Category Archives: Reference

Molalla’s Newest Admission of Failure to Properly Manage Wastewater

Molalla’s lawyers, Ring Bender, recently send DEQ and Bear Creek Recovery’s legal team the follow letter – another admission that the wastewater plant failed to properly report and/or manage effluent. It is a sad admission that we will likely never know how much Molalla has really violated its permit over the years, thus endangering ground and Molalla River water.

Note how the city has just “discovered” all kinds of questionable practices and that they don’t know how long the questionable practices were going on.

Molalla Waste Water: Links to City of Molalla Documents

The  City of Molalla posts all wastewater management documents at the following site, including work to improve I&I, monthly reports, notices of violations and permits. Visit the site to discover what Molalla is doing to comply with the Clean Water Act:

I&I report:

Molalla I&I Plan Assessment and Reduction 2015

Update to I/I Plan:

Update Memo from Public Works Director regarding Molalla's I/I document.

Update Memo from Public Works Director regarding Molalla’s I/I document.

I/I Assessment and Reduction


City of Molalla


Prepared For:

Oregon Department of Environmental Quality

Prepared By:

Jennifer Cline

NPDES Permit #:101514

January, 2015


SECTION 1 INTRODUCTION……………………………………………………………………………….. 1-1

1.1 Purpose ………………………………………………………………………………………………. 1-1

1.2 Background ………………………………………………………………………………………… 1-2

1.3 Legal Authority…………………………………………………………………………………… 1-3

1.4 Mapping…………………………………………………………………………………………….. 1-3

SECTION 2 SELECTION OF STUDY AREAS ………………………………………………………… 2-1

2.1 No Historical Sewer System Overflows ……………………………………………… 2-1

2.2 Initial Prioritization of Sewer Basins …………………………………………………… 2-1


3.1 Administration……………………………………………………………………………………. 3-1

3.2 Public Relations ………………………………………………………………………………….. 3-1

3.3 I/I Quantification………………………………………………………………………………… 3-2

3.3.1 Flow Monitoring …………………………………………………………………………………. 3-2

3.3.2 Rainfall Monitoring …………………………………………………………………………….. 3-3

3.4 Interviews …………………………………………………………………………………………… 3-3

3.4.1 Manhole and Visual Pipe Inspections …………………………………………………. 3-4

3.4.2 Smoke Testing …………………………………………………………………………………….. 3-5

3.4.3 CCTV ………………………………………………………………………………………………….. 3-6

3.4.4 Dyed-Water Testing ……………………………………………………………………………. 3-7

3.5 Establishing Source Flows and Costs ………………………………………………….. 3-8

3.6 Recommendations and Implementation Plan ……………………………………… 3-8

SECTION 4 I/I REDUCTION ………………………………………………………………………………… 4-1

4.1 Priority 1 – Cost Effective Rehabilitation …………………………………………….. 4-1

4.1.1 Manhole Rehabilitation ………………………………………………………………………. 4-1

4.1.2 Pipeline Rehabilitation………………………………………………………………………… 4-2

4.2 Priority 2 – Structural Rehabilitation …………………………………………………… 4-2

4.2.1 Manhole Rehabilitation ………………………………………………………………………. 4-2

4.2.2 Pipeline Rehabilitation………………………………………………………………………… 4-2

4.3 Preventative Maintenance …………………………………………………………………… 4-2

4.4 Post-Rehabilitation Flow Monitoring ………………………………………………….. 4-3

SECTION 5 PROJECT SCHEDULE ………………………………………………………………………… 5-1


Figure 1 – Sewer Basin Map ……………………………………………………………………………………….. 1-5

Figure 1A – Collection System Basin Details………………………………………………………………. 2-2

Figure 2 –Schedule for I/I Assessment and Reduction Activities ……………………………….. 5-2


A – Example Field Inspection Forms

B – Example Notification Letter and Door Hanger


CCTV Closed Circuit Television

DEQ Oregon Department of Environmental Quality

EPA Environmental Protection Agency

FTE Full Time Employee

GIS Geographic Information System

GPS Global Positioning System

I/I Infiltration and Inflow

MACP Manhole Assessment and Certification Program

MGD Million Gallons per Day

MGH Million Gallons per Hour

NPDES National Pollution Discharge Elimination System

PACP Pipe Assessment and Certification Program

RII Rainfall Induced Infiltration

SDC System Development Charges

SSES Sewer System Evaluation Study

SSO Sanitary Sewer Overflow

WWTP Wastewater Treatment Plant


1.1 Purpose

Like many wastewater collection systems, the City of Molalla’s collection system was
designed according to industry standards, but now appears to experience levels of
inflow and infiltration (I/I) that exceed levels originally expected. Consequently, the
City has developed its I/I Assessment and Reduction Plan to implement a consistent,
long-term approach to utilizing the City’s limited resources to efficiently address I/I
within the City’s collection system.

The goals of the City’s I/I Assessment and Reduction Plan include:

. Minimization of infiltration, inflow and exfiltration, and maximum conveyance of
wastewater to the wastewater treatment plant;
. Efficient use of allocated funds; and
. Identification, design and prioritization of solutions to address I/I issues.

The intent of the City I/I Assessment and Reduction Plan is to optimize use of the City’s
limited human and material resources to effectively and efficiently address I/I. The City
intends to establish its I/I Assessment and Reduction Plan as a matter of City policy.

The City’s I/I Assessment and Reduction Plan complies with NPDES Permit No. 101514,
Schedule D (July 1, 2014). Schedule D requires the City to develop an I/I plan within 180
days of the effective date of the NPDES permit. The NPDES permit requires the City’s
I/I program to address or include the following:

. Identification of all overflow points.
. Verification that sewer system overflows are not occurring up to a 24-hour, 5-year
storm event or equivalent.
. Monitoring of all pump station overflow points.
. A process for identifying and removing inflow sources into the permittee’s sewer
system over which the permittee has legal control, including a time schedule for
identifying and reducing inflow.
. If the permittee does not have the necessary legal authority for all portions of the
sewer system or treatment facility, a strategy and schedule for gaining legal
authority to require inflow reduction and a process and schedule for identifying
and removing inflow sources once legal authority has been obtained.

The City’s I/I Assessment and Reduction Plan addresses each of these items. It also
outlines a comprehensive, long-term approach to efficiently prioritizing the City’s I/I
assessment and reduction efforts.

