City of DerbyWater Pollution Control Authority

I Ehzabeth Street Derby, CT 06418203 736 147s

June25,2014

Mr. Dennis Greci, PESupervising Sanitary EngineerPlanning & Standards DivisionBureau 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 tothe Derby/Ansonia Interconnection. As you might imagine, the closing statement of your lettercauses 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 itdoes not address the upcomrng 20 year planning period nor is it anticipated to receive anyfunding from the CWF (Clean Water Fund) as presented."

The WPCA has been w'orking diligently on the various studies and preparation of this importantdocument since 2010. Prior to beginning work on the plan, your department reviewed andapproved the consultant's scope of work. When the plan was completed, your departmentreviewed and made comments on the draft Wastewater Facilities Plan document on two differentoccasions. These review documents are attached hereto for reference. In neither of those reviewswas any comment or concern raised about the plan's assessment of our facilities and how theywill be managed and upgraded throughout the 2}-year planning period.

As has been explained by our consultant, their assessment has taken into consideration thecondition of the existing facilities and processes, the anticipated changes to our City'swastewater flows and loads, and their resulting recommendations include a series of stagedupgrades through the planning period that are planned maxrmize the remaining life of thestructures and equipment while utilizing a funding approach that can be managed over time. Wewould observe that although it might be desirable to undertake a single facility-widecomprehensive upgrade, such a project would not only likely exceed the City's borrowingcapacity, but also most certainly exceed our users' ability to repay the loans required. The abilityto pay is a major concem for both the City and the WPCA. As your letter describes yourconfusion related to this "limited scope of the plant upgrades" being proposed, we hope that thisexplanation offers sufficient explanation to aid in your understanding. The WPCA understandsand 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 andmore parameters that may be added requiring additional treatment system or equipment to meetthe future NPDES permit" leaves the WPCA wondering how to address such unknown andspeculative conditions. We might suggest that should DEEP be concerned with such issues, theyshould indicate so during the review and approval of the engineering scopes of service. At this

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Mr. Dennis GreciJwrc25,2014

point in time, it is difficult to address such an issue, and it should not be represented by yourdepartment as an incomplete study item. In a similar fashion, your statement that, "The twoparameters on the horizon are tighter effluent limits for metals and control of pharmaceuticalsand personal care products. The intention is to do the complete modernization now to last for thenext twenty years." It seems to us that these types of issues should be addressed at the time thatthey become regulated, not when they are simply a perceived "on the horizon" issue. Therecently upgraded Ansonia WPCF is not designed for the removal of metals and control ofphatmaceuticals and personal care products. The Ansonia WPCF will also need an additionalupgrade in the future if the State were to impose tighter effluent limits for these parameters eventhough the Ansonia WPCF upgrades were only completed a few years ago at a substantial cost tothe residents of Ansonia.

We understand that Mr. Greci spoke recently with our engineering consultant, and that the reasonfor DEEP's decision to forego formal "approval" of the Wastewater Facilities Plan centeredupon the overall project's low perceived cost and its failure to generate sufficient points to placehigh enough on the Priority List. Your statement that the Plan will not be approved "since it doesnot address the upcoming 20 year planning period" is completely incorrect, and as such, we takeexception to this remark. Further, earlier in y,our letter, you state that. "The reason for the lowrating is that the proposed project does not contain cefiain component upgrades that wouldwarrant a higher point score." Perhaps DEEP should recognize that only the necessarycomponent upgrades are included and recommended, and that other "certain componentupgrades" are neither needed nor waranted pursuant to our study.

As your letter to Mayor Dugatto makes specific reference to the "Derby/Ansonialnterconnection" w'hich is an important consideration of our Wastewater Facilities Plan, webelieve that it would be prudent to fuither consider additional efforts and informationdevelopment 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 reliesupon:

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, and4. 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 ofthese issues, and since we have asked for, on multiple occasions, but never received therequested information regarding the Ansonia WPCF, we suggest that DEEP fund these additionalinvestigations that are not included within our engineer's scope of services for our WastewaterFacilities Plan. We are willing to undertake these additional efforts under our WastewaterFacilities Plan process, and have begun discussions with Ansonia's WPCA regarding theseefforts. It should be noted that both the Derby and Ansonia WPCA's are in agreement tocontinue working together to attain conditions in each wastewater system that will support acost-effective interconnection. We both realize, however, that these conditions can realisticallyonly be attained over a period of years, as portrayed by our current Wastewater Facilities Plan.

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Mr. Dennis GreciJune 25,2014

Furthermore, in our discussions with the Ansonia WPCA we are both in agreement that over thenext 20 to 40 years the entire lower Naugatuck Valley should consider regionalizing thewastewater 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 DerbyBoard of Alderman, City of Derby

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