From: Susan Hansen
Sent: Thu May 19 14:09:09 2016
To: YELTON-BRAM Tiffany
Cc: DECONCINI Nina; HAMMOND Joni
Subject: RE: Letter to Molalla mayor and council members
Importance: Normal
Thanks for responding Tiffany. However, I still believe that it was clear that the "past inaction" on the choked lagoons was the cause of the event in Dec. When a public works director like Howett admits in public, as he did in early 2013 to the meeting we all attended, that he expected the lagoons to overflow onto highway 211 because of all the "inaction" on biosolids, it should have been clear to DEQ that the "inaction" was the cause. And that "inaction" was caused by DEQ allowing Molalla to use lack of adequate funds as an excuse for years to fail to take care of infrastructure problems. We all know that Molalla has barely removed enough biosolids since that meeting to even keep up with incoming load in the recent years so the same problem that Howett noted clearly was at fault. If they had stepped up and found the money to make meaningful removal I would not be noting this, but to me at least it still seems like another whitewash about Molalla's failure to maintain its sewage infrastructure to working standards that protect the public and Bear Creek.
Thanks for any work you can do to demand better compliance. Money can't be the issue any longer, as it was when Howett spoke about Molalla being too broke to hire biosolids haulers to take meaningful amounts to Central or Eastern Oregon where it is easy to dispose of large amounts of biosolids. If they don't remove meaningful amounts and we have more rain events the same thing can be expected to happen again.
Sincerely,
Susan
-----Original Message-----
From: yelton-bram.tiffany@deq.state.or.us
Sent: Thu, 19 May 2016 19:45:56 +0000
To: foxglovefarm@inbox.com
Subject: RE: Letter to Molalla mayor and council members
Dear Susan,
In the letter to the city about the bypass DEQ just sent, we acknowledged that there are two views of the bypass event: the immediate facts of the storm event in December and the history of the past 5 years or so with the city and DEQ. Your point relates to the recent history and DEQ acknowledges this in the letter-
DEQ cannot conclusively say that past action would have prevented the December 2015 bypass, but it
is reasonable to state that, in general, past inaction did not help the city maintain its infrastructure
and maximize lagoon holding capacity. (page 2, second paragraph, last sentence)(emphasis added)
In the past few years, the city had to update Biosolids and Recycled Water plans as well as plan and undertake repair of infiltration and inflow in the collection system. This work continues and DEQ expects that the city will continue towards a state of more efficient management of the collection system and lagoon storage capacity.
Tiffany Yelton Bram
WQ Source Control Manager
Oregon Department of Environmental Quality
700 NE Multnomah St., Suite #600
Portland OR 97232
Desk 503 229 5219
Mobile 503 975 0046
From: Susan Hansen [mailto:foxglovefarm@inbox.com]
Sent: Monday, May 16, 2016 10:24 AM
To: DECONCINI Nina; HAMMOND Joni; YELTON-BRAM Tiffany
Subject: FW: Letter to Molalla mayor and council members
Dear Nina, Tiffany and Joni,
While BCR and I are happy to see the violation letters with the suggestion that Molalla enter into a MAO, I have expressed two concerns to Nina and Tiffany.
First, the violation letter listed past violations but failed to list the Feb. 2016 violations. Tiffany said she would amend the letter to reflect those violations and that she will forward a copy of the amended violation letter. Thanks in advance for that!
Second, to claim that the overflow event of Dec 2015 could not be reasonably have been predicted was, I believe, not true. Tiffany attended a meeting in Molalla on Feb. 20, 2013 (see attached flyer) regarding Molalla's biosolids problem. At that meeting in early 2013, then Public Works Director Howett noted in public in front of Tiffany and city officials that Molalla had a dire problem with biosolids choking the lagoons. Mr. Howett stated that because of money problems Molalla could only consider sites close to the city for biosolids removal and that if such removal didn't happen he predicted that the lagoons would overflow - just as happened in Dec. 2016. So again, I believe it was not true for DEQ to state that this could not have been forseen or prevented. I hope in the future DEQ is more honest in its evaluation. At this stage of the problems we see, I don't believe it is helpful to solving the problems to make what seems to me a false excuse for that event. If adequate biosolids had been removed in a timely manner over the last several years there would have been capacity in the lagoons to hold at least some of what became days of polluted overflow into Bear Creek.
I hope in the future DEQ is more careful when it evaluates the circumstances and reasons for events like the Dec. 2015 polluted water discharge into Bear Creek.
I support your work to bring Molalla into full compliance but that can only happen with honest appraisal of circumstances.
Sincerely,
Susan Hansen
Bear Creek Recovery
-----Original Message-----
From: deconcini.nina@deq.state.or.us
Sent: Mon, 16 May 2016 15:53:42 +0000
To: meador.minnette@deq.state.or.us
Subject: Letter to Molalla mayor and council members
Mimi,
Here is Susan Hansen’s email address for the letter she and I just discussed. Could you please forward it to her electronically?
Thanks!
Nina
Nina DeConcini
Oregon Department of Environmental Quality
NW Region Division Administrator
700 NE Multnomah Street, Suite 600
Portland, OR 97232
Office: 503.229.6271
Mobile: 503.804.0840
Fax: 503.229.6924