Maintaining the value of the City’s investment in its infrastructure is vital. The collection
system represents a major capital investment for the community and it is one of the
community’s major capital assets. Equipment and facilities will deteriorate through
normal use and age. Maintaining value of the capital asset is a major goal of the City’s I/I
Assessment and Reduction Plan. The City’s infrastructure provides crucial City’s
services and generates revenues. Proper reinvestment in capital facilities maintains the
City’s ability to provide those services at the lowest cost possible. It also helps ensure
compliance with environmental requirements. As a capital asset, the collection system
and wastewater treatment plant require ongoing investment to ensure design capacity
while maintaining existing facilities and equipment, as well as extending the life of the
system. The City will use its I/I Assessment and Reduction Plan to, in part, manage its
assets; in this case, the collection system itself.

1.2 Background

The City of Molalla currently operates and maintains approximately 29.3 miles of
sanitary sewer. In addition, the City maintains 5 lift stations and one wastewater
treatment facility. Eleven (11) basins encompassing 1157.7 acres contribute flow to the
wastewater treatment facility (see Figure 1A).

In February, 1997, the City’s Public Works Department completed an I/I Field Monitoring
Summary (1997 I/I Report) to determine the general condition of the wastewater
conveyance system at that time. The 1997 I/I Report evaluated areas of the City that had
significant I/I, specifically the older portions of the conveyance system where the pipes
had been constructed mainly with concrete, AC and other materials that deteriorate with
time. Flow metering was conducted at selected locations and data analysis was done
utilizing a spreadsheet to calculate and organize the data. The data concluded that the
following basins, as listed on the current Sewer Basin Map (Figure 1), appeared to have
the highest I/I inputs: TL_A, TL_D, TL_F and BC_A.

More recently, when developing the 2013-14 fiscal budget, the City contracted with
Curran-McLeod to complete an SDC Methodology and Sewer System Capital
Improvement Plan (2013-14 Capital Improvement Plan). One component of the City’s
implementation of the 2013-14 Capital Improvement Plan in the 2013-14 fiscal budget was
to target certain SDC funds for collection system I/I abatement and system expansion,
trunk line upgrades and collection line upgrades.

In addition, over the past few years, the City has worked toward improving
collection system reliability and maintenance. The City has completed the following
activities as part of this work:

1. In 2013, the City purchased a new sewer jetter and vacuum truck to clean sewer
lines and remove debris from manholes. The City’s Public Works Department has
integrated this equipment into its regular collection system maintenance

2. In the 2013-14 Fiscal Year, the City budgeted $75,000 for I/I investigation to
study the current system and identify areas for future targeted maintenance
and capital improvements. This budget has been set aside to fund planned

field investigation work, but not limited to, I/I flow monitoring, smoke
testing, dye testing, manhole or pipe inspections, training and data analysis.

3. In October 2014, the City completed mapping the collection system with GPS
coordinates and utilizing current GIS technology. The City’s updated Sewer
Basin Map (Figure 1) provides the most comprehensive, accurate and complete
map of the collection system the City has ever had.

1.3 Legal Authority

The City has the legal authority necessary to regulate the volume of flow entering the
collection system, including from residential and commercial properties. See Molalla Code
Ch. 13.08 (available at

The City maintains strict control over the connection of private sewer laterals to sewer
mains. Molalla Code Ch. 13.08.270. Generally, in older collection system such private
sewer lateral connections can have significant potential to be sources of infiltration.

Standards for new connections are clearly specified. Molalla Code Ch. 13.08.420. The
City’s sewer use ordinance also contains provisions for inspection, approval of new
connections, and a program to implement the requirements. Molalla Code Ch. 13.08.620-
640, 68-770 (inspections); Molalla Code Ch. 13.08.330-470 (new connections); Molalla Code
Ch. 13.08.710 (authority to require repair of leaks).

The City also prohibits stormwater connections to the sanitary sewer. Molalla Code
13.08.440 (“No person shall make connection of roof downspouts, exterior foundation
drains, areaway drains, or other sources of surface runoff or groundwater to a building
sewer or building drain which in turn is connected directly or indirectly to a public
sanitary sewer. (Ord. 2007-07 §1; Ord. 1976-2 Art. 4 §11)”).

Direct stormwater connections to a separate sanitary sewer system are known as inflow.
Inflow can severely impact the ability of the collection system to transport flows to the
treatment plant during wet weather, leading to overflows and noncompliance with the
wastewater treatment plant’s NPDES permit. Generally, the City prohibits direct
stormwater connections that could generate inflow. Consequently, the primary target of
the City’s I/I Assessment and Reduction Plan is infiltration.

1.4 Mapping

The City believes it crucial to develop and maintain accurate, current maps of the City’s
collection system. Efficient collection system maintenance and I/I identification requires
functional maps. Collection system maps are also useful sources of information that City
personnel use to carry out their assignments.

Prior to 2014, the City did not have a single unified map of sewer collection system
features. As part of the City’s ongoing O&M and general sewer system management and
upgrade program, the City developed a GIS-based map of sewer system features. That
Sewer Basin Map is shown in Figure 1.

The Sewer Basin Map contains information on the following:

. Mains, trunk lines and force mains;
. The Tolliver Bypass;
. The Bear Creek Bypass;
. Lift Stations;
. Lampholes;
. Manholes;
. Sub-basins and the City boundary (service area boundary); and
. The Wastewater Treatment Plant.

The City intends to continue to update the information contained on the Sewer Basin
Map. The City plans to collect and add information concerning the following:

. Laterals;
. Cleanouts;
. The properties served; and
. Other landmarks (roads, water bodies).


2.1 No I/I Historical Sewer System Overflows

The City of Molalla has had no known historic sewer system overflows (SSOs)
associated with I/I since January 2006. The City does not presently have concerns
that I/I related SSOs are likely nor has the Department of Environmental Quality
expressed concern with the potential for I/I related SSOs in the City’s collection
system. In many Oregon cities, SSOs are a driver of I/I assessment and reduction
programs because I/I often overwhelms the older collection systems present in
many communities. Molalla does not have such a situation. The City’s collection
system and wastewater treatment plant is generally able to handle the wastewater
quantities flowing into the wastewater treatment plant without any I/I related SSOs

2.2 Initial Prioritization of Sewer Basins

The City periodically evaluates the capacity of the sewer system in both wet and dry
weather flows to ensure the capacity is maintained as it was designed. The City’s I/I
Assessment and Reduction Plan is intended to build upon ongoing activities and the
everyday preventive maintenance that the City undertakes in the system.

The City’s efforts as part of its I/I Assessment and Reduction Plan involve a number of

. Inventory and Prioritization;
. Flow Monitoring;
. Sewer System Testing;
. Identification of I/I Locations;
. Sewer Rehabilitation Program

The City’s assessment begins with an inventory of the current collection system and
prioritization of areas for initial investigation. The City’s collection system inventory
includes the following basic information about the system:

. Population served;
. Total system size;
. Inventory of pipe length, size, material and age, and interior and exterior condition
as available;
. Inventory of appurtenances such as bypasses, siphons, diversions, pump stations,
tide or flood gates and manholes, etc., including size or capacity, material and age,
and condition as available;
. Force main locations, length, size and materials, and condition as available;

. Pipe slopes and inverts; and
. Location of laterals.

