FACT SHEET 

And 

NPDES WASTEWATER DISCHARGE PERMIT EVALUATION 

Department of Environmental Quality 

Western Region - Salem Office 

750 Front Street NE, Suite 120, Salem, OR 97301-1039 

Telephone: (503) 378-8240 

PERMITTEE: City of Medford 

411 West Eighth Street 

Medford, Oregon 97501 

File Number: 55125 

1100 Kirtland Road 

Jim Hill, Administrator 

Telephone Number: (541) 774-2100 

Mark E.Hamlin Telephone Number: 503-378-8240, 

extension 239 

Renewal of a National Pollutant Discharge Elimination 

System (NPDES) wastewater discharge permit 

Major Domestic 

Level IV 

Level IV 

November 29,1996 

992777 

SOURCE LOCATION: 

SOURCE CONTACT: 

PERMIT WRITER: 

PROPOSED ACTION: 

SOURCE CATEGORY: 

TREATMENT SYSTEM CLASS: 

COLLECTION SYSTEM CLASS: 

PERMIT APPLICATION DATE: 

PERMIT APPLICATION NUMBER: 

BACKGROUND 

Introduction 

City of Medford operates a wastewater treatment facility located in Central Point, Oregon, Wastewater 

is treated and discharged to the Rogue River in accordance with National Pollutant Discharge 

Elimination System (NPDES) Permit number 100985. The Permit for the facility was issued on 

September 30,1992 and expired on May 31,1997. 

The Department received a renewal application on November 29,1996. A renewal permit is necessary 

to discharge to state waters pursuant to provisions of Oregon Revised Statutes (ORS) 468B.050 and the 

Federal Clean Water Act. The Department proposes to renew the permit. 

Facility Description 

Wastewater treatment facilities have existed at this site since the federal government operated it for 

Camp White. The City of Medford obtained the site in 1948. The existing treatment facilities were 

initially constructed in 1970. Phased expansions have occurred on a regular basis since 1980. Since 

1999, the following projects have been completed: 

• Construction of a headworks diversion structure to divert sewage flow around the facility in case 

of extreme flows in order to avoid damage to the treatment facility. 

• Installation of two new bar screens rated at 60 mgd each. 
City of Medford Evaluation Report 

Page 2 

• Installation of an additional magnetic flow meter. 

• Construction of a fifth secondary clarifier. 

• Completed conversion to liquid sodium hypochlorite for disinfection. 

• Completion of the chlorine contact tank expansion. 

• Installation of a 1000 kW emergency generator. 

• Installation of fiber optic Ethernet throughout the facility. All 6 controllers have been switched to 

Allen and Bradley PLCs. RSView operating software has been installed, 

• Installation of the new outfall and multiport diffuser 

• Construction of the trickling filter snail removal system 

• Renovation and lining of the west sludge drying beds 

The major treatment process used is the Trickling Filter/Activated Sludge. The liquid treatment portion 

of the facility consists of headworks, grit removal, primary treatment, trickling filter/activated sludge 

secondary treatment (consisting of two activated sludge aeration basins), secondary clarification, 

chlorine disinfection and dechlorination and the outfall to the Rogue River through a multiport diffuser. 

The solids portion of the facility consists of gravity belt thickening, anaerobic digestion, sludge storage 

and biosolids drying. 

The liquid facilities include two mechanically raked screens, two aerated grit tanks, two rectangular 

primary clarifiers, a 140 foot diameter trickling filter, five 90 foot diameter secondary clarifiers, four 

chlorine contact basins and two outfalls (see the Outfalls section for more detail). The solids facilities 

are discussed under the Biosolids Management and Utilization section. 

Besides serving the City of Medford, the facility treats wastewater from Central Point, Jacksonville, 

Talent, Phoenix, Eagle Point, the White City Sanitary District and some unincorporated areas of 

Jackson County. Some of the wastewater is collected by the Bear Creek Valley Sanitary Authority 

(BCVSA) and pumped by a pump station located adjacent to the treatment plant. The facility also 

accepts leachate from Diy Creek Landfill. No septage is accepted for treatment. 

The dry weather flows do not include the high levels of infiltration and inflow that are associated with 

the winter in Oregon. Therefore, the design dry weather flows are used mostly to estimate how much 

treatment capacity there is for organic loads. For this facility, the average design dry weather flow is 20 

million gallons/day (MGD). The current actual dry weather flow for June through October during the 

last two years was 16.24 MGD, Based on the current flows, this facility is at 81.2 percent of treatment 

capacity. 

The current actual average wet weather flow for November 2000 through May 2001 was 14.14 MGD. 

The peak day flow over the past year was 17.6 MGD in December 200u. However, the previous 

winter, the average flow was 20,0 MGD with a peak day of 54.8 MGD in April 2000. Several 

differences have contributed to the change, Oregon is currently experiencing a major drought. A large 

industrial contributor obtained a separate wastewater permit and significantly reduced flows to the 

City's treatment system. In addition, a significant amount of Inflow and Infiltration (I/I) work has been 

completed in the collection systems. It is unknown exactly how much of the reduction is attributable to 

each factor. See the section on Inflow and Infiltration (I/I) for a further discussion of winter flows and 

hydraulic capacity issues. 

The permittee is responsible only for that portion of the collection system owned and operated by the 

City of Medford, Other jurisdictions are responsible for the collection systems within their respective 

boundaries. 

As long as the phased improvements continue to stay apace of growth, the Department does not see the 

need for requiring a specific, major upgrade of treatment facilities. 

Biosolids Management and Utilization 

The permittee's biosolids management plan was approved August 22,1988. All waste sludge must be 

managed in accordance with the Department approved Biosolids Management Plan to ensure 
City of Medford Evaluation Report 

Page 3 

compliance with the federal biosolids regulations (40 CFR Part 503). The permittee has submitted an 

updated Biosolids Management Plan for Department approval. The Department is proposing to 

approve the plan as a part of this permit action. 

After treatment necessary to comply with vector attraction and pathogen reduction requirements, the 

Class B biosolids can be beneficially land applied on sites in Jackson County. The permittee may 

continue to utilize all previously authorized land application sites. Any future land application sites 

must conform to the site selection criteria in the Biosolids Management Plan and must be in Jackson 

County, Past analyses indicate that the Biosolids quality is equivalent to Class A, however, the 

processing procedures are Class B and the City land applies the Biosolids as Class B. 

