Tag Archives: RWUP

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.

Who is Potentially Impacted by the MSTP Wastewater Outfall Pipe in the Molalla River?

Coleman Ranch Impacts upon Molalla River

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.

July 2014: DEQ Letter to Molalla, seeking further info prior to issuing a revised RWUP

The letter is by Tiffany Yelton-Bram, who is Manager of the Water Quality Source Control Section at the DEQ office in Portland. It sets a deadline of 7/22/2014 for Molalla to produce the requested answers and records.

The closing paragraph includes three ‘recommendations’ that DEQ would like to see Molalla do:

  1. keep all recycled water irrigation records for five years
  2. identify an alternative means (such as a website) to share records with the Public
  3. rewrite and reorganize the RWUP to improve readability for the Public.

Here is a link to the PDF:

20140710.. Letter to D.Huff re MSTP RWUP, need more info, by T.Yelton-Bram (2p)

 

January 24, 2014: Letter to the Editor

The following is Bear Creek Recovery’s Letter to the Editor, as published in the Molalla Pioneer…


Molalla and the Clean Water Act: Why We Care

“If there is magic on this planet, it is contained in water. “ – Loran Eisely, The Immense Journey

As you travel around the Molalla countryside, have you noticed all the “magic waters” that gather and flow? Our hills and dales are filled with springs, vernal pools, wetlands, creeks and one amazing wild and scenic river. Some of our watersheds feed the Molalla River; many others flow west to join the Pudding River. Some water emerges and then seeps below ground to recharge our wells. All our gathering waters finally join the Willamette and the Columbia. Along the way – from the tiniest springs and seasonal pools to the mighty Columbia – wildlife, domestic animals and humans depend on clean water to survive.

Last spring, a group of local people gathered to discuss concerns about Molalla area watersheds. A non-profit called Bear Creek Recovery (BCR) was formed. Bear Creek was chosen as a symbol of a local watershed in need of mitigation and protection. BCR’s goals include working to educate the public about Bear Creek and its adjoining watersheds and wetlands.

BCR has learned a great deal about the functions of local watersheds and identified threats to our fragile wetland environments. We have focused on Molalla’s wastewater treatment plant, because the City discharges treated effluent into the Molalla River while it also, during the dry months, applies tens of millions of gallons of wastewater to areas of the Bear Creek Watershed. What we learned is that the City is falling behind on the most basic upkeep and maintenance causing major problems for our watersheds. For years, the City has been using illegal disposal sites. For its part, DEQ has looked the other way and has never once enforced the permit against the City.

Molalla’s violations revolve around inflow and infiltration of groundwater into the old sewers (I&I), lack of adequate recycled water application sites, sewage sludge accumulation and ponding, run-off and creek re-charge from over-irrigating with recycled water

A recent report from DEQ indicates that an estimated 500,000 gallons per day of groundwater and stormwater are entering its sewage system, which overwhelms the treatment plant. The City’s I&I problems has been known for years, yet DEQ continues to allow the City to delay taking significant steps to fix the failing sewer pipes. DEQ now proposes to amend the City’s permit without requiring the most basic maintenance of the City’s system.

Here is what Molalla’s former Director of Public Works, Dean Madison, stated in a memo to DEQ in 1997: “Molalla has major I&I problems…flows up to 100 times normally acceptable levels…the entire older system has high I&I throughout.” Seventeen years later, no aggressive action has been taken to solve the I&I problems. DEQ should ensure that the City actually begins resolving the I&I issue under its new permit, but, based on the draft permit, this is not likely to happen.

What is DEQ’s answer? It proposes to rubber stamp the illegal disposal sites that Molalla has been using for years. That’s like punishing your child by patting him on the back and saying, “nice job, son.” Even with multiple unpermitted sites in use in the past, Molalla caused overspray, ponding, run-off and re-charge of Bear Creek; at times the city disposed of recycled water in the Molalla River during summer and fall. With DEQ unwilling to police the City, violations will likely continue.

Another major problem is that once water is separated and processed to be recycled, the City is left with sewer sludge (biosolids), which fills up its lagoons. This build-up of sludge has contributed to the City’s need to violate its permit in the past to avoid lagoon overflow and failure. The City needs to clean out its system, dispose of the sludge properly, and get back on track.

Water may seem “magic” but there is no alchemy that can solve the many water quality problems we observe in Molalla. It will take education, cooperation and, ultimately, major changes to Molalla’s practices to meet compliance with the Clean Water Act. BCR’s 60 day notice is an invitation for all local stakeholders – urban and rural – to work together immediately to find solutions for Molalla’s recycled water, I&I and biosolids violations. This is the least that we should expect from the City as a good neighbor in our small community.

Ignoring water quality problems for decades causes them to be more difficult and expensive to solve. Molalla’s ability to thrive and grow will depend on its willingness to finally meet these challenges head on. Bear Creek Recovery encourages everyone to help with our mission to honor, protect and enhance the fantastic water resources we share in this amazing place we all call home.

October 2013: DEQ Warning Letter for Molalla STP Violations

On October 7, 2013, Tiffany Yelton Bram, manager at DEQ’s Water Quality Source Control Section, issued a warning letter and opportunity to correct deficiencies at the Molalla Sewage Treatment Plant (MSTP). The letter was addressed to both Molalla City Manager Dan Huff and Molalla Public Works Director Marc Howatt.

Within the letter, it was noted that MSTP was found to be in violation of their NPDES permit, that during the 2013 irrigation season they had applied treated MSTP wastewater at numerous locations not included within the permit. The permitted locations included the MSTP property and the South portion of Coleman Ranch. The non-permitted (violation) locations included:

  • Jorgensen property
  • North Coleman Ranch
  • Coleman Ranch corrals
  • Adams Cemetery
  • Mandan Nursery site (east side of Molalla Ave., just south of Bear Creek)

The letter notes that the violation locations were not included in the list of approved application sites in Molalla’s 2004 Recycled Water Use Permit (RWUP). A draft RWUP revision was submitted in July 2013.

July 2013: Draft Recycled Water Use Plan for MSTP (41-pages)

As part of the process for renewing their permits, Molalla STP prepared a draft Recycled Water Use Plan (RWUP), dated July 18, 2013.

“The City irrigates the Coleman Ranch, Jorgensen property, and the wastewater plant, in the summer to make it until the next discharge cycle. We treat the irrigation water with the same process as the water discharged to the Molalla River.”

– text from pg.8 of this draft RWUP

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?

March 2009: MSTP ends Online Posting of Pollution Sample Reports

Here is a copy of a webpage portion, with links to the reports, as screen-captured on 1/25/2015. It is also viewable at: http://www.cityofmolalla.com/publicworks/page/pollution-sample-report20150125scp.. Molalla Wastewater Division webpage, 'Pollution Sample Report'
And, here is the full set of reports, from September 2008 into mid-March 2009, compiled into one PDF:

20080905scp.. Sep-2008(wk1) portion of weekly grab sample compilation

(click on image to view/download compiled PDF reports)

April 2007: Signed Consent Decree resolving Molalla Irrigation v. City of Molalla

The image below is page one of the 19-page Final Consent Decree, in which City of Molalla paid fines and agreed to comply with specific monitoring requirements. The city also agreed to be transparent with data for a two year period, by regularly posting data online. Click on this [LINK] to open or download a PDF copy of the complete document….
20070411.. Consent Decree settling Molalla Irrigation et al v. CIty of Molalla (pg.1 pic)