From: Gerald Fisher
Sent: Mon Oct 17 12:07:45 2016
To: Elizabeth Klein; Dan Huff
Cc: Deborah Rogge; Jimmy Thompson; Jason Griswold; Stephen Clark; Leota Childress; Glen Boreth; Chaunee Seifried; Rod Lucich; Kelly Richardson
Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period
Importance: Normal
Microsoft Exchange Server;converted from html;
Hi Elizabeth,
The 1977 treatment plant plans show the high water level at 12 feet and the top of the lagoons at 15 feet. The desirable range for treatment is between 8 and 9 feet.
The revision to the permit will likely take place before the end of our current permit which is June 01, 2019. The permit started on June 01, 2014.
DEQ said they would not approve the discharge but would take our request and the circumstances behind our request into consideration when turning information over to the branch of DEQ that issues fines for permit violations.
The City risks violating its permit by not holding water until November 01. We cannot hold the water onsite and the effluent currently meets all of the criteria for discharging to the river now except for the date. We have to discharge to protect the integrity of our lagoons.
DEQ recommended we meet all of the discharge requirements in our permit even if we couldn’t meet the date requirement. As of today, we are meeting the discharge requirements and have 2.5 MGD flowing into the plant from our collection system.
Again, I will reiterate that it will take some time to fix all of the issues we have with the wastewater system as a whole.
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
CONFIDENTIALITY NOTICE: The information contained in this email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and have received this communication in error, please contact the sender by reply email and destroy all copies of the original message. Thank you.
From: Elizabeth Klein [mailto:eklein@cityofmolalla.com]
Sent: Wednesday, October 12, 2016 8:12 AM
To: Dan Huff
Cc: Deborah Rogge ; Jimmy Thompson ; Jason Griswold ; Stephen Clark ; Leota Childress ; Glen Boreth ; Gerald Fisher ; cseifried@cityofmolalla.com; Rod Lucich ; Sadie Cramer ; Diana Hadley
Subject: Re: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period
Hello,
Thank you for the update. A few questions:
The discharge to the Molalla River will begin tomorrow morning and will be monitored to maintain the safest maximum lagoon depth possible.
Our lagoons are currently at approximately 12 feet and rising.
- What is the safest Maximum lagoon depth?
- What is the desirable range for lagoon depth?
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.
- Did the DEQ approve this revision request and / or how long of a process is it "normally" to get a request reviewed and responded to?
-What risk is the City facing if the request is denied and/or the City proceeds to discharge without receiving approval?
DEQ is fully aware of our situation and has provided us with advice for this proceeding.
- Would you be able to provide us a little more detail about what the DEQ advice included?
Thank you!
Elizabeth Klein
City Council
City of Molalla
503-829-6855
From: "Dan Huff" dhuff@cityofmolalla.com>
To: "Deborah Rogge" drogge@keycarpetsllc.com>, "Jimmy Thompson" jthompson@cityofmolalla.com>, "Jason Griswold" jgriswold@cityofmolalla.com>, "Stephen Clark" sclark@cityofmolalla.com>, "Leota Childress" lchildress@cityofmolalla.com>, "Elizabeth Klein" eklein@cityofmolalla.com>, "Glen Boreth" gboreth@cityofmolalla.com>
Cc: "Gerald Fisher" gfisher@cityofmolalla.com>, cseifried@cityofmolalla.com, "Rod Lucich" rlucich@molallapolice.com>, "Sadie Cramer" cityrecorder@cityofmolalla.com>, "Diana Hadley" dhadley@lincc.org>
Sent: Tuesday, October 11, 2016 5:16:29 PM
Subject: FW: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period
Mayor and Council – Based on numerous conversations with DEQ we will be discharging to the river beginning tomorrow. Please take a look at Gerald Fisher’s e-mail below that will give you the basis for this process and procedure. We have been discussing discharge components with DEQ for at least two-years to no avail. However, DEQ is fully aware of our situation and has provided us with advice for this proceeding.
Dan Huff
City Manager
City of Molalla, Oregon
(503) 829-6855
_______________________________________________________________________________
PUBLIC RECORDS LAW DISCLOSURE
This e-mail is a public record of the City of Molalla and is subject to public disclosure unless exempt from disclosure under Oregon Public Records Law. This e-mail is subject to State Retention Schedule
From: Gerald Fisher [mailto:gfisher@cityofmolalla.com]
Sent: Tuesday, October 11, 2016 3:00 PM
To: YELTON-BRAM Tiffany tiffany.yelton-bram@state.or.us>
Cc: COLE David david.cole@state.or.us>; WILLIAMS Karen karen.williams@state.or.us>; Jason Clifford jclifford@cityofmolalla.com>; BAILEY Randall randall.bailey@state.or.us>; Dan Huff (Molalla) dhuff@cityofmolalla.com>; J.W. Ring (Ring-Bender) jwring@ringbenderlaw.com>; Mark Strandberg (Ring-Bender) MStrandberg@ringbenderlaw.com>
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 1st and October 31st 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
CONFIDENTIALITY NOTICE: The information contained in this email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient and have received this communication in error, please contact the sender by reply email and destroy all copies of the original message. Thank you.