Waste secondary sludge is pumped to the 2-meter gravity belt thickener which thickens the sludge to 

approximately 5 percent solids. The primary sludge (also about 4 to 5 percent solids) and the thickened 

waste activated sludge are pumped to the anaerobic digesters. Each digester is 85 feet in diameter and 

34.2 feet deep. A third digester is no longer used. The digested sludge is pumped to one of four sludge 

storage lagoons (total surface area of 12.5 acres. The lagoons are currently being rehabilitated with 

liners, Sludge removed from the sludge lagoons is spread onto 30 acres of drying beds. Dried sludge 

may be land applied as biosolids on almost 1200 acres of farm land at agronomic rates on eight 

different sites. Beneficial land application is currently performed during the summer on Department 

approved sites in Jackson County. The permittee produces approximately 2856 dry metric tons of 

biosolids per year. 

The proposed permit requires monthly reporting of the methods used to comply with vector attraction 

and pathogen reduction requirements. Volatile solids reduction in the biosohds is the process used to 

demonstrate compliance with vector attraction reduction requirements. Monitoring of volatile solids 

reduction is proposed in the renewal permit. Fecal coliform testing of the biosolids is the process used 

to demonstrate compliance with pathogen reduction requirements. Monitoring for fecal coliform 

content is proposed in the renewal permit. 

Waste sludge accumulations can also be disposed of as a solid waste in a landfill. During the last two 

years, virtually all of the waste sludge has been disposed of as daily cover in Dry Creek Landfill. 

Unless the waste sludge is beneficially land applied, it is not considered biosolids and compliance with 

the federal biosolids regulations (40 CFR Part 503) is not required. When the waste sludge is 

landfilled, monitoring to confirm compliance with biosolids regulations is not necessary. Instead, 

proper monitoring is to be prescribed by the receiving landfill in accordance with the solid waste rules. 

An annual sludge disposal report is required by February 19 each year regardless of whether the 

biosolids are land applied or disposed of as waste. The permittee conducts chemical testing of biosolids 

that includes analysis for several metals. The results of the monitoring performed for the 2000 annual 

report is found below: 

Table 1 - Biosolids Metals Results for 2000 

Parameter 

Arsenic 

Cadmium 

Chromium 

Copper 

Lead 

Mercury 

Mg/dry Kg 

0.861 

2.53 

38.2 

787 

79.9 

1.22 

§503.13 

table 3 

Limit 

41 mg/kg 

39 mg/kg 

No limit 

1500 mg/kg 

300 mg/kg 

17 mg/kg 

Parameter 

Molybdenum 

Nickel 

Selenium 

Silver 

Zinc 

Mg/dry 

Kg 

7.42 

37.1 

4.27 

39.5 

706 

§503.13 

Table 3 Limit 

No limit 

420 mg/kg 

100 mg/kg 

No limit 

2800 mg/kg 

Inflow and Infiltration (T/D 

High storm-related flows have historically occurred at this facility. Excessive flows would impede 

settling in the secondary clarifiers leading to poor effluent quality. However, given the current drought 
City of Medford Evaluation Report 

Page 4 

conditions, the reduction in flows from a large industrial user and the I/I work that has been completed, 

excessive flows do not appear to be a significant problem at this time. 

Prior to 1996, the City of Medford did not routinely report sewage overflows of the sanitary sewage 

system. A Notice of Noncompliance (NON) was issued for failure to report a raw sewage overflow that 

occurred during the high rainfall event of December 1996. On March 18,1997, the Department issued 

a Notice of Permit Violation in relation to this overflow. Since that time the City has reported the 

following overflows: 

Table 2 - Raw Sewage Overflows Since 1996 

Date 

12/4/96-

12/10/96 

12/30/96-

1/2/96 

3/21/97 

5/13/97 

7/9/97 

8/15/97 

8/18/97 

8/23/97 

11/14/97 

11/28/97 

12/26/97 

2/8/98 

2/21/98 

5/27/98 

7/28/98 

9/14/98 

9/18/98 

9/21/98 

9/22/98 

10/11/98 

10/12/98 

11/21-23/98 

Location 

Howard Avenue 

Various Locations 

Northwood Road 

Main and Lewis 

Washington S. of 

Main 

Newtown and 8 

Streets 

Grape and 11th 

Streets 

Willamette Avenue 

14th & King Streets 

Palm & Rose Streets 

816 4th Street 

Murphy Road South 

ofBarnett 

1539 Grand Ave. 

Columbus Ave. and 

Bryant Street 

3034 Lone Pine Rd. 

1504KenyonSt. 

Olympic Ave. 

321 North Ivy 

8

th

 & Mistletoe 

1917 Roberts Rd 

1670 Roberts Rd 

l l m & Hamilton 

Amount 

Released 

>70,000 gallons 

~ 3,000,000 

gallons 

75 gallons 

> 15,000 gallons 

50 gallons 

100 gallons 

5 gallons 

25 gallons 

Not reported 

Not reported 

Not reported 

Not reported 

800 gallons 

50 gallons 

3000 gallons 

100 gallons 

500 gallons 

25 gallons 

50 gallons 

400 gallons 

750 gallons 

Not reported 

Effected 

Stream 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Lone Pine 

Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Bear Creek 

Cause 

Excessive I/I 

Excessive I/I 

Mainline plugged 

with rags and debris 

Excessive I/I 

Mainline plugged 

with rags and debris 

Mainline plugged 

with rags and debris 

Mainline plugged 

with rags and debris 

Mainline overflowed 

while clearing. 

No Written Report 

No Written Report 

No Written Report 

No Written Report 

No Written Report 

Mainline plugged 

with rags and debris 

Blockage 

Blockage 

Construction debris 

blockage 

Private lateral 

plugged 

Rag Blockage 

Grease Blockage 

Grease Blockage 

Excessive I/I 
City of Medford Evaluation Report 

Page 5 

Table 2 - Raw Sewage Overflows Since 1996 (Continued) 

Date 

11/21-23/98 

11/21-23/98 

11/21-23/98 

9/30/1999 

Location 

Grand & Ruskin 

Merriman & 

Morningstar 

Corona & Grand 

1444 Angelcrest 

Drive 

Amount 

Released 

Not reported 

Not reported 

Not reported 

500 gallons 

Effected 

Stream 

Bear Creek 

Bear Creek 

Bear Creek 

Lazy Creek 

Cause 

Excessive I/I 

Excessive I/I 

Excessive I/I 

Blockage 

Should excessive flows from the BCVSA collection system occur, the excess volume is pumped to 

lagoons owned and operated by BCVSA (under a separate NPDES permit) that are adjacent to the 

treatment facility. The Regional Water Reclamation Facility operation can be greatly affected by I/I 

from the other tributary collection systems. In a NON dated July 12,1999, the Department requested 

that the City initiate discussion with owners of the tributary collections systems for more aggressive I/I 

reduction programs. This was because the violations noted in that NON were partially the result of 

excessive I/I in the tributary collection systems. If raw sewage overflows occur within the tributary 

systems or if excessive flows cause recurring permit limit violations, the Department may require more 

formal action on the part of the permittee and/or tributary system owners, 

The proposed permit includes a condition requiring implementation of a I/I reduction program and 

submittal of an annual report on I/I reduction activities within the City of Medford collection system 

only. In order to obtain the winter period mass load limits for BOD and TSS based on wet weather 

flow, all inflow must be removed from the collection system. The City does not have the necessaiy 

legal authority over all portions of the sewer system to require inflow removal. The BCVSA has 

expressed interest and is proceeding to obtain that responsibility within their NPDES permit. 

