Chapter 3: ATS Performance

Packaged sewage treatment systems, or ATS, in theory should be able to perform as well as Mother Nature in transforming sewage waste to clean, harmless substances, most especially water and nitrogen gas.  But interest in determining whether this desired performance is actually happening in the field has not kept pace with interest in selling and installing the equipment.

One of the first people in Connecticut to look at performance was Herbert Gram, a retired engineer from Madison.  He and other members of a group called Citizens for a Clean Hammonasset River questioned a number of plans for treatment of wastewater in the Hammonasset watershed.  In particular, they challenged the proposed installation of an AT system on the property of the Griswold Airport adjacent to Hammonasset State Park.  The purpose of using an alternative technology was to enable a high-density residential development on the property. 

Mr. Gram analyzed the performance data on the technologies proposed, and he came up with the following summaries in table and chart form.  These date from 2007: 

These illustrations vividly described a problem that had not been widely recognized:  AT systems were not all working well.  Many were not meeting permit requirements consistently, and a couple were operating without permits. 

Proponents of ATS objected that such presentations of the data were unfair.  We critics tend to say that a system that is not meeting its permit requirements is in failure.  Others rely more on a health-code definition of “failure,” that is, complete loss of control of the sewage, such that it is erupting above ground or into groundwater or backing up into the house or other structure from whence it came. 

Unfortunately, this ambiguity has persisted in the proposed rules for the state’s first Decentralized Wastewater Management District, in Old Saybrook.  Enforcement of permits appears still to be difficult unless total failure can be demonstrated. 

Another problem we have is that when an operator does not meet permit requirements for monitoring tests, we have counted that as noncompliance and an instance of failure.  In the data gathered more recently, however, we separated failure to meet water quality standards from failure to perform required monitoring.  Nevertheless, skipping over required tests is a warning that something is wrong.

Thanks to the cooperation of the Connecticut Department of Energy and Environmental Protection (DEEP), the support of our funder, and a lot of work by volunteers and interns in our group, we were able to review many of the ATS files on record and thus to expand an evaluation of ATS performance.  The evaluation is not comprehensive, primarily because the data included in this section were extremely difficult to gather.  At the DEEP all data are recorded in long paper reports, and the permits are not filed with the monitoring reports.  (The latter are called DMRs, for Discharge Monthly Reports).  Since the permits vary somewhat, the discrepancies sometimes make it difficult to assess compliance with the permit.  Also, DEEP personnel may keep files in their office for one reason or another, which means those files are hard to find when requested. Nothing is available online, and it was not easy to match up the times when access is possible with the schedules of the volunteers and interns working on the project. 

After a couple of years, it became apparent that it would not be possible to cover all facilities or to get information in the consistent form that we desired.  We focused, then, on getting recent data for a couple of years in a row from a representative range of the installations.  In general, this is a method favorable to the technology because performance has tended to improve and because we turned something of a blind eye to apparent noncompliance in periods that for obvious technical reasons were not appropriate. 

ATS in Connecticut

As of April 2009, there were 54 alternative treatment system sites in Connecticut.  Forty-eight discharged into groundwater, and six discharged into surface waters.  The latter are not considered part of the subsurface discharge program and are usually called “private sewage treatment plants.”  They have different permit criteria, but the technology is basically the same as for standard AT systems. 

These 54 alternative treatment systems were installed at locations where more wastewater was created than could be processed in a conventional system.  Examples are schools, shopping plazas, restaurants, and a few residential developments.  ATS were by statute barred from public drinking-water watersheds and were not permitted for single-family residences.  This residential use of ATS was accepted by the DEEP only in the newly created Old Saybrook Decentralized Wastewater Management District, where some 400 individual ATS have been proposed.

 Rivers Alliance of Connecticut gathered data on some 29 sites in Connecticut.  These sites were chosen in order to include a range of technologies and varying levels of design flow.  We made an effort to gather recent data on many of the sites.  The Zenon system is overrepresented in part because DEEP issued a Zenon Performance Appraisal in 2008, but DEEP has yet to produce summary appraisals of other products used in Connecticut.  This report also picks up earlier years of Zenon’s performance, some of which were not good.  But newer Zenon installations, such as the one in Georgetown, CT, with the Z-WEED membrane filter, are reported to be performing exceptionally well — much better than the permits require.   

