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
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ATTEST: 1)44, -�A
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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.