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Response A.1
Item A.2
The facility has an unpermitted structure for bypass and flood stage pumping
which, when in use, allows the untreated sewage to be discharged to the
Housatonic River.
Response A.2
We do not believe that the WPCF has any unpermitted bypass structures. All
wastewater that is conveyed to the WPCF is treated by the WPCF and
discharged to the Housatonic River. In the past, the WPCF had a highwater
bypass opening at the influent pumping station. This opening had been
permitted when the WPCF was constructed in 1964. However, this bypass
opening was obstructed in 2000 as part of the WPCF upgrades project that
was reviewed, approved and funded by DEEPsClean Water Fund (CWF)
Program. The bypass opening is now sealed by the installation of a sluice
gate. According to the operations staff, the sluice gate has not been
utilizedsince the upgrade. A photograph of the sluice gate is provided below.
The facility was constructed in 1964 and last upgraded in 1973 and is now
operating 22 years beyond its design life. Therefore, the mechanical reliability of
the entire physical facility is lessening due to its significant age.
Response A.3
The Order states that the City of Derby Water Pollution Control Facility was
constructed in 1964 and upgraded to secondary treatment in 1973. However,
we also clarify that the most recent upgrades to the WPCF were completed in
2000, which were also reviewed and funded by DEEPs CWF Program.
As part of the 2000 upgrades, an MLE system was installed for the purpose
of nitrogen removal. DEEP records indicate that Derby has received
substantial Nitrogen Removal Credit payments resulting from the treatment
levels afforded by these upgrades. The 2000 upgrades project included the
following components:
Installation of a sluice gate on the influent pumping station overflow.
See Response A.2 above for additional information.
Replacement of the influent wastewater pumps
Installation of a sewage grinder in the influent channel
Structural repairs and modifications to the primary clarifiers
Process Modifications for the incorporation of an MLE process within
the aeration basins
A new fine bubble diffused aeration system with a new Positive
displacement blower.
Installation of new emergency generators
Modifications to the secondary clarifiers
A new sodium hypochlorite and sodium bisulfate chemical feed
system
Please note that the information about the 2000 upgrades is referenced in
Section 9.1.4.2 of the City of Derbys Wastewater Facilities Planning Study
where reference is made to the overflow being sealed (See Response A.2).
Item A.4
Within the last few years the facility has conducted some temporary and/or
permanent modifications to the treatment facility without the Commissioners
approval, which is in violation of Section 4(O) of the permit.
Response A.4
Item A.5
The Departments inspection conducted on April 28, 2015 shows the facility to be
poorly operated and in overall disrepair due to its age and the lack of adequately
trained facilities personnel. A number of data reporting violations and nonfunctioning equipment were noted in the inspection report and an NOV was
issued on May 19, 2015.
Response A.5
We are concerned about the term poorly operated. Therefore, the WPCA is
requesting that DEEP clarify the intent of thepoorly operated term, as this
appears to be subjective. For example,review of the payments made to
Derby through the Nitrogen Credit Trading Program over the past 15 years
suggestthat Derby has been and remains at the forefront of nitrogen removal
in the state. A WPCF that is poorly operated and in overall disrepair due to
its age and lack of adequately trained facilities personnelas noted in Item A.5
would not be capable of maintaining consistent compliance with its effluent
pollutant limits and optimized Nitrogen removal over the past 15 years.
With regards to the WPCF personnel, all facility personnel possess the
appropriate licenses and training to complete their assigned positions. A
copy of each persons job description along with a copy of their license is
attached to this response.
To date, the WPCA has not received any correspondence from DEEP
regarding the Citys response to the May 19, 2015 NOV. The decision by
DEEP to issue the currentOrder without providing a formal response to the
WPCAs corrective action plan from the May 19, 2015 NOV is concerning, as
it did not give the WPCA a chance to correct any of the remaining issues from
the May 19, 2015 NOV. Further, we believe that some of the elements of this
current Order are factually inaccurate, and many elements of the Order have
already been resolved.
Some elements of this Order (see sections below) do not relate to the issues
from the May 19, 2015 NOV. This Order requires Derby to re-evaluate its
plan of upgrading the WPCF and the financials of shutting down the WPCF
and pumping to the City of Ansonia. The financials of shutting down the
Derby WPCF and pumping to the Ansonia WPCF have already been
thoroughly studied and found to be cost prohibitive to the City of Derby.
Further, execution of the interconnection would require another substantial
upgrade to the Ansonia WPCF, adding costs to both cities.The Derby WPCA
has had numerous meetings with CT DEEP and representatives from
Ansonia to review the facts, the data, and the financials on this issue, all of
which are presented in Section 8 of the recently completed Derby
Wastewater Facilities Planning Study. DEEP has reviewed this document
and has asked the WPCAs Engineer, the WPCF superintendent, and the
WPCA, off the record, to change the findings and recommendations of
Wastewater Facilities Planning Study, which the WPCA is not inclined to do.
We request a meeting with DEEP to review these issues relative to any new
data from DEEP that may impact the alternatives analysis of the Facilities
Plan.
Item A.6
The Municipality has prepared a report entitled City of Derby, Water Pollution
Authority, Wastewater Facilities, and Planning Study which was received by the
By virtue of the above, pollution by the Municipality exists and can be reasonably
be anticipated in the future.
Response A.7
The Derby WPCF is not polluting the waters of the State. DEEP is making an
overreaching assumption that pollution can be reasonably anticipated in the
future fromthe Derby WPCF. We do not believe this is accurate, nor does
the past effluent data suggest this. Attached please find the past 10 years of
monthly operating reports. This information is also on file with DEEP.