But a warning: Zenon or any other good product will not necessarily ensure high performance.  A number of the most dramatically problematic AT installations in Connecticut were Zenon products in schools.  Bad installation and bad maintenance can turn a Rolls Royce into a rusted jalopy.

Permit Parameters and Standards

The key permit parameters for subsurface discharges are:

BOD, or Biological Oxygen Demand. This is a measure of oxygen needed by bacteria as they consume organic (carbon-containing) substances, including fecal matter.  The higher the BOD the more biodegradable organic material in the sewage.  A common limit is 20 mg/l (20 milligrams per liter) as a monthly average, 30 mg/l maximum for one day.  BOD-5 refers to BOD over a five-day period.  This permit limit is met with relative ease.

TSS, or Total Suspended Solids.  A common limit is 20 mg/l as a monthly average; 30 mg/l maximum for one day.  This permit limit is met with relative ease.

TN, or Total Nitrogen.  This is the nutrient that causes plant growth and algae blooms, leading to dead zones in Long Island Sound.  It has the most impact in salt water.  A common limit is 10 mg/l, which is the drinking-water standard but is actually rather high for ecological health.  The maximum daily limit is usually 30 mg/l. 

TP, or Total Phosphorus.  This nutrient also causes plant growth and algae blooms.  It has the most impact in fresh water.  A common limit is 15 mg/l. 

FC, Fecal Coliform.  These are fecal bacteria.  A common standard is 200 col/100 ml (200 colonies per 100 milliliters) of water.  

Subsurface Discharge Facilities

The section below shows data from some of the ATS facilities in Connecticut on record with the DEEP.  We list them alphabetically by town.  We believe it would be somewhat misleading to list alphabetically by type or brand name, because a technology or product that works poorly on one site may work very well on another.  Appropriate design, installation, operation, and maintenance are extremely important to performance. 

We also list notable exceedances because these are often overlooked in discussions of how well the technology works.  Some advocates for the technology tend to say that occasional exceedances are not a worry as long as on average the technology is working.  But, as the old saying goes:  His head was in the refrigerator and his feet were in the oven, so his average temperature was fine but he was dead.  

Our sources were discharge monitoring reports (DMRs) held in the Office of Public Records at the DEEP, the DEEP appraisal of Zenon’s performance, and calculations by Herb Gram, a retired engineer from Madison, CT. 

When operators significantly fell short of supplying the number of reports required in the permit, we calculated an overall score that reflects noncompliance with the permit.  If they were reporting approximately on schedule, we didn’t count that as concompliance. 

Here are the data.

Barkhamsted, CT (2008)

Mallory Brook Plaza (UI0000129) 2,100 gpd    

Watershed: Morgan Brook   

Type:  Zenon

Point of Environmental Concern: Surface Water Body

 PERMIT TESTING REQUIREMENTS

NOTABLE EXCEEDANCES

BOD-5:   BOD-Stated Limit: 30mg/l (Max Daily)
(July) 190mg/l; (Aug) 72mg/l 

TN:   TN-Stated Limit: 10mg/l (Max Daily)
(Jan) 150mg/l, 130mg/l; (Feb) 42mg/l, 37mg/l; (Mar) 30mg/l, 24mg/l; (Apr) 48mg/l, 75mg/l; (May) 61mg/l, 77mg/l; (Jun) 84mg/l, 88mg/l; (Jul) 85mg/l, 86mg/l; (Aug) 130mg/l, 110mg/l;

FC:   FC-Stated Limit: 4col/100ml 
(Aug) 8col/100ml

The DEEP Performance Appraisal, covering 1/03 to 8/06, shows some much lower numbers:  80% compliance with BOD, 98% for TSS, 17% for TN (nitrogen), 25% for TP (phosphorus), and 89% for FC (fecal coliform). Enforcement action was followed by improved performance.   

