From: Jennifer Cline
Sent: Tue Apr 21 12:42:09 2015
To: Dan Huff
Cc: J.W. Ring; Jason Clifford
Subject: Fwd: Follow up from our February 17th meeting
Importance: Normal
Dan,
I'm confused.. It seems the timeline to do this work has shortened drastically from my understanding in our meeting with Tiffany and Nina regarding new recycled water properties. As planned, we will be utilizing the Colman ranch this year with 2 big guns and hand lines sparingly. The cemetery is also another planned location as permitted. Her language in the email is vague as to new or permitted locations.
I will check into the permitting language regarding the recycle water plan but it was my understanding the plan was already approved with the permit? Am I wrong?
Jenn
Sent from my iPhone
Begin forwarded message:
From: YELTON-BRAM Tiffany <YELTON-Bram.Tiffany@deq.state.or.us>
Date: April 21, 2015 at 11:00:55 AM PDT
To: 'Jennifer Cline' <jcline@cityofmolalla.com>, "'dhuff@cityofmolalla.com'" <dhuff@cityofmolalla.com>
Cc: DECONCINI Nina <DECONCINI.Nina@deq.state.or.us>, HEINS Pat <Heins.Pat@deq.state.or.us>
Subject: RE: Follow up from our February 17th meeting
Hello Jennifer and Dan,
We will be at the City Council meeting tomorrow night. I need to know if you have started and are making progress on agreements with property owners to apply recycled water to the approved sites listed in your 8/29/2014 Recycled Water Plant. As we discussed in February and documented in the mails from March below (see highlight), the city needs to have sites to apply recycled water to at agronomic rates since no discharge to the Molalla River is allowed May 1 to October 31 and holding capacity in the lagoon is finite.
This topic will come up at the council meeting and at the public hearing on the edits to the recycled water plan scheduled for 4/30. I have received no written response to my emails below. If asked about recycled water sites during the meeting tomorrow, I will have to say that we have not received any information from the city regarding which sites will be used for this year’s irrigation season.
If you have detail to share, please send it.
Thanks!
Tiffany Yelton Bram
WQ Source Control Manager
Oregon Department of Environmental Quality
2020 SW 4th Ave., Suite 150
Portland OR 97201
Desk 503 229 5219
Mobile 503 975 0046
This spring, DEQ's Northwest Region Office will be moving to a new location - the 700 Lloyd Building at 700 NE Multnomah St., Suite #600, Portland, OR 97232. The target date for operating at the new location is May 18th, 2015.
From: YELTON-BRAM Tiffany
Sent: Tuesday, March 17, 2015 2:20 PM
To: 'Jennifer Cline'; 'dhuff@cityofmolalla.com'
Cc: DECONCINI Nina
Subject: RE: Follow up from our February 17th meeting
Hello Jennifer and Dan
I wanted to check in to see if you had any questions on the list of items that are Molalla’s (in my original e-mail)—if so please call or write to me.
Here is an update on our items:
· Due to a conflict, we will attend the council meeting on the 22nd of April, not the 8th.
· I have tasked Mark Hynson in my section to craft some guidance for you and other communities on transition from minor to major dischargers. To fit this into his workload and produce clear and comprehensive guidance, it will take longer than I anticipated. So our new plan is to have a list of speaking points about the transition from minor to major to share with you in advance of the city council meeting on April 22nd.
· I hope my answer to the question of whether discharge to the Molalla River outside the timeframe in the permit was clear. I made a typographical error—“ But the TMDL document does not provide us guidance on this so we don’t have a river flow number or effluent temperatures and flows to reference.” My apologies for the error.
· ODA has provided me with documentation requiring Mr. Coleman to exclude his cattle from the unnamed tributary to Bear Creek, Bear Creek and Creamery Creek and to do that, Mr. Coleman has chosen to build a fence. I spoke with Ray Jandl today and learned that some of the fence has been installed. I have consulted with our recycled water and biosolids specialist, Pat Heins, and we have some simple edits to the August 29, 2014 Recycled Water Plan for your review. These changes are in the attached document. Please let me know if you have any questions. After your review, we’d prepare this for public notice for 35 days and we would hold a public hearing for testimony. From the written and verbal comments, other changes could be made but the scope of the comments would only be on the specific sections changed. Until such time as this process is complete, Molalla would operate under and must comply with the current plan but we would ask you to voluntarily comply with irrigation setbacks from the new fencing that Mr. Coleman is installing.
