From: Jennifer Cline
Sent: Thu May 05 08:57:42 2016
To: geraldf@pdgnw.com; leeb@pdgnw.com
Cc: Jason Clifford; Dan Huff
Subject: FW: Comments on the Molalla O&M manual.
Importance: Normal
Hi Lee
Lee schedule a meeting in the next couple of weeks to go over these comments and recommendations below. Please provide a few times that work for your schedule.
Regards,
Jennifer Cline, P.E. | Public Works Director
Licensed in OR, WA
117 N Molalla Ave. | PO Box 248 * |Molalla, OR 97038
O: 503.759.0218 | F: 503.829.3676
From: BAILEY Randall [mailto:Bailey.Randall@deq.state.or.us]
Sent: Thursday, May 05, 2016 8:46 AM
To: 'Jennifer Cline (Molalla)' <jcline@cityofmolalla.com>
Cc: YELTON-BRAM Tiffany <YELTON-Bram.Tiffany@deq.state.or.us>; COLE David <COLE.David@deq.state.or.us>; PINNEY Mike <PINNEY.Mike@deq.state.or.us>
Subject: Comments on the Molalla O&M manual.
Good Morning, Jennifer.
After our meeting, we have gone through the O&M plan(s) and put together some comments to give you some direction on the revisions:
First, my comments:
I looked at the Biosolids Management Plan (2014) and the current Recycled Water Use Plan and the 2015 I&I reduction plan in addition to the 2008 O&M plan. Among these plans I do not find an adequate plan for the management of the lagoons. The lagoons are an integral part of Biosolids management, Recycled Water management and wastewater treatment and must be operated and maintained to perform all 3 tasks.
I think that for this facility it makes sense to pull this information into the O&M manual. The Biosolids and Reclaimed water plans currently contain parts of the information that need to be coordinated.
The O&M plan should identify how much water storage is necessary in the ponds to avoid over filling during reasonably expected events, how much solids can be accommodated, when the sludge needs to be measured ,and when it must be removed to maintain an adequate volume of water storage. This is of course a long term plan and requires consideration of the plant design and flows.
The O&M plan should contain the strategy used to manage the water levels during the discharge and re-use seasons. I think the plan should include target levels and SOPs to always be working responsibly toward the targets. The goal is to always be at the target levels or be moving expeditiously towards it (no matter what the immediate weather forecast is).
A crucial part of the recycled water management is the applicators (sprinklers). I am assuming that the City has responsibility for these (?). I think the plan should identify how much sprinkler capacity needs to be available and how that is maintained. Sprinklers break down (a lot) and waiting for excessive periods for parts or repairs can put the operation behind. I think the City should have a written decision process to decide when to wait for parts and when to rent another sprinkler. There are other pieces of the operation that are critical as well. (but few are as failure prone.)
I know this is getting detailed, but for this part of the operation it is important.
This is the major gap that I see in the current O&M plan.
This plan helps to identify what is within the city’s “reasonable” control.
Also, David Cole had some specific comments on the current O&M manual.
· Update Table 2-3, p. 2-13, to show David Cole, and not Lyle, as the DEQ contact.
· Update Table 2-3, p. 2-13, to include Matt Michel, Canby’s General Manager, as the contact for Canby Utility, since Canby gets their drinking water from the Molalla River, downstream of Molalla’s outfall.
· Update the Maintenance section, p. 3-2, to include annual flow meter calibration/verification/certification, for the influent flow meter, the effluent flow meter, and the recycled water flow meter, as required in their permit, Tables B1, B2 and B9, respectively.
· Section 4.5, Control Systems, Description, p. 4-6. The text simply reads, “To be included in final document”. I’d like to know when, or request a hard delivery date, for submitting the “final document”, with the complete description of the Control System.
· The document’s table of contents lists six appendices. These include the following: (A) NPDES permit, (B) Recommended Publications, (C) Standard Operating Procedures (City to provide), (D) Equipment O&M manuals (Bound Separately), (E) As-Built Drawings (Bound Separately), and (F) MSDS (Bound Separately). I’d like to request they submit their “final document” to include Appendices B and C, since the rest we already have or should be able to get from them upon request or inspection.
And finally,
Our Senior Engineer Mike Pinney reviewed the current plan and had the following comments:
For the 2008 O&M from 2008 tetratech:
· The general description should discuss the plant history and Sequence of improvements to date.
· The plan needs an Aerial photo or plan with piping / water flow directions through the plant
o Locate everything
o Include Utilities locations
· SOP’s need to be incorporated into the O&M plan.