 PERMIT TESTING REQUIREMENTS                                                                                                                              Mallory Brook Plaza

NOTABLE EXCEEDANCES

BOD-5:   BOD-Stated Limit: 30mg/l (Max Daily)
(Oct) 74mg/l     

TN:   TN-Stated Limit: 10mg/l (Max Daily)
(Feb) 37mg/l; (Mar) 24mg/l, 32mg/l; (Apr) 30mg/l, 29mg/l; (May) 30mg/l, 21mg/l; (Jun) 34mg/l, 20mg/l; (Jul) 86mg/l, 82mg/l; (Aug) 72mg/l, 55mg/l; (Sept) 20mg/l

TP:   TP-Stated Limit: 15mg/l (Max Daily)
(Oct) 31.4mg/l

Chester, CT

Chester Village West (UI0000104) 18,676 gpd

Watershed: Menunketesuck River

Permit Expires: July 1, 2032

Type:  RBC

PERMIT TESTING REQUIREMENTS

 NOTE

This facility frequently meets its permit requirements, but its effluent limits for BOD and TN are more lenient than those for the majority of other facilities discharging into groundwater.

NOTABLE HIGH VALUES

TSS Groundwater: No Stated Limit for Groundwater
(Aug) 500mg/l, 100mg/l; (Nov) 64mg/l                        

FC Groundwater: No Stated Limit for Groundwater
(Nov) 70col/100ml

PERMIT TESTING REQUIREMENTS                                                                 Chester Village West, Chester

 NOTE

This facility frequently meets its permit requirements, but its effluent limits for BOD and TN are more lenient than those for the majority of other facilities discharging into groundwater.

NOTABLE EXCEEDANCES

TSS Groundwater:   TSS-Stated Limit: No Stated Limit for Groundwater
(Aug) 1100mg/l, 120mg/l, 1900mg/l, 160mg/l

Clinton, CT

Clinton Crossing (UI0000296) 4,800gpd

Permit Issuance Date: September 11, 1996

Type: Zenon

Point of Environmental Concern: Toe of slope

PERMIT TESTING REQUIREMENTS

PERMIT TESTING REQUIREMENTS                                                                      Clinton Crossing

NOTE

Merit: Award facility a "green star" for reporting TN and TP more frequently than required.  We scored the facility 100% on compliance with number of tests required for BOD and TSS, although the testers did only one test in December rather than two.  But they did do 24 tests altogether as required. 

The DEEP Zenon performance appraisal from 1/03 to 8/06 recorded only one element of noncompliance:  87% TN (nitrogen).

Coventry, CT

Town of Coventry WPCA (UI0000075) 200,000 gpd

Watershed: Willimantic River

Permit Expires:  NA

Type: Clarigester (an anaerobic digester combined with a clarifier)

Use: Municipal

PERMIT TESTING REQUIREMENTS

NOTES

The above table was created from information contained in the Coventry WPCA’s permit, which is older than most and has a somewhat different format. The permit was modified on September 30, 1983.

Unlike for the majority of other facilities, the permit requires BOD-5 to be tested only in the influent and TN to be tested only in the influent and monitoring wells.  

Groundwater monitoring data were not included because no limit was required.  From the period January-April 2009, the facility reported groundwater data once in March.

*Total Nitrogen is broken down as "Organic Nitrogen, Ammonia, Nitrate" and "Nitrite."

NOTABLE EXCEEDANCES

TSS: TSS-Stated Limit: 30mg/l (Max Daily)

(Jan) 68mg/l, 73mg/l, 85mg/l, 86mg/l, 88mg/l, 100mg/l, 100mg/l, 120mg/l;

(Feb) 80mg/l, 81mg/l, 97mg/l, 100mg/l, 100mg/l, 130mg/l, 130mg/l;

(Mar) 62mg/l, 65mg/l, 96mg/l, 100mg/l, 110mg/l, 120mg/l;

(Apr) 71mg/l, 86mg/l, 86mg/l, 87mg/l, 89mg/l, 89mg/l

PERMIT TESTING REQUIREMENTS             Town of Coventry WPCA

NOTES

Note reporting TSS more frequently than was required despite being required to test for TSS more frequently than the majority of other facilities.

*Total Nitrogen is broken down as "Organic Nitrogen, Ammonia, Nitrate" and "Nitrite."