The next step in the City’s assessment is to identify the locations of significant I/I input
to the collection system. These locations may warrant further investigation in the form of
flow and rainfall monitoring and inspection procedures to identify and quantify the I/I
issues associated with a particular location. The City’s ultimate goal is to identify the
major sources of I/I that contribute to the influent entering the WWTP.

The City’s collection system is divided into Ten (10) sewer basins and Eight (8) sewer sub-
basins. For the purpose of its I/I Assessment and Reduction Plan, the City has prioritized
these basins and sub-basins for assessment using factors such as the age of the basin and
sub-basin infrastructure, known backups that have occurred at a given location, and
anticipated high I/I areas. Since excessive I/I from deteriorated pipes, pipe joints,
manholes, and illegal connections by private homeowners normally occurs to a greater
extent in older sewer systems, the City’s assessment has been prioritized accordingly.

Basin ID





Toliver Line Basins





























































Bear Creek Line














































Figure 1A: Collection System Basins


As part of the City’s I/I Assessment and Reduction Plan, the priority basins and sub-
basins identified in Section 2 will be studied to identify and assess the extent of I/I. All
studies will generally follow the guidelines established in the Existing Sewer Evaluation
& Rehabilitation, (WEF Manual of Practice FD-6 and ASCE/EWRI Manuals and Reports
on Engineering Practice No. 62, 2010).

The City’s program consists of the following six (6) key components:

. Administration;
. Public Relations;
. I/I Quantification;
. I/I Identification;
. Source Flow Analysis; and
. Final Recommendations and Implementation Plan.

The City will assign existing personnel (FTEs) to take on the roles of collection system I/I
inspector/technician. These FTEs will be involved in all field inspection and
rehabilitation activities, and will be supplemented by other City staff as necessary. An
engineering consultant will assist with field inspections and will complete analysis of
flow and rainfall data, quantify I/I flows based on field inspections, complete cost-
effective analysis, and provide final recommendations for rehabilitation improvements.

The field inspections (I/I identification), source flow analysis, and the implementation
plan will initially focus on critical areas identified during the investigation. These critical
areas will be addressed first. Ultimately, the results of the investigation will be used to
determine whether significant I/I is entering the collection system and to demonstrate
whether I/I reductions can be achieved cost-effectively. The implementation plan will
provide the projected costs of removing public sector I/I sources. Repairs that are shown
to be cost effective will be compared with the costs of removing private sector (or laterals)
I/I. The investigation will also determine whether private sector I/I is a significant
source and, if so, how to cost-effectively address it.

3.1 Administration

Progress meetings will be held regularly to review the project goals, objectives, and
schedule. Public hearings and Council meetings will be conducted to discuss the project
and answer questions from the public and/or City.

3.2 Public Relations

Field inspection notification letters will be sent at least one week prior to any
investigations. The notification letter will explain the field inspections that will be taking
place and the reasons for these inspections. A press release will also be printed in the

City paper describing field inspections.

In the event that manhole structures identified for inspection are located on inaccessible
private property, a door notification will be left for the property owner. The door
notification will contain an explanation of the need to conduct an inspection of the
structure, along with a telephone number enabling residents to contact the City for more
information and to schedule a convenient time for the inspection.

Forty-eight hours (48) prior to smoke testing, a notification to potentially affected property
owners will be provided via door hangers on homes and businesses. This notice will
include general information about the testing, including instructions to fill infrequently
used plumbing traps with water to prevent smoke from entering buildings via service
lines. A telephone number will be provided enabling residents to contact the City for more
information or with any special needs and concerns they may have.

3.3 I/I Quantification

Dry weather and wet weather flow rates measured in the system are a good indicator as
to which priority areas experience significant I/I entering the system. The results of flow
monitoring will be used to refine the priority ranking described in Section 2 so that the
City can concentrate the assessment efforts on the areas that exhibit high rates of I/I.

3.3.1 Flow Monitoring

Fundamental information about the City’s collection system can be obtained by flow
monitoring. Flow monitoring provides information on dry weather flows as well as
areas of the collection system potentially affected by I/I.

Flow measurements performed for the purpose of quantifying I/I are typically
separated into three components: base flow, infiltration, and inflow. Base flow is
generally taken to mean the wastewater generated without any I/I component.
Infiltration is the seepage of groundwater into pipes or manholes through defects such
as cracks, broken joints, etc. Inflow is the water which enters the sewer through direct
connections such as roof leaders, direct connections from storm drains or yard, area, and
foundation drains, the holes in and around the rim of manhole covers, etc. Many
collection system owners or operators add a third classification: rainfall induced
infiltration (RII). RII is stormwater that enters the collection system through defects that
lie so close to the ground surface that they are easily reached. Although not from piped
sources, RII tends to act more like inflow than infiltration.

In addition to the use of flow meters, other methods of inspecting flows will be
employed such as visually monitoring manholes during low-flow periods to determine
areas with excessive I/I. For a small system like Molalla’s, this technique is often an
effective and low-cost means of identifying problem areas in the system which require
further investigation.

The City’s goal is to efficiently identify locations of excessive I/I within its system. The
program looks at the wastewater treatment plant, pump stations, flows, and rainfall
data to characterize peaking factors for the system.

For the flow monitoring portion of its investigation, the City plans to purchase and place
eight (8) temporary flow meters within the collection system. The City calculated the
flow meter study design using the flow meter assessment rule of thumb of 1 meter per
15,000-25,000 linear feet (LF). The City currently has 29.34 miles or 154,915 LF of
existing collection lines. Thus, eight flow meters will provide sufficient data with which
to assess flows in the system under wet and dry conditions.

The flow meters are area velocity flow modules with sensors. The flow meters record
flow, velocity and depth readings every fifteen minutes. The collection system’s
response to wet-weather events will be monitored through the winter of 2015, with a
monitoring period for 2 weeks in late summer to determine average dry weather flow.

The data collected with the flow meters will be used to determine the flows in each basin
and sub-basin under wet and dry conditions.

3.3.2 Rainfall Monitoring

Rainfall monitoring will be conducted concurrently with flow monitoring activities. A
rainfall gauge will be placed near the center of town. Data collected from the rainfall
gauge will be used in conjunction with flow monitoring data.

The flow and rainfall data collected will be analyzed for the following:

. Average daily and peak hourly dry-weather flows
. Peak high groundwater infiltration flows
. Peak wet-weather inflows
. Peak wet-weather total flows

The results of the flow analysis will be used to rank basins and sub-basins on I/I
contributions to the collection system and to refine the priority ranking described in
Section 2.

