From: HAMMOND Joni
Sent: Thu Sep 25 13:26:28 2014
To: YELTON-BRAM Tiffany
Cc: DECONCINI Nina
Subject: Fwd: RE: I and I report for Molalla
Importance: Normal
Attachments: Integrated Water Resources Strategy commentsedit.docx; -------- Original message -------- From: Susan Hansen Date:09/25/2014 12:06 PM (GMT-08:00) To: HAMMOND Joni Subject: RE: RE: I and I report for Molalla Thanks Joni. DEQ might be trying, in the record keeping department, to hold Molalla to a higher standard, but from the recycled water discharge practices I observed all summer long they are not holding themselves to a standard of avoiding ponding, avoiding runoff into creeks and avoiding over saturation of fields. They set sprinklers and let them run for days in the same place, they are only using limited areas because they are either too lazy to move the sprinklers or they don't have enough pipe hook ups in the ground to irrigate wider areas of the approved sites. I know DEQ can't go out and inspect day by day but I certainly can and do - and I document it with my camera. We have had it with any excuses about being too poor or too understaffed for Molalla to meet standards. They continue to stuff in big developments - a giant apt complex and a number of blocks of single family houses - yet they still fail to meet standards or to upgrade. As far as I know their utility rates are low compared to competent cities - and I see those competent cities frankly telling their citizen residents that rates have to rise to meet environmental standards. Until Molalla is forced to face that fact I expect they will continue to fail. Also, I have seen no progress with Coleman ranch as far as heeding what ODA told them must be done to protect water quality. I am waiting for the report of their visit on Sept 18 but I already know nothing has been done to correct the extensive problems - yet Coleman ranch is the big receiver of the recycled water. When DEQ allows recycled water discharge on fields that contain huge amounts of manure and have cattle wallowing in the creeks that then drain into the city or into rural areas, DEQ is failing to protect the public. As I noted in the past, those creeks and that groundwater goes to areas of rural dwellers on wells and to even city dwellers on wells - and some of the contaminated water daylights in city neighborhoods. I hope that DEQ is working closely with DOA on those issues. It was my understanding that there is supposed to be progress toward an Integrated Water Strategy - I submitted comments about that to the proper oversight (see attached) but so far it still seems that each agency wants to pass the buck at some dividing line. There is no way that the recycled water doesn't add to the E.Coli problems we saw this summer - the creek would not have been running unless there was recycled water in use on the fields. As soon as the rains start in earnest the fields will drain the manure back into the water. By the way, that heavy rain we just had was not enough to make Creamery Creek flow - but that recycled water over application around Aug. 25 flooded the creek and made if flow for days in the hottest, driest part of summer so you can imagine how much recycled water was over applied. Thanks again for being accessible and proactive. I really appreciate that! Sincerely, Susan Hansen -----Original Message----- From: hammond.joni@deq.state.or.us Sent: Thu, 25 Sep 2014 18:10:01 +0000 To: foxglovefarm@inbox.com Subject: RE: RE: I and I report for Molalla Susan: I asked Tiffany to answer the questions in your email. Her reply is below. I agree with you that we need to do a better job of holding Molalla accountable for meeting all of their permit conditions. I believe we are doing that now. Best Joni Joni: I see that Susan has concerns about the standard to which DEQ is holding Molalla respective to their compliance with their NPDES permit. Specific to Infiltration and Inflow (I&I) it is true that an annual report is required annually to summarize the work to correct I&I completed by the city in the past calendar year. In March of 2014, Molalla should have reported on the progress made in 2013. What I shared with Susan includes what Molalla submitted in 2013 for calendar year 2012. Lyle told Marc that the submittal was not sufficient. The information I forwarded to Susan also includes an e-mail from Marc Howatt to Lyle dated July 16, 2013, that summarized some scoping of I&I problems with a camera in a portion of the Molalla collection system. This is the extent of the work that was done in 2013, according to the documentation Molalla has since Marc’s departure. Molalla did not, as they said they would do in March of 2013, take this data and put it into a report form showing what was done, what was completed and what is still pending. I accept responsibility for not assuring that they submit this level of detail (the summary of what was done, and what still needs to be done) by March 1 of 2014. I have spoken with the city and confirmed that the July 16, 2013 e-mail does document the extent of the I&I work. I decided that having the city re-write this information into a 2014 report at this time would not result in more useful or different information. I have accepted this as meeting the March 2014 requirement. During the Spring and Summer of 2014, I had meetings with the city where they stated that a more comprehensive I& I study to determine the overall status of the collection system and associated infrastructure would be created. Section 1 of Schedule D in the NPDES permit issued to Molalla sets a clear requirement that within 180 days of issuing the permit, the city would submit for approval an Inflow Removal Plan. This plan then becomes the benchmark by which annual progress will be measured. I will be following up with the city on Tuesday, September 30th, about the progress on this plan. I have set the expectation with my staff that annual reports required by permits are to be recorded when received and reviewed. If the report is not complete, it will be returned to the facility. I will also be following our enforcement guidance to any subsequent enforcement action. Tiffany From: Susan Hansen [mailto:foxglovefarm@inbox.com] Sent: Tuesday, September 23, 2014 1:33 PM To: HAMMOND Joni Subject: FW: RE: I and I report for Molalla Dear Joni, We have ongoing concerns, as you know, about DEQ's failure to hold Molalla to the highest standards on their wastewater issues. Below is a message from Tiffany about this year's I&I report. First, in past years Molalla failed to even file a report - your employee Lyle questioned why two years of reports didn't get filed and Molalla wrote that it was short of money. Lyle actually accepted that excuse. This year a report was due in March and it was not filed on time because Tiffany noted that. Now Tiffany notes that whatever this is dated in 2013 isn't up to expectations. So is this actually what was accepted for the March 2014 report? Or is it what was sent in 2013 and still no 2014 report has been filed as required in March 2014 because I see nothing in this package dated 2014. How many more chances does Molalla get with DEQ before it is REQUIRED to do things correctly? Why do years go by with DEQ accepting no or shoddy reports? Aside from the damage it does to the environment and to the failure to fix failing infrastructure, Molalla is an insult to all the cities that follow the rules and do things correctly. Not being able to afford to do things right is not an excuse. Loss of staff can't be an excuse. Sincerely, Susan Hansen Bear Creek Recovery -----Original Message----- From: yelton-bram.tiffany@deq.state.or.us Sent: Tue, 23 Sep 2014 01:12:13 +0000 Subject: RE: I and I report for Molalla Hi Susan I am attaching what they have sent to date. We are meeting with the new public works director, Jennifer Cline, next week and we’ve communicated expectations for future I&I reports that should provide more concise and thorough reporting. The person who scanned it did it upside down. You may wish to print it and then arrange the pages for reading. Tiffany Yelton Bram Water Quality Source Control Section Manager Water Quality Program, NW Region Oregon Department of Environmental Quality 2020 SW 4th Ave., Suite 150 Portland OR 97201-4987 desk 503 229 5219 mobile 503 975 0046 From: Susan Hansen [mailto:foxglovefarm@inbox.com] Sent: Monday, September 22, 2014 5:57 PM To: YELTON-BRAM Tiffany Subject: I and I report for Molalla Dear Tiffany, I have made several requests to you about whether or not Molalla has filed an I and I report for this year. You had told me that it was not filed on time in March 2014 because they lost their public works manager. You also said recently you would check to see if it was submitted yet and would let me know. I would appreciate an answer - did they file an I and I report late or is it still not filed? Thanks, Susan Hansen Bear Creek Recovery