NOTABLE EXCEEDANCES

TSS: TSS-Stated Limit: 30mg/l (Max Daily)

(Jan) 67mg/l, 76mg/l, 94mg/l, 95mg/l, 100mg/l, 100mg/l, 100mg/l, 100mg/l, 110mg/l, 110mg/l; (Feb) 68mg/l, 76mg/l, 80mg/l, 100mg/l, 110mg/l; (Mar) 62mg/l, 92mg/l, 100mg/l, 150mg/l; (Apr) 62mg/l, 68mg/l, 68mg/l, 68mg/l, 70mg/l, 76mg/l, 78mg/l; (May) 62mg/l, 62mg/l, 68mg/l, 76mg/l; (Jun) 60mg/l, 68mg/l, 76mg/l, 77mg/l, 78mg/l, 80mg/l, 86mg/l, 88mg/l; (Jul) 62mg/l, 64mg/l, 78mg/l, 86mg/l, 96mg/l, 97mg/l, 97mg/l, 130mg/l; (Aug) 74mg/l, 77mg/l, 100mg/l, 100mg/l, 110mg/l, 403mg/l; (Sep) 62mg/l, 68mg/l, 68mg/l, 70mg/l, 98mg/l, 110mg/l; (Oct) 62mg/l, 62mg/l, 75mg/l, 82mg/l, 82mg/l, 90mg/l; (Nov) 66mg/l, 67mg/l, 79mg/l, 80mg/l, 140mg/l, 160mg/l; (Dec) 68mg/l, 70mg/l, 72mg/l, 73mg/l, 73mg/l, 74mg/l, 80mg/l

Essex, CT

Essex Meadows (UI0000172) 28,000gpd 

Watershed: Mud River

Use: Convalescent Home     

Permit Expires: February 9, 1995*

Type:  RSF

PERMIT TESTING REQUIREMENTS

NOTES

 This facility has a Max Daily Limit of 20mg/l of BOD-5, which is a typical average monthly limit for other facilities. The average limit tends to be more lenient than the Max Daily Limit, thus the facility has a more stringent Max Daily Limit than many other facilities. However, even if the Max Daily Limit for BOD-5 were 30mg/l, the number of tests in compliance with the permit would remain the same.

This facility was never within its permit limit for TN in the effluent, despite its limit for TN being more lenient than those for the majority of other facilities.

*According to DEEP Records, the DEEP extended this permit until 2000; the facility filed an application for another extension of its permit in 2000.

** No stated limit for FC, and FC levels were extremely high.

NOTABLE HIGH VALUES

BOD:   BOD-Stated Limit: 20mg/l (Max Daily)
(Mar) 44mg/l

TN Groundwater:  No Stated Limit
(Sept) 22.12mg/l, 24.62mg/l, 26.51mg/l, 22.41mg/l
(These values were noted despite there being no stated limit for TN in groundwater.)

FC Groundwater:  No Stated Limit for Groundwater

(Mar) >2,000col/100ml; (Jun) 2,200col/100ml; (Sept) >20,000col/100ml
(This value was noted despite there being no stated limit for FC in groundwater.)

PERMIT TESTING REQUIREMENTS                                                     Essex Meadows, Essex, CT

NOTES

Mark with merit for reporting more frequently than was required, even though the facility is required to report effluent parameters less frequently than many other facilities.

If the Max Daily Limit for BOD-5 were 30mg/l, the 2008 BOD-5 levels would be in compliance with permit limits.  This facility’s limit for TN is more lenient than that for the majority of other facilities.

*FC levels were extremely high.

NOTABLE HIGH VALUES

FC Groundwater: FC-Stated Limit: No Stated Limit for Groundwater

(Jan) >10,000col/100ml (Mar) >2,000col/100ml; (Jun) 2,200col/100ml; (Sept) >2,000col/100ml; (Dec) >20,000col/100ml

Greenwich, CT

Brunswick School (UI0000332) 15,200gpd

Permit Issuance Date: February 7, 2001; Modified on December 22, 2004

Type: Zenon

Point of Environmental Concern: Toe of slope

PERMIT TESTING REQUIREMENTS

NOTE

The DEEP Zenon Performance Appraisal covering 1/05-8/06 showed problems.  Compliance with TN (nitrogen) was 43%:  “serious inflow and infiltration issues” were noted.  Enforcement action led to improved results.  Herb Gram’s calculations, covering 72 months, indicate that the facility was out of compliance for 65 months, or 90% of the time.

