Tiffany Yelton Bram, manager at DEQ’s Water Quality Source Control Section, sent this two-page warning letter to Dan Huff and Marc Howatt:
As part of the process for renewing their permits, Molalla STP prepared a draft Recycled Water Use Plan (RWUP), dated July 18, 2013.
The text within this draft RWUP specifically notes that the reason for irrigating is to “…make it until the next discharge cycle.” In other words, this is seen as a simple engineering problem: manage the accumulating wastewater until the date arrives, sometime in the fall, when it is again legal to discharge directly into the Molalla River. It is that simple.
To appease citizen concerns, they promote this irrigation as a ‘beneficial use’. Officials pretend there are no health issues associated with this treated wastewater, but given the history, can we really trust that this ‘treated wastewater’ has been adequately ‘cleaned’? Can we be confident that the wastewater being used to irrigate pastures for grazing cattle and other properties does not have hazardous (and persistent) elements such as synthetic pharmaceutical compounds? Is it possible that using this water to irrigate at Coleman Ranch and other locations is triggering other problems, such as blooms of E.coli contamination?
The key question is this: would it be safer and healthier, and would we thus be better off, if we stored the MSTP wastewater through the summer then discharged into the river during the rainy season? And, if so, do we have sufficient storage capacity at the MSTP lagoons to pursue this as a real option? Or, are the MSTP ponds too small, or too plugged with accumulated sludge that has not been regularly removed?