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.
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: https://www.cityofmolalla.com/sites/default/files/fileattachments/public_works/page/1642/20190212_final_2018_molalla_annual_ii_report.pdf
Molalla hired professionals to perform a smoke test of public and private sewer lines to find places that leak and allow infiltration that overwhelms the sewer treatment facility. Here’s a link to the document. Molalla and private property owners have a lot of work ahead to fix all the leaks.
…the following is Susan Hansen’s Letter to the Editor, sent to the Molalla Pioneer…
Thank you, Molalla Pioneer, for printing this letter in the 1/28/2015 print edition.
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)
- the Feyrer Park Bridge
- immediately upstream of the City’s Molalla River outfall
- at the downstream edge of the mixing zone, which is 50 feet downstream of the City’s Molalla River outfall
- the Highway 211 bridge
- the point where Fryer Park Road crosses the irrigation ditch
- 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.
At 7:00pm on Wednesday, January 28th, the Molalla City Council and the Molalla Urban Renewal Agency (MURA) will conduct Regular and Executive Meetings. The public is invited to attend the Regular Meeting sessions, which will be held at the Adult Center.
In preparation, the City of Molalla posted two large PDF documents, which can be viewed/downloaded via these links:
- Molalla City Council Agenda, 38p (1/28/15 meeting) (30 MB)
- MURA meeting, agenda & advance packet, 56p (1/28/15 meeting) (10 MB)
Bear Creek Recovery reviewed the documents. Three items were found that relate to the BCR mission: a scope/budget approval for contract work related to NPDES, spending approval of seven flow meters to monitor sewer I&I, and proposed tax abatement for Pacific Fibre Products, Inc. Two of these items were already approved; the third item is proposed. Details and links are provided below:
(1) Brown & Caldwell Project Scope:
NOTE: NPDES stands for National Pollutant Discharge Elimination System. This is a federal system managed by the U.S. EPA, to ensure proper management and handling of pollutants so that water quality is protected. An NPDES permit is required before wastewater can be discharged into Bear Creek or the Molalla River. Application of sewage sludge (aka, biosolids) on farmland and other sites, is also subject to federal guidelines.
This issue was brought up at the 12/17/2014 Molalla City Council meeting, and approved.
(2) MSTP Flow Meters for I&I:
NOTE: ‘I & I’ is inflow and infiltration. Both terms refer to the invasion of extra and unwanted water into the raw sewage flow. Infiltration is water that leaks via poor pipe seals or pipe fractures. Inflow is the addition of rainwater and other liquids that is improperly piped into the sewer lines. An ‘I&I Analysis’ is done to assess the quality of a sewer system in terms of leakage.
This issue was brought up at the 1/14/2015 Molalla City Council meeting, and approved.
(3) Proposed Tax Abatement for Pacific Fibre:
NOTE: The following was included in the 1/14/2015 ‘City Manager’s Report’:This proposal seeks to continue to waive tax payments for a company operating in Molalla. In trade, the company is to pay new employees at a high wage level, IF they hire any new employees. Molalla forgoes tax revenues in exchange for what is potentially (?likely?) zero benefit.
The proposal is listed cryptically on the agenda, as a ‘5 year enterprise zone agreement’, with no mention of the company involved, or the impacts of that company (both positive and negative). A city deficient in parks and behind on maintaining and upgrading it’s sewers is thus giving away needed funds.
Is this a local example of ‘Crony Capitalism‘? Will the City Council reject this bad idea? Will they ask the hard questions on Wednesday, or do citizens need to speak up?
Here’s a link to an analysis by BCR.
In late 1999, an agreement was signed between Coleman Ranch and the City of Molalla. The agreement called for Molalla to pipe their recycled sewage treatment plant wastewater, to be used during half of the year as irrigation for pasture at the ranch. The pipe used to deliver this water was later extended, creating a new Molalla sewage treatment plant (MSTP) wastewater outfall. Thus, while all MSTP wastewater was pumped into Bear Creek prior to 2006, once the new outfall was finished, the wastewater was pumped into the Molalla River. The northbound river flow is indicated by the blue arrow in the image above.
How does this impact local citizens? Well, during hot summer days, locals commonly swim in the Molalla River, just upstream from the Highway 211 bridge (see above aerial view, at “1”). People park near the 211 bridge and hike in, using trails on both the east side and west side of the river. Another popular site, for those willing to hike further, is at “2” above, where there is a rope swing over a pool. Both of these swimming sites are downstream from the MSTP outfall pipe, which is at the orange square (see “3” above).
MSTP is not allowed to discharge during the summer months. However, the same outlet pipe is used to supply treated sewage water to Coleman Ranch, for summer irrigation of cattle pastures. So, water quality for swimmers depends on the effectiveness of the valves on the MSTP discharge line. Also, over the years, MSTP has had repeated events where the ponds are too full and, due to heavy rain, MSTP has needed to open the valves and discharge into the river. Oregon DEQ is helpless to deny their requests, as MSTP cannot let the ponds overflow into the Bear Creek drainage. Consequently, it is conceivable that some may swim in the Molalla River in late Spring or early Fall, unaware that the water includes wastewater discharged by MSTP.
