2.7 million gallons/hr. No. 1 Pump is capable of 1.47 million gallons/hour and is driven by a Variable 

Frequency Drive which allows us to vary the speed of the pump to vary the pumping volume and pressure. The suction bays for these 

pumps are 55’-2” deep. These bays have a 5-foot wooden bulkhead installed at the bottom of the bay. Both the 1929 and 1939 pump

house sections have movable screens installed in the river in front of the pump suction bays to keep debris from entering the pump 

suctions. These are slow moving, self-cleaning screens that utilize river water sprays to clean the screens into a trough where the 

debris is removed. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 3

The pumps move the river water to the Main Plant via two 54-inch diameter and one 48-inch diameter discharge pipes where the water 

is used for once through cooling in the Chiller Condensers, Chiller Turbine Oil Coolers, Bearing Cooling Water Heat Exchanger and 

the House Turbine Generator Oil Cooler. The water is also used to fill the boiler slag collection tanks which seal the bottom of the 

boilers from the atmosphere and provide cooling of the slag (molten bottom ash) that flows from the boilers. The water from the slag 

tanks is discharged to the plant sump pump system where it is pumped into the City of Kansas City, Missouri’s sanitary sewer system. 

The water from the coolers flows into a series of discharge pipes that combine into an 84” diameter river water return pipe. This pipe 

travels underground back to the river where it is connected to a weir assembly. The purpose of the weir is to insure that the 84” 

discharge line stays full of water from the main plant to the weir to insure that there always a slight draw on the line. The water that 

overflows the weir is discharged into the Missouri river downstream and to the east of the Pump House. Veolia Energy Kansas City, 

Inc.’s central region manager certified that the facility through its process is not adding pollutants to the cooling water prior to 

discharge. 

The Design Flow is 153.67 MGD. The receiving stream is the Missouri River. All storm water runoff, material storage runoff and

construction runoff flows to the Kansas City Combined Sewer System. Kansas City Water Services Department is the downstream 

landowner. The city of Kansas City does periodic water quality sampling and analysis of the storm water runoff, material storage 

runoff and construction runoff. The analysis consists of pH and Total Suspended Solids (TSS). 

Have any changes occurred at this facility or in the receiving water body that effects effluent limit derivation? 

 - Yes; (please provide simple description or reference appropriate location in the Fact Sheet. 

 - No. 

Application Date: 07/14/11 

Expiration Date: 02/15/12 

Last Inspection: 03/02/11 In Compliance ; Non-Compliance 

OUTFALL(S) TABLE: OUTFALL #001 

OUTFALL DESIGN FLOW (CFS) TREATMENT LEVEL EFFLUENT TYPE

DISTANCE TO

CLASSIFIED SEGMENT (MI) 

001 238.2 BMP Non-contact cooling water 0.0 

Outfall #001- Steam and Air Conditional Supply – SIC #4961 and NAICS #221330 

Non-contact cooling water 

UTM Coordinates: X=363403, Y=4330696 

Design Flow is 153.67 MGD 

Average Flow: 7.60 MGD 

Maximum Flow: 82.00 MGD 

Receiving Stream: Missouri River (P) 

First Classified Stream and ID: Missouri River (P) (356) 

USGS Basin & Sub-watershed No.: 10300101-0301 

Receiving Water Body’s Water Quality & Facility Performance History: 

Missouri River (P) (356) is listed on the 2010 Missouri 303(d) List for bacteria. This facility is not a source of the listed impairment. 

Comments: 

Temperature monitoring of intake and effluent (Outfall #001) non-contact cooling water is proposed with limitations being those

specified in Missouri Water Quality Standards Criteria [10 CSR 20-7.031(4)(D)1.] Upon examination of Veolia Energy Kansas City,

Inc. five-year discharge monitoring reports (DMR), the facility shows in compliance with ΔT. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 4

Part II – Operator Certification Requirements 

 Not Applicable; 

This facility is not required to have a certified operator. 

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 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)]: 

 

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 1st 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 STREAM(S) TABLE: 

WATERBODY NAME CLASS WBID DESIGNATED USES* 12-DIGIT HUC 

Missouri River (P) 356 IRR, LWW, AQL, SCR, DWS, IND, WBC-B 10300101-0301 

* - Irrigation (IRR), Livestock & Wildlife Watering (LWW), 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). 

RECEIVING STREAM(S) LOW-FLOW VALUES: 

The flows and level of the Missouri River are controlled by the US Army Corps of Engineers and are subject to human interference. 

The critical low flow values for the Missouri River were calculated by the U.S. EPA, at a 30Q10 of 28,823 cfs in the summer and

17,248 cfs in the winter (applicable to Ammonia); a 7Q10 of 11,674 cfs (applicable to all other parameters). US EPA conducted their 

study on February 13-14, 2008.

MIXING CONSIDERATIONS THERMAL: 

Missouri’s Water Quality Standards [10 CSR 20-7.031(4)(A)1.], specifically state that mixing considerations for toxics do not apply to 

thermal mixing considerations and that thermal mixing considerations are located in [10 CSR 20-7.031(4)(D)6.], which states thermal 

mixing considerations are limited to 25% of the cross-sectional area or volume of a river, unless a biological survey performed in 

response to 316(a) of the Clean Water Act indicate no significant adverse effect on aquatic life. For the purpose of mixing 

considerations, the Department typically uses the 25% of the daily flow vs cross-sectional area. For a more detailed determination 

and discussion of thermal mixing, please see Appendix A: Temperature Limit Guidance. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 5

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; 

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(d)(4); 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. 

