DEQ is overreaching here. We should discuss these issues and carefully think about our response to DEQ. DEQ is not running the plant nor are they deciding priorities for the City.
Jeff
J.W. Ring
[T] (503) 964-6723 office direct
[T] (503) 841-9380 mobile one
[T] (503) 841-8415 mobile two
email: jwring@ringbenderlaw.com
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From: Gerald Fisher [mailto:gfisher@cityofmolalla.com]
Sent: Monday, October 24, 2016 7:10 PM
To: YELTON-BRAM Tiffany
Cc: COLE David; BAILEY Randall; Dan Huff (Molalla); J.W. Ring; Mark Strandberg
Subject: RE: City of Molalla's 2015 I&I Plan
Hi Tiffany,
I&I is specifically called out as project O1 of the CIP and I believe that the update to the wastewater master plan will address many if not all of the concerns raised by Randy. We currently budget $75K per year for I&I work which is almost twice of what the master plan recommended. The current master plan is 16 years old (long in the tooth) and some of the assumptions made back when it was developed may not track with what growth we may be experiencing in the future. We will be wrapping up the Lagoon Leak Test project and the O&M Plan Update project about the time we advertise the Request for Proposals for the master plan update. I am focusing my energy right now on finishing the current projects. Thanks.
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: YELTON-BRAM Tiffany [mailto:tiffany.yelton-bram@state.or.us]
Sent: Friday, October 21, 2016 12:17 PM
To: 'Gerald Fisher' <gfisher@cityofmolalla.com>
Cc: COLE David <david.cole@state.or.us>; BAILEY Randall <randall.bailey@state.or.us>
Subject: City of Molalla's 2015 I&I Plan
Hello Gerald,
I wasn’t sure if you had a copy of this document. The city’s NPDES permit requires an annual report on the progress made on this plan by March 1st for the year prior. In addition to that annual progress report, This I&I plan should adapt to new information and revisions of the plan as a result of new information must be shared with DEQ. The specific actions called out in this plan and future revisions should be included in Capital Improvement Plan and other relevant planning documents.
Randy and I were discussing his review of ht CIP and he has some additional comments to those I’ve shared with you.
· It is not clear that any of the collection system improvements in the CIP are aimed at I&I reduction.
· I&I reduction is key to keeping the facility in compliance and avoiding an overflow. Some of the pipes scheduled for replacement may be major sources of I&I, but we have no information about that.
· The piping size upgrades are good for getting additional flow to the WWTP but how will that impact compliance with the permit? Can the additional flow be treated adequately to meet permit limits and be stored if needed within the current lagoons?
· The treatment plant projects are focused on building more capacity, more storage. I do not see anything aimed at increasing their ability to get rid of water. (more land application area, sprinklers, etc.)
· DEQ believes I&I reduction campaign should be priority and will inform the need for new lagoons and more treatment capacity.
Thanks for your attention, Gerald.
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