NOTABLE EXCEEDANCES

FC:   FC-Stated Limit: 4col/100ml
(May) 80col/100ml; (Aug) <10col/100ml

 PERMIT TESTING REQUIREMENTS                      Brunswick School, Greenwich

NOTABLE EXCEEDANCES

TN:   TN-Stated Limit: 10mg/l (Max Daily)
(Oct) 50.53mg/l                   

Greenwich, CT

Whitby School (UI000355), 2,310gpd

Type:  Zenon (constructed fill)

Permit Issued:  December 30, 2002

Point of Environmental Concern: Toe of slope

DEEP Performance Appraisal:  1/03-6/06, 38 months

100% compliance with BOD, TSS, and TP (phosphorus)

91% compliance with TN (nitrogen)

95% compliance with FC (fecal coliform)

Herb Gram had slightly different numbers, estimated over 60 months:

98% compliance with BOD

87% compliance with TN

93% compliance with FC

He noted that one monitoring well was dry.  DEEP recommended a warning letter.

Guilford, CT

The Gables at Guilford (UI0000175) 16,500 gpd

Watershed: Hoadley Creek, South Central Shore

Permit Expires:  May 8, 2018            

Type:  RBC

PERMIT TESTING REQUIREMENTS

 NOTES

This facility frequently meets its permit requirements, but its effluent limits for BOD and FC are more lenient than those of the majority of other facilities discharging into groundwater. The limit of 400col/100ml for Fecal Coliform is particularly high. 

 Only an average monthly limit was given for TN, so reported values were compared with this limit: 10mg/l.

The permit required groundwater to be monitored quarterly, but five tests were submitted. 

NOTABLE HIGH VALUES

 FC: FC-Stated Limit: 400col/100ml
(Feb) >2000col/100ml

 FC: FC: No Stated Limit for Groundwater
(Jun) 30col/100ml   

 PERMIT TESTING REQUIREMENTS                                                                              The Gables, Guilford

NOTABLE HIGH VALUES

 FC: FC-Stated Limit: 400col/100ml
(Jan) 3500col/100ml; (Feb) >2000col/100ml; (Jun) 1050mg/l; (Aug) >2000col/100ml

FC: FC-Stated Limit: No stated limit for groundwater
(Mar) 200col/100ml, 30col/100ml, 60col/100ml
(This value was noted despite there being no stated limit for groundwater.) 

 Table based on eight months of data found at DEEP (Jan-Aug 2007).

Guilford, CT

Wal-Mart (UI0000384) 4,530gpd 

Watershed: Sluice Brook

Permit Expires: March 13, 2016

Type: Bioclere     

PERMIT TESTING REQUIREMENTS

NOTE

Overall compliance for TN is actually higher than compliance per test, because the operator tested more frequently than required for TN.  Sometimes increased frequency occurs because the operator is trying to track and bring down the exceedance.

NOTABLE HIGH VALUES

BOD:   BOD-Stated Limit: 30mg/l (Max Daily)
(Feb) 60mg/l        

TN Effluent:  TN-Stated Limit: 10mg/l (Max Daily)

(Feb) 20mg/l, 45mg/l, 32mg/l, 21mg/l; (Mar) 27mg/l, 25mg/l; (Jul) 30mg/l

TP Effluent:   No Stated Limit for Effluent.  Standard is usually 15mg/l

(Jun) 49mg/l; (Aug) 51mg/l

 FC Groundwater:  No Stated Limit for Groundwater.  Standard is usually 200col/100ml.
(Aug) 400col/100ml

 PERMIT TESTING REQUIREMENTS                                                            Wal-Mart, Guilford

NOTE

Mark with merit for reporting more frequently than was required.