ANTIDEGRADATION:

In accordance with Missouri’s Water Quality Standard [10 CSR 20-7.031(2)], the Department is to document by means of 

Antidegradation 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. 

AREA-WIDE WASTE TREATMENT MANAGEMENT & CONTINUING AUTHORITY:

As per [10 CSR 20-6.010(3)(B)], ...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. 

BIOSOLIDS & SEWAGE SLUDGE: 

Biosolids 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 biosolids and sludge is located at the following web address: 

http://dnr.mo.gov/env/wpp/pub/index.html, items WQ422 through WQ449. 

 Not applicable; 

This condition is not applicable to the permittee for this facility. 

COMPLIANCE AND ENFORCEMENT: 

Enforcement is the action taken by the Water Protection Program (WPP) 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 WPP is to resolve violations and return the entity to compliance. 

 Not Applicable; 

The permittee/facility is not currently under Water Protection Program enforcement action. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 6

COAL COMBUSTION RESIDUALS (CCR): 

Coal Combustion Residuals (CCR), often referred to as coal ash, and is currently considered exempt wastes under an amendment to

RCRA, the Resource Conservation and Recovery Act. Coal ash is residues from the combustion of coal in power plants and captured 

by pollution control technologies, like scrubbers. Potential environmental concerns from coal ash pertain to pollution from 

impoundment and landfills leaching into ground water and structural failures of impoundments. 

The US EPA is currently proposing the first-ever national rules to ensure the safe disposal and management of coal ash from coalfired power plants under the nation’s primary law for regulating solid waste, the RCRA. The EPA is putting forward two (2) 

proposals that reflect different approaches to managing the disposal of coal ash and both are to ensure the safe management of coal ash 

that is disposed in surface impoundments and/or landfills. 

Both options will provide for the first time on a national basis that liners and ground water monitoring are in place at new landfills 

handling coal ash and impoundments in order to prevent leaching of contaminants to groundwater and resulting risks to human health. 

Under the Subtitle C proposal, EPA is adopting measures intended to phase out the wet handling of CCRs and existing surface 

impoundments; under the Subtitle D proposal, existing impoundments would require liners, which will create strong incentives to

close these impoundments and transition to safer landfills which store coal ash in dry form. Both proposals will ensure stronger 

oversight of the structural integrity of impoundments. Additionally, both options will require liners and groundwater monitoring, and 

corrective action if there is any contamination detected. For the Subtitle D Option, the corrective action requirements are not as 

extensive. 

Veolia Energy Kansas City, Inc. has electrostatic precipitator (ESP). The fly ash and bottom ash (coal combustion residual) is 

removed from our facility by Underground Services Company (UI-0000010). USC uses the ash for structural stabilization of 

underground limestone mines. 

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 

 Not Applicable; 

The permittee, at this time, is not required to have a Pretreatment Program or does not have an approved pretreatment 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. 

 Not Applicable; 

A RPA was not conducted for this facility.

CHLORINATION OF OUTFALL #001 

Chlorination (Free Available and/or Total Recoverable) as established in 40 CFR 423.12 and 423.13 is not applicable to this facility 

for once through cooling water due to the fact that this facility does not chlorinate. Additionally, WET testing as a schedule condition 

will not be applied to this facility due to the fact that they do not use pesticides for organisms (e.g., zebra mussels) that obstruct their 

intake structure. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 7

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 (BOD5) and Total Suspended Solids (TSS) for Publicly Owned 

Treatment Works (POTWs)/municipals. 

 Not Applicable; 

Influent monitoring is not being required to determine percent removal. 

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. 

 - Not applicable. This facility is not required to develop or implement a program for maintenance and repair of the collection 

system; however, it is a violation of Missouri State Environmental Laws and Regulations to allow untreated wastewater to discharge 

to waters of the state. 

SCHEDULE OF COMPLIANCE (SOC): 

A schedule of remedial measures included in a permit, including an enforceable sequence of interim requirements (actions, operations, 

or milestone events) leading to compliance with the Missouri Clean Water Law, its implementing regulations, and/or the terms and 

conditions of an operating permit. 

 Not Applicable; 

This permit does not contain a SOC. 

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. 

 Not Applicable; 

At this time, the permittee is not required to develop and implement a SWPPP. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 8

TEMPERATURE LIMITS CONSIDERATIONS: 

The temperature limits contained in this operating permit are based on Missouri’s Temperature Guidance (see Appendix A). 

Missouri’s Water Quality Standards establish Temperature Criteria that provide several forms of protection from the impacts of heat 

energy on receiving water bodies. The purpose of the Temperature Limit Guidance is to provide an approach to help both permit 

writers and the public understand Temperature Criteria and how they are applied in Missouri State Operating Permits. 

This approach assumes that the receiving water consumes 100% of the heat energy being discharged. At any time the permittee has 

reason to believe that their facility discharge may exceed their permit temperature limits or if the permittee does exceed their permit 

limit, the permittee may determine it necessary to take action that may include, but not limited to, seeking a 316(a) Variance, a Mixing 

Zone Study, or conduct a “Heat Model”. 

