RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

From: Mark Strandberg

Sent: Wed Oct 12 11:04:10 2016

To: Gerald Fisher

Cc: J.W. Ring

Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

Importance: Normal

Did you get any response from Tiffany?

-Mark

From: Gerald Fisher [mailto:gfisher@cityofmolalla.com]

Sent: Tuesday, October 11, 2016 5:33 PM

To: Mark Strandberg

Cc: J.W. Ring; dhuff@cityofmolalla.com

Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

Will do.

Regards,

Gerald Fisher, P.E. | Public Works Director

City of Molalla

117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038

Office: 503.829.6855 | Direct: 503.759.0218

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From: Mark Strandberg [mailto:MStrandberg@ringbenderlaw.com]

Sent: Tuesday, October 11, 2016 4:57 PM

To: Gerald Fisher <gfisher@cityofmolalla.com>

Cc: J.W. Ring <jwring@ringbenderlaw.com>; dhuff@cityofmolalla.com

Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

This email to Tiffany will need to be posted to the website.

Thanks,

Mark

From: Gerald Fisher [mailto:gfisher@cityofmolalla.com]

Sent: Tuesday, October 11, 2016 3:00 PM

To: YELTON-BRAM Tiffany

Cc: COLE David; WILLIAMS Karen; Jason Clifford; BAILEY Randall; Dan Huff (Molalla); J.W. Ring; Mark Strandberg

Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

Hi Tiffany,

Thanks for looking into this for us. As discussed in our phone conversation yesterday, we need to revise our permit regarding the link between the TMDL and discharge dates.. The dates are arbitrary and do not coincide with real world conditions in Molalla, Oregon.

In answer to your question, we believe that the upward spike in lagoon levels is due to downspout connections in the older parts of town and very heavy rains which are beyond the control of the City. This is consistent with some of the video inspection work we have been doing as part of our I&I project.

The notes on the DMR are related to our Biosolids Land Application project. The City applied biosolids, on September 26-28, to the Mt Hope Road site which was approved by DEQ on July 27, 2015.

The following summarizes our current emergency conditions at the plant:

1. We have received several inches of rainfall over the past week and a half and our flows into the plant have increased to approximately 2MGD.

2. The moisture block readings today at our irrigation locations have exceeded the maximum values (at 75-85%) to allow for irrigation in all but one location.

3. One location is at approximately 20% but contains visible ponding and per our permit and consent decree we are unable to irrigate at that location.

4. In accordance with SOP #32, which was reviewed and approved by DEQ, in the event that the City cannot irrigate between May 1^st and October 31^st due to wet conditions it will be required to discharge to the Molalla River to protect the integrity of the lagoon levees.

5. Our lagoons are currently at approximately 12 feet and rising.

Based on the conditions listed above, the City will be required to discharge treated effluent to the river in order to protect the integrity of our lagoons and to protect Bear Creek. I have instructed our operators to only discharge what is necessary to maintain the integrity of the lagoons and to post notifications at the prescribed locations prior to discharge. The discharge to the Molalla River will begin tomorrow morning and will be monitored to maintain the safest maximum lagoon depth possible.

On November 1st the City will increase our treated discharge to bring the lagoons back down to recommended operating levels. Unfortunately, we have no other options available to us at this time and as per our conversation yesterday, we are implementing our plan to reduce I&I.

Call me if you have any additional questions.

Regards,

Gerald Fisher, P.E. | Public Works Director

City of Molalla

117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038

Office: 503.829.6855 | Direct: 503.759.0218

From: YELTON-BRAM Tiffany [mailto:tiffany.yelton-bram@state.or.us]

Sent: Monday, October 10, 2016 5:18 PM

To: Jason Clifford <jclifford@cityofmolalla.com>; Dan Huff (Molalla) <dhuff@cityofmolalla.com>; 'Gerald Fisher' <gfisher@cityofmolalla.com>

Cc: COLE David <david.cole@state.or.us>; WILLIAMS Karen <karen.williams@state.or.us>; BAILEY Randall <randall.bailey@state.or.us>

Subject: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period

Dear Jason, Dan and Gerald,

In response to Jason’s request today, I want to provide a little background. When DEQ issued the current NPDES permit in May of 2014, we needed to remove language found in the permit before this one, that had allowed off season discharge if DEQ approved in writing. DEQ does not have the authority to allow discharges outside of the time periods established in Total Maximum Daily Load (TMDL) documents unless that document has language allowing conditional discharges (such as when the flow in the river is a certain level and other criteria are met). The current TMDL does not have this conditional discharge language and we had to align the permit with the TMDL.

This is one of the main reasons that we have been working with Molalla to assure that the collection and treatment system are operated in such a way that the city can show that the infiltration and inflow are being addressed, recycled water application maximized, and other aspects of operations and maintenance (such as biosolids removal), are planned and carried out to do the best the city can with the current lagoon capacity.

If the city has done the best it can to manage the system, and rain and influent flows are still such that the lagoon levels are no longer in the optimal range, then discharge to the Molalla River could be the decision that the city needs to make. DEQ cannot give you express permission to do this, but our enforcement response would consider the actions within Molalla’s control that have or have not been taken to prepare for rain events in the “shoulder” seasons. Shoulder seasons are those periods of time just before or after the calendar dates when river discharge switches to land application and vice versa. Discharge to Bear Creek, which is not currently a permitted discharge point, would be evaluated differently than out of season discharge to the Molalla River.

In reviewing the September DMR, we noticed that the lagoon levels were in the 9 foot range for the month. What caused the steep upward spike now? We also noted that turbidity exceedances and application of something to a “Mt. Hope Road” site were noted. Please explain the cause of the turbidity exceedance and what was applied to the Mt. Hope Road site.

Thank you. We’d appreciate your response by the end of the week.

Tiffany Yelton Bram

WQ Source Control Manager

Oregon Department of Environmental Quality

700 NE Multnomah St., Suite #600

Portland OR 97232

Desk 503 229 5219

Mobile 503 975 0046

From: Jason Clifford [mailto:jclifford@cityofmolalla.com]

Sent: Monday, October 10, 2016 11:47 AM

To: 'COLE David'

Cc: Dan Huff; Gerald Fisher

Subject: molalla wwtp discharge

Dave,

As of this morning, 10/10, our lagoon levels are at 11’ and 12.5’. Our incoming influent flow from yesterday was 1.8 mgd. Our weekend rainfall at the WWTP was 2.75”. Coleman Ranch cannot be irrigated at this point in time. With 21 days left in this month, the city’s lagoons will not be able to sustain a plant shutdown and hold incoming flows. I am asking the DEQ for approval to commence an early discharge to the Molalla River in order to prevent structural damage to our levees and for our lagoon levels to reach critical levels that will cause issues in the coming winter months. As of 0500 this morning, the Molalla River reading was 1026 cfs. Our lagoon temperatures are below the required 18 degree C. Please respond to this request at your earliest convenience. Thank you for your time.

Respectfully,

Jason Clifford

503-793-5283