OSWPCA: Sunshine / Letter to OSWPCA 8Sep2009

Text facsimile

---------------------------> Joel R. Anderson

                             13 George Drive
                             Old Saybrook CT 06475-2636
                             860 388-9858
                             http://govtwork.home.att.net/
                             8Sep2009
WPCA Chairman Pavel Wilson
Old Saybrook Town Hall
302 Main Street
Old Saybrook, CT 06475

Dear Chairman Wilson:

Re your letter of 31Jul2009,
"Next you requested a definition of, as you say by way of letters you wrote to the WPCA dated 6Oct08 and 14May09, "the definition of an under sized septic tank that could be challenged in court".

"The answer to that is that the OSWPCA does not define an "undersized septic tank". Please refer to the Connecticut General Statutes that gives that authority to the Connecticut Health Department. Those regulations are available on line for your edification."

The Health Dept defines the current standard for new or replacement tanks. The decision taken that tanks smaller than current code are 'undersized' and therefor must be replaced is pure OSWPCA and your interpretation can be challenged in court.

Since the OSWPCA is bent on replacing 200+/- tanks [Table 2] solely on the basis that they're smaller than current code, obviously you believe that there is sound pollution-reduction science behind your decision. Or is there?

Table 1, below, indicates that household size and pumpout frequency are the relevant variables, NOT tank size.

Where is your science proving that arbitrarily increasing tank size will reduce pollution? Show us your science!


Table 1. Estimated Septic Tank Pumping Frequencies in Years*
Tank
size      ------- Household size  (number of people) ------
(gals.)      1        2        3        4        5        6
 500       5.8      2.6      1.5      1.0      0.7      0.4
 750       9.1      4.2      2.6      1.8      1.3      1.0
 900      11.0      5.2      3.3      2.3      1.7      1.3
1000      12.4      5.9      3.7      2.6      2.0      1.5
1250      15.6      7.5      4.8      3.4      2.6      2.0
1500      18.9      9.1      5.9      4.2      3.3      2.6
1750      22.1     10.7      6.9      5.0      3.9      3.1
2000      25.4     12.4      8.0      5.9      4.5      3.7
2250      28.6     14.0      9.1      6.7      5.2      4.2
2500      31.9     15.6     10.2      7.5      5.9      4.8
*Pennsylvania State University Cooperative Extension Service Publication:
'The Care and Feeding of Your Septic Tank System'
From: National Small Flows Clearinghouse, West Virginia U


TABLE 2. OSWPCA Suggested Wastewater Management Activity
                                New
                  Further       Tank         Upgr  Needs
                  Invest-  New  or    Vac-   Comp  Alt
                   igate  Tank  Leach  ant   (ok)  Treat
   15 Focus Areas
     ChalkerBeach    12     5    157    22     9    56
    CornfieldPark    21    23     47     0     7     0
   CornfieldPoint    11    41    151     8    38    51
          Fenwood    29    45     24     0    13     0
     GreatHammock     8     2     46     4     2    24
       Indiantown    19     0    131     6    27    12
       InghamHill     4     3      8     0     1     1
    MapleAveNorth    12    38    113    12    27     1
        Meadowood    13     8     40     3     3     3
  OysterRiverEast     9     8     50     6     2    14
         PlumBank     2     0      4     1     0     54
    SaybrookAcres    20    11     60     1     8     2
    SaybrookManor     9     9    183     7    17    15
    SaybrookPoint     4     5     10     1     7    10
         Thompson     1     1     26     0     2     0

        Totals*     174   199   1050    71   163   243      

      * Counts are thought to represent map PDFs (+/-).

The OSWPCA failed in its duty to inform the public when it didn't put the "Groundwater Monitoring Report, Sep 2004" (Cummings Envirotech, Old Lyme, 19Oct2004) online. This report shows the location of the test wells and results of the monitoring. The report is defective in that there are no 'control' wells. The study failed to test in any area where no pollution could be expected. The 'pollution' indicated, in the absence of controls, could be mere background noise to be found anywhere in CT.

                              Very truly yours,



                              Joel R. Anderson
c:
Michael Pace, 1st Selectman   Betsey Wingfield, Bureau Chief
Town of Old Saybrook          Bureau of Water Protection
302 Main St                   & Land Reuse
Old Saybrook CT 06475         Dep't of Environmental Protection
                              79 Elm St
                              Hartford CT 06106-5127