If action is taken by the permittee that warrants a modification to this operating permit, then the permittee will need to submit an 

application for a permit modification. Submitting an application for permit modification does not guarantee approval of said action 

and does not directly indicate that the result of said action will be implemented into an operating permit. A Quality Assurance Project 

Plan (QAPP) must be submitted for any alternative compliance approach. 

VARIANCE: 

As per the Missouri Clean Water Law § 644.061.4, variances shall be granted for such period of time and under such terms and 

conditions as shall be specified by the commission in its order. The variance may be extended by affirmative action of the 

commission. In no event shall the variance be granted for a period of time greater than is reasonably necessary for complying with the 

Missouri Clean Water Law §§644.006 to 644.141 or any standard, rule or regulation promulgated pursuant to Missouri Clean Water 

Law §§644.006 to 644.141.

 Not Applicable; 

This operating permit is not drafted under premises of a petition for variance. 

WASTELOAD ALLOCATIONS (WLA) FOR LIMITS: 

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. 

 Not Applicable;

Wasteload allocations were not calculated.

WLA MODELING: 

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. 

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 life by itself, in 

combination with or through synergistic responses when mixed with receiving stream water. 

 Not Applicable; 

At this time, the permittee is not required to conduct WET test for this facility. However, if the facility is required to apply biocides to 

the intake structure, the permit will need to be modified and a WET test will be required. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 9

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 headworks. 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(m)(1)(i)]. 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(m)(4)(i)(A), (B), & (C). Any bypasses from this facility are subject to the reporting required in 40 CFR 122.41(l)(6) and per 

Missouri’s Standard Conditions I, Section B, part 2.b. Additionally, Anticipated Bypasses include bypasses from peak flow basins or 

similar devices designed for peak wet weather flows.

 - Not Applicable; 

This facility does not bypass. 

303(d) LIST & 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; 

MISSOURI RIVER (P)(356) is listed on the 2010 Missouri 303(d) List for Bacteria. This facility is not noted as a contributor to the 

impairment. 

316(a) THERMAL VARIANCE

Section 316(a) of the Clean Water Act (CWA) applies to point sources with thermal discharges. It authorizes the NPDES permitting 

authority to impose alternative effluent limitations for the control of the thermal component of a discharge in lieu of the effluent limits 

that would otherwise be required under section 301 or 306 of the CWA. 

Regulations implementing section 316(a) are codified at 40 CFR Part 125, subpart H. These regulations identify the criteria and 

process for determining whether an alternative effluent limitation (i.e., thermal variance from the otherwise applicable effluent limit) 

may be included in a permit and, if so, what that limit should be. This means that before a thermal variance can be granted, 40 CFR 

Parts 125.72 and 125.73 require the permittee to demonstrate that the protection and propagation of the water body’s balanced, 

indigenous population (BIP) of shellfish, fish, and wildlife is being attained. 

The burden of proof is on the permittee to demonstrate that it is eligible to receive an alternative thermal effluent limit under section 

316(a). This means the permittee must demonstrate to the Missouri Department of Natural Resources that a thermal effluent limit 

necessary to meet the requirements of sections 301 or 306, specifically 10 CSR 20-7.031(4)(D)1 and 10 CSR 20-7.031(4)(D)5, is 

more stringent than necessary to assure the protection and propagation of a BIP in and on the body of water into which the discharge is 

made. 

 - No Demonstration of 316(a) Variance 

At this time, the permittee is not operating under a 316(a) Variance and has not requested a 316(a) Variance. If during the cycle of 

this operating permit the permittee determines that a 316(a) Variance is needed, the permit will contain language indicating that the 

permit can be reopened and modified, or alternatively revoked and reissued to: incorporate new or modified requirements applicable 

to implementing a Department approved 316(a) Variance. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 10

316(b) COOLING WATER INTAKE STRUCTURE 

Section 316(b) of the Clean Water Act (CWA) applies to new or existing facilities operating a cooling water intake structure (CWIS). 

Section 316(b) requires that location, design, construction, and capacity of CWISs reflect the best technology available (BTA) for 

minimizing adverse environmental impacts (AEI). Under current regulations, existing facilities are subject to section 316(b) 

conditions that reflect BTA for minimizing AEI on a case-by-case, best professional judgment (BPJ) basis. 

The Environmental Protection Agency’s (EPA) Phase II Section 316(b) Existing Facilities Rule was remanded to the EPA in 

Riverkeeper, Inc, et al. v EPA 475 F.3d 83 (2d Cir. 2007). The Federal Water Pollution Control Act Amendments of 1972 require 

cooling water intake structures to reflect the best available technology for minimizing adverse environmental impact. Best technology 

available must consider intake design, location, construction, and capacity. 

Part V – Effluent Limits Determination 

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 LIMITATIONS TABLE: OUTFALL #001 

PARAMETER UNIT

BASIS FOR 

LIMITS

DAILY 

MAXIMUM

WEEKLY 

AVERAGE

MONTHLY 

AVERAGE

MODIFIED

PREVIOUS PERMIT 

LIMITATIONS

OUTFALL #001 

FLOW (EFFLUENT) CFS 1 * NO * 

STREAM FLOW (NOTE 1) CFS 1 * YES ** 

TEMPERATURE (STREAM) (NOTE 2) °F 1,3 * NO * 

TEMPERATURE (EFFLUENT) °F 1,3 * NO * 

ΔT (NOTE 3) °F 1,3 5°F 5°F YES ** 

TCAP (NOTE 4) °F 1,3 90°F 90°F YES ** 

 * - Monitoring requirement only. 

