From: Jennifer Cline
Sent: Mon Aug 31 15:25:59 2015
To: Christine Hein
Cc: J.W. Ring; Phillip Bender; Mark Strandberg; Dan Huff (dhuff@cityofmolalla.com)
Subject: RE: Molalla ERP - Final Draft comments.
Importance: Normal
Attachments: 2015-08-31_Molalla ERP Spill Response Plan (Revised for DEQ Comments).docx; appendix B.pdf; Hi Tina, I revised the description to include the effluent/irrigation transfer pumps and the DMS information per the attached appendix B, Figures 4 & 5. 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: Christine Hein [mailto:CHein@ringbenderlaw.com] Sent: Monday, August 31, 2015 10:07 AM To: Jennifer Cline <jcline@cityofmolalla.com> Cc: J.W. Ring <JWRing@ringbenderlaw.com>; Phillip Bender <PBender@ringbenderlaw.com>; Mark Strandberg <MStrandberg@ringbenderlaw.com>; Dan Huff (dhuff@cityofmolalla.com) <dhuff@cityofmolalla.com> Subject: RE: Molalla ERP - Final Draft comments. Hi Jennifer- Attached is a revised ERP draft addressing David’s comments. My notes are below. There is one place (Section 3.1.3) where I will need your help filling in technical details about the dechlorination part of the system. There might be other operational details that should be added there to given David’s comments. I will leave that to your judgment. Please make that edit and then we can finalize and return it to David. In the meantime, I will give him a call to let him know it should be coming today. I will run the edited language about sampling by him to ensure that the next version we send will not be just returned again. Also, some of the appendixes are not contained in this word document because they maps and things that we just manually insert before scanning to final. Hope you had a nice weekend, Tina From: Jennifer Cline [mailto:jcline@cityofmolalla.com] Sent: Tuesday, August 18, 2015 9:17 AM To: Christine Hein Subject: FW: Molalla ERP - Final Draft comments. Hi Tina, I don’t understand David’s need to comment on grammar and punctuation. Anyways, moving forward, I thought I had read a section that stated to sample as soon as possible. May be he had missed that section? 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: Tuesday, August 18, 2015 8:43 AM To: 'Jennifer Cline' <jcline@cityofmolalla.com> Cc: COLE David <COLE.David@deq.state.or.us>; YELTON-BRAM Tiffany <YELTON-Bram.Tiffany@deq.state.or.us> Subject: Molalla ERP - Final Draft comments. Hello Jennifer. I just got done reviewing your draft ERP and have the following comments and suggestions: 1. Appendix 4, section 11 (Sampling), lacks any mention of when to sample. This should be done as soon as possible after release discovery. Timely sampling results will help you determine what kind of physical and communications/notification response efforts you need to perform. For example, if your sampling results show high E. coli in the creek, then a blanket notice to avoid contact sent broadly and quickly is the right public notice content, while a leak from the chlorinated recycled water line, contained to an irrigation ditch, would be better served by direct communication with ditch users. This section gives no guidance to personnel about when to collect samples. This omission renders this section inadequate and incomplete. Done. 2. Section 3.7, Sampling and Monitoring, this section should stress that sampling should take place as soon as possible after release discovery. As it is now, this section does not mention when to take samples, rendering this section inadequate and incomplete. Done. 3. Section 5.1.1, Initial Response, lacks any mention of sampling, which should be done as soon as possible after release discovery. This omission renders this section inadequate and incomplete. Done. 4. Section 3.1.3, first paragraph, omits mentioning the dechlorination system in the Discharge Monitoring Station. This is a critical component in the overall treatment system, because it assures that the potentially toxic effects of chlorine in the discharge do not harm humans or the environment. You need to describe and document the entire treatment system so that you can address failures of any particular part. This omission renders the system description inadequate and incomplete. Need City or B&C’s help addressing this comment. 5. Section 2.3, second bullet, last sentence, would read better if you delete the word “and” between “supplement” and “this”. Done. 6. Section 3.1.3, second paragraph, last sentence. Change the word “and”, between the word “under” and “approved”, to “an”. Done. 7. Table 3.1, Public Works Leadman section, delete one of the two colons (“:”).Done. 8. Figure 3.1, the bottom four boxes around the text are missing from the organization chart. My assistant will fix this before submission. 9. Section 3.3.4, first paragraph, last sentence, delete the word “on”, between the words “be” and “directed”. Done. 10. Section 4, Decision Process and ERP Activation, first paragraph, first sentence, replace the word “it”, between the words “having” and plan”, with “a”. Done. 11. Section 5, Emergency Response, Recovery & Termination, first paragraph, fourth sentence, capitalize the word “action” between the words “Response” and “Plans”. Done. 12. Appendix 4, section III (Release Prevention Measures), first paragraph, last sentence, change the word “or”, between the words “operators” and “any”, with the word “of”. Done. Please send me your revised draft for review and approval no later than close of business on Friday, Aug. 28, 2015. Thank you. From: COLE David Sent: Thursday, August 13, 2015 2:44 PM To: 'Jennifer Cline' Cc: YELTON-BRAM Tiffany; 'Christine Hein'; Dan Huff; Jason Clifford; COLE David Subject: RE: Molalla ERP - Final Draft Thanks Jennifer. I look forward to reviewing it soon. From: Jennifer Cline [mailto:jcline@cityofmolalla.com] Sent: Thursday, August 13, 2015 2:39 PM To: COLE David Cc: YELTON-BRAM Tiffany; 'Christine Hein'; Dan Huff; Jason Clifford Subject: Molalla ERP - Final Draft Hi David, Please see the attached final draft of the Molalla ERP Spill Response Plan. Please let me know if you have any questions. 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