FW: 3 updates: wastewater treatment and collection system work sheet; prolonged ponding and minor to major

From: Susan Hansen

Sent: Fri Apr 17 14:05:05 2015

To: DECONCINI Nina; HAMMOND Joni

Subject: FW: 3 updates: wastewater treatment and collection system work sheet; prolonged ponding and minor to major

Importance: Normal

I just got off the phone with Nina complaining about how DEQ has handled Molalla. I find it stunning that Tiffany can't find the work sheet for the classification of Molalla's wastewater system. And why use subjective words about "ponding" if they have no meaning? This is very much of concern that a state agency would not be able to provide vital records and that it constantly allows vague subject terms to be used on plans designed to protect the environment.

Susan Hansen

Bear Creek Recovery

-----Original Message-----

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

Sent: Fri, 17 Apr 2015 21:00:10 +0000

To: foxglovefarm@inbox.com

Subject: 3 updates: wastewater treatment and collection system work sheet; prolonged ponding and minor to major

Hello Susan

I want to update you on three requests that you have asked of me.

1)A copy of the wastewater classification work sheet for the Molalla Wastewater Treatment Plant and collection system—As I began I working on your public records request for a copy of the work sheet, I have found that it is missing in our files. We have looked thoroughly for it and we have asked the city if they have a copy (we often send the facility a copy as a courtesy). So at this point in time, I cannot provide a copy of our original work. We are in the process of recreating the worksheet and will try to provide you a copy by April 30, 2015.

2) Definition of prolonged ponding-- The term “prolonged ponding” is not present in Oregon Statue(Chapter 454) or Oregon Administrative Rules(340-055) related to recycled water. The term ponding is used in the August 29, 2014, version of the city of Molalla’s Consolidated Recycled Water Use Plan. In the plan, ponding is described as a means by which the users of the plan will visually monitor for and adjust the irrigation in response to the presence of ponding.

For DEQ, we would make a determination as to whether a violation of the recycled water rules occurred for Class A recycled water based on indications of the recycled water running off site. Per the plan, DEQ expects that the regulated entity would recognize that the recycled water application arrangement was not working and would be expected to make the needed adjustments. The presence of ponding on an application site of Class A recycled water is not a violation of Oregon regulations.

3)Minor to Major—There are two sets of terms that mean roughly the same thing: major and minor and Tier 1 and Tier 2. The Clean Water Act uses the terms major and minor and our state rules use the terms Tier 1 and Tier 2. We use these designations to determine the fees we charge, the level of monitoring we require and the frequency of inspections, among other things. In Oregon Administrative Rules 340-045-0075, we have a definition of a Tier 1 domestic facility. The definition has two parts:

(b) Tier 1 domestic facility. A facility is classified as a Tier 1 domestic facility if the facility:

(A) Has a dry weather design flow of 1 mgd or greater; or

(B) Serves an industry that can have a significant impact on the treatment system.

Please let me know if you have further questions.

Tiffany Yelton Bram

WQ Source Control Manager

Oregon Department of Environmental Quality

2020 SW 4th Ave., Suite 150

Portland OR 97201

Desk 503 229 5219

Mobile 503 975 0046

This spring, DEQ's Northwest Region Office will be moving to a new location - the 700 Lloyd Building at 700 NE Multnomah St., Suite #600, Portland, OR 97232. The target date for operating at the new location is May 18^th, 2015.