NOTABLE EXCEEDENCES

BOD:   BOD-Stated Limit: 30mg/l (Max Daily)
(Feb) 172mg/l      

TN Effluent:  TN-Stated Limit: 10mg/l (Max Daily)

(Jan) 63.1mg/; (Feb) 53mg/l, 30mg/l; (Mar) 20mg/l; (Apr) 23mg/l; (May) 22mg/l, 23mg/l, 26mg/l, 34mg/l (Jun) 23mg/l, 28mg/l, 43mg/l, 32mg/l; (Jul) 33mg/l, 34mg/l, 34mg/l, 36mg/l; (Aug) 30mg/l, 23mg/l, 27mg/l, 31mg/l; (Sept) 57mg/l; (Nov) 26mg/l, 20mg/l

FC Groundwater:  FC-Stated Limit: No Stated Limit for Groundwater

(Aug) 450col/100ml (Monitoring Well 2); 960col/100ml (MW1), >1000col/100ml (MW3)

Guilford, CT

Goose Lane Medical, LLC (UI000400), 4,800gpd

Permit Issued:  July 9, 2004

Type:  Zenon

Point of Environmental Concern: Property line (This is more a point of legal concern than environmental concern, but it is a traditional testing point.)

DEEP Performance Appraisal:  2/05-8/06, 19 months

100% compliance with BOD, TSS, and FC

82% compliance with TN

5% compliance with TP

Herb Gram, looking at 37 months, calculated:

89% compliance with TN

33% compliance with TP

He noted that six months had “no data” entries under TP and recommended that test well 3 be redrilled to greater depth.  DEEP issued a Notice of Violation.

Madison, CT

The Hearth (UI0000354) 13, 125 gpd)

Type:  Zenon

Permit Issuance Date: March 4, 2002

Point of Environmental Concern: Toe of slope         

PERMIT TESTING REQUIREMENTS

NOTES

The 2006 DMR states that FC is tested two times a month, whereas the DEEP’s Zenon Performance Appraisal, which also includes 2006 values, states FC is to be tested weekly.  An FC limit of 200col/100ml is listed in the 2006 DMR, whereas the 2007 DMR lists no FC limit.  Those values listed in the hard copy 2006 DMRs were judged against a limit of 200col/100ml.

For March 2006, the front page of the DMR lists "March 2006," whereas the attached sheets are labeled "February 2006." The values reported evidently were meant to be for March 2006.

 This facility has done well historically.  The DEEP Appraisal covers March 2002 to May 2006.  Using DEEP methods of calculation, the compliance rate is 100% for nitrogen, BOD, and TSS; and 89% for phosphorus.  DEEP notes no limit on fecal coliform.  Using Herb Gram’s calculation (which counts “no data” reports as noncompliance), the compliance rate is 92% for nitrogen, 95% for phosphorus.   Using the standard limit for fecal coliform, compliance would be 81%.

Compliance was evaluated based on data available at time of gathering, at which time neither groundwater permit requirements nor complete groundwater monitoring data were available.

The 2006 DMR states an FC limit of 200col/100ml, but the Zenon Performance Appraisal does not state a limit for FC.  Because 2007 values were taken from the Zenon Performance Appraisal, no limit was used.

NOTABLE HIGH VALUES

 FC:  FC: No Stated Limit in Zenon Performance Appraisal.  Facility is adjacent to Tunxis Pond.
(Mar) 104col/100ml

PERMIT TESTING REQUIREMENTS                                                                                      The Hearth, Madison

Madison, CT

Madison High School (UI0000376) 29,550gpd

Type: Amphidrome

The data we have for this facility come from Herb Gram, covering 10/6/04-11/23/05. They show flows varying from 579gpd to 13,496gpd.  Variable flows are a common difficulty in school facilities.  We have the data in graph form as follows. 

New Fairfield, CT

Consolidated School/Meeting House Hill (UI0000356) 11,000gpd

Watershed: Ball Pond Brook

Permit Expires: October 22, 2014

Type: Bioclere

PERMIT TESTING REQUIREMENTS

NOTES

The permit specifies effluent testing to be done twice a month, but in some cases the DMRs gave only one daily value, which was a max value.  In such cases, we used only that one max daily value. In cases with more than one daily value reported, all values given were evaluated against permit limits for that parameter.  Even though effluent testing was required only twice a month, the average was not used to infer other values because the operator stated that the actual number of samples to equal the average value stated varied from two to four per month.