Pretreatment 

City of Medford implements an industrial pretreatment program that was originally approved by the 

Department on July 7,1983. The Department approved modifications to the City's Pretreatment 

program ordinance on August 31,1992. The Department approved modifications to the City's 

pretreatment program implementation procedures on June 6,1994. The Department approved 

modifications to the City s local limits on February 13,1995. Federal and state pretreatment 

requirements were included in the NPDES permit for this facility when the previous permit was issued. 

The City of Medford currently permits 21 significant industrial users. Pretreatment Compliance 

Inspection (PCI) of the industrial pretreatment program was conducted on April 13 and 14, 2000. The 

primary focus of the PCI was to evaluate the accuracy of the information provided in previous annual 

reports and the adequacy of program implementation and industrial user compliance records and files. 

As a result of the PCI, the Department's report dated April 19,2000 listed one NPDES permit 

violation, two required actions and two recommended actions. The City's response dated May 10, 

2000 and follow-up information provided on July 21,2000 indicated to the Department that all of the 

required and recommended actions had been or were in the process of being adequately addressed. 

Schedule E, Condition 12, of the current permit requires the City to submit substantial pretreatment 

program modification requests to the Department for approval. The City submitted a request for 

modification of its local limits on October 20,2000. The Department proposed to approve the 

modifications on November 8,2000. The City issued a public notice of the proposed modifications and 

the Department's intent to approve them. On January 9,2001, the City notified the Department that it 

had completed the public review process and did not receive substantial comments or a request for a 

public hearing. 
City of Medford Evaluation Report 

Page 6 

The Department notified the Environmental Protection Agency (EPA), Region 10, of our intent to 

approve the City's modifications and afforded EPA the requisite thirty (30) days to object to the 

Department's approval, pursuant to 40 CFR 403.11(d). The EPA did not object to the approval. 

On March 8,2001, the Department approved the City's Technically Based Local Limits. Federal 

pretreatment regulations (cf., 40 CFR 403.18) require that these modifications be incorporated into the 

City's NPDES permit. Therefore, the Department is incorporating the new local limits into the City's 

NPDES permit renewal with the re-issuance of the permit. 

Pollutants Discharged 

The current permit allows the City of Medford to discharge treated effluent from the wastewater 

treatment plant year-round. The currentpermit sets limits on the following pollutants: Five-day 

Biochemical Oxygen Demand (BODs), Total Suspended Solids (TSS), Fecal Coliform (FC) bacteria 

and Total Residual Chlorine. The discharge is also regulated for pH and pollutant removal efficiency. 

Outfalls 

Treated wastewater is discharged year-round through a new 54-inch pipe to the Rogue River at river 

mile 130.5 (see Attachment #T), The outfall (designated Outfall 001) has a multi-port diffuser with a 

peak capacity of 100 MGD. This new outfall was constructed to improve the mixing and hydraulic 

capacity of the previous outfall (designated Outfall 001A), Outfall 001A discharges through a 42 inch 

pipe to a shoreline outfall through a vortex energy dissipation structure, which entrains air into the 

effluent and produces foam near the outfall. The old outfall is still functional and can be used for 

emergency purposes. The combined capacity of the two outfalls is 170 MGD. 

The permittee has requested a new outfall for the irrigation of Level IV reclaimed water. This new 

outfall is designated Outfall 002 (see below for discussion of current Outfall 002.) 

Other outfalls are for emergency use only. Discharges of untreated sewage are permitted only if the 

cause is an upset condition or if the discharge is caused by a substantial storm event as defined later in 

this report. Outfalls 002 through 008 were included in the previous permit. Outfalls 002 (Railroad Park 

at Hwy 62 and Bear Creek) and 004 (Crater Lake Avenue pump station at 3460 Crater Lake Avenue) 

have been eliminated and will be deleted from the permit. 

Since the existing permit was issued, a new pump station has been constructed, The overflow point for 

the King Center pump station is designated Outfall 009. In 1999, the facility upgraded the headworks. 

As part of this expansion, a new influent diversion structure was constructed. The purpose of the 

diversion structure is to divert a portion of the influent sewage into the storm drainage system to protect 

the facility from physical damage when influent flows get too high. The new overflow point for tnis 

diversion structure is included in this permit as Outfall 010. 

The emergency outfalls are listed as follows: 

Table 3 - Emergency Overflows Points 

Outfall 

003 

005 

006 

007 

008 

Outfall Location 

Airport P.S., Manhole #1G40 

3500 Medco Haul Road 

Fairview/Greenway P.S., Manhole 

#6J16 

Fairview & Greenway 

Montcrest P.S., Wetwell Manhole 

South of Donnalee Drive 

Army Reserve P.S., Manhole #5D14 

Columbus & McAndrews 

Broad Street P,S„ Manhole #5D6 

Broad & Taft 

Discharge Location 

Midway Creek 

East Irrigation Canal to Larson/Bear 

Creeks 

Under 1-5 into Bear Creek 

Drainage Ditch/Storm Drain to Bear 

Creek 

Drainage Ditch/Storm Drain to Bear 

Creek 
City of Medford Evaluation Report 

Page 7 

Table 3 - Emergency Overflows Points (Continued) 

lOiitfall 

009 

010 

Outfall Location 

King Center P.S., Manhole #0G18 

Commerce Dr. & Cardinal Way 

Influent Diversion Structure 

Discharge Ldteafidn 

Midway Creek 

Stormwater Outfall 

Receiving Streams/Impact 

The water quality standards for the Rogue Basin (Oregon Administrative Rules 340-41-0365) are 

intended to be protective of the beneficial uses for the basin. Treated wastewater is discharged to the 

Rogue River at river mile 130.5. 

At this location, the Rogue River is water quality limited for temperature (based on salmonid rearing) 

during the summer months. The Rogue River is also water quality limited for bacteria (based on water 

contact recreation) during fall, winter and spring. Discharges of disinfected wastewater that are in 

compliance with the permit limits should not contribute to violations of the instream bacterial 

standards. 