 ** - Parameter not previously established in previous state operating permit. 

 Basis for Limitations Codes: 

1. State or Federal Regulation/Law 7. Antidegradation Policy 

2. Water Quality Standard (includes RPA) 8. Water Quality Model 

3. Water Quality Based Effluent Limits 9. Best Professional Judgment 

4. Lagoon Policy 10. TMDL or Permit in lieu of TMDL 

5. Ammonia Policy 11. WET Test Policy 

6. Antidegradation Review 

OUTFALL #001 – DERIVATION AND DISCUSSION OF LIMITS: 

 Flow (Effluent). 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.

 Flow (Stream). Daily monitoring only requirement in cfs. It is the Department’s expectations that the permittee will obtain 

stream flow data from appropriate and applicable upstream USGS or COE (or both) Gauging Stations. If there is a significant 

distance from the facility to the nearest gauging station, it may be in the best interest of the permittee to fund a new gauging 

station; however, it is not required. Additionally, the Department will only use gauging station data as a viable source of stream 

flow. Meaning that flows (design or actual) from other point sources will not be considered (i.e., added to the flow 

determination).

 Temperature (Effluent). Daily monitoring only requirement in °F. Temperature (Effluent) is the measured temperature of the 

discharge and is not the measured difference between the intake temperature and the discharge temperature.
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 11

 Temperature (Stream). Daily monitoring only requirement in °F. For most facilities, the intake temperature can be used to 

determine stream’s temperature. However, in some cases, the ambient stream temperature can be used. The permittee will need 

to inform the Department that they may use the actual stream’s temperature.

 Temperature Cap (Tcap). In accordance with 10 CSR 20-7.031(4)(D)5., this facility shall not exceed the monthly temperature 

criteria established of 90°F. Tcap is calculated as follows: 

Tcap = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] 

Where, 

Qs/4 = the receiving stream flow in cfs divided by 4 or the flow represented in the cross-sectional area of the receiving stream divided 

by 4 in accordance with [10 CSR 20-7.031(4)(D)6.] 

Qe= Effluent Flow. 

Ts = Receiving stream’s ambient temperature. A facility’s intake temperature can be used for this parameter if the facility believes 

that it is representative of the receiving stream’s actual temperature. 

Te = Temperature of the Effluent. 

For additional description, please see Appendix B – Temperature Limit Guidance. 

 Delta Temperature (ΔT). The permittee shall not cause the temperature of the receiving stream to change by +/- 5°F, in 

accordance with [10 CSR 20-7.031(4)(D)1.]. ΔT is calculated as follows:

ΔT = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts 

Where, 

Qs/4 = the receiving stream flow in cfs divided by 4 or the flow represented in the cross-sectional area of the receiving stream divided 

by 4 in accordance with [10 CSR 20-7.031(4)(D)6.] 

Qe= Effluent Flow. 

Ts = Receiving stream’s ambient temperature. A facility’s intake temperature can be used for this parameter if the facility 

 believes that it is representative of the receiving stream’s actual temperature. 

Te = Temperature of the Effluent. 

For additional description, please see Appendix A – Temperature Limit Guidance.

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. 

 Not Applicable; 

The Department is not required to determine findings of affordability because the facility is not a combined or separate sanitary 

sewer system for a publically-owned treatment works. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 12

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 Missouri 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 Missouri Department of Natural Resources is transitioning from the traditional methods with which Missouri’s water resources 

have been managed to a Watershed Based Management (WBM) approach. The WBM approach will manage watersheds on the eightdigit Hydrological Unit Code (HUC8) scale. As permitting and permit synchronization is a key aspect of successful implementation of 

a Watershed Management Plan (WMP), the same HUC8 groups that will move through the WBM cycle will have their permit 

expirations and issuances synchronized in the same fiscal year. The typical five-year term of the permit issuances aligns with the 

proposed five-year WBM cycle and the two processes will be intimately tied together. 

The immediate goals of the permit synchronization include the following: 

 The administrative and technical streamlining of Water Protection Program and Regional Office activities such as permitting, 

inspections, and water quality monitoring. 

 Providing the basis for future watershed permitting. 

 Beginning to further examine Missouri’s water resources on a watershed basis. 

This permit will expire on June 30, 2014 in order to meet the permit synchronization goals. 

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 

permittee 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 is tentatively scheduled to begin in June 2012. 

DATE OF FACT SHEET: 11 MAY 2012 

COMPLETED BY: 

JOY JOHNSON, ENVIRONMENTAL SPECIALIST III 

NPDES PERMITS UNIT

WATER PROTECTION PROGRAM 

(573) 751-6982 

joy.johnson@dnr.mo.gov
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 13

APPENDIX A: TEMPERATURE LIMIT GUIDANCE

Temperature Limits Derivation: 

General & Limited Warm-Water 

Fisheries Stream Method 

Introduction 

Missouri’s Water Quality Standards (WQS) establish Temperature Criteria that provide several forms of protection from 

the impacts of heat energy on receiving water bodies. The purpose of this derivation document is to provide a simplistic 

approach to help both permit writers and the public understand the Missouri WQS’s Temperature Criteria and how they 

are applied in Missouri State Operating Permits. 