The Derby WPCA has provided facts in its responses to Items A.1 through
A.7. Therefore, we believe that DEEPs Items A.1 through A.7 have been
addressed. The Derby WPCA respectfully requests that DEEP reconsider its
position, and consider rescinding several elements of this Order.
Item B
Item B.1.A
The Commissioner, acting under Sections 22a-6, 2a-424, 22a-428 and 22a-431 of
the Connecticut General Statutes, orders the Municipality as follows:
On or before December 1, 2015, the Municipality shall provide a description in a
tabular form of all modifications performed at the facility since January 1, 2010.
Response B.1.A The above requested information was provided to CT DEEP in the NOV
response letter dated June 9, 2015. A copy of the letter is attached. In
addition to the attached letter, the tabular format of modifications to the
WPCF is summarized below (includes excerpts from June 9, 2015 NOV):
B. Modifications to Waste Activated Sludge (WAS) pumping
Modifications were not made to the WAS pumping system. However
modifications were made to the thickened waste activated sludge (TWAS)
pumping system. These modifications were made after the mixers failed
in the TWAS sludge holding tank attached to the aerobic digesters. Due
to upgrades to the solids handling system (which were in design at the
time) and the high cost of replacing the mixers a temporary more
affordable solution was sought. After discussions with the operations
staff the TWAS piping arrangement was installed to allow TWAS to be
wasted to the primary sludge well. By wasting the TWAS to the primary
sludge well, the TWAS and primary sludge are allowed to mix in the
primary sludge well prior to dewatering on our belt filter press. The
process modification results in the same result which is the mixing of the
TWAS and primary sludge prior to dewatering on our belt filter press.
Originally the TWAS and primary sludge were mixed in the TWAS sludge
holding tank attached to the aerobic digester prior to dewatering.
The area where the hose was splashing TWAS onto the ground has been
repaired. During the winter the TWAS transfer pipe from the secondary
control building froze and a temporary hose was installed (note: this is a
temporary fix on a temporary fix!). The pipe has been returned to its
original configuration and discharges inside the primary sludge well at or
below the water level which minimizes splashing. As you are aware the
City is currently in the process of re-bidding our upgrades to the solids
handling system. The solids handling system will eliminate this temporary
piping arrangement all together and will provide a more flexibility with
regards to the solids processing system as well as process redundancy of
equipment which is desperately needed.
In the future all modifications to the WPCF, no matter how small or
insignificant, will be reported to DEEP. In an effort to provide full
disclosure the following modifications were recently completed:
1. We replaced the submersible anoxic mixers with vertical shaft anoxic
mixers. We received a rebate from UI to complete this work. This
was completed approximately 6 months ago.
2. We replaced the hypochlorite feed system as the chemical
storagehad reach the end of their useful life and the pumps were
Response B.1.B The current job descriptions of every WPCA employee are attached. In
addition to the job descriptions, the licenses of all WPCA employees are also
provided.
Item B.2.
a. On or before September 30, 2015, the Municipality shall retain one or more
qualified consultants acceptable to the Commissioner to prepare the
documents and implement or oversee the actions required by this order and
shall, by that date, notify the Commissioner in writing of the identity of such
consultants. The Municipality shall retain one or more qualified consultants
acceptable to the Commissioner until this order is fully complied with, and,
within ten days after retaining any consultant other than the one originally
identified under this paragraph, the Municipality shall notify the Commissioner
in writing of the identity of such other consultant. The consultant(s) retained
shall be qualified professional engineer licensed to practice in Connecticut and
shall be acceptable to the Commissioner. The Municipality shall submit to the
Commissioner a description of a consultants education, experience, and
training which is relevant to the work required by this order within ten days
after a request for such a description. Nothing in this paragraph shall preclude
the Commissioner from finding a previously acceptable consultant
unacceptable.
b. On or before June 30, 2016, the Municipality shall submit to the Commissioner
for his review and written approval an Engineering Report for either the
modernization of the entire treatment facility or its abandonment and the
redirection of wastewater to other permitted facility and a schedule for
implementing the recommended alternative. In no case shall the completion
date for such work be later than December 31, 2020.
Response B.2
for 30 years on top of their $365 per year sewer bill. A sewer bill of $885
per year for a single family home is not deemed financially feasible for the
City of Derby.
3. The Derby WPCA is currently in the process of conducting a $15.0 million
modernization upgrade to the WPCF. The upgrades are proceeding
without CT DEEP Clean Water Funding. In November 2014 the citizens
of the City of Derby overwhelmingly voted in favor of the WPCF
modernization upgrades as part of the WPCA Capital Improvements
Referendum.
The modernization upgrades are anticipated to be
completed by 2018.
4. The Derby WPCA and the Ansonia WPCA have met several times and
have been discussing and planning for nearly a year on the possibility of
processing the sludge generated by the Ansonia WPCF at the Derby
WPCF. Based on a cost analysis, this regional concept may be a viable
cost saving option for both communities. As noted above, the upgrades
to Derbys Solids Dewatering System are bid-ready, and once these
upgrades are completed, cooperation and regionalization between
Ansonia and Derby can be further considered. Correspondence between
the two WPCAs regarding this concept is attached hereto for your use.
Based on the inaccuracies presented in this Order, as well as the additional facts and
information provided within this response, the City of Derby WPCA respectfully requests that the
Commissioner immediately rescind all or the majority of this Order. The City of Derby WPCA
would be more than happy to meet with the Commissioner as well as other members of the
DEEP staff to discuss the items outlined in this order.
Respectfully submitted,
The City of Derby Water Pollution Control Authority
Ms. Beth M. Allaire
Mr. William Bolland
Ms. Carolyn Duhaime Chairman
Mr. Robert Miani
Ms. Rose Marie Pertoso
Attachments:
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CC: