COMPLAINT abou postted Molalla document: molalla_wastewater_improvements.pathway_to_regulatory

From: Susan Hansen

Sent: Fri Feb 16 13:49:36 2018

To: YELTON-BRAM Tiffany; wwtp@cityofmolalla.com

Cc: MINER Jason * GOV; BACHMAN Jeff; AUNAN Lauri * GOV; PINNEY Mike; DECONCINI Nina; rdavis@oregonian.com; WHITMAN Richard; WHEELER Sarah

Subject: COMPLAINT abou postted Molalla document: molalla_wastewater_improvements.pathway_to_regulatory_compliance.pdf

Importance: Normal

Dear Tiffany,

Per your responses to my questions, I now wish to file a formal complaint about Molalla's posted "pathway to regulatory compliance" online document. You have confirmed a false statement was made about "mistakes" and that in no way is any amended plan a sure bet. Please ask the City of Molalla to correct its false and misleading statements. Not only is this an attempt to mislead the interested public, it is also less than flattering to DEQ to suggest "mistakes" were made. The Molalla community deserves to understand the whole truth, not lies and half truths, about the regulatory process that is in progress.

Susan Hansen

Bear Creek Recovery

> -----Original Message-----

> From: tiffany.yelton-bram@state.or.us

> Sent: Fri, 16 Feb 2018 19:34:14 +0000

> To: foxglovefarm@inbox.com

> Subject: Fwd: Questions about this posted Molalla document:

> molalla_wastewater_improvements.pathway_to_regulatory_compliance.pdf

> Susan,

> The public records request I filled on the 15th (prrHansen7494) includes

> a hand out we provided to the city of Molalla and their consultants

> during our meeting on 1/26/2018 that is relevant to your questions.

> Does DEQ accept as fact that there were "mistakes" made in the permit?

> No. The city has asked us if a mistake was made in the 2009 permit and

> carried over to the 2014 permit because Bear Creek is subject to very

> strict limits by rule for Total Suspended Solids (TSS) and Biochemical

> Oxygen Demand (BOD) but the Molalla River is not. Based on the notes we

> have at the time from the permit writer for the 2009 permit, keeping the

> strict standards in the permit even though the discharge point changed

> from Bear Creek to the Molalla River was a decision deliberately made

> because of the consent decree in the city was under at the time and the

> requirement to provide Class A recycled water. On December 18, 2017 and

> January 26, 2018, I shared what I understood the permit writer's notes to

> state with the city. It is possible, though for the permit to be

> amended.

> Is it factual that there is a "Recycled water reuse plan amendment" being

> produce for Molalla and is DEQ in approval of any such "amendment"? If

> so, what is the name of this document? What is being amended and when?

> As you will see from the 1/26/2018 handout, the city asked questions

> about modifying their permit and revising the Recycled Water Plan. At

> this time, we have not received anything from the city in written form

> for a permit modification or a recycled water plan revision. A permit

> modification asking for the opportunity to increase the load of

> pollutants from the existing load comes to DEQ where we evaluate it and

> if we approve, it goes through review by the Environmental Quality

> Commission and public notice and comment. A recycled water plan revision

> is drafted by the city must be approved by DEQ and then is subject to

> public notice and comment.

> Thank you for bringing the document to my attention. I will follow-up

> with the city.

> I hope that this answers your questions.

> Tiffany

> ________________________________

> -------- Original message --------

> From: Susan Hansen <foxglovefarm@inbox.com>

> Date: 2/15/18 10:03 AM (GMT-08:00)

> To: sarah.wheeler@state.or.us, Richard Whitman

> <richard.whitman@state.or.us>

> Cc: rdavis@oregonian.com, DECONCINI Nina <nina.deconcini@state.or.us>,

> BACHMAN Jeff <jeff.bachman@state.or.us>, PINNEY Mike

> <mike.pinney@state.or.us>, lauri.aunan@oregon.gov,

> jason.miner@oregon.gov, YELTON-BRAM Tiffany

> <tiffany.yelton-bram@state.or.us>

> Subject: FW: Questions about this posted Molalla document:

> molalla_wastewater_improvements.pathway_to_regulatory_compliance.pdf

> Ms. Wheeler and Mr. Whitman,

> This is my fourth attempt to get answers to the below questions regarding

> the attached document Molalla has posted about its supposed "pathway to

> regulatory compliance." The initial email on Feb. 12 was sent to several

> DEQ employees who should be familiar with the issues addressed - but no

> response. On Feb. 13 the email was again forwarded to Nina Deconcini - no

> response. I left a message on Feb. 14 for Nina Deconcini on her voice

> mail asking for answers - no response. Please ask DEQ staff to answer the

> following questions asked on Feb. 12 regarding the attached Molalla

> document:

> Attached is a newly posted online Molalla document that is supposed to

> inform about wastewater path to compliance. Some statements are made as

> factual about supposed mistakes in the permit and a post on the timeline

> to compliance features early on the 2018 timeline "2018 wastewater reuse

> in permit compliance / Recycled water reuse plan amendment" tag.

> Does DEQ accept as fact that there were "mistakes" made in the permit?

> Is it factual that there is a "Recycled water reuse plan amendment" being

> produce for Molalla and is DEQ in approval of any such "amendment"? If

> so, what is the name of this document? What is being amended and when?

> Thanks for providing transparency, Bear Creek Recovery is eager to

> understand DEQ's position regarding the statements made in the Molalla

> "pathway to compliance" report.

> Susan Hansen

> Bear Creek Recovery

> -----Original Message-----

> From: foxglovefarm@inbox.com

> Sent: Tue, 13 Feb 2018 15:04:46 -0800

> To: nina.deconcini@state.or.us

> Subject: FW: Questions about this posted Molalla document:

> molalla_wastewater_improvements.pathway_to_regulatory_compliance.pdf

> Dear Nina,

> Bear Creek Recovery requests a prompt answer to the questions below

> related to the attached document which Molalla has posted several places

> on its website. Tiffany is out sick. Please note that the "facts" in the

> posted document would affect how people view DEQ's work regarding

> bringing Molalla into compliance.

> Susan Hansen

> Bear Creek Recovery

> -----Original Message-----

> From: foxglovefarm@inbox.com

> Sent: Mon, 12 Feb 2018 15:29:46 -0800

> To: tiffany.yelton-bram@state.or.us

> Subject: Questions about this posted Molalla document:

> molalla_wastewater_improvements.pathway_to_regulatory_compliance.pdf

> Dear Tiffany (or any other DEQ rep who can answer the questions),