Missouri’s WQS Temperature Criteria [10 CSR 20-7.031(4)(D)] establish two (2) main areas of compliance for general 

and limited warm-water fisheries. The first compliance requirement deals with the rise of temperature in a receiving water 

body (stream), and the second compliance requirement deals with the overall stream’s temperature not to exceed. Both 

compliance requirements are to be established at the end of the regulatory mixing zone (if applicable – depending on 

stream classification). These two (2) compliance requirements are located in Missouri WQS [10 CSR 20-7.031(4)(D)1. & 

5.]. 

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)1.] contains both compliance requirements for all streams. 

However, the overall stream’s temperature not to exceed in this specific regulation does not cover the Mississippi River. 

Missouri WQS Temperature Criteria for the Mississippi River is established in [10 CSR 20-7.031(4)(D)5.], which also 

establishes a Percent Deviation Allowance to the Mississippi River and a maximum temperature not to exceed. 

In addition to establishing temperature limits in an operating permit, Missouri’s WQS Temperature Criteria also establish 

Mixing Zone regulations contain in [10 CSR 20-7.031(4)(D)6.]. In comparison to Missouri’s WQS Toxic Mixing 

Considerations that use low-flow considerations (i.e, 1Q10, 7Q10, & 30Q10), the Missouri WQS Temperature regulations 

require the Missouri Department of Natural Resources (Department) to establish a Thermal Mixing Zone limited to either 

25% of the cross-sectional area or 25% volume of a river. 

This approach assumes that the receiving water consumes 100% of the heat energy being discharged. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 14

TABLE OF CONTENTS: 

A. Compliance with ΔT°F-------------------------------------------------------------------------------------------------------------------PAGE 3 

B. Compliance with 90°F Temperature Criteria-------------------------------------------------------------------------------------PAGE 4 

C. Compliance with Mississippi River Monthly Temperature Criteria-------------------------------------------------------Page 5 

D. Establishing in an Operating Permit for a 90°F Facility----------------------------------------------------------------------Page 8 

E. Establishing in an Operating Permit for a Mississippi River Facility----------------------------------------------------Page 9 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 15

A. COMPLIANCE DETERMINATION WITH ΔT°F 

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)1.] establishes that point sources discharging to streams in 

Missouri shall not raise or lower the temperature of the receiving stream by 5°F. Because this is a WQS, this criteria can 

be applied at the end of the regulatory Mixing Zone. In the determination of compliance with the temperature criteria of 

ΔT, several factors/conditions need to be obtained (i.e., intake temperature, stream flow, effluent flow, & effluent 

temperature). Without placing requirements in an operating permit for these additional parameters, the Department would 

not be able to determine if compliance with ΔT is being met. 

The following calculation determines compliance with the +/- 5°F. 

ΔT = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

ΔT: is the amount in T°F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory 

mixing zone. 

If the ΔT is greater than 5°F, then the facility is in non-compliance. 

The term Qs will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the Department’s 

expectation that the permittee will obtained the Qs data from appropriate and applicable the nearest upstream USGS or 

Corp. or Engineers (or both) Gauging Stations. 

If there is a significant distance from the facility to the nearest upstream gauging station, it may be in the best interest of

the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use 

gauging station data as a viable source of receiving stream flow. Meaning that flows (design or actual) from other point 

sources may not be considered (i.e., added) to the flow determination. 

If there is a near-by gauging station downstream of the facility, then the permittee can use this data but must subtract their 

daily effluent discharge from the receiving stream flow. 

The term Qe will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that 

effluent flow be used; however, Intake flow can be used for this determination. 

The term Ts will be established in the operating permit as Temperature (Stream) and reported in the unit °F. For most 

facilities, the intake temperature can be used to determine Ts. However, in some cases, ambient stream temperature can 

be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. 

Remember, that we are discussing compliance with the receiving stream’s temperature and not their intake structure’s 

water temperature. 

The term Te will be established in the operating permit as Temperature (Effluent) and reported in the unit °F. This is not a 

measurement of the change in temperature from the intake to the effluent, but as it sounds – the temperature of the 

effluent. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 16

B. COMPLIANCE DETERMINATION WITH 90°F (TEMPERATURE CAP):

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)1.] also establishes that point sources discharging to streams 

(other than the Mississippi River) shall not cause or contribute to the receiving stream in excess of 90°F. In order to 

determine compliance with the Tcap, the same equation used for ΔT compliance, with some modification, is used. 

The following equation determines compliance with Temperature Cap Criteria of 90°F. 

Tcap = [((Qs/4)Ts + QeTe)) / ((Qs/4) + Qe)] 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

Tcap: is the temperature of the receiving stream at the end of the regulatory mixing zone. 

If the Tcap is greater than 90°F, then the facility is in non-compliance. 

The term Qs will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the expectation of the 

Department that the permittee will obtained the Qs data from appropriate and applicable the nearest upstream USGS or 

Corp. or Engineers (or both) Gauging Stations. 

If there is a significant distance from the facility to the nearest upstream gauging station, it may be in the best interest of

the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use 

gauging station data as a viable source of receiving stream flow. Meaning that flows (design or actual) from other point 

sources may not be considered (i.e., added) to the flow determination. 

If there is a near-by gauging station downstream of the facility, then the permittee can use this data but must subtract their 

daily effluent discharge from the receiving stream flow. 

The term Qe will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that 

effluent flow be used; however, Intake flow can be used for this determination. 

