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Derby WPCA Letter To State

Derby WPCA Letter To State

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Derby WPCA Letter To State
Derby WPCA Letter To State

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Published by: ValleyIndyDotOrg on Jul 03, 2014
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09/06/2014

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City of Derby

Water Pollution Control Authority
I Ehzabeth Street Derby, CT 06418
203 736 147s
June25,2014
Mr. Dennis Greci, PE
Supervising Sanitary Engineer
Planning & Standards Division
Bureau of Water Protection and Reuse
RE: Derby Wastewater Facilities Plan
Dear Mr. Greci:
We received and read with great interest your correspondence dated May 72, 2014 refering to
the Derby/Ansonia Interconnection. As you might imagine, the closing statement of your letter
causes the City of Derby Water Pollution Control Authority (WPCA) a great deal of concern.
Your statement that, "At this point rve will not be approving your facility planning report since it
does not address the upcomrng 20 year planning period nor is it anticipated to receive any
funding from the CWF (Clean Water Fund) as presented."
The WPCA has been w'orking diligently on the various studies and preparation of this important
document since 2010. Prior to beginning work on the plan, your department reviewed and
approved the consultant's scope of work. When the plan was completed, your department
reviewed and made comments on the draft Wastewater Facilities Plan document on two different
occasions. These review documents are attached hereto for reference. In neither of those reviews
was any comment or concern raised about the plan's assessment of our facilities and how they
will be managed and upgraded throughout the 2}-year planning period.
As has been explained by our consultant, their assessment has taken into consideration the
condition of the existing facilities and processes, the anticipated changes to our City's
wastewater flows and loads, and their resulting recommendations include a series of staged
upgrades through the planning period that are planned maxrmize the remaining life of the
structures and equipment while utilizing a funding approach that can be managed over time. We
would observe that although it might be desirable to undertake a single facility-wide
comprehensive upgrade, such a project would not only likely exceed the City's borrowing
capacity, but also most certainly exceed our users' ability to repay the loans required. The ability
to pay is a major concem for both the City and the WPCA. As your letter describes your
confusion related to this "limited scope of the plant upgrades" being proposed, we hope that this
explanation offers sufficient explanation to aid in your understanding. The WPCA understands
and agrees with the staged upgrade approach that is recommended by the study.
Your statement that, "In twenty years there likely will
[be]
more stringent discharge limits and
more parameters that may be added requiring additional treatment system or equipment to meet
the future NPDES permit" leaves the WPCA wondering how to address such unknown and
speculative conditions. We might suggest that should DEEP be concerned with such issues, they
should indicate so during the review and approval of the engineering scopes of service. At this
Page 1 of3
Mr. Dennis Greci
Jwrc25,2014
point in time, it is difficult to address such an issue, and it should not be represented by your
department as an incomplete study item. In a similar fashion, your statement that, "The two
parameters on the horizon are tighter effluent limits for metals and control of pharmaceuticals
and personal care products. The intention is to do the complete modernization now to last for the
next twenty years." It seems to us that these types of issues should be addressed at the time that
they become regulated, not when they are simply a perceived "on the horizon" issue. The
recently upgraded Ansonia WPCF is not designed for the removal of metals and control of
phatmaceuticals and personal care products. The Ansonia WPCF will also need an additional
upgrade in the future if the State were to impose tighter effluent limits for these parameters even
though the Ansonia WPCF upgrades were only completed a few years ago at a substantial cost to
the residents of Ansonia.
We understand that Mr. Greci spoke recently with our engineering consultant, and that the reason
for DEEP's decision to forego formal "approval" of the Wastewater Facilities Plan centered
upon the overall project's low perceived cost and its failure to generate sufficient points to place
high enough on the Priority List. Your statement that the Plan will not be approved "since it does
not address the upcoming 20 year planning period" is completely incorrect, and as such, we take
exception to this remark. Further, earlier in y,our letter, you state that. "The reason for the low
rating is that the proposed project does not contain cefiain component upgrades that would
warrant a higher point score." Perhaps DEEP should recognize that only the necessary
component upgrades are included and recommended, and that other "certain component
upgrades" are neither needed nor waranted pursuant to our study.
As your letter to Mayor Dugatto makes specific reference to the "Derby/Ansonia
lnterconnection" w'hich is an important consideration of our Wastewater Facilities Plan, we
believe that it would be prudent to fuither consider additional efforts and information
development that might help to clarify the important issues related to the potential partnership.
As we have shown in our Plan, the interconnection is feasible, but its cost effectiveness relies
upon:
1. The removal of sufficient VI volumes from the Derby system,
2. Capacity upgrades to the Ansonia WPCF,
3. Formation of a Regional WPCA with both communities paying equally for a mutually
beneficial system, and
4. The ability of the City residents to pay the debt sen'ice.
Since DEEP has stated that further study must be completed to determine the cost impacts of
these issues, and since we have asked for, on multiple occasions, but never received the
requested information regarding the Ansonia WPCF, we suggest that DEEP fund these additional
investigations that are not included within our engineer's scope of services for our Wastewater
Facilities Plan. We are willing to undertake these additional efforts under our Wastewater
Facilities Plan process, and have begun discussions with Ansonia's WPCA regarding these
efforts. It should be noted that both the Derby and Ansonia WPCA's are in agreement to
continue working together to attain conditions in each wastewater system that will support a
cost-effective interconnection. We both realize, however, that these conditions can realistically
only be attained over a period of years, as portrayed by our current Wastewater Facilities Plan.
Page 2 of3
t
I
l{-
Mr. Dennis Greci
June 25,2014
Furthermore, in our discussions with the Ansonia WPCA we are both in agreement that over the
next 20 to 40 years the entire lower Naugatuck Valley should consider regionalizing the
wastewater systems for the Towns of Seymour and Oxford as well as the Cities of Ansonia,
Derby, and Shelton thus reducing the overall systems to the taxpayers.
We look forward to your response, and to your help in completing this important study.
Very truly yours,
The City of Derby Water Pollution Control Authority
CC: Mayor Anita Dugatto, City of Derby
Board of Alderman, City of Derby
Page 3 of3

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