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Res 1975 - Wastewater Facilities & Rate PlansCOUNCIL BILL NO. 2837 RESOLUTION NO. 1975 A RESOLUTION ADOPTING THE WASTEWATER FACILITIES PLAN AND RATE STUDY AS REQUIRED BY THE OREGON DEPARTMENT OF ENVIRONMENTAL QUALITY AND DIRECTING STAFF TO IMPLEMENT SAID PLAN WHEREAS, the City Council by Resolution 1952 adopted the final draft of the Wastewater Facilities Plan and Rate Study ("the Plan") and authorized the City Administrator to submit the plan to the Oregon Department of Environmental Quality ("DEQ") for review and approval; and WHEREAS, by letter dated July 23, 2010, DEQ approved the Plan subject to certain minor modifications specified in Exhibit "A"; and WHEREAS, the City has incorporated all of the DEQ modifications and is prepared to adopt the Plan; NOW, THEREFORE THE CITY OF WOODBURN RESOLVES AS FOLLOWS: Section 1. The City hereby adopts the Wastewater Facilities Plan and Rate study as modified by DEQ. A complete copy of the adopted Plan is on file with the City Recorder and is, by this reference, incorporated into this Resolution. Section 2. Staff is hereby directed to implement the provisions of the Plan as adopted by the City Council and approved by DEQ. Approved as to form CYI�v City Attorney Approve Passed by the Council Submitted to the Mayor Approved by the Mayor Filed in the Office of the Recorder Page 1- Council Bill No. 2837 Resolution No. 1975 g -/q "Zot 0 ATTEST: 1)44, -�A stina Shear r, ty Recorder City of Woodburn, Oregon Page 2- Council Bill No. 2837 Resolution No. 1975 EXHIBIT A Page 1 of 5 Responses to DEQ Comments in Letter to Randy Scott, Water Resources Division Manager DEQ Comment Response Volume 1: Wastewater Treatment Section 1 Pg. 1-2, Table 1-1, fifth bullet. The CMOM guidelines have not been promulgated as regulations. Reworded for Following the proposed regulations Is encouraged; however, compliance is not required at this potential time and may never be. compliance. Same table, Growth. It is stated that a key factor related to growth is to increase density. Removed. However, as will be pointed out In a later chapter, a desire to increase the socio-economic status of migrant residents is stressed in an effort to build more traditional single family housing. These "key factors" seem to be at odds with one another. Section 2 Pg. 2-9, Section 2.2.7.3, Senecal Creek. It should be mentioned that Senecal Creek has Added text historically been impacted by the Marlon County Ash Monofill, and will likely see impacts due provided by to high total dissolved solids for vears to come. DEQ. Pg. 2-14, Section 2.3.1.1, Age. The third paragraph is in complete contrast to the statement Removed made In Table 1-1. It appears that Woodburn's "Key Factors" are to increase housing density, "increasing while the City's "Policy" is the exact opposite. Perhaps a review of the City's Comprehensive density' in Table 1-1. Plan is In order to come to the proper conclusion as to what the City's priorities officially are. If the comp -plan priorities differ significantly from current opinions or demographics, a comp - plan update process may be warranted. Pg. 2-15, Section 2.3.1.5, Nativity. The subject matter contained in this section relates to Removed immigration, culture and lifestyle, household sizes, and education levels. The reader could paragraph. possibly interpret the message of this section to be an opinion on subject of immigration. DEQ does not feel that such a message is appropriate for a Department approved Facilities Plan. Pg. 2-16, Section 2.3.2., Economic Conditions and Trends. In the first bullet, the lower range of Removed. the hourly wage is stated as being $7.00/hour. This is below the State of Oregon Minimum Wage. Is this due to non -hourly salary employment, agricultural employment, or some other type of status? The matter needs clarification. Pg. 2-17, Population. The Department is aware that the City's growth management plans are Population under appeal at the Oregon Court of Appeals. While the outcome of the case may not have an projection are effect on the 20 -year population forecast, the population numbers would need to be adjusted, consistent with the Woodburn if necessary, pending the decision. Note however that the population coordinated number for Comprehensive the year 2030 is 37,216. Population projections beyond the 20 -year planning period are less Plan, Appendix certain and, because of the many unknowns, become highly speculative. F and G of the report provide supporting documentation: It is important to grasp, that although population projections are provided. EXHIBIT A Page 2 of 5 Responses to DEQ Comments in Letter to Randy Scott, Water Resources Division Manager DEQ Comment Response residential flow projections are based on 2.8% increase from now to 2020 and 1.9% increase from 2020 to 2060, which is consistent with the comp plan of both the City and Marion County. See section 4.5.1 of the report Section 4 Pg. 4-1, Section 4.3, Service Area Projections. A number of expectations and assumptions are Added note, made In this section, specifically, paragraph three. The basis of these assumptions should be referencing identified. comprehensive plan. Pg. 4-7, Table 4-7 The base line TSS concentration value listed in the Table appears to be on the low side Added footnote and does not seem to reflect the TSS loads in Tables 4-5 and 4-7. about Smuckers in 2004. Page 4-9, item 4.5.1, bullet #1, do the flow Increases projected here represent an accurate estimate of Added note future flows given the fact that 1/1 may Increase with time? referring to discussion in Volume 2: Wastewater Collection and Transmission System. Section 5 Pg. 5-1, Section 5.1.1, Regulatory Requirements. It is stated that the water quality standards for Corrected. the Willamette