The thermal load in the permittee's discharge likely contributes to the water quality temperature 

violations. A Total Maximum Daily Load (TMDL) for temperature is scheduled to be completed for 

the Rogue Basin in 2004. The TMDL will assign thermal Waste Load Allocations (WLA) to most 

discharges in the basin. The Department will renew the NPDES permits and incorporate the thermal 

WLAs as permit limits. The NPDES permits in the Middle Rogue are scheduled for renewal in 2005. 

The permit contains a reopener clause allowing the Department to modify the permit and include the 

thermal WLA as a permit limit. 

Once the thermal WLA is incorporated as a permit limit, the City will have to implement the corrective 

action plan required by this permit in order to comply with the new limit. The Temperature 

Management Plan (TMP) that the Department proposes to approve as a part of this permit action 

includes evaluations of internal management practices and treatment and/or disposal alternatives 

needed to come into compliance. The City's preliminary evaluation indicates they will discontinue all 

discharges to the Rogue River during at least part of the summer period. 

The Department has completed an Antidegradation Review Sheet (see attachment 4) that supports the 

issuance of this permit. The Department is not aware of any other water quality violations that may be 

attributable to this source. 

Temperature 

Stream temperatures are generally rising throughout the State of Oregon and many streams exceed the 

applicable trigger temperature in the summer, The applicable trigger temperature for rearing and 

spawning are a maximum of 64°F and 55°F respectively, based on a seven-day average of maximum 

daily temperature readings. 

Point source dischargers are required to help stop and reverse the warming trend. In order to prevent 

further warming, most discharge permits will identify the maximum allowable thermal discharge. The 

permit must also prohibit further increases. The temperature standard prohibits dischargers from 

causing a measurable increase in stream temperature under certain conditions. The two conditions that 

apply to the City of Medford discharge are: 

• When the stream temperature exceeds 64°F while salmonid rearing occurs; and, 

• When the stream contains Threatened and Endangered species and the increase would impair their 

biological integrity. 

Salmonid Rearing 

The streams in this basin are water quality limited for temperature in the summer and may not fully 

support the rearing of salmonid species. The proposed permit addresses the potential impact of this 
City of Medford Evaluation Report 

Page 8 

discharge on stream temperature, The effluent temperature at some times of the year exceeds the 

applicable trigger temperature. However, the effluent is not expected to exceed 77° F at any time. 77° 

F is considered to be lethal for salmonids. 

The effluent will cause a measurable increase of temperature at times, at the edge of the mixing zone. 

A "measurable increase" is defined as greater than a 0.25° F increase at the edge of the mixing zone, 

factoring in the effluent temperature and dilution at the edge of the mixing zone, and using the 

applicable stream trigger temperature. 

Threatened and Endangered Species 

Besides the period when the Rogue River exceeds the trigger temperature of 64°F, the City's discharge 

cannot cause a measurable increase in stream temperature if threatened or endangered species are 

present, Alternatively, the Permittee must show that the increase in stream temperature will not affect 

the biological integrity of the threatened or endangered species. Coho Salmon are a threatened species 

and are present in the Rogue River year-round. 

The City's discharge can cause a measurable increase year round under certain conditions and could 

therefore potentially impact Coho Salmon during adult migration and during juvenile rearing. The 

trigger temperature for these beneficial uses is 64°F. Coho use tributary streams for spawning and 

incubation and are not present in the Rogue River for that beneficial use (when the trigger temperature 

is 55°F). 

When the Department's Temperature Standard was modified in 1996, the Issue Paper prepared by the 

Temperature Subcommittee included a detailed discussion of the temperature requirements of Coho 

Salmon by life stage. Based on studies by Reiser and Biornn (1979) and Brett (1952), the Oregon 

Department of Fish and Wildlife identified the preferred juvenile rearing temperature as between 

11.8°C (53.2°F) and 14.6°C (58.3°F). Ifjuvenile fish inhabit colder waters than the preferred 

temperature during winter, the likely effect is reduced growth rates at that time of year. Obviously, 

colder winter temperatures are part of the natural thermal regime and do not impair biological integrity, 

Adult migration can occur over a much wider range of temperatures, They can migrate in stream 

temperatures between 7.2°C (45.0°F) and 15,6°C (60.1°F). 

The lowest Rogue River flows (and therefore the period with the lowest available dilution) generally 

occur during late September through early November, Based on the temperature data presented, the 

instream temperature drops rapidly after the warm summer period and is well below 55°F before the 

end of September. Minimum stream temperatures are slightly over 40°F. Stream temperatures 

consistently remain below 50°F for up to 6 months before slowly warming up again. 

During critical case winter conditions (minimum dilution with maximum temperature differential), the 

City's discharge could result in a temperature increase outside the mixing zone of about 1,5°F, These 

conditions could only occur when minimum stream flow and temperature coexist with maximum 

effluent flow and temperature. While these conditions are theoretically possible, the Department does 

not believe it is realistic to expect to see a temperature increase of that magnitude. In addition, a 

Department aquatic biologist does not believe a measurable increase at this time of year would impact 

the food organisms for any salmonid species (see attachment 5). The memo states it is not likely that 

such an increase in temperature would alter the biological integrity of the invertebrate community or 

impact the food base for salmonids. 

While the increase would be measurable under these circumstances, the City contends that the 

biological integrity of the Coho salmon would be ensured because the stream temperature would be 

lower than the preferred rearing temperature and are generally at the lower end of (or lower than) the 

migration temperature range. The Department generally agrees with this assessment. 

If no effluent is discharged during all or part of the summer and there is no impact on the biological 

integrity when ambient temperature are very cold, the only remaining concern would be during the 

short periods when stream temperatures are near the important trigger temperatures. Because these 

periods are so short, it is not likely that even a measurable temperature increase would impact the 

biological integrity of the Coho salmon. 
City of Medford Evaluation Report 

Page 9 

However, the potential should be evaluated after the periods of discharge are finally determined. 

Therefore, the proposed permit includes a condition requiring submittal of an approvable plan and 

schedule for coming into compliance with the temperature waste load allocation by no later than 6 

months after issuance of the Rogue River Total Maximum Daily Load (TMDL) or with the next permit 

renewal application (whichever is later). The plan must also evaluate the potential for impacts on the 

biological integrity of Threatened and Endangered Species that may be present during the discharge 

period. 

