Thank you, Jeff, for the follow up. I appreciate the detail in the communication below and I have a question. You described to me the need to discharge wastewater from the lagoons that has been treated but will not be chlorinated and de-chlorinated to Bear Creek, while still discharging fully treated waste water to the Molalla River, in order to prevent “severe property damage” as defined in the current NPDES permit . If that still correct?
This action is called a bypass of the treatment facilities and is described in Condition B3 of Schedule F of the current NPDES permit for the city of Molalla. Subpart c. of B3 describes anticipated and unanticipated bypass. The action that the city is taking today is being treated as an unanticipated bypass, and as such, please follow condition D5 of Schedule F.
The Emergency Response Plan that the city submitted to DEQ should be followed and DEQ requests that we be copied on external communications to the public and media so that we can respond to question we may receive. I will be your point of contact for copies of those communications.
Thank you again.
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: J.W. Ring [mailto:JWRing@ringbenderlaw.com]
Sent: Monday, December 21, 2015 1:36 PM
To: YELTON-BRAM Tiffany; COLE David
Cc: Dan Huff (dhuff@cityofmolalla.com) (dhuff@cityofmolalla.com); Jennifer Cline (jcline@cityofmolalla.com); Christine Hein; Mark Strandberg
Subject: Emergency Bypass Molalla
Tiffany:
I am writing this email to confirm our conversation this morning. Due to the record rainfall Molalla and the rest of Oregon have experienced this month, which shows no sign of letting up, Molalla is experiencing an upset at its wastewater treatment plant. As we discussed that upset is causing us to need to discharge partially treated wastewater into Bear Creek to ensure that the wastewater treatment ponds do not overtop. If the ponds were allowed to overtop, it would likely cause significant structural damage, up to and including the potential failure of one or both Lagoons and serious damage to the remainder of the treatment plant. To ensure that this discharge will have as little an effect as possible, Molalla will take the following steps, as we agreed to on our call:
- Complete the 24-hour and 5-day reporting as required in Section D.5 of the City’s NPDES Permit;
- Notify residents and owners of wells adjacent to Bear Creek within one mile downstream of the discharge, by phone, email, or door-to-door contact;
- Post public notification on the City’s website;
- Monitor the volume of the discharge;
- City staff will observe and document carefully that Bear Creek is not overflowing its banks; and
- City staff will conduct sampling upstream and downstream, both before and after the discharge.
We will keep you posted of all further developments.
J.W. Ring - Managing Partner
[T] (503) 964-6723 office direct
[T] (503) 841-9380 mobile one
[T] (503) 841-8415 mobile two
email: jwring@ringbenderlaw.com
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Best,