River are reviewed on a yearly basis. Although it is true that Oregon's OARs are continually evaluated and reviewed for potential modifications, the official review period is the 3 -year "Triennial Review" process. it is also stated that the current NPDES permit is scheduled for review and renewal in 2009. Point of clarification: The permit expired on November 30, 2009, and is scheduled to be renewed In mid 2010. It Is stated in this section that the MAO modifies the permit compliance schedule for Reworded per temperature and winter ammonia. It should be made clear that the MAO Is an enforcement enforcement action and not a modification of the NPDES permit. The permit compliance schedule has not note; referenced been changed; rather, an enforcement action has been taken which set forth its own current MAO compliance schedule, modifications. EXHIBIT A Page 3 of 5 Responses to DEQ Comments in Letter to Randy Scott, Water Resources Division Manager DEQ Comment Response Pg. 5-8, Section 5.1.1.8, Micro -contaminants. In addition to the source control and discharge Added limitations, consumer product regulation combined with public education will very likely be statement to part of this emerging area of concern. plan. Pg. 5-10, Section 5.1.1.12, Sanitary Sewer Overflows. The reference to the 5 -year, 24-hour SSO Added prohibition should Include the January, 2010 effective date. statement to plan. Pg. 5-10, Section 5.1.1.13 Effluent Blending. The current NPDES permit does not allow blending. The Reworded. General Conditions, Schedule F of the permit references bypassing under certain conditions, however, the Department is generally silent on blending. Pg. 5-11, Section 5.1.1.14, Table 5-7, are the acronyms ZID and RMZ defined earlier in the document? Defined acronyms. Pg. 5-11, last paragraph, second sentence, should "RFP" be "RPA"? Corrected. Pg. 5-17, Permit Requirements, It Is stated that the Class B recycled water could qualify as Class A Added recycled water with additional disinfection. This statement should be expanded to include disinfection reference to and filtration. It should also be noted that if the City decides to expand recycled water to privately filtration; added owned property, that both parties are ultimately responsible to manage the recycled water under the notation. new recycled water use rules with or without a contract In place. Pg. 5-25, Section 5.1.5.2, and second paragraph — what are the 100 year and 500 year flood elevations? Added text Will the structural integrity of the wetland system be preserved during these flood storm events? addressing this. EXHIBIT A Page 4 of 5 Responses to DEQ Comments in Letter to Randy Scott, Water Resources Division Manager DEQ Comment Response Section 7 Page 7-1, Section 7.2. The last paragraph references the monthly 2007 flows and loads from the two Modified table. farms In Table 7-1 and Figure 7-1. However, Figure 7-1 appears to be a 6 -yr (2002-2007) average monthly plot of flows and loads. Pg. 7-10, Municipal Wastewater Management Strategies, second paragraph. Please elaborate in the Added relationship between temperature mitigation and ammonia criteria. references to Figures 5-1 and 5-2. Pg. 7-10, last paragraph. Please explain "sufficient" in the contest of projected influent flows. Reworded. Pg. 7-27, last paragraph, last sentence. Is the monitoring and evaluation to analyze and establish the Added notation true capacity of the filters being done now? Otherwise when is it recommended to be done by? that existing filters remain. Pg. 7-30, last paragraph, 2nd line, please Include material of the outfall pipe in the description. Added pipe material to description. Section 8 Pg. 8-15, Section 8.3.4 Hyporheic Discharge and High Rate Irrigation. Note that any use of a hyporheic Added discharge will need to be reviewed and approved in accordance with the Departments EMD guidelines reference to for a hyporhelc discharge. IMD guidelines. Section 11 Environmental Report (ER). No environmental report has been submitted to the Department. Should No changes to the City be interested in financing this project through the CWSRF, an ER needs to be prepared Facility Plan. according to the guidelines (http://www.deq.state.or.us/wq/loans/docs/GreenGuide.pdf) Volume 2: Wastewater Collection and Transmission System Section 3 Pg. 3-1 Establish Approach, 1. Please define CHS. Defined. Section 5 Pg. 3, Table 5-1. Does the third pump at the Mill Creek Pump Station have a capacity greater than 5500 Updated gpm? Otherwise why is the firm capacity 2X the capacity of pump #1 or pump #2 when pumps 1 & 2 are information. running with the third pump out of service? Section 6 Pg. 6-6. Please define WERF. Defined in report. Section 8 EXHIBIT A Page 5 of 5 Responses to DEQ Comments in Letter to Randy Scott, Water Resources Division Manager DEQ Comment Response Pg. 8-3, Section 8.3, bullet #1. Is it realistic to assume that there will be no increase in RDII In the Added existing sewer system during the planning period? Our experience with Oregon communities regarding reference that the most aggressive collection system maintenance programs would suggest otherwise. The FP the dedicated document must Include a dedicated annual budget for an aggressive ongoing collection system annual budget is identified in maintenance program to keep the RDII flows In the existing system to current (2010) levels over the 20 proposed CIP. year planning period. Appendix C It is not clear the relevance of including McMinnville's rainfall Information in the document. Is this the Corrected title closest rainfall monitoring station? to figure. Volume 3: Wastewater Rate and System Development Charge Study Pg. 7-6, Table 7-3. Please define NTS. Defined in report. Clean Water State Revolving Fund Requirements No changes. Errata Corrected.