· All “refer to manufacturer for O&M requirements” should be replaced by the actual requirements for those equipment pieces and sub-pieces. The operator should not have to refer to the manufacturers material except in extreme conditions where it needs to be rebuilt or returned to the manufacturer. (A table of requirements? {Randy’s comment})
· Needs some description of the SCADA system and its upkeep.
· Computer systems, their backup storage and restart, location of programs, location of program documentation, usually not mentioned, would probably be wise to include.
· Pictures and diagrams, troubleshooting matrix and maintenance schedule matrix all welcome in this document.
· Does the City have an Asset Management Program? EPA has a free one called CUPSS. Here is a link
https://www.epa.gov/dwcapacity/information-check-program-small-systems-cupss-asset-management-tool
(Our State Revolving Fund folks have some experience with it and have helped some cities get started. {Randy’s comment})
I hope this helps focus the effort.
Please feel free to ask questions if any of this doesn’t make sense.
Randy Bailey NW Region, OR DEQ
503-229-5019 bailey.randall@deq.state.or.us
From: YELTON-BRAM Tiffany
Sent: Friday, April 29, 2016 9:04 AM
To: BAILEY Randall
Subject: RE: Molalla O&M manual.
I think that would be great. Please let them (and me) know when that review might be done. It let’s be clear with them now that what we want from them is more comprehensive than what might “normally” be asked for since to manage their lagoon system well given the constraint of a limited period of time they can discharge to the Molalla River, their I&I plan, Recycled Water Plan and Biosolids Mgmt plans by necessity must be well integrated into the all over management of the plant.
From: BAILEY Randall
Sent: Friday, April 29, 2016 9:01 AM
To: YELTON-BRAM Tiffany
Subject: RE: Molalla O&M manual.
Perhaps we should tell Molalla that we are reviewing the plan and preparing a list of comments?
Then send them all together?
Randy Bailey NW Region, OR DEQ
503-229-5019 bailey.randall@deq.state.or.us
From: YELTON-BRAM Tiffany
Sent: Thursday, April 28, 2016 6:13 PM
To: BAILEY Randall
Subject: FW: Molalla O&M manual.
Hi Randy
Please share these comments with Molalla if they haven’t already been shared.
Tiffany
From: YELTON-BRAM Tiffany
Sent: Friday, March 04, 2016 2:27 PM
To: COLE David
Cc: PINNEY Mike
Subject: RE: Molalla O&M manual.
Thanks for filling me in. I just spoke to Mike Pinney and he will review the manual and then the combined comments and requests from both of you can go to Molalla. Mike knows that the reason this document was requested now is to be a part of the BRC review of the bypass. Let’s see what he says before you finish your enforcement document.
I will forward Mike the link to the document.
Tiffany
From: COLE David
Sent: Friday, March 04, 2016 1:54 PM
To: YELTON-BRAM Tiffany
Cc: COLE David
Subject: Molalla O&M manual.
Hi Tiffany. I did a quick (1-hour +) review of their 86-page manual, dated January 2008, from Tetra Tech, and have the following concerns:
· Update Table 2-3, p. 2-13, to show me, and not Lyle, as the DEQ contact.
· Update Table 2-3, p. 2-13, to include Matt Michel, Canby’s General Manager, as the contact for Canby Utility, since Canby gets their drinking water from the Molalla River, downstream of Molalla’s outfall.
· Update the Maintenance section, p. 3-2, to include annual flow meter calibration/verification/certification, for the influent flow meter, the effluent flow meter, and the recycled water flow meter, as required in their permit, Tables B1, B2 and B9, respectively.
· Section 4.5, Control Systems, Description, p. 4-6. The text simply reads, “To be included in final document”. I’d like to know when, or request a hard delivery date, for submitting the “final document”, with the complete description of the Control System.
· The document’s table of contents lists six appendices. These include the following: (A) NPDES permit, (B) Recommended Publications, (C) Standard Operating Procedures (City to provide), (D) Equipment O&M manuals (Bound Separately), (E) As-Built Drawings (Bound Separately), and (F) MSDS (Bound Separately). I’d like to request they submit their “final document” to include Appendices B and C, since the rest we already have or should be able to get from them upon request or inspection.
Other than that, the manual seems to be quite thorough and detailed.
Your thoughts?
David Cole, R.G.
Water Quality Specialist
DEQ - Northwest Region & Western Region
700 NE Multnomah Street, Suite 600
Portland, OR 97232
503-229-5011 (P)
503-229-6957 (F)