3.4 Interviews

Prior to field inspections, the City will interview current and past staff about the existing
sewer system. City staff who have worked with the collection system are the people who
are most familiar with the system. The City expects that those staff may have
information on defect locations and the history of the performance within areas of the
system. The staff also may have information on private property problems within the
system. In areas with previously reported backups, residents will be interviewed
during the field inspection process to determine the history of the problems.

The information collected from staff members and residents will be noted and special
attention given in the field to the areas with historical problems.

3.4.1 Manhole and Visual Pipe Inspections

Defective manholes are typically significant contributors of I/I in a sanitary sewer system.
Manhole inspections are used to locate these sources of I/I, assess the conditions and the
state of deterioration inside manholes, and to determine the need for repair or
replacement. Visual inspection of manholes and pipelines are the first line of defense in
the identification of existing or potential problem areas. Visual inspections will take
place on both a scheduled basis and as part of any preventive or corrective maintenance
activity. Visual inspections provide additional information concerning the accuracy of
system mapping, the presence and degree of I/I problems, and the physical state-of-
repair of the system.

Manhole inspections will be accomplished using a two-person crew. Manholes will
generally be inspected from the surface using survey rods, digital cameras, mirrors, and
high-powered spot lights. Industry standard OSHA, NIOSH, and NASSCO confined
space entry policies and practices will be followed to ensure safe entry and egress of all
confined spaces.

Manhole inspection forms and visual pipe inspection forms will be completed for each
manhole. Example forms are contained in Appendix A. The forms include a field
sketch of the plan view of each manhole to verify sewer line configurations. Digital
photographs of each manhole and the connecting pipe sections will be taken during
manhole inspections. All photos shall be taken north-facing to ensure consistency and
provide a standard point of reference for viewing and analysis.

The following manhole components will be inspected for signs of I/I and for structural
soundness per the NASSCO Manhole Assessment Certification Program (MACP)
inspection guidelines. Digital photographs will also be taken of noted I/I defects and
other non-I/I related defects such as roots, debris, or structurally deteriorated steps.

Each field crew will use metal detectors and probing rods where necessary to assist in
locating manholes. If a manhole cannot be located during a 15-minute time period, the
manhole shall be placed on a “Can Not Locate” list and provided to the City with a
general map of the position for location services at a later time. If a manhole is found to
be buried, the approximate location of the manhole will be identified in the field and
submitted to the City. New manholes found by field crews shall be assigned a temporary
manhole number consisting of the last known downstream manhole number followed by
a T1, T2, T3, etc., as applicable. If located on public sewer mains, these manholes will be
inspected and location details for the manhole will be provided to the City.

In addition to manhole structure inspections, the incoming and outgoing sanitary sewer
lines will be visually inspected by a pole mounted camera from accessible manholes.
This procedure is called a visual pipe inspection and will be conducted in accordance
with MACP guidelines. Data from the visual pipe inspection will be used to identify
defects near the manhole structure and to select lines for further investigation through
CCTV inspections.

Prior to inspection, all Public Works crew members will attend an MACP/PACP and
QC informational training on the standardized processes for inspection of manholes
and collection pipes.

The manholes will be labeled according the City’s manhole ID numbers. The size, type,
depth and condition of the manhole and pipes will be collected. Photos will be taken
and recorded on each inspection form.

All of the information collected will be used to estimate the amount of rehabilitation
work required for each manhole. The typical defects found in manholes are:
broken/cracked covers, broken/cracked frames, deteriorated frame seals, deteriorated
frame adjustments, defective cones, defective walls, defective or deteriorated steps,
deteriorated troughs or inverts, deteriorated pipe seals, and deteriorated benches.

The following equipment will be used to perform the manhole and visual pipe

. Manhole pick and shovel to open the manholes;
. Wrench to open bolted down manholes;
. Flashlight;
. Camera mounted on a bar;
. Hand held camera;
. Traffic control equipment such as cones, signs, flags, etc.;
. Metal detector; and
. Probing rods.

3.4.2 Smoke Testing

Smoke testing is a relatively inexpensive and quick method of detecting sources of inflow
in sewer systems, such as down spouts, or driveway and yard drains and works best for
detecting cross connections and point source inflow leaks.

The City will conduct smoke testing on all line segments located within the priority basins
in order to detect I/I sources, to locate manholes not identified on the City’s existing map,
and to obtain a lineal footage of the sewer line segments for the system inventory. Smoke
sources will be photographically documented and precisely located with a handheld GPS
unity to allow for efficient analysis and, as necessary, repair.

Although the initial purpose of the testing will not be to identify private sources of I/I, the
smoke testing will likely identify some of these private sources. These sources will be
recorded and the City will request that the homeowner remove any illicit connections
identified through smoke testing.

Smoke testing will be used to augment the manhole and visual pipe inspections. Prior
to any smoke testing, the fire department will be notified and door hangers will be
placed at each property. An example notification letter/door hanger is provided in
Appendix B.

Smoke testing will be completed by blowing white smoke into an isolated line segment
with high-capacity blowers. Blowers will be placed over an isolated line segment and
three five-minute smoke bombs will be inserted into the blower intake to blow smoke
into the sewer. Smoke emissions from sewer mains, storm sewers, and manholes
indicate possible leaks and cross connections.

Every sewer segment within the study scope will be attempted. Before any smoke
testing is conducted a training workshop with the inspection crew will be conducted.
Smoke testing forms and procedures will be explained. A smoke testing crew will
consist of two people. One person will set up the smoke test for a segment while the
other will walk around and note everywhere they see smoke, record the location with a
hand held GPS unit, and take pictures of each emission. While one person from the
crew is setting up for the next segment, the other person will be filling out the smoke
testing form from the previous smoked segment. There will be one smoke testing crew.

The segment of main that will be smoked will be identified by an upstream and
downstream manhole ID. A map created from the recorded locations of the handheld
GPS unit of all visible smoke will be a description of the location (streets/cross-streets,
address) with ties to this location (measurement from the corner of a building, house,
survey marker, etc.). The smoke will be rated as light, medium, or heavy and the area
that drains to this leak will be estimated and photographs will be taken. An example
smoke testing form is provided in Appendix A.

The following equipment will be needed to perform the smoke testing:

. Blower;
. Sandbags;
. Smoke bombs;
. Flags;
. Hand held cameras;
. Tape measure;
. Manhole pick and shovel;
. Wrench for bolt down manhole lids;
. Flashlight; and
. Traffic control equipment such as cones, signs, flags, etc.

3.4.3 CCTV

The CCTV utilizes a closed circuit television camera to observe the conditions on the
sewer mains and detect any defects. Inspections will be conducted per the NASSCO
Pipeline Assessment Certification Program (PACP). For each segment that is
inspected, a form will be completed, data collected electronically and a videotape of the
segment will be created.