Give the operator a green star for testing more than required.   He evidently tried very diligently the first five years to meet permit limits.  The operator noted that total nitrogen levels tend to be better during groundwater testing.

NOTABLE EXCEEDANCES

BOD: Stated Limit: 30mg/l (Max Daily)
(Feb) 142mg/l, 123mg/l; (Mar) 101mg/l, 138mg/l; (Apr) 71, 79

TN Effluent:  Stated Limit: 10mg/l (Average Monthly, Max Daily)
(Jan) 40mg/l, 69.5mg/l; (Feb) 46.1mg/l, 31.8mg/l, 26.9mg/l; (Mar) 37.5mg/l, 42.8mg/l, 42.5mg/l

PERMIT TESTING REQUIREMENTS                                  Consolidated School, New Fairfield

NOTABLE EXCEEDANCES

BOD:  BOD-Stated Limit: 30mg/l (Max Daily)
(May) 78mg/l;  (Nov) 64mg/l; (Dec) 72mg/l

TN Effluent:  TN-Stated Limit: 10mg/l (Average Monthly, Max Daily)
(Jan) 31.6mg/l, 71mg/l, 76.8mg/l, 59mg/l; (Feb) 64.4mg/l, 48mg/l, 67.7mg/l; (Mar) 61.9mg/l, 52.1mg/l, 52.7mg/l; (Apr) 49.2mg/l, 48mg/l, 32,4mg/l; (May) 55.4mg/l, 57.6mg/l, 56.9mg/l, 57.2mg/l; (June) 57.1mg/l, 45.6mg/l, 44mg/l, 33.3mg/l; (Sept) 35.4mg/l, 27.4mg/l, 27.3mg/l; (Oct) 29.9mg/l, 22.5mg/l, 22.6mg/l; (Nov) 22mg/l, 21.4mg/l, 24.5mg/l; (Dec) 70.4mg/l, 91.3mg/l, 54.8mg/

PERMIT TESTING REQUIREMENTS                          Consolidated School, New Fairfield

NOTABLE EXCEEDANCES

BOD:  BOD-Stated Limit: 30mg/l (Max Daily)
(Jan) 73mg/l, 211mg/l; (Feb) 252mg/l; (Mar) 166mg/l; (Oct) 107mg/l; (Dec) 69mg/l.

TSS:  TSS-Stated Limit: 30mg/l (Max Daily)
(Dec) 70mg/l

TN Effluent:  TN-Stated Limit: 10mg/l (Average Monthly, Max Daily)
(Jan) 44.9mg/l, 35.1mg/l, 31.5mg/l; (Feb) 43.2mg/l, 38.5mg/l; (Mar) 63.9mg/l, 33.7mg/l, 23.6mg/l; (May) 33.7mg/l, 38.7mg/l, 47.1mg/l, 44.7mg/l; (June) 58.1mg/l, 41.4mg/l, 50mg/l; (Sept) 30.0mg/l, 33.7mg/l, 35.9mg/l, 39.2mg/l; (Oct) 77.2mg/l, 44.4mg/l, 28.8mg/l, 41.2mg/l; (Nov) 29.8mg/l, 25.2mg/l, 22.5mg/l; (Dec) 49.8mg/l, 70.6mg/l, 75.1mg/l, 31.3mg/l

Old Lyme, CT

Old Lyme Stores (UI0000097) 11,724gpd

Watershed: Lieutenant River 

Use: Grocery & Retail

Permit Expires: November 8, 2003*

Type: RSF

PERMIT TESTING REQUIREMENTS

*According to DEEP records, Old Lyme Stores filed an application for an extension of its permit in 2003. The application is in process at the DEEP.

