Hi All,
Last week I had a phone conversation with Tiffany I believe on 5/31 in regards to the SOP we previously submitted. She wanted to give us a call so that it was NOT a public record. She commented that she was pleased with our work and ask that I add a statement that the City has developed and manages several plans to maximize the holding capacities of the Lagoons. I completed the work on Friday and sent DEQ the update.
Late yesterday I received this email below. Which of course in now a public record.
My thoughts are to reply to David and state: Thank you for providing feedback on the City’s recently developed Seasonal Lagoons SOPs. The comments will be considered and may be implemented during the upcoming update of our O&M Manual. Also, see my comments below.
I don’t understand their methods of managing municipality permits. They make one request and then take a complete opposite action. In my opinion this is NOT good or clear communication.
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: COLE David [mailto:COLE.David@deq.state.or.us]
Sent: Friday, June 10, 2016 4:13 PM
To: 'Jennifer Cline' <jcline@cityofmolalla.com>; 'jclifford@cityofmolalla.com' <jclifford@cityofmolalla.com>
Cc: COLE David <COLE.David@deq.state.or.us>; YELTON-BRAM Tiffany <YELTON-Bram.Tiffany@deq.state.or.us>; BAILEY Randall <Bailey.Randall@deq.state.or.us>
Subject: Improvements to Molalla Seasonal Lagoons SOPs.
Hello Jennifer and Jason. We would like to see the following changes and additions to your lagoon SOPs:
The plans should be clear that the target level is 9 feet for lagoon 1 (same for lagoon 2 if they are connected), and if they are above 10’, facility personnel need to be using all equipment necessary for returning the levels back below 10’.
Add this to both SOP’s:
· Facility personnel will manage lagoons to maintain levels as close to 9 feet as practicable. We already indicate this is optimal level. However, this is not always the best management practice when Operations needs to prepare for holding water at the end of each season. Should not restrict the operator to maintain 9-feet.
Add these to the Summer SOP:
· When conditions result in a lagoon level above 10ft. at the daily reading, facility personnel will maximize irrigation, using all available irrigation equipment. This is not consistent with the maximum design level being 12’.
· Facility personnel will maintain at least enough working irrigation capacity to dispose of 1 million gallons per day during normal irrigation hours. For the winter season this is not needed. This is not a requirement of our permit. And we are always restricted by the recycled water plan that we cannot irrigate 1 MGD when moisture levels do not permit. It is contradictory.
Add this to the Winter SOP:
· When conditions result in lagoon levels above 10 ft. at the daily reading, facility personnel will maximize discharge to the river. Once again, this should not be a restriction. Our maximum design capacity is 12-feet.
The plans should also require that the operator consider how much water needs to be discharged every day so that the lagoons stay below, or can get below, 10 feet as soon as reasonably possible. Not a permit requirement.
The operators should record daily:
· Starting lagoon levels (facility personnel does this already).
· Expected influent (MGD, estimate).
· Planned irrigation/disposal (MGD).
To clarify what this means: Once again, 12’ is the maximum operation level and many factors play into whether the plant irrigates through the weekend, for instance the weather forecast. A 10-ft lagoon operation level is not why we are having lagoon capacity issues. It is obvious the issue we have with the lagoon is due to DEQ restricting the City to hold water during times due to an arbitrary date in the TMDL when the plant could still discharge and meet the Winter discharge permit requirements.
· If lagoon levels are below 10 ft. on Friday during the summer, then weekend irrigation is optional.
· If the lagoons are at 10 ft. or higher during the summer, facility personnel should irrigate to get below 10 ft..
· If the facility deviates from their SOPs, then a violation is not automatic. However, this invites risk. If facility personnel choose to deviate from the SOP, and it leads to an unpermitted discharge to avoid overtopping, or some other violation, then DEQ will consider the violation was not beyond reasonable control, which would likely result in enforcement action.
Please call or email me if you have any questions or concerns about this response. Thank you.
From: Jennifer Cline [mailto:jcline@cityofmolalla.com]
Sent: Friday, June 03, 2016 5:44 PM
To: COLE David
Cc: YELTON-BRAM Tiffany; 'Lee Brennan'; Dan Huff; Jason Clifford
Subject: Final Draft - Seasonal Lagoons SOPs
Hi David,
Attached are the final drafts of the Seasonal Lagoon SOPs that are updates the draft versions submitted in regards to the 2016-WLOTC-1557 letter. Please let me know if you have any questions.
Respectfully,
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