A CCTV inspection crew will consist of two people full time. There will be one crew
member who will conduct the CCTV inspections.Before any CCTV inspections are
conducted, a training of the inspection crew will be conducted. CCTV inspection
forms (if necessary), controls and procedures will be explained.

The equipment that will be needed for the testing is as follows:

. Equipment required to clean sewer main segments
. Equipment required to conduct CCTV inspections of sewer main segments

The CCTV inspection will take place immediately following the field investigations,
manhole inspection and smoke testing.

3.4.4 Dyed-Water Testing

Dyed-water testing is a rainfall simulation technique used to identify defects that can
contribute significant I/I during a storm event. Dyed water testing may be used to
establish the connection of a fixture or appurtenance to the sewer. It is often used to
confirm smoke testing or to test fixtures that did not smoke. As is the case with smoke
testing, it is not used on a routine basis but rather in areas that have displayed high wet
weather flows. Dyed water testing can be used to identify structurally damaged
manholes that might create potential I/I problems. This is accomplished by flooding the
area close to the suspected manholes with dyed water and checking for entry of dyed
water at the frame-chimney area, cone/corbel, and walls of the manhole.

Dyed-water will be deposited into the storm sewers, streams, ditches, or driveway,
stairwell, or area drains that are suspected to be connected to, or leaking into, the sewer
system. The presence of dye-water in the adjacent downstream manhole, or within the
sewer main, observed visually by inspectors or through CCTV, indicates infiltration.

A dyed-water testing crew will consist of two people. There will be one crew member
who will conduct the dyed-water testing and CCTV inspections. Only suspected cross
connections, or leakage into the sewer system, identified through manhole, visual pipe,
and smoke testing within the priority areas will be dyed-water tested.

Before any dyed-water testing is conducted, a training workshop with the inspection
crew will be conducted. Dyed-water testing forms and procedures will be explained. An
example dyed-water test form is included in Appendix A.

Fluorescent dyes will be used for dyed-water testing. The equipment that will be
needed for the testing is as follows:

. Equipment required to carry water to the site;
. Fluorescent dye;
. Sand bags to block sewer segments;
. CCTV equipment, if required;
. Manhole pick and shovel;
. Wrench for bolt down manhole lids;
. Flashlight; and
. Traffic control equipment such as cones, signs, flags, etc.

The dyed-water testing will be conducted concurrently with Smoke or CCTV inspections,
as potential I/I sources are identified.

3.5 Establishing Source Flows and Costs

Once the field inspections for a priority area have been completed, the data collected
will be analyzed to determine how much I/I was identified (in terms of flow rates) and
the associated reduction options and associated costs to remove this I/I from the
system. These costs will be used to conduct a cost effective analysis to determine the
most effective and efficient use of the City’s limited funds.

Recognizing that the observations of I/I during manhole inspections, CCTV, smoke
testing, and dye-testing may not be truly representative of the I/I entering the system
during peak wet-weather events, the flow monitoring data will be used to calibrate a
hydrologic and hydraulic model that will “mimic” the City’s collection system and
predict the I/I from each basin.

Based on work done in numerous communities in the Willamette Valley, the City is
initially contemplating a basin-wide approach to collection system rehabilitation for the
purposes of I/I abatement. This may include both the public and private portions of
the collection system, including private laterals. Pilot projects may be implemented to
determine the cost-effectiveness of this approach.

Once modeling has been completed and basins have been prioritized based on leakage rates,
a cost effective analysis will be completed. This cost effective analysis will first
determine what sources are the most cost effective to remove and how this cost compares
to the cost of transporting and treating the I/I.

3.6 Recommendations and Implementation Plan

The completed inspections forms, video, and photographs will be incorporated into a
database and/or other Asset Management tool. Through field inspections, it may be
found that most of the defects are located on mains of a certain age or within certain
areas. These mains can be grouped by these categories to better prioritize rehabilitation
efforts. The field inspection forms for all field activities can be integrated. Once the data
has been entered, QA/QC will be conducted to ensure all information was input

During field inspections, immediate attention items and maintenance items will be
identified as work orders or scheduled maintenance. This will help to ensure that these
items get repaired in a timely fashion.

A final report for each sewer basin will be provided in a clear and concise format
summarizing the findings and recommendations for the field investigations and data
analysis. The following information will be included in the reports:

. Executive Summary – highlights all tasks performed, conclusions,
recommendations, and costs.
. Background Information – describes the problem statement, previous studies and
rehabilitation work within the study area.
. Sewer Map – delineates sub-basins monitoring locations, and sewer sizes.
. Field Data Analysis – tabulates the results of the field activities and quantifies I/I
flows per source.
. Recommendations – lists the recommended activities for each basin, including cost
and finalized implementation schedule.
. Appendix – includes a complete bound copy of written inspection forms and a CD
containing scanned images of the inspection forms and digital inspection photos.


The I/I Reduction Plan to manage and control peak wastewater flows will consist of
public sector I/I reduction/elimination. I/I reductions will be divided into the
following categories:

. Priority 1 – Cost Effective Rehabilitation
. Priority 2 – Structural Rehabilitation
. Preventative Maintenance
. Post-Rehabilitation Flow Monitoring

The City has a sewer rehabilitation program, but it typically has addressed major
problems when they occur, such as pipeline backups. The objective of the City’s
updated sewer rehabilitation program, as outlined in this I/I Assessment and
Reduction Plan, is to maintain the overall viability of the City’s collection system.
This is done in three ways: (1) ensuring its structural integrity; (2) limiting the loss of
conveyance and wastewater treatment capacity due to excessive I/I; and (3)
controlling exfiltration from the pipe network. The rehabilitation program builds on
information obtained from all forms of maintenance and observations made during
O&M, as well as the specific investigative activities described in this Plan.

There are many rehabilitation methods which the City considers for particular
issues. The City’s choice of methods for addressing a given issue depends on pipe
size, type, location, dimensional changes, sewer flow, material deposition, surface
conditions, severity of I/I, and other physical factors, as well as cost-benefit ratio,
available or anticipated funding and priority in comparison to other existing or
anticipated O&M issues.

4.1 Priority 1 – Cost Effective Rehabilitation

Cost-effective rehabilitation are those repairs that remove I/I and meet the lowest costs
as determined by the composite cost curve method described in Section 3.5. Cost
effective rehabilitation can consist of manhole, pipeline and public lateral rehabilitation,
as well as closing off stormwater sources.