Temperature Management Plan 

A Total Maximum Daily Load (TMDL) addressing the water quality limited status for temperature has 

not yet been approved for the sub-basin. Until the TMDL is issued and a Waste Load Allocation is 

assigned, the purpose of a TMP is to show how the source will reduce its thermal loading to the stream 

rather than schedule the improvements necessary to come into compliance. 

The City has submitted a TMP to the Department for approval on December 18,2001 and amended the 

submittal on April 25,2002, Temperature monitoring must be conducted in accordance with the TMP. 

Other components of the TMP have been included in Schedule C of this permit. They include 

submittal of an evaluation of internal and external management practices and submittal of a plan and 

schedule for coming into compliance with the thermal waste load allocation. 

The Department is proposing to approve the City's TMP. Applicable portions of the TMP have been 

incorporated into the permit, As long as the City complies with the requirements of the TMP, the City 

shall not be deemed to be causing or contributing to a violation of the numeric temperature criterion 

(OAR 340-04 l-0026(3)(a)(D)(vi)). 

Groundwater 

Based on the Department's current information, this facility has a low potential for adversely impacting 

groundwater quality. Therefore, the Schedule D of the proposed permit states that no groundwater 

evaluations will be required during this permit cycle. The permit also includes a condition in Schedule 

A that prohibits any adverse impact on groundwater quality. 

Stormwater 

Stormwater is not addressed in this permit. General NPDES permits are required for wastewater 

treatment facilities with a design flow of more than 1 MGD with stormwater discharges. The City has 

registered their assignment to the current General 1200-Z NPDES Permit. The City received two 

Notices of Noncompliance (dated September 12,1994 and November 16, 1994) for violations of the 

General NPDES Stormwater Permit. 

Compliance History 

This facility was last inspected August 8,2001 and was found to be operating in compliance. 

The monitoring reports for this facility were reviewed for the period since the current permit was 

issued, including any actions taken relating to effluent violations. The permit compliance conditions 

were reviewed and all inspection reports for the same period were reviewed. Based on this review, the 

following violations have been documented at this facility during the term of the current permit: 

Table 4 - Enforcement Actions Since 1995 

Date of Violation 

7/21/1995 

12/20/1996 

Type of Enforcement Action 

Notice of Noncompliance 

Notice of Noncompliance 

Description of Violation 

Facility alterations without 

Department approval 

Failure to promptly notify and 

failure to submit complete report 

regarding overflow 
City of Medford Evaluation Report 

Page 10 

Table 4 - Enforcement Actions Since 1995 (Continued) 

Date of Violation 

3/18/1997 

8/17/1997 

7/12/1999 

4/19/2000 

Type of Enforcement Action 

Notice of Permit Violation 

Notice of Noncompliance 

Notice of Noncompliance 

Notice of Noncompliance 

Description of Violation 

Violations regarding the overflow 

as noted above 

Violation ofBODs and TSS 

concentration, mass load and 

percent removal limits 

Violation of BOD5 and TSS mass 

load and chlorine concentration 

limits 

Industrial Pretreatment Program 

deficiencies 

Many of the above violations have been corrected. The BOD5 and TSS violations were related to flood 

conditions. Unless damage to the facility and/or activated sludge biomass results, the Department 

encourages treatment facilities to reduce raw sewage overflows by maximizing flows through the 

treatment plant. The Department considers this facility to be in substantial compliance with the terms 

of the current permit. 

PERMIT DISCUSSION 

Face Page 

The permittee is authorized to construct, install, modify, or operate a wastewater collection, treatment, 

control and disposal system. Permits discharge of treated effluent to the Rogue River and by spray 

irrigation of Level IV reclaimed water within limits set by Schedule A and the following schedules. 

Eight emergency outfalls are also listed, All other discharges are prohibited. 

The term of the permit will be 5 years from date of issuance. 

Schedule A - Waste Discharge limitations 

BOD and TSS concentration and mass limits 

Based on the Rogue Basin minimum design criteria, wastewater treatment resulting in a monthly 

average effluent concentration of 10 mg/L for BOD5 or carbonaceous biochemical oxygen demand 

(CBOD5) and TSS must be provided from June 1 - October 31. From November 1 - May 31, a 

minimum of secondaty treatment or equivalent control is required. Secondary treatment for this facility 

is defined as monthly average concentration limit of 30 mg/L for BOD5 (or 25 mg/L for CBOD5) and 

30 mg/L for TSS. The Department is proposing concentration limits at least as stringent as the basin 

minimum design criteria. 

The City has requested a change from BOD5 to CBODs in the summer. The proposed monthly average 

summer CBOD5 and TSS concentration limits are 10 mg/L with a weekly average limit of 15 mg/L. 

The proposed monthly average winter BOD5 and TSS concentration limits are 30 mg/L with a weekly 

average limit of 45 mg/L. 

The summer mass limits for CBOD5 and TSS are based on the design average dry weather flow 

(ADWF) of 20 MGD and the monthly average CBOD5 and TSS concentration limits of 10 mg/L and 10 

mg/L, respectively. The only change in the summer concentration and mass limits is the conversion of 

BOD5 limits to CBOD5 limits. 

The City has requested a change in the winter mass load limits for BOD5 and TSS in accordance with 

OAR 340-41 -120(9)(a). The City identified the design average wet weather flow (AWWF) as 27.1 
City of Medford Evaluation Report 

Page 11 

MGD. However, the City's analysis used a strictly proportional calculation considering only one year 

(summer 1998 and winter 1998/99). In accordance with a DEQ guidance memo dated May 14,1993, 

only one half of the existing I/I may be used to calculate the AWWF. Using the guidance memo and 

including a second year (summer 1999 and winter 199/001 the Department determined the appropriate 

AWWF is 25.3 MGD. The most recent year (summer 2000 and winter 2000/01) was not used due to 

the influences of the drought. 

The winter mass limits for the facility may be based on the AWWF of 25.3 MGD and the monthly 

average BODS or TSS concentration limits of 30 mg/L and 30 mg/L, respectively. On any day that the 

daily flow exceeds 40 MGD (twice the design ADWF), daily mass load limits shall not apply. 

However, the City would be required to remove all inflow sources from the collection system. The 

City does not have the legal authority necessary to identify and remove inflow from the satellite 

collection systems and does not wish to obtain the authority. 

The BCVSA has expressed interest and is proceeding to accept the responsibility for obtaining the legal 

authority and implementing the inflow removal program within the satellite collection systems. 

