From: Gerald Fisher
Sent: Mon Oct 10 17:56:07 2016
To: Jason Clifford
Cc: Dan Huff (Molalla)
Subject: RE: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period
Importance: Normal
Hi Jason,
Can you send me a copy of the DMR you submitted to DEQ? We can discuss and then get a response back to DEQ. Biosolids happened on the 26th-28th if memory serves and I think the turbidity was high until the new media was installed. Once I confirm the answer with you then we can respond back to DEQ regarding her questions below as well as our ongoing steps to minimize I&I and the fact that we had to maintain the lagoon levels for the leak test. I spoke with her on the phone and it sounds as if they will notify us of a violation but it likely won’t result in any fines. Keep doing the best we can and when we have to discharge let’s keep it to a minimum until we pass our Oct 31st date and then we can go full blast to get you back down to where you need to be. We can also say that in our response.
Regards,
Gerald Fisher, P.E. | Public Works Director
City of Molalla
117 N Molalla Ave. | PO Box 248 |Molalla, OR 97038
Office: 503.829.6855 | Direct: 503.759.0218
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From: YELTON-BRAM Tiffany [mailto:tiffany.yelton-bram@state.or.us]
Sent: Monday, October 10, 2016 5:18 PM
To: Jason Clifford <jclifford@cityofmolalla.com>; Dan Huff (Molalla) <dhuff@cityofmolalla.com>; 'Gerald Fisher' <gfisher@cityofmolalla.com>
Cc: COLE David <david.cole@state.or.us>; WILLIAMS Karen <karen.williams@state.or.us>; BAILEY Randall <randall.bailey@state.or.us>
Subject: City of Molalla request to discharge to the Molalla River in advance of the November 1 discharge period
Dear Jason, Dan and Gerald,
In response to Jason’s request today, I want to provide a little background. When DEQ issued the current NPDES permit in May of 2014, we needed to remove language found in the permit before this one, that had allowed off season discharge if DEQ approved in writing. DEQ does not have the authority to allow discharges outside of the time periods established in Total Maximum Daily Load (TMDL) documents unless that document has language allowing conditional discharges (such as when the flow in the river is a certain level and other criteria are met). The current TMDL does not have this conditional discharge language and we had to align the permit with the TMDL.
This is one of the main reasons that we have been working with Molalla to assure that the collection and treatment system are operated in such a way that the city can show that the infiltration and inflow are being addressed, recycled water application maximized, and other aspects of operations and maintenance (such as biosolids removal), are planned and carried out to do the best the city can with the current lagoon capacity.
If the city has done the best it can to manage the system, and rain and influent flows are still such that the lagoon levels are no longer in the optimal range, then discharge to the Molalla River could be the decision that the city needs to make. DEQ cannot give you express permission to do this, but our enforcement response would consider the actions within Molalla’s control that have or have not been taken to prepare for rain events in the “shoulder” seasons. Shoulder seasons are those periods of time just before or after the calendar dates when river discharge switches to land application and vice versa. Discharge to Bear Creek, which is not currently a permitted discharge point, would be evaluated differently than out of season discharge to the Molalla River.
In reviewing the September DMR, we noticed that the lagoon levels were in the 9 foot range for the month. What caused the steep upward spike now? We also noted that turbidity exceedances and application of something to a “Mt. Hope Road” site were noted. Please explain the cause of the turbidity exceedance and what was applied to the Mt. Hope Road site.
Thank you. We’d appreciate your response by the end of the week.
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: Jason Clifford [mailto:jclifford@cityofmolalla.com]
Sent: Monday, October 10, 2016 11:47 AM
To: 'COLE David'
Cc: Dan Huff; Gerald Fisher
Subject: molalla wwtp discharge
Dave,
As of this morning, 10/10, our lagoon levels are at 11’ and 12.5’. Our incoming influent flow from yesterday was 1.8 mgd. Our weekend rainfall at the WWTP was 2.75”. Coleman Ranch cannot be irrigated at this point in time. With 21 days left in this month, the city’s lagoons will not be able to sustain a plant shutdown and hold incoming flows. I am asking the DEQ for approval to commence an early discharge to the Molalla River in order to prevent structural damage to our levees and for our lagoon levels to reach critical levels that will cause issues in the coming winter months. As of 0500 this morning, the Molalla River reading was 1026 cfs. Our lagoon temperatures are below the required 18 degree C. Please respond to this request at your earliest convenience. Thank you for your time.
Respectfully,
Jason Clifford
503-793-5283