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Biosolids, recycled wastewater draw scrutiny

Molalla to come up with new wastewater management plan after DEQ stopped the citys application of recycled water on fields not approved by the agency.


by: DEPARTMENT OF ENVIRONMENTAL QUALITY - DEQ officials used this map Tuesday to show the sites the city had been using to recycle wastewater through irrigation, including sites not listed in the city’s recycled water management plan. Those sites are, from the left: the Jorgensen, Nursery, North Coleman Ranch, Coleman Corrals and Adams Cemetery sites. The sites (right) where the city discharges wastewater from the treatment plant into the river, and lower right, where the drinking water intake is loated, are also shown.During a special informational meeting held by the Department of Environmental Quality, about 25 Molalla citizens spoke out Tuesday evening on the city’s use of recycled wastewater for rural irrigation, with the big question being “How can we trust the city?”

DEQ set up the meeting to discuss the proposed renewal of the city’s water quality permit and approval of associated biosolids and recycled water management plans for Molalla Wastewater Treatment Plant.

“So the big question is how can we trust the city of Molalla to be self monitoring and stop all this ponding? I’ll be out again next summer with my camera.”

— Susan Hansen

DEQ representatives asked for comments from community members on the permit conditions and city management plans for the beneficial reuse of biosolids and recycled water. The permit was last issued in 2009.

Tiffany Yelton-Bram, a DEQ water quality manager, said the meeting came about after the DEQ became aware late last summer that the city was applying recycled wastewater to rural properties that were not included in the city’s recycled water management plan. Those sites included the Jorgensen property, the North Coleman Ranch, the Coleman Corrals, Adams Cemetery and the Mandan nursery site.

DEQ stopped the city from irrigating those sites and took steps to see that the city begin corrective action.

Last autumn, the DEQ sent at least two warning letters to the city concerning the violations.

A warning letter dated Oct. 7, 2013 and addressed to Dan Huff and Marc Howatt followed a Sept. 23, 2013 letter. The Oct. 7 letter, signed by Yelton-Bram, stated the city had applied recycled water at sites that were not identified in the city of Molalla’s 2004 recycled water management plan.

According to the letter, city officials had violated ORS-46B.025: “No person shall violate the conditions of any waste discharge permits.”

The National Pollutant Discharge Elimination System permit includes specific requirements related to recycled water, including that all irrigation must conform to an approved recycled water use plan.

Recycled water management plans provide specific details related to the use of recycled water under the permit.

Five DEQ representatives conducted the Tuesday meeting, led by Yelton-Bram and Connie Schrandt, DEQ northwest region coordinator of biosolids and recycled water programs. City Manager Dan Huff and Jon Patrick, the city wastewater treatment plant superintendent, were on hand to answer questions.

Recycled wastewater

In the meeting, which included a lengthy question and answer session, Molalla-area resident Susan Hansen asked how DEQ could justify approving irrigation with recycled wastewater of Coleman Ranch fields.

“Most of those fields are flowing all year long with Bear Creek and they also are the headwaters on the north side for Bear Creek and Creamery Creek,” she said. “So how do you justify approving adding more water to those fields, especially when we’ve often seen Bear Creek flow in the middle of summer due to irrigating of those fields. Where is the logic when you know there are wetlands and flowing streams through those fields?”

“We had to restrict them from using those sites they were using already. We did send warning letters. And the corrected action we asked for is what’s got us here today.”

— Tiffany Yelton-Bram

DEQ manager

The DEQ representatives replied that the city’s recycled water use plan requires a 50-foot setback to irrigation near any water feature.

“We are not allowing watering on the entire ranch,” said Yelton-Bram, adding that she realized there are very large areas, especially on the south part of the Coleman fields, where ponding can be reached quickly. “So that’s the condition we put on there — you can’t irrigate if at 50 percent or more field capacity, and 100 percent means the field is ponding already.”

Hansen responded that “it happened all this summer, and you didn’t stop it. The city didn’t monitor itself. So finally you issued a warning letter only after I contacted the EPA. So the big question is how can we trust the city of Molalla to be self monitoring and stop all this ponding? I’ll be out again next summer with my camera.”

Yelton-Bram said DEQ last summer “had conversation with the city” to let them know they were irrigating sites with recycled wastewater that had not been approved through DEQ. “And so we had to restrict them from using those sites they were using already. We did send warning letters. And the corrected action we asked for is what’s got us here today.”

The Plan

As a corrective action, the DEQ required the city to provide a current recycled water management plan that identifies all sites where recycled water is to be applied. In the Oct. 7 warning letter, it states that until such time that the new plan is approved, the city must only apply recycled water on the sites currently authorized under the existing plan.

The letter listed additional actions needed to ensure that the recycled water plan and its implementation can be more closely monitored for compliance.

— The city must conduct a beneficial use survey of the properties near the sites used for recycled water application to determine what uses of groundwater are happening on those properties. That means the city must do “a physical door-to-door survey” of any properties within a certain distance from the recycled water irrigation sites, including the Jorgensen property, North Coleman Ranch, the Coleman Corrals, Adams Cemetery and the Mandan nursery site. This must be completed by May 1, 2014 (the next irrigation season). The results are to be shared with DEQ, when further sampling of groundwater may be required.