Schedule A has two conditions related to BOD and TSS limits. The first section contains the existing 

permit limits based on dry weather flow year-round. The second section contains the permit limits that 

will become effective upon either: 1) issuance of a renewal permit to the Bear Creek Valley Sanitary 

Authority that includes the provisions of OAR 340-04 l-0120(9)(a)(G)(iv); or 2) submittal of 

documentation to the Department that either Bear Creek Valley Sanitary Authority and/or the City of 

Medford has acquired and has accepted the necessary legal authority to require removal of inflow 

sources in all portions of the sewer system discharging into the Regional Water Reclamation Facility. 

The proposed permit includes a Schedule C condition requiring submittal of a program and time 

schedule for identifying and removing inflow within the City of Medford's collection system. The 

BCVSA is in the process of obtaining the legal authority necessary to identify and remove inflow from 

the satellite collection systems. 

All mass load limitations have been rounded to two significant figures. The proposed limits are: 

(1) June 1 - October 31: 

Parameter 

CBODs 

TSS 

Average 

Concei 

Monthly 

10 mg/L 

10 mg/L 

\ Effluent 

Titrations 

Weekly 

15 mg/L 

15 mg/L 

Monthly 

Average 

lb/day 

1700 

1700 

Weekly 

Average 

lb/day 

2600 

2600 

Daily 

Maximum 

Lbs 

3400 

3400 

(2) November 1 - May 31 (upon issuance): 

Parameter 

BOD, 

TSS 

Average 

Concei 

Monthly 

30 mg/L 

30 mg/L 

; Effluent 

ltrations 

Weekly 

45 mg/L 

45 mg/L 

Monthly 

Average 

lb/day 

5000 

5000 

Weekly 

Average 

lb/day 

7500 

7500 

Daily 

Maximum 

Lbs 

10,000 

10,000 

(3) November 1 -May 31 (upon compliance with OAR 340-04l-0120(9)(a)(G)(iv)) 

Parameter 

BODs 

TSS" 

Average Effluent 

Concentrations 

Monthly Week! 

30 mg/L 45 mg/L 

45 mg/L 

Monthly 

Average 

lb/day 

6300 

"53W" 

Weekly 

Average 

lb/day 

9500 

'WW 

Daily 

Maximum 

Lbs 

13,000 

30 mg/L 13J000 

Calculations: 

(1) Summer CBOD5 and TSS 
City of Medford Evaluation Report 

Page 12 

fa) 20 MGD x 8.34 #/gal x 10 mg/L monthly avg. = 1700 lbs/day 

(b) 1700 lbs/day monthly avg. x 1.5 = 2600 lbs/day weekly avg. 

(c) 1700 lbs/day monthly avg, x 2.0 = 3400 lbs/day daily max. 

(2) Winter BODs and TSS (upon issuance) 

(a) 20 MGD x 8.34 #/gal x 3 0 mg/L monthly avg. = 5 000 lbs/day 

fb) 5000 lbs/day monthly avg. x 1.5 = 7500 lbs/day weekly avg. 

(c) 5000 lbs/day monthly avg. x 2.0 = 10,000 lbs/day daily max. 

(3) Winter BOD5 and TSS (upon compliance with OAR 340-04 l-0120(9)(a)(G)(iv)) 

(a) 25.3 MGD x 8.34 #/gal x 30 mg/L monthly avg. = 6330 lbs/day 

(b) 6330 lbs/day monthly avg, x 1.5 = 9495 lbs/day weekly avg. 

(c) 6330 lbs/day monthly avg. x 2.0 = 12,660 lbs/day daily max. 

A review of recent monitoring data indicates the City should generally be able to comply with the 

permit limits. The previous permit limits for BOD5 and TSS will be change in two ways. The summer 

BOD5 limits changed to CBODs limits. The winter period BODs and TSS limits will be based on wet 

weather flow rather than dry weather flow upon compliance with OAR 340-041 -0120(9)(a)(G)(iv). 

BOD and TSS Percent Removal Efficiency 

A minimum level of percent removal for BODS (or CBODS) and TSS for municipal dischargers is 

required by the Code of Federal Regulations (CFR) secondary treatment standards (40 CFR, Part 133). 

An 85 percent removal efficiency limit is included in the proposed permit to comply with federal 

requirements. An examination of the DMR data indicates the permittee will have little difficulty 

meeting the limit with the current facilities. 

PH 

The Rogue Basin Water Quality Standard for pH is found in OAR 340-4 l-0365f2)(d). The allowed 

range is 6.5 to 8.5. The proposed permit limits pH to the range 6.0 to 9.0. This limit is based on 

Federal wastewater treatment guidelines for sewage treatment facilities, and is applied to the majority 

of NPDES permittees in the state. Within the permittee's mixing zone, the water quality standard for 

pH does not have to be met. It is the Department's belief that mixing with ambient water within the 

mixing zone will ensure that the pH at the edge of the mixing zone meets the standard, and the 

Department considers the proposed permit limits to be protective of the water quality. 

Fecal Bacteria 

The proposed permit limits are based on an E. coli standard approved in January 1996. The proposed 

limits are a monthly geometric mean of 126 E. coli per 100 mL, with no single sample exceeding 406 

E. coli per 100 mL, The new bacteria standard allows that if a single sample exceeds 406 E coli per 

100 mL, then the permittee may take five consecutive re-samples. If the log mean of the five resamples is less than or equal to 126, a violation is not triggered. The re-sampling must be taken at four 

hour intervals beginning within 28 hours after the originalsample was taken. 

The bacteria limits for irrigation of level IV reclaimed water are a 7-day median of 2.2 organisms/100 

mL, with no sample to exceed 23 total coliform per 100 mL. All proposed effluent bacterial limits are 

achievable through proper operation and maintenance. 

Chlorine Residual 

Disinfection of the effluent with chlorine is the process the permittee uses to comply with the waste 

discharge limitations for bacteria, Chlorine is a known toxic substance and as such is subject to 

limitation under Oregon Administrative Rules. The rule (OAR 340-4 l-0365(2)(p)) states in part that 

toxic substances shall not be discharged to waters of the state at levels that adversely affect public 

health, aquatic life or other designated beneficial uses. In addition, levels of toxic substances shall not 
City of Medford Evaluation Report 

Page 13 

exceed the criteria listed in Table 20 which were based on criteria established by the EPA and 

published in Quality Criteria for Water (1986), unless otherwise noted. 

However, OAR 340-41-445 (4) states that the Department may allow a designated portion of a 

receiving water to serve as a zone of dilution for wastewaters and receiving waters to mix thoroughly 

and this zone will be defined as a mixing zone, The Department may suspend all or part of the water 

quality standards, or set less restrictive standards, in the defined mixing zone, provided the water within 

the mixing zone is free of materials in concentrations that will cause acute toxicity to aquatic life as 

measured by the acute bioassay method and outside the boundary of the mixing zone is free of 

materials in concentrations that will cause chronic toxicity. 