This Post is NOT about stirring panic, but offered instead to make sure that people are informed about a real hazard in the Molalla area. E. coli is serious, and people need to be informed…
Escherischia coli is a rod-shaped bacterium commonly found in the lower intestine of warm-blooded organisms such as humans and cattle. There are many different strains and most are harmless, but a few strains have caused foodborne illness. E. coli O157:H7 causes abdominal cramping, vomiting and a diarrheal illness, often with bloody stools. Most healthy adults can recover completely within a week. Young children and the elderly are at highest risk for developing HUS, which can lead to serious kidney damage and even death. A Shiga toxin may be produced by some strains; it causes ulcers in the colon, and when these ulcers bleed, they commonly produce bloody diarrhea.
When found in mass-produced food items, E. coli can result in enormous food safety recalls. The last large U.S. recall was in May 2014, when eleven people in four states were sickened by E. coli O157:H7 infections, and a Detroit meat packing company recalled 1.8 million pounds of ground beef. Today, in Alberta, at least 157 E. coli illnesses have been confirmed, caused by tainted pork in wontons, spring rolls and other frozen Asian food products.
How dangerous are some of the E. coli strains?
In 2011, nearly 4,000 people became ill, mostly in Germany, from eating bean sprouts that were tainted with the O104:H4 strain; more than 50 died. In the fall of 2006, 199 people in multiple U.S. states came down with illness after eating packaged spinach tainted with E. coli O157:H7, and three died. In spring 2009, 72 people nationwide became ill from prepackaged Nestle Toll House cookie dough; they had snacked on the raw product (don’t we all, when making cookies?), and the rash of hospital visits prompted a product recall.
Many of us remember the original story that made E. coli big news, in January 1993, when a 2-yr-old boy became the first fatality among more than a hundred victims of food poisoning, caused by tainted hamburger served at Seattle-area Jack-in-the-Box fast food restaurants.
Some of the most costly product recalls related to E. coli have been for ground beef. In a 60-slide presentation published in 2006 (approx.), USDA-ARS scientist Mick Bosilevac concluded that a leading cause of E. coli contamination was at the ‘kill floor’, when the hides of cattle were not properly cleaned. If enough of the bacteria passes into the final ground beef product, the hamburger is no longer safe to sell raw; it must be destroyed, or converted to a cooked hamburger final product.
What does this have to do with the creeks in Molalla?
During the summer now ending, Molalla has piped millions of gallons of wastewater from the sewage treatment plant west of Safeway to Coleman Ranch, on the east end of town. It has been used to irrigate hundreds of acres of pasture. This pasture is at the headwaters area for both Bear Creek and Creamery Creek. When the soils become saturated and the water ponds, the excess flows into the creeks, then downstream through Molalla neighborhoods.
E. coli contamination typically occurs in relation to the feces of cattle, humans, and other mammals. So, there would appear to be a substantially high probability that Molalla STP wastewater irrigated in excess onto ranchland could elevate E. coli in our local creeks.
Twice this year, agricultural officials from the State of Oregon have sampled waters in the ditch area near the United Methodist Church. Both times they found substantially elevated E. coli levels. The waters in this ditch become Creamery Creek, which flows northwest through the residential areas between the High School and the downtown area.
DEQ and City officials have been made aware of these elevated E. coli readings in Creamery Creek watershed, but it is not clear if any officials have done any sampling of the creek, or if they have warned any residents about this potential health hazard. In the meantime, heavy pasture irrigation continues, using Molalla STP wastewater, and this heavy irrigation is likely helping to maintain (or even raise) the elevated E. coli levels.
We depend on our government officials to take the lead in protecting all citizens. Just two months ago, swimming at Vancouver Lake was closed by Vancouver officials, due to high E. coli levels. They handled it correctly, for Public safety: they measured the hazard frequently, and they posted the data online:In Molalla, irrigation using Molalla STP wastewater is allowed by a permit process involving DEQ oversight. There is also a need to monitor the results of this permitted wastewater application, just as there is a need to timely communicate with the citizens if and when a potential health hazard arises.
Given the known dangers of E. coli, and given the readings collected by Ag officials twice this year (which were far higher than the Vancouver Lake readings between 308 and 1,203 on July 8th), it would appear that DEQ and City officials may be failing their duties to serve Molalla residents near Creamery Creek.
A creek in a backyard should be a thing of joy and wonder, an opportunity for exploration and learning for a curious child. A healthy addition to our home and community. Molalla is blessed with such creeks. We need to take care of them.
- Oregon Girl, 4, Dies From Complications Linked to E. Coli — (9/10/2014)
- Applebee’s E. coli Outbreak Source Was Likely Cabbage, Officials Say — (8/29/2014)
- Multistate Outbreak of Shiga toxin-producing Escherichia coli O121 Infections Linked to Raw Clover Sprouts — (8/1/2014)
- E. Coli count closes Vancouver Lake to swimmers — (7/10/2014)
- Multistate Outbreak of Shiga toxin-producing Escherichia coli O157:H7 Infections Linked to Ground Beef — (6/20/2014)