NOTABLE EXCEEDANCES

BOD:   BOD-Stated Limit: 20mg/l (Average Monthly)

(Feb) 456mg/l; (Mar) 244mg/l; (Aug) 490mg/l

TSS: TSS-Stated Limit: 20mg/l (Average Monthly)
(Feb) 230mg/l; (Mar) 74mg/l; (Aug) 92mg/l

TN: TN-Stated Limit: 10mg/l (Average Monthly)
(Feb) 42.11mg/l; (Mar) 50.1mg/l; (Apr) 49.74mg/l; (May) 32.67mg/l; (Jun) 32.2mg/l; (Jul) 26.4mg/l; (Aug) 86.14mg/l; (Sept) 27.9mg/l; (Oct) 31.96mg/l; (Nov) 32.76mg/l; (Dec) 39.31mg/l  

 PERMIT TESTING REQUIREMENTS                               Old Lyme Stores, Old Lyme, CT

NOTABLE EXCEEDANCES          

TSS: TSS-Stated Limit: 20mg/l (Average Monthly)
(Feb) 42mg/l; (Sept) 67.5mg/l

TN: TN-Stated Limit: 10mg/l (Average Monthly)
(Jan) 27.08mg/l; (Feb) 24.35mg/l; (May) 55.51mg/l; (Jun) 42.8mg/l; (Sept) 28.64mg/l; (Dec) 27.94mg/l

Old Saybrook, CT

Between the Bridges (UI0000373) 17,800 gpd

Use: Office & Restaurant

Type: FAST

Permit Expires: A new permit pending as of 2010

PERMIT TESTING REQUIREMENTS

NOTE

The 10 mg/l limit for max daily nitrogen is strict.  It is usually 30 mg/l, with the monthly average set at 20 mg/l. However, only two of the 12 tests for TN came in under 20 mg/l. 

   PERMIT TESTING REQUIREMENTS    Between the Bridges, Old Saybrook

NOTABLE EXCEEDANCES

TN:   TN-Stated Limit: 10mg/l (Max Daily)
(Jul) 25.3mg/l; (Aug) 29.16mg/l, 30.4mg/l; (Sep) 25.8mg/l, 34.1mg/l; (Oct) 31mg/l, 32.7mg/l; (Nov) 39.2mg/l; (Dec) 27.9mg/l, 46.3mg/l

PERMIT TESTING REQUIREMENTS  Between the Bridges, Old Saybrook

Pomfret CT

Pomfret School (UI0000305) 30,000 gpd

Watershed: Wappaquia Brook

Use: School

Type: Activated Sludge

Permit Expiration: August 4, 2007*

PERMIT TESTING REQUIREMENTS

 NOTES

Mark with merit for reporting more frequently than was required, even though the facility is required to report effluent parameters less frequently than many other facilities.
*According to DEEP Records, Pomfret School filed an application for an extension of its permit in 2007; the application is in process at the DEEP.
**Unlike the majority of permits, no limits were listed for BOD-5 or TSS, and this facility was not required to test for TN, TP, or FC in the effluent.

NOTABLE HIGH VALUES 

BOD-5 Effluent: BOD-Stated Limit: No Stated Limit
(May) 430mg/l; (Jun) 92mg/l  (These values were noted despite there being no stated effluent limit for BOD.)

TSS Effluent: TSS-Stated Limit: No Stated Limit
(May) 130mg/l; (Jun) 74mg/l  (These values were noted despite there being no stated effluent limit for TSS.)

 TN Groundwater: TN-Stated Limit: No Stated Limit
(Jan) 17.3mg/l, 24.5mg/l, 25.1mg/l, 26.5mg/l; (Apr) 11.2mg/l, 12.7mg/l, 14.1mg/l, 21.2mg/l  (These values were noted despite there being no stated limit for TN in groundwater.)

 TSS Groundwater: TSS-Stated Limit: No Stated Limit
(Jan) 120mg/l, 150mg/l, 170mg/l, 350mg/l, 2500mg/l; (Apr) 110mg/l, 390mg/l; (Jul) 130mg/l, 160mg/l, 7,000mg/l; (Oct) 100mg/l, 220mg/l, 3,000mg/l  (These values were noted despite there being no stated limit and no required testing for TSS in groundwater.)

FC Groundwater: FC-Stated Limit: No Stated Limit
(Jul) 130col/100ml, 180col/100ml, 230col/100ml  (These values were noted despite there being no stated limit for FC in groundwater.)

 PERMIT TESTING REQUIREMENTS                                                       Pomfret School