Furthermore, 40 CFR §122.44(d) states that permit limitations must control all pollutants or pollutant 

parameters which are or may be discharged at a level which will cause, have the reasonable potential to 

cause, or contribute to an excursion above any state water quality standard, including state narrative 

criteria for water quality. The fresh water criteria for chlorine were used to calculate permit limitations. 

According to OAR 340-41, Table 20, chlorine concentrations of 11 ug/L can result in chronic toxicity 

in fresh waters while 19 ug/L can result in acute chlorine toxicity in fresh waters. 

Compliance with acute toxicity criteria is required at the edge of the Zone of Immediate Dilution (ZID) 

and compliance with chronic toxicity criteria is required at the edge of the mixing zone. The existing 

permit contains the following total chlorine residual limit: 

Shall not exceed a daily average of 0.038 mg/L. 

The previous permit's limit was derived by the Department based on an estimate of the dilution 

available within the mixing zone and ZID. However, in 2000, the permittee installed a multiport 

diffuser to enhance dilution within the mixing zone and reduce potential toxic effects on the receiving 

stream. For the facility, outfall, and mixing zone as presently configured, the dilution factors for the 

ZID and mixing zone were determined during critical low stream flow conditions (846 cfs) using the 

CORMIX computer model. The dilution factors at the edge of ZID and mixing zone are 2:1 and 13.9 

respectively. 

The new dilution values were used to perform a reasonable potential analysis for chlorine (see 

Attachment #2). The analysis indicated there was a reasonable potential for chlorine to cause toxicity 

within the receiving stream. 

Therefore, permit limits based on the acute and chronic criteria were calculated. Since the acute and 

chronic criteria are based on different durations, the durations have to be equalized using an EPA 

spreadsheet program to determine the more restrictive criteria (see Attachment #3). 

In this case, the acute criteria is the more stringent of the two. Thus, new end-of-pipe limits based on 

that criteria are proposed in the renewal permit. The new limits state the effluent shall not exceed a 

monthly average concentration of 0.02 mg/L and a daily maximum concentration of 0.04 mg/L. The 

permittee uses sodium bisulfite to dechlorinate the effluent prior to discharge to reduce potential toxic 

effects on the receiving stream and meet permit limits. The permittee should be able to meet the limits 

on a consistent basis with the facilities available. 

Ammonia 

Ammonia is a substance normally found in wastewater. The wastewater treatment processes, 

particularly aeration and biological treatment, can convert a large portion to nitrate and nitrite but the 

treated effluent still contains some ammonia. After discharge, the continued process of oxidizing the 

ammonia removes dissolved oxygen from the ambient water. 

Unionized ammonia is also a toxic agent and must be limited to prevent toxicity. As with chlorine 

residual, the water outside the boundary of the mixing zone shall be free of materials in concentrations 

that will cause chronic (sublethal) toxicity while the water outside the ZID must be free of pollutants 

that will cause acute toxicity. 
City of Medford Evaluation Report 

Page 14 

If ammonia may be discharged at a level which will cause, have the reasonable potential to cause, or 

contribute to an excursion above any state water quality standard (dissolved oxygen or toxicity), it must 

be limited by the permit. The ambient water conditions in the Rogue River several miles downstream 

from the City of Medford's discharge consistently comply with the water quality standards for 

dissolved oxygen. No permit limit for ammonia based on dissolved oxygen is necessary. In order to 

determine if a permit limit for ammonia is needed based on toxicity, a more detailed evaluation was 

performed. 

According to EPA's 1986 Quality Criteria for Water and OAR 340-41, Table 20, toxic concentrations 

of total ammonia are pH and temperature dependent. The pH in the Rogue River ranges up to 7.75 

with temperature levels as high as 20.2°C in late summer. Using these worst case conditions (and 

assuming salmonids are present), the chronic criteria for ammonia expressed as N is 1.17 mg/l with an 

acute criteria of 6.61 mg/l. Instream background levels of ammonia can be as high as 0.04 mg/l. 

Using a DEQ spreadsheet program (see Attachment #2), an analysis was performed to determine if the 

discharge will cause, have the reasonable potential to cause, or contribute to any excursion above state 

water quality standard for ammonia. No evaluation of ammonia was performed for the winter period 

because pH and temperature values are lower and dilution is higher. 

Twenty-two effluent ammonia concentration results from the treatment facility were reviewed. The 

highest concentration found was 20,3 mg/l, Using the CORMIX dilutions within the ZID and mixing 

zone, the spreadsheet calculated that there was a reasonable potential for chronic toxicity due to 

ammonia. The Department proposes summer period ammonia limits be included in the permit. 

Using the critical case river conditions (listed above) and effluent conditions (7.4 for pH and 22°C) and 

dilution factors, the expected pH and temperature conditions at the edge of the mixing zone and ZID 

were calculated using the procedures in EPA's DESCON program. At the edge of the ZID, the 

calculated pH and temperature values are 7.46 and 21.1 respectively. At the edge of the mixing zone, 

the calculated pH and temperature values are 7.64 and 20,3 respectively. Using these values, new endof-pipe limits based on the criteria were calculated (see Attachment #3). The proposed limits are 11 

mg/L monthly average and 23 mg/L daily maximum. 

Temperature 

The Department is proposing a new excess thermal load limit in this permit. It will be based on the 

average dry weather design flow and the difference between the weekly average of the maximum 

effluent temperatures and the appropriate trigger temperature. In this case, the Rogue River is water 

quality limited for salmonid rearing during the summer. The appropriate trigger temperature for that 

beneficial use is 64°F. The proposed excess thermal load limit was calculated as follows: 

20 DADWF (MGD) x 8.34 #/gallon x (75.6 weekly average maximum effluent temperature in 

F - 64 applicable trigger temperature in °F) = 1,934.88 Million BTUs/day o 

The proposed limit is 1,900 MBTU. 

Mixing Zone and Zone of Immediate Dilution 

The Department's rules (OAR 340-041-0365(4)) allow for designation of a portion of a receiving 

stream as a mixing zone serving as a zone of dilution for wastewaters and receiving waters. The 

Department may suspend all or part of the water quality standards within a mixing zone. The proposed 

permit contains a mixing zone developed in accordance with the rules. 

The allowable mixing zone is that portion of the Rogue River contained within a band extending out 

one hundred (100) feet from the south bank of the river and extending from a point ten (10) feet 

upstream of the outfall to a point three hundred (300) feet downstream from the outfall. The Zone of 

Immediate Dilution (ZID) shall be defined as that portion of the allowable mixing zone that is within 

thirty (30) feet of the point of discharge. 
City of Medford Evaluation Report 

Page 15 

The Department believes there will be no environmental impact from such a mixing zone and that the 

defined mixing zone meets the criteria in the rule. 