— The city must take action to ensure that recycled water is applied so that ponding and runoff are avoided, effective immediately. Since DEQ can take enforcement action against both the city as the supplier and the property owner as the end user of the recycled water, DEQ recommended that the city communicate clearly with end users about the roles and responsibilities of all parties for compliance with the permit, and provide a copy to DEQ, to confirm the communication took place.

The letter warned that should the violation remain uncorrected, or should the city repeat the violation, the matter may be referred for formal enforcement action, including assessment of civil penalties and a DEQ order.

The permit in question is known as a National Pollutant Discharge Elimination System water quality permit.

At Molalla’s treatment plant, wastewater goes through a treatment and disinfection process before being pumped to an irrigation system. From Nov. 1 to May 31, the wastewater is discharged into the Molalla River at a point just downstream from Feyrer Park, near the Shady Dell community.

The permit sets conditions for how the facility deals with the following pollutants: Biochemical oxygen demand, suspended solids, bacteria, residual chlorine, ammonia and temperature. The permit further requires the city to monitor pollutants using federally-approved monitoring practices and standards.

Monitoring the sites

In Tuesday’s meeting, one man questioned whether the city’s required monitoring of the sites would be made available for everyone to see.

“I would like the city to look at posting that monitoring so people can follow it,” he said. “I don’t have a lot of trust in the city on doing their reports. I personally witnessed city employees taking samples from the wrong areas and then reporting on it.”

DEQ representatives were asked if they have the authority to include a provision in the permit that would require the city to post the results of weekly monitoring in the newspaper when the wastewater is being applied. “We’d like a concise declaration of the facts, so we can be sure that nothing’s being done under the table.”

When the question was put to Huff, he said, “I don’t think we are prepared to answer that tonight.”

Laurie Freeman Swanson, president of The Molalla Irrigation Company, asked about the monitoring process where irrigation ditches border two of the sites in question.

“We have great concern about this,” Freeman said. “We need to return that water to the river. So I would like you guys to know where the irrigation ditches are.”

Jon Patrick, the city’s wastewater plant superintendent, said “If you see a creek running next to a property, we might not know it belongs to an irrigation company.”

Patrick noted, however, that the city is responsible for sending out letters of notification to all neighbors of these sites.

Biosolids

The proposed city permit also includes conditions and requirements related to the removal and land application of biosolids dredged from lagoons, as detailed in the Biosolids Management Plan.

Yelton-Bram said the plan documents how biosolids are monitored for land application, how they will be applied and criteria for requesting new sites for authorization. Biosolids from lagoon systems typically have to be removed every 15 to 20 years.

One man asked about the use of biosolids close to the irrigation canal. “I’m concerned about the Johnson property,” he said. “There’s a ditch that runs through that property. Will a 50-foot setback be enough to keep nitrogen out of the ditch? It’s really close to the river there, and that’s our concern. If applied this summer, and we get a heavy rain, will it wash into the river?”

Schrandt, the DEQ coordinator for biosolids, said the city had agreed to move the biosolids site from the Coleman Ranch after concern was raised by Molalla River Watch and Molalla Irrigation.

She said the biosolids applied are not actually solids. Rather, the city applies a liquid form of biosolids out of the back of a water truck, to about an inch deep. On a dry day, the biosolids will go right down into the soil, which acts like a sponge, providing filtration of the wastewater and solids. “So I believe 50 feet is sufficient, if this is only allowed during dry periods,” she said.

Hansen asked if the DEQ had assessed the amount of biosolids now being stored, stating that she was told by the public works manager that “it was a crisis” and the city had to move biosolids to nearby locations because it couldn’t afford to haul the biosolids to eastern Oregon or other areas.

“The big question is are you looking yourself at how much biosolids are there?” Hansen said. “And what about the cost of getting rid of biosolids?”

Yelton Bram answered that DEQ did a sampling and analysis in 2012 to estimate the amount of solids. “It’s up to the city’s budget how much of these dredged solids can be removed,” she said. “If that one site is only so many acres, we can allow only so much to go out there. So if they are going to dredge more solids, they need more places to put it.”

Patrick said the city has about four acres seven feet deep of pure solids stored.

“So we have more than 5 or 6 million gallons in there,” he said, adding that the city is still looking for more fields to get rid of it all.

That prompted one man to comment, “I know a farmer who used biosolids several years in a row. He was getting very good hay, but it was glowing in the dark after a while.”

The DEQ representative explained that according to state rules, once a site reaches a certain level of concentration of zinc or lead, the city will have to stop applications at that site.

“There will come a time when yes, you will have to pull that truck off,” she said.

“They have to come to me to get authorization of that site. We have a check list that includes all the information they need to provide to DEQ, and I’ll do a site visit. I won’t authorize that site until after we’ve had enough time to hear from the neighbors. Then if I consider it sensitive, it has to go out to public hearings. That often doesn’t happen because if the city knows there’s dissidence, they will go somewhere else.”




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