4.1.1 Manhole Rehabilitation

Cost-effective manhole rehabilitation is typically focused on the top-end of the
manhole where higher I/I flows are usually found. Such rehabilitation can include the

. Replace Vented Covers Below Grade;
. Raise Manhole to Grade;
. Replace/Rehabilitate Frame/Seal; and/or
. Replace/Rehabilitate Chimney.

4.1.2 Pipeline Rehabilitation

Cost-effective pipeline rehabilitation may consist of the following methods:

. Point Repairs;
. Full Line Replacement;
. Full Line Rehabilitation;
. Abandon/Realign Pipeline;
. Defective Service Tap Rehabilitation;
. Disconnecting Direct Storm Connections; and
. Disconnecting Indirect Storm Connections.

4.2 Priority 2 – Structural Rehabilitation

Additional defects that exhibited enough structural deterioration to warrant
rehabilitation but may not be classified as cost effective will be recommended for further
evaluation and possible repair. Structural rehabilitation also consists of both manhole
and pipeline rehabilitation.

4.2.1 Manhole Rehabilitation

Structural manhole rehabilitation may consist of the following methods:

. Replace/Rehabilitate Frame Seal;
. Replace/Rehabilitate Chimney;
. Rehabilitate Cone and Wall;
. Rehabilitate Bench and Invert; and
. Rehabilitate Pipe Seals.

4.2.2 Pipeline Rehabilitation

Structural pipeline rehabilitation may consist of the following methods:

. Point Repairs;
. Full Line Replacement;
. Full Line Rehabilitation; and
. Abandon/Realign Pipeline.

4.3 Preventative Maintenance

The City is currently developing a preventative maintenance and emergency
maintenance plan to more explicitly describe the City’s current O&M activities. The City
will integrate preventative maintenance activities into its O&M activities to address
those areas with identified I/I but which are lower on the priority scale.

4.4 Post-Rehabilitation Flow Monitoring

Following the rehabilitation of individual study areas, post-rehabilitation flow analysis
will be conducted to measure the success of the program. Flow monitoring will be
performed in the same locations as were monitored prior to rehabilitation. Flow data
will then be compared to pre-rehabilitation flow monitoring. Results will be evaluated to
determine the success of the rehabilitation program and whether future rehabilitation
methods should be altered.


A project schedule for completion of the SSES and related I/I reduction improvements
is presented in Figure 2. Each basin will be studied separately and is divided into five
categories: initial flow monitoring; completion of the SSES, including the cost-benefit
analysis and preparation of the final report; design and bidding of the selected I/I
rehabilitation improvements; construction of the selected I/I rehabilitation
improvements; and post-rehabilitation flow monitoring.

The project schedule is constrained by weather and other uncontrollable factors. For
example, smoke testing cannot be performed when the soil surrounding the pipes is
saturated or frozen or during windy days. Inspections will only be conducted during
working hours, excluding holidays, and weather permitting days.

Figure 2: Proposed Schedule for I/I Assessment and Reduction Activities

Appendix A

Field Inspection Forms

Appendix B

Notification Letter
and Door Hanger

Public Works

117 N Molalla Avenue, PO Box 248, Molalla, Oregon 97038

Phone: (503) 829-6855 Ext. #218 Fax: (503) 829-3676


Resident name


Dear Resident:

The City of Molalla will soon be implementing field inspection activities as part of the City’s ongoing efforts to
improve the sanitary sewer system. These improvements are intended to eliminate excess stormwater and groundwater
from entering the sanitary sewer system. This excess stormwater and groundwater overloads the sanitary sewers
causing basement flooding and sewer back-ups during and after periods of heavy rainfall. These field inspections
will lead to improvements to the sanitary sewer system.

The field inspection activities include conducting smoke testing activities during the summer months. The purpose
of “SMOKE TESTING” is to locate obstructions and defects in the sanitary sewer collection system. The smoke
that you see coming from the vent stacks on houses or holes in the ground is: NON-TOXIC, HARMLESS, HAS NO

The smoke should not enter your house unless you have defective plumbing or dry drain traps. If this occurs, you
should consult your licensed plumber. In any event, the smoke can enter through faulty plumbing. The potential,
likewise, exists for dangerous sewer gases to enter your home or establishment. Should smoke enter your building,
you may contact a member of the smoke testing crew working in your neighborhood. If you have any seldom used
drains, such as floor drains in basements, please pour water in the drain to fill the trap, which will prevent smoke from
entering there. Drain traps should always be filled with water to prevent sewer gases or odors from entering the
building. Additionally, washing machine drain pipes do not have traps. To help prevent smoke from entering your
building around the washing machine drain pipe, tie a damp rag around the drain opening.

About 72 hours before smoke testing begins, door hangers will be distributed at each residence providing
information regarding the procedure and names and phone numbers of personnel to contact for more information.
During the smoke testing activities, personnel will be identifying defects that are revealed when smoke escapes through
them. Locations for defects may include roof downspouts, uncapped cleanouts, driveway drains, stairwell drains,
yard or area drains, window well drains, foundation-perimeter drains and defective service pipes. Smoke testing
is anticipated to begin in early April and continue through the summer and fall months.

Thank you for your cooperation and assistance in helping the City of Molalla in its effort to improve the quality of
service to all of our customers. Additional information concerning these activities may be found at either


If you have any questions or require additional information, please contact the City at 503-829-6855.

City of Molalla, Oregon

City of Molalla, OR


The City of Molalla is implementing field inspection
activities as part of the City’s ongoing efforts to
improve the sanitary sewer system. These
improvements are intended to eliminate excess
stormwater and groundwater from entering the
sanitary sewer system. This excess stormwater and
groundwater overloads the sanitary sewers causing
basement flooding and sewer back-ups during and
after periods of heavy rainfall.

The field inspection activities include smoke testing.
The smoke testing will occur in your area during
the week of .

The smoke should not enter into buildings unless
leaks or plumbing defects exist. The smoke that you
see coming from the vent stacks on houses or from
holes in the ground is: NON TOXIC, HARMLESS,
HAZARD. Please make sure that traps for all
basement floor drains and other sink traps and
plumbing fixtures are full of water by pouring
approximately 24 ounces of water into each drain.
Smoke may also enter your building around the wax
ring, if faulty, at the base of the toilet.

Should you detect smoke in your building, the room
should be ventilated through an open window or
door. Leave the area and ventilate well to dissipate
the smoke. Also, please notify the field technicians
who are conducting the test should smoke enter your

Thank you for your cooperation and assistance in
helping the City of Molalla in its effort to improve
the quality of service to all of our customers.
Additional information concerning these activities
may be found at either

City of Molalla, OR


The City of Molalla is implementing field inspection
activities as part of the City’s ongoing efforts to
improve the sanitary sewer system. These
improvements are intended to eliminate excess
stormwater and groundwater from entering the
sanitary sewer system. This excess stormwater and
groundwater overloads the sanitary sewers causing
basement flooding and sewer back-ups during and
after periods of heavy rainfall.