The term Ts will be established in the operating permit as Temperature (Stream) and reported in the unit °F. For most 

facilities, the intake temperature can be used to determine Ts. However, in some cases, ambient stream temperature can 

be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. 

Remember, that we are discussing compliance with the receiving stream’s temperature and not their intake structure. 

The term Te will be established in the operating permit as Temperature (Effluent) and reported in the unit °F. This is not a 

measurement of the change in temperature from the intake to the effluent, but as it is – the temperature of the effluent. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 17

C. COMPLIANCE DETERMINATION WITH MISSISSIPPI RIVER TEMPERATURE CAP CRITERIA:

Missouri WQS Temperature Criteria [10 CSR 20-7.031(4)(D)5.] establishes that point sources discharging to the 

Mississippi River shall not cause or contribute to the receiving stream in excess of a Monthly Temperature Criteria. The 

methodology for the determination of compliance is similar to the Tcap for 90°F established above. However, the 

fundamental difference is the Monthly Temperature not to be exceeded. Thus, the criteria is established per calendar 

month and per Mississippi River Zone, as follows: 

Month A & B C 

°F °C °F °C 

January 45 7 2/9 50 10 

February 45 7 2/9 50 10 

March 57 13 8/9 60 15 5/9 

April 68 20 70 21 1/9 

May 78 25 5/9 80 26 6/9 

June 86 30 87 30 5/9 

July 88 31 1/9 89 31 6/9 

August 88 31 1/9 89 31 6/9 

September 86 30 87 30 5/9 

October 75 23 8/9 78 25 5/9 

November 65 18 3/9 70 21 1/9 

December 52 11 1/9 57 13 8/9 

Zone A = Zone 1A: Des Moines River to Lock and Dam No. 25. 

Zone B = Zone 1B: Lock and Dam No. 25 to Lock and Dam No. 26. 

Zone C = Zone 2: Lock and Dam No. 26 to the Missouri-Arkansas state line. 

In addition to the Monthly Tcap, [10 CSR 20-7.031(4)(D)5.] establishes a Percent Deviation Allowance. The Percent 

Deviation Allowance provides a specific amount of time (in hours) that a facility can be out-of-compliance with their 

Monthly Tcap. Finally, [10 CSR 20-7.031(4)(D)5.] establishes a Maximum Tcap (Tmax) that is never to be exceeded. The 

Tmax = Tcap + 3°F. Meaning that if a facility located in Zone C is discharging their cooling water during the month of 

January, their Tcap would be 50°F and their Tmax would be 53°F as long as they had time available for deviation from their 

Tcap. 

The following equation determines compliance with Monthly Tcap.

Tcap = [((Qs/4)Ts + QeTe)) / ((Qs/4) + Qe)] 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

Tmax: is the temperature of the receiving stream at the end of the regulatory mixing zone. 

If the Tcap is greater than the Monthly Temperature Criteria, then the facility may or may not be in non-compliance with 

Missouri’s Water Quality Standards, Temperature Criteria due to Percent Deviation Allowance. Please see below: 

If the Tcap is greater than the monthly limit but is below the Tmax; and there is time available in their applicable Percent 

Deviation Allowance, then the permittee is in compliance. 

If the Tcap is greater than the monthly limit but is below the Tmax; but there is NO time available in their applicable Percent 

Deviation Allowance, then the permittee is in non-compliance. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 18

C. COMPLIANCE DETERMINATION WITH MISSISSIPPI RIVER TEMPERATURE CAP CRITERIA (CONTINUED):

If the Tcap is greater than the monthly limit and above the Tmax; then the facility is in non-compliance. 

The following equation determines compliance with Monthly Tmax.

Tmax = [((Qs/4)Ts + QeTe)) / ((Qs/4) + Qe)] 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

Tmax: is the temperature of the receiving stream at the end of the regulatory mixing zone. 

If the Tmax is greater than the Monthly Temperature Criteria, then the facility is in non-compliance and the “clock is ticking” 

with regards to Percent Deviation Allowance time. 

The term Qs will be established in operating permits as Ambient Stream Flow in the unit of cfs. It is the expectation of the 

Department that the permittee will obtained the Qs data from appropriate and applicable the nearest upstream USGS or 

Corp. or Engineers (or both) Gauging Stations. 

If there is a significant distance from the facility to the nearest upstream gauging station, it may be in the best interest of

the permittee to fund a new gauging station; however, it is not required. Additionally, the Department will only use 

gauging station data as a viable source of receiving stream flow. Meaning that assumptions (e.g., other point sources) will 

not be considered as an added flow determination. 

If there is a near-by gauging station downstream of the facility, then the permittee can use this data but must subtract their 

daily effluent discharge from the receiving stream flow. 

The term Qe will be established in the operating permit as Flow and reported in the unit cfs. It is recommended that 

effluent flow be used; however, Intake flow can be used for this determination. 

The term Ts will be established in the operating permit as Temperature (Stream) and reported in the unit °F. For most 

facilities, the intake temperature can be used to determine Ts. However, in some cases, ambient stream temperature can 

be used. The permittee only need inform the Department that they may or may not use ambient stream temperature. 

Remember, that we are discussing compliance with the receiving stream’s temperature and not their intake structure. 

