Molalla's excuse that "too much rain" caused wastewater permit violations

From: Susan Hansen

Sent: Mon Jul 10 11:40:00 2017

To: Richard Whitman; DECONCINI Nina; YELTON-BRAM Tiffany; BACHMAN Jeff

Cc: wwtp@cityofmollala.com; jason.miner@oregon.gov; jthompson@cityofmolalla.com; cdragowsky@cityofmolalla.com; dpalumbo@cityofmolalla.com; kswigart@cityofmolalla.com; gboreth@cityofmolalla.com; eklein@cityofmolalla.com

Subject: Molalla's excuse that "too much rain" caused wastewater permit violations

Importance: Normal

Attachments: DEQ submission Molalla May-June 2017 temperature and rainfall chart.pdf; Molalla big gun irrigation.jpg; Molalla big gun irrigation (2).jpg; Molalla big gun irrigation (3).jpg; BCR DEQ Molalla Wastewater Discharge Violations.docx;

July 10, 2017

Dear Oregon DEQ,

Regarding the City of Molalla's claim that too much rain caused the City of Molalla to have to illegally discharged for 24 days into the Molalla River in May/June of 2017, a Class One violation, please find attached a chart of temperature and rainfall for Molalla for May/ June 2017, complied by a Bear Creek Recovery member (with comments).

Bear Creek Recovery strongly protests any suggestion that too much rain is the cause of Molalla's ongoing discharge violations. We have participated since 2012 with DEQ on wastewater/ biosolids/ lagoon issues. We know that violations such as these 2017 discharge violations, as well as the 20 days of discharge violations in October 2016, are caused by Molalla's failure to maintain enough lagoon capacity to accommodate Oregon's weather. Another well-known factors are that the I&I shows that far too much groundwater infiltrates Molalla's aging collection system pipes and there is no adequate storm water program to keep storm water from filling the lagoons. The growing amount of Molalla's sewage as the city adds ever more dwellings is yet another factor.

Please also consider the attached documents from the May 24 Molalla City Council meeting where Molalla Public Works sought approval for "big gun" land application expenses because "Wastewater treatment staff is concerned about increasing mechanical and control issues" for the "big gun". Why didn't the Molalla Wastewater staff seek approval and receive delivery of this needed equipment well in advance of ground application season? Public Works notes in the attached that "failure of one or more of the irrigation units may cause a permit violation"? This speaks of City of Molalla's failure to plan ahead and pay for needed upgrades to keep from violating. Did the City delay land application and violate its permit with 24 days of non-permitted discharge because its irrigation equipment was not sound enough to trust in 2017?

Bear Creek Recovery disputes any actions that absolve the City of Molalla from responsibility for violating any conditions of its permit.

Sincerely,

Harlan Shober, President

Susan Hansen, Vice President

Bear Creek Recovery Board of Directors