The field inspection activities include smoke testing.
The smoke testing will occur in your area during
the week of .

The smoke should not enter into buildings unless
leaks or plumbing defects exist. The smoke that you
see coming from the vent stacks on houses or from
holes in the ground is: NON TOXIC, HARMLESS,
HAZARD. Please make sure that traps for all
basement floor drains and other sink traps and
plumbing fixtures are full of water by pouring
approximately 24 ounces of water into each drain.
Smoke may also enter your building around the wax
ring, if faulty, at the base of the toilet.

Should you detect smoke in your building, the room
should be ventilated through an open window or
door. Leave the area and ventilate well to dissipate
the smoke. Also, please notify the field technicians
who are conducting the test should smoke enter your

Thank you for your cooperation and assistance in
helping the City of Molalla in its effort to improve
the quality of service to all of our customers.
Additional information concerning these activities
may be found at either

If you have any questions, contact the City at 503-


If you have any questions, contact the City at 503-


February 4: Planning Commission to Consider Proposal to Increase Density for a 5-acre Parcel (P44-2014, at 1118 Toliver Rd.)

20150201cpy.. 1118 Toliver cropped taxmapThe Molalla Planning Commission meets at 6:30PM, on Wednesday February 4th, at City Hall. At this meeting, they will again hear a proposal that was tabled in early January, on a proposal to rezone a parcel in northwest Molalla, to allow high-density residential development.

The site is a single-family residential property measuring nearly six acres total. The property is roughly triangular. A long curve of the abandoned Molalla Forest Road is to the southwest, the Elementary School is to the east, and Toliver Road is to the north.

The development proposal is being handled by Frank Walker, for the Donald Itschner family estate. The site is relatively level, with a small yard and garden area near the house and shop building. Roughly half of the property is in mature deciduous forest. It is adjacent to a school, a ballfield, and an abandoned corridor (the historic Molalla Forest Road). There is a small creek running through the center of the property. As is typical of the area, there are wetlands with soils that are seasonally saturated with water.20150201scp.. 1118 Toliver Molalla, Google Map with outline of entire propertyAs shown on the Google satellite image below, the property (orange ellipse) is one of the only natural and forested areas within walking distance of hundreds of densely packed homes to the north (large area outlined in red). There are no parks serving this large subdivision area.20150201scp.. Google Map with markups for 1118 Toliver, large area view Here are three close-up satellite views, from Google Maps. The first shows the home/garden in the northern portion of the property. The second shows most of the southern portion of the property. The third shows the western half of the apartment complex to the north, in the middle of the large Molalla subdivision area; this is what high density development would look like, if the City approves the zoning change.:20150201scp.. 1118 Toliver Molalla, Google Map of northern portion of property20150201scp.. 1118 Toliver Molalla, Google Map of middle portion of property20150201scp.. Meadow Drive Apts Molalla, Google Map of western portion of property

A Better Plan

The location and natural qualities of this property make it an absolute no-brainer for the City of Molalla. We need to develop this property as a valuable asset for this area: a corridor trail to serve the community with parks, recreation, and wildlife habitat. City of Molalla should work toward acquiring most or all of this property. Generous grants are available (from both state and federal sources), but the City needs to provide the see money for those grants. Thus, the City should NOT be granting property tax emptions, as the City Council did on January 28th for ‘Pacific Fibre Products, Inc.’.

The City’s goals should be to:

  1. preserve the forest area as a refreshing wildlife habitat and nature-viewing area;
  2. develop picnic and play facilities on the non-forested southern portion of the parcel;
  3. make minimal improvements to the Molalla Forest Road between Highway 213 and Highway 211, as a bicycle and pedestrian corridor, to accommodate the recreational needs of area residents;
  4. over time, pursue expansion of this bicycle and pedestrian corridor, using the historic Molalla Forest Road, all the way to the Molalla River Recreation Area.

See also:

January 2015: A ‘Letter to Editor’ to Molalla Pioneer, regarding MPC Hearing & Wetlands Near Toliver Road

…the following is Susan Hansen’s Letter to the Editor, sent to the Molalla Pioneer…

Molalla’s usual haphazard planning, putting developers’ demands above sound and orderly planning and zoning, is on display with the proposal to re-zone a Toliver Road parcel from single family to multi-family.

City Manager Huff claims that Molalla needs more multi-family. If that is true, why did Huff advocate to re-zone a big chunk of land in Big Meadow from multi-family to single family this summer? In sound urban planning, multi-family is integrated into residential areas so traffic filters out onto multiple neighborhood feeder roads. The property on Toliver would dump multi-family traffic onto already busy Toliver, right next to the Grade School.

The Toliver property hosts wetlands outlined on Molalla’s official Wetland Inventory (BC-6A). Before any development can occur, a property owner must hire wetlands experts to produce a wetland delineation report and submit it to the Division of State Lands. How can Molalla’s Planning Commission make an informed decision about re-zoning to multi-family before that required study is submitted and approved? No one knows how much of the subject property could actually be developed and what constrictions will be imposed because of the wetlands.

The subject property’s wetlands are part of a 10 acre Toliver Road to Main Street wetlands complex that feed Bear Creek. The Inventory notes the wetlands have high enhancement potential, provide wildlife habitat and have potential for educational use and recreational activities. The wetlands feature a mature forest of Oregon white oak and ash. A segment of the Forest Road runs though these wetlands and the area would make a fantastic park for the woefully underserved west side of Molalla.

Molalla’s Comp Plan Goal 5 (pages 16-17 “Water Resources”) states: “Maintain natural wildlife corridors along protected creeks and drainage ways; Give priority to preservation of contiguous parts of that network which will serve as natural corridors throughout the city for the protection of watersheds and wildlife; Conserve significant trees and vegetation within protected water resource areas…”

Will Molalla respect the value of the wetlands by following its Water Resources mandate and step up to provide quality of life enhancing parks? Or will Molalla’s unthinking, greedy march to stuff in ill planned development continue unabated?

A hearing on Feb. 4 will consider what path to take; citizen input is critical.

Thank you, Molalla Pioneer, for printing this letter in the 1/28/2015 print edition.

The Public Needs Transparency in MSTP Reports

With transparency, citizens can know how well their public employees are serving. Thus, if the Molalla Sewage Treatment Plant (MSTP) is well run, transparency lets us know, so we can be confident and appreciative of a job well done. But, if the Molalla Sewage Treatment Plant is poorly run, transparency empowers citizens to put pressure on elected officials to correct problems, and restore needed efficiencies. Unfortunately, when it comes to sewage services, the leadership of Molalla has a history of impeding transparency.