The term Te will be established in the operating permit as Temperature (Effluent) and reported in the unit °F. This is not a 

measurement of the change in temperature from the intake to the effluent, but as it is – the temperature of the effluent. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 19

Percent Deviation Allowance 

The site-specific criteria for the Mississippi River allows the permittee to exceed their applicable criteria either 1% of the 

year for Zone 1A and 2; and 5% of the year for Zone 1B. It has been determined that this percent exceedances 

allowance should be tracked in hours for a calendar year. 

Zone 1A and 2 = 1% = [(365)(24)(0.01)] = 87.6 hours = 88 hours 

Zone 2A = 5% = [(365)(24)(0.05)] = 438 hours. 

Tracking of time used for Percent Deviation Allowance, can be captured and tracked via a permit Special Condition or 

actual effluent limit (if available in MoCWIS). If the permittee’s Tcap exceeds the Monthly Temperature Criteria but is below 

the Tmax and there is available time in the Percent Deviation Allowance, then the facility is in compliance. However, if the 

facility exceeds their Tcap and does not have any time remaining on their Percent Deviation Allowance, then the facility is 

in non-compliance. Finally, if a facility exceeds Tcap & Tmax, they are in non-compliance and the Percent Deviation 

Allowance “clock” is running during the time of the excursion. 

For every episode that the permittee uses their available time, the operating permit shall require that the permittee submit 

the time with their DMR that they exceeded their Tcap. This is very important to put this into the permit because it has 

implications for tracking and data entry in MoCWIS. 

The below is an example of Percent Deviation in an Operating Permit. This does not indicate that this is the only 

language to use, but the language should be very near and try to capture the same. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 20

D. ESTABLISHING IN AN OPERATING PERMIT FOR A 90°F FACILITY:

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

PAGE NUMBER 2 of 8

PERMIT NUMBER MO-xxxxxxx

The permittee is authorized to discharge from 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 

EFFLUENT PARAMETER(S) 

UNITS 

FINAL EFFLUENT LIMITATIONS MONITORING 

REQUIREMENTS 

DAILY 

MAXIMUM 

WEEKLY 

AVERAGE 

MONTHLY 

AVERAGE 

MEASUREMENT SAMPLE 

FREQUENCY TYPE 

Outfall #001 

Flow (Effluent) 

Stream Flow (Note 1) 

Temperature (Stream) (Note 2) 

Temperature (Effluent) 

ΔT (Note 3) 

Tcap (Note 4) 

cfs 

cfs 

°F 

°F 

°F 

°F 

* 

* 

* 

* 

5°F 

90°F 

 

5°F 

90°F 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

A. Effluent Limitations and Monitoring Requirements (continued) 

* - Monitoring requirement only. 

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow. 

Note 2: Temperature (Intake). It is recommended that if the Intake structure does not adequately provide a temperature of the 

receiving stream, then the facility should use the receiving stream’s ambient temperature. 

Note 3: ΔT = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

ΔT: is the amount in T°F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory mixing zone. 

Note 4: Tcap = [((Qs/4)Ts + QeTe)) / ((Qs/4) + Qe)] 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

Tcap: is the temperature of the receiving stream at the end of the regulatory mixing zone. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 21

E. ESTABLISHING IN AN OPERATING PERMIT FOR A MISSISSIPPI RIVER FACILITY:

A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS 

PAGE NUMBER 2 of 8

PERMIT NUMBER MO-xxxxxxx

The permittee is authorized to discharge from 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 

EFFLUENT PARAMETER(S) 

UNITS 

FINAL EFFLUENT LIMITATIONS MONITORING 

REQUIREMENTS 

DAILY 

MAXIMUM 

WEEKLY 

AVERAGE 

MONTHLY 

AVERAGE 

MEASUREMENT SAMPLE 

FREQUENCY TYPE 

Outfall #001 

Flow (Effluent) 

Flow (Stream) (Note 1) 

Temperature (Stream) (Note 2) 

Temperature (Effluent) 

ΔT (Note 3) 

Tcap (Note 4) (assumes zone c) 

January 

February 

March 

April 

May 

June 

July 

August 

September 

October 

November 

December 

Tmax (Note 4) (assumes zone c) 

January 

February 

March 

April 

May 

June 

July 

August 

September 

October 

November 

December 

cfs 

cfs 

°F 

°F 

°F 

°F 

°F 

* 

* 

* 

* 

5°F 

50 

50 

60 

70 

80 

87 

89 

89 

87 

78 

70 

57 

53 

53 

63 

73 

83 

90 

92 

92 

90 

81 

73 

60 

 

5°F 

50 

50 

60 

70 

80 

87 

89 

89 

87 

78 

70 

57 

53 

53 

63 

73 

83 

90 

92 

92 

90 

81 

73 

60 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 

once/day grab 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 22

A. Effluent Limitations and Monitoring Requirements (continued) 

* - Monitoring requirement only. 

Note 1: Stream flow. Stream flow is the daily flow of the receiving stream – intake flow. 

Note 2: Temperature (Stream). It is recommended that if the Intake structure does not adequately provide a temperature of the 

receiving stream, then the facility should use the receiving stream’s ambient temperature. 

Note 3: ΔT = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe)] - Ts 

Where: 

Qs/4: is the daily receiving stream’s mixing zone flow in cfs minus the Intake flow in cfs. 

Qe: is the effluent’s flow in cfs. 

Ts: is the stream’s temperature (ambient/intake temperature). 

Te: is the effluent’s temperature. 

ΔT: is the amount in T°F that the facility is causing the receiving stream’s temperature to rise at the end of the regulatory mixing zone. 