Thank you for your time and cooperation.
Tiffany Yelton Bram
WQ Source Control Manager
Oregon Department of Environmental Quality
2020 SW 4th Ave., Suite 150
Portland OR 97201
Desk 503 229 5219
Mobile 503 975 0046
This spring, DEQ's Northwest Region Office will be moving to a new location - the 700 Lloyd Building at 700 NE Multnomah St., Suite #600, Portland, OR 97232. The target date for operating at the new location is May 26th, 2015.
From: YELTON-BRAM Tiffany
Sent: Tuesday, March 03, 2015 5:26 PM
To: 'Jennifer Cline'; dhuff@cityofmolalla.com
Cc: DECONCINI Nina
Subject: Follow up from our February 17th meeting
Hello Jennifer and Dan
Thank you both for agreeing to meet with Nina and I on February 17th. I wanted to follow up on some items I said DEQ would do and note some work we need Molalla to do. Let me know if you have any questions or concerns.
DEQ responsibility
· Nina and Tiffany will attend an upcoming city Council Meeting. This is scheduled for April 8, 2015.
· DEQ will provide guidance on what it means for Molalla to be a major discharger under the NPDES program versus the current status of minor. This guidance will be in the form of a letter. I intend to get this to you by the end of March.
· Molalla asked if there is the possibility of discharging to the Molalla River during the month of May. The previous permit allowed this but the previous permit was out of alignment with the Molalla-Pudding Total Maximum Daily Load (TMDL). Tiffany worked with Karen Williams to better understand the basis for excluding the month of May. What we discovered is that data shows that the spawning season in the Molalla starts in May. Thus, to protect the fish, the treated effluent, which can raise the water temperature (among other concerns) must not be discharged during May. In the past, DEQ had language in the permit that allowed discharge to the river outside of the window in the permit. When approving those discharges, DEQ set flow and temperature conditions on the river and the discharge. But the TMDL document does not provide us guidance on this so we don’t have a fiver flow number or effluent temperatures and flows to reference. Based on new legal advice, DEQ no longer includes language in permits that allows requests for discharge outside of the season set in the TMDL. The TMDL would require additional research and revision to support changing the no discharge season, none of which is scheduled at this time.
· DEQ is waiting for further detail from ODA on how the Coleman Ranch will exclude cattle from the unnamed tributaries to Bear Creek and Creamery Creek and will then edit the approval of the Coleman site as a site for the application of recycled water. Some of this information from ODA arrived on March 2nd so we will start work on the Recycled Water Plan revision.
Molalla responsibility
· Start investigating addition recycled water and biosolids sites. DEQ needs to know how the city will identify and conduct outreach to find additional sites that may be approvable. As we discussed it takes a while to get a site approved so we need to know that the city looking for additional options in case the existing sites are not available for any reason. In a worst case scenario, biosolids can be disposed of in landfills but recycled water needs to be used beneficially according to rule. Our goal is to aid the city in having enough workable options so that compliance with DEQ rules maintained. Milestones we’d like to see are: agreements from currently approved sites stating that they will accept recycled water this season, identification of sites close to the existing conveyance and the infrastructure costs to provide water to them (ex: Ivor Davies Park), and exploration of the trucking water to sites in the short term. This is something we could discuss at the council meeting. These three examples are items that we’d like to see developed soon—agreements with the currently approved sites should be developed before May 1.
· Annual reports are required per the permit for recycled water application, biosolids application and Inflow and infiltration progress.
· The DEQ permit modification to extend the period of time for lagoon testing has been completed. There were no public comments. We look forward to the results from this summer’s testing.
· Once the city receives guidance from DEQ on the transition from minor to major, begin action to budget for additional monitoring and sampling of new pollutants. This information will be required for the renewal of the city’s permit. The application for renewal is due 180 days prior to expiration (May of 2019).
Thank you again. My staff and I look forward to helping the city achieve compliance with the NPDES permit.
Tiffany Yelton Bram
WQ Source Control Manager
Oregon Department of Environmental Quality
2020 SW 4th Ave., Suite 150
Portland OR 97201
Desk 503 229 5219
Mobile 503 975 0046
This spring, DEQ's Northwest Region Office will be moving to a new location - the 700 Lloyd Building at 700 NE Multnomah St., Suite #600, Portland, OR 97232. The target date for operating at the new location is May 26th, 2015.