As a case in point, consider how poorly MSTP handled transparency eight years ago, when they signed a Consent Decree. MSTP was required to post weekly data reports for the two-year duration of the Consent Decree. They failed. Only a few of the weekly reports and some of the monthly reports were posted. Years later, the website was changed making it difficult to find the report copies. (click here to view all reports as copied on 1/25/2015)

Anyway, here’s the background on transparency failures with the Consent Decree of 2006…

In late May 2006, multiple groups and individuals filed a civil action against the City of Molalla charging violations in waste handling at the Molalla Sewage Treatment Plant. Roughly eight months later, a settlement was reached between the parties, in the form of a Consent Decree. The key terms of this Consent Decree, which remained in effect for two years, included:

  • For two years, City of Molalla would do additional weekly water testing at the following locations: (para.16)
    1. the Feyrer Park Bridge
    2. immediately upstream of the City’s Molalla River outfall
    3. at the downstream edge of the mixing zone, which is 50 feet downstream of the City’s Molalla River outfall
    4. the Highway 211 bridge
    5. the point where Fryer Park Road crosses the irrigation ditch
    6. and, at the point where the City’s effluent pipeline crosses the irrigation ditch.
  • When conducting these additional weekly water tests, City of Molalla would use grab samples to analyze for Biological Oxygen Demand (BODS), total suspended solids, ammonia, e-coli, temperature, and pH. (para.16)
  • For two years, City of Molalla would post data on its website. This would include both the weekly analysis results at the above six locations, and the monthly/quarterly MSTP monitoring reports filed with DEQ, in accordance with the NPDES Permit. (para.16)
  • City of Molalla would pay $6,324 in civil penalties (para.22)
  • City of Molalla would pay $50,000 in legal fees (para.24)
  • City of Molalla would pay $110,000 to fund a supplemental environmental project administered by Molalla Riverwatch (para.23)

And how well did the City of Molalla do? Well, some of the monthly reports were posted online, and some of the additional weekly water test results were posted, too. So, during some times of the two year Consent Decree, citizens were able to see the data. But the data was spotty. And, unfortunately, once the two year requirement of the Consent Decree was done, Molalla quit posting their monthly reports.

A Bear Creek Photograph: Low Water, Early Fall

Less than ten years ago, the wastewater produced in Molalla was pumped straight into Bear Creek, near Highway 213. It then flowed west past Dryland Road, Highway 170, Barlow Road and eventually joined the Pudding River south of Aurora.  Nobody knows what toxins and other hazards were deposited in Bear Creek during the sewage decades. Here is a picture from downstream, in one area where Nature appears to be doing well. This picture is looking east, just upstream from Dryland Road.

Bear Creek, just E of Dryland Road, view upstream

If you have a Bear Creek photograph for us to post at this website, please attach it with an email to:

E. coli Risk Reported Downstream of the Silverton Sewage Treatment Plant

…this news story indicates that the risk of E. coli is becoming common in many places in Oregon, not just in Creamery Creek…

20140916.. Silverton map showing E.coli impact area downstream from STPAnother Oregon incidence of elevated E.coli readings, this time just west of Silverton. The readings were in Silver Creek,  which flows from east to west.

Here is a copy of a Statesman Journal article by Joce DeWitt:

High levels of E. coli discovered near Silverton wastewater treatment plant

Silverton city officials advised people to avoid contact with a portion of Silver Creek due to a high concentration of E. Coli discovered downstream from a wastewater treatment plant.

Fishing and swimming in the creek should be avoided until bacteria levels return to normal, the city said in a press release.

The presence of E. coli bacteria indicates that the water may be contaminated with human or animal waste. Contact with the waste could cause symptoms like diarrhea, cramps, nausea and headaches. It could be particularly risky for infants, children and some elderly people, as well as those with compromised immune symptoms.

The wastewater treatment plant is at 400 Schemmel Lane to the south of Silverton High School’s Pine Street campus.

Swimming areas north of the treatment plant are not affected.

August 2014: A ‘Letter to Editor’ to Molalla Pioneer, regarding Biosolids

…the following is Jeff Lewis’ Letter to the Editor, sent to the Molalla Pioneer…

As a local citizen in the Molalla area, I appreciate that our local newspaper covers important government decisions that can impact health and quality of life. One example is the recent Pioneer coverage on 8/20/2014, ‘Council Accepts New Biosolids Plan’.

The article accurately notes that the Molalla Sewage Treatment Plant (the large ponds just west of Les Schwab) generates lots of waste byproducts, all of which must eventually be removed. What concerns me though is that the article implies lots of rules are being followed and that applying this sludge onto cropland is all positive, but the article fails to identify the negatives. Nor does the article mention a better and safer solution: this sludge needs to be sent to a landfill, not disposed onto cropland.

I am working with a few other concerned citizens who are trying to help Molalla officials improve Molalla, especially around the resource we know as Bear Creek. Our nonprofit group has created a website,, where we are posting information and inviting community discussion. One of our key areas of concern is what the Molalla Sewage Treatment Plant (MSTP) does with their waste byproducts: the wastewater and sludge.

Fifty years ago, most U.S. cities disposed of sewage waste by piping it into rivers and barging it out for ocean dumping. The Clean Water Act put an end to that. A few years later, EPA began a positive ‘spin’ program, to convince the public that sewage treatment byproducts do not have to be fully cleaned and can be ‘beneficial’ if disposed onto farmland.

How dangerous is this stuff? Just go online and Google ‘biosolids Georgia dairy lawsuit’. There are hundreds of news articles, congressional testimonies and more about one of the worst biosolid stories: more than 200 cows killed by accumulation of biosolid toxins that eventually destroyed two dairies. Or, please see the collection of links at the website.

It is good that Mayor Rogge, the City Council and Mr. Huff are looking at this issue, deliberating in public sessions, and explaining their decision to the press. This is transparency, which we need to happen. But, we are all aware of the power of ‘spin’ to distort public perception. A public manipulated to see only the good while ignoring the bad is a public poorly served by officials. So, in the interest of full disclosure, I hope that Molalla officials will soon clarify:

  • of the “750,000 gallons of sludge” declared in the article, how much of that is water, and how much of that is actual solids dredged from the MSTP ponds?
  • what percentage of total accumulated biosolids do we expect to see removed under this new contract transporting “750,000 gallons of sludge” to the Macksburg farmland?
  • what testing is MSTP doing on this “750,000 gallons of sludge” to assess the presence and concentration of such toxic elements as heavy metals, persistent synthetic pharmaceuticals, dioxins, etc. …the same biosolids toxins that have damaged and even destroyed farmlands elsewhere in the United States?

Thank you, Molalla Pioneer, for printing this letter at page 4 in the 8/27/2014 print edition. [link to jpeg]