Note 4: Temperature Cap is the temperature of the receiving stream at the end of the regulatory mixing zone (if applicable). It is 

designated with [Tcap] in the equation below. 

Tcap = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe))] 

Where: 

Qs/4 = Daily receiving stream’s flow divided by 4 (Mixing Consideration) in cfs minus the Intake flow in cfs. 

Ts = Daily receiving stream’s temperature. This can be the actual ambient temperature of the receiving stream or the intake 

 water temperature (both in °F). 

Qe = Daily effluent flow or intake flow. 

Te = Daily effluent temperature in °F. 

(a) If the Tcap calculated temperature value is less than the specific month’s Daily Maximum or Monthly Average Tcap, the 

permittee is to report the calculated temperature value as Tcap and report a “No Discharge” for Tmax. 

(b) If the Tcap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average Tcap limit, but is 

below the Tmax and there is time available in Percent Deviation Allowance (see Note 6); then the permittee is to report in 

accordance with Note 5 below. 

(c) If the Tcap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average Tcap limit but is 

below the Tmax, but there is no time available in Percent Deviation Allowance (see Note 6); then the permittee is to report 

the calculated temperature value as Tcap and report a “No Discharge” for Tmax. 

(d) If the Tcap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average Tcap and Tmax; then 

the permittee is to report in accordance with Note 5. 

(a)

Note 5: Temperature Maximum is the maximum that a facility can increase the temperature of the receiving stream by at the end of 

the regulatory mixing zone (if applicable. It is designated with the [Tmax] in the equation below and is the Tcap monthly limit plus three 

(+3°F). 

Tmax = [((Qs/4)Ts + QeTe) / ((Qs/4) + Qe))] 

Where: 

Qs/4 = Daily receiving stream’s flow divided by 4 (Mixing Consideration) in cfs minus the Intake flow in cfs. 

Ts = Daily receiving stream’s temperature. This can be the actual ambient temperature of the receiving stream or the intake water 

temperature (both in °F). 

Qe = Daily effluent flow or intake flow. 

Te = Daily effluent temperature in °F. 

(a) If the Tcap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average Tcap limit, but is 

below the Tmax and there is time available in Percent Deviation Allowance (see Note 6); then the permittee is to report the 

calculated temperature value as Tmax and report a “No Discharge” for Tcap. 

(b) If the Tcap calculated result is greater than the specific month’s Daily Maximum and/or Monthly Average Tcap and Tmax; then 

the permittee is to report the calculated temperature value as Tmax and report a “No Discharge” for Tcap. 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 23

Note 6 – Missouri’s Water Quality Standards allows permittees to exceed their applicable criteria for 1% of the year in Zone 2A (or C) 

in the Mississippi River. Percent Deviation Allowance shall be tracked in hours per year (please see Special Condition 7 – Percent 

Deviation Allowance). 

7. Percent Deviation Allowance 

Site-specific temperature criteria for the thermal discharges to the Mississippi River allow the permittee to exceed their applicable 

temperature criteria for 1% of the year for Zone 1A and 2. This facility discharges to Zone 2 of the Mississippi River. Therefore, 

the permittee is authorized to exceed their Temperature Cap effluent limitation for 88 hours in one (1) calendar year. However, 

the permittee is not authorized to exceed their Temperature Max limitation at any time. 

(a) The permittee shall document the time in hours to the nearest minute that their calculated temperature values exceeded a 

specific month’s Daily Maximum Tcap effluent limit. This time is to be subtracted from 88 hours to the nearest minute. 

(b) The permittee shall submit an annual report on January 28th of each year that includes the number of hours that the facility 

exceeded their Temperature Cap effluent limits for each month during the previous calendar year. 

(c) If the permittee exceeds their maximum allowed Percent Deviation Allowance of 88 hours prior to the end of the calendar 

year, then the permittee shall submit a Maximum Percent Deviation Exceeded Report to the Southeast Regional Office 

within 15 days of notice. 

(d) Percent Deviation Allowance is not applicable to the permit parameter of Temperature Maximum. 

ATTACHMENT 1 VEOLIA ENERGY KANSAS CITY, INC MAP 
Veolia Energy Kansas City, MO 

MO-0004847 

Fact Sheet, Page 24

ATTACHMENT 2 

GRAND AVENUE STATION WATER BALANCE

MO‐0004847

   

INTAKE: 29,300,000 GPD                       

                        DISCHARGE TO OUTFALL 001

            29,296,000 GPD  

   

                 8,000 GPD                

              12,000 GPD                     12,000 GPD

          48,000 GPD                                                                                                        40,000 GPD

           691,000 GPD                                                                 48,000 GPD

         

        557,000 GPD STEAM DIST. & EVAP LOSSES

     643,000 GPD           86,000 GPD

   

     109,000 GPD                       109,000 GPD   

              

    14,000 GPD               14,000 GPD

MAY 2012

MISSOURI RIVER 41, 000 CFS MIN. DURING NAVIGATION SEASON 

CONDENSER 

COOLING, 

MISC. 

COOLING & 

HYDROVACTO

SLAG TANKS 

PUMP 

SEALS 

WATER 

SOFTENERS 

BOILERS 

1A, 6, 7 & 8

GENERAL 

SERVICES

SANITARY

KANSAS CITY 

SEWERS 

309,000 GPD

CITY WATER 

862,000 GPD