EI\EI(\' I E

ENVIRONMENTAL
PROTECTION
79 Elm Street
.
Hartford, CT 061-06-5127 www.ct.gov/deep
Affirmative Action/Equal OpportunitY E
tlf.ay 12,2014
Anita Dugatto
Honorabie Mayor
Derby City Hall
I Elizabeth Street
Derby, CT 06418
Re: Derby/Ansonia Interconnection
Dear Mayor Dugatto:
Thank you for meeting with us on March 12,2Al4 to discuss the City's wastewater issues. We
have reviewed your recently completed facilities plan and have several observations based on that review
and our meeting. The Derby wastewater treatment facility was originally constructed in 1964 and last
upgraded in L973. The plant is designed for an average daily flow of 3.5 Million gallon per day (MGD)
and its current flow is 1.6 MGD, approximately 95Yo of &e properties in Derby are currently serviced by
sewers. Wastewater keaftnent plants typically have a design 'life" of 20
-
30 years before equipment
wears and obsolescence becomes critical causing issues affecting operations. As was discussed on
March's 2014 meeting the interconnection with Ansonia needs further evaluation in order that a cost-
effective comparison with a comprehensive facility upgrade can be made.
The DEEP administers the Clean Water Fund (CWF) program as defined by Section 22a475
through 22a483 of the CGS and by regulations adopted February 19,1992 pursuant to CGS 22a482.
The program is a financial assistance program which provides combination of grants and loans for
eligible water pollution control projects.
The DEEP uses a priority ranking system for funding eligible projects. The priority list is
developed every two years and ranks the eligible projects based on several criteria which emphasize the
impacf of each upon public health, the improvement of water quality and water resource utilization. The
priorrty system and the priorrty list include point ratings which become the basis for committing available
and anticipated state and federal funds.
The DEEP has public noticed their draft 2AAD015 priority list and held a hearing on April 15,
2014. The $9,000,000 Derby Water Pollution Control upgrade project is rated \s #75 with 1l priority
points which is very low and will not likely be reachable for funding anytime in the near future. The
i"uso1 for the low rating is that the proposed project does not contain certain component upgrades that
would warrant a higher point score.
After reviewing your facility planning document we were somewhat
puzled that a limited scope
ofthe plant upgrades are being proposed. A large portion ofthe needed upgrades are not scheduled to
occur vrfiil2027 and be completed by 2A32 which is almost twenty years from now. In twenty years there
likely will more stuingent discharge limits and more parameters may be added requiring additional
treatnent system or equipment to meet the future NPDES permit. 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. At this point we will not be
approving your facility planning report since it does not address the upcoming2A year^ planning period
nor it is anticipated to receive any funding from the CWF as presented.
If you have any questions regarding this matter or would like to set up a meeting, please contact
Stela Marusin at 860424-3742.
P.E.
Sanitary Engineer
lanning & Standards Division
Bureau of Water Protection and Reuse
Cc: John Saccu (WPCA Chairman)
Henry Domurad (City of Derbyi
Daniel Lawrence
flileston
& Sampson)
Sincerely,