Reclaimed Water Outfall 002 

The utilization of treated effluent for agricultural purposes is regulated under OAR 340-55. The City 

has proposed facility modifications to produce up to 4 MGD of Level IV reclaimed water. No specified 

irrigation site or crops have been proposed. 

Prior to irrigation of the reclaimed water, the City is required to submit and obtain approval of a 

Reclaimed Water Use Plan. In addition, the discharge must comply with total coliform limits based on 

protection of human health due to human pathogens. For Level IV reclaimed water, the limits include a 

weekly median of 2.2 total coliform per 100 mis and no sample shall exceed 23 total coliform per 100 

mis, 

The application of reclaimed water must be managed in accordance with an approved Reclaimed Water 

Use Plan. All reclaimed water shall be distributed on land, for dissipation by evapotranspiration and 

controlled seepage by following sound irrigation practices so as to prevent: 

• Prolonged ponding of treated reclaimed water on the ground surface, 

• Surface runoff or subsurface drainage through drainage tile. 

• The creation of odors, fly and mosquito breeding or other nuisance conditions. 

• The overloading of land with nutrients, organics, or other pollutant parameters. 

. Impairment of existing or potential beneficial uses of groundwater. 

Specific crops, application rates and buffers will be approved by the Department within the Reclaimed 

Water Use Plan. The bacterial effluent limitations are achievable through proper operation and 

maintenance. 

Emergency Overflows 

No waste may be discharged from these outfalls unless it is due to a storm event as allowed under OAR 

340-41-120(13) and (14). In the summer, raw sewage overflows are prohibited except during a storm 

event greater than the one-in-ten-year, 24-hour duration storm. In the winter, overflows are prohibited 

except during a storm event greater than the one-in-five-year, 24-hour duration storm. 

Schedule B - Minimum Monitoring and Reporting Requirements 

In 1988, the Department developed a monitoring matrix for commonly monitored parameters. 

Proposed monitoring frequencies for ail parameters are based on this matrix and, in some cases, may 

have changed from the current permit, The proposed monitoring frequencies for all parameters 

correspond to those of facilities of similar size and complexity in the state. 

The permittee is required to have a laboratory Quality Assurance/Quality Control program. The 

Department recognizes that some tests do not accurately reflect the performance of a treatment facility 

due to quality assurance/quality control problems. These tests should not be considered when 

evaluating the compliance of the facility with the permit limitations. Thus, the Department is also 

proposing to include in the opening paragraph of Schedule B a statement recognizing that some test 

results may be inaccurate, invalid, do not adequately represent the facility's performance and should not 

be used in calculations required by the permit. 

Monitoring for E. coli must be performed in accordance with one of the methods approved by the 

Department. Monitoring for total coliform must be performed when irrigating reclaimed water. 

Total chlorine residual and chlorine used must be monitored daily using an EPA approved method. 

Continuous monitoring of chlorine levels for process control purposes need not be reported. 
City of Medford Evaluation Report 

Page 16 

The permittee will be required to monitor influent flow on a daily basis and calibrate the flow meter 

quarterly. 

Monitoring for ammonia has been included during the summer period because a new ammonia limit is 

proposed in Schedule A. The monitoring frequency is the same as the Carbonaceous Biochemical 

Oxygen Demand (CBODs) monitoring frequency. Whenever one or more permit limitations are based 

on CBOD5, Department policy requires monitoring for ammonia concentration in the same sample. 

In order to characterize the treatment facility's contribution of nutrients to the receiving stream during 

low flow periods, the proposed permit includes a requirement to monitor the treated effluent for certain 

nutrients. Weekly monitoring of Total Kjeldahl Nitrogen, nitrate plus nitrite and total phosphorus is 

proposed for the period from June 1 through October 31 each year. 

Temperature monitoring of the effluent and Rogue River is required in accordance with the 

Temperature Management Plan (TMP). In addition, the permittee will be required to calculate the 

weekly average of the maximum temperatures of the effluent and the thermal load discharged. 

The streams in this basin are water quality limited for temperature in the summer and may not fully 

support the rearing of salmonid species, This discharge has a reasonable potential to contribute heat to 

the water quality limited sections. Therefore, the TMP must include stream monitoring for 

temperature. The TMP specifies the monitoring sites, the quality control procedures and reporting 

requirements. An annual report summarizing the temperature monitoring is required. 

Because this facility has a pretreatment program, the proposed permit includes a requirement to 

conduct quarterly bioassay tests using three species. Bioassay tests are to be conducted in accordance 

with EPA test methods and procedural requirements as defined in Schedule D. 

The Department recognizes that the bioassay tests are quite expensive to conduct. If the results of the 

first year's bioassay tests show that the effluent samples are not toxic at the dilutions determined to 

occur at the Zone of Immediate Dilution and the Mixing Zone, no further bioassay testing will be 

required during this permit cycle, 

In addition, the permittee must regularly perform a scan for priority pollutant in the plant influent and 

effluent. Certain specific toxic pollutants (metals and cyanide) must be monitored more frequently. 

Volatile solids reduction in the biosolids is the process used to demonstrate compliance with vector 

attraction reduction requirements. Monitoring of volatile solids reduction is proposed in the renewal 

permit. Fecal coliform testing of the biosolids is the process used to demonstrate compliance with 

pathogen reduction requirements. Monitoring for fecal coliform content is proposed in the renewal 

permit. 

The proposed permit includes monitoring of the reclaimed water for flow, chlorine used and residual, 

pH, nutrients, turbidity and total coliform. The monitoring frequencies are in accordance with 

Department rules and guidance. An annual report describing the effectiveness of the reclaimed water 

system is required. 

The estimated or actual duration and volume of each overflow from the emergency outfalls must be 

recorded. 

Discharge monitoring reports must be submitted to the Department monthly by the 15th day of the 

following month. The monitoring reports need to identify the principal operators designated by the 

City to supervise the treatment and collection systems. The reports must also include records 

concerning application of biosolids and all applicable equipment breakdowns and bypassing. 

Schedule B of the permit includes the requirement for the submittal of annual reports. The conditions 

are standard language requirements concerning: 
City of Medford Evaluation Report 

Page 17 

Annual report on inflow and infiltration removal 

Annual report on land application of biosolids and landfilling of sludge 

Annual report on temperature monitoring 

Annual report on the use of reclaimed water 

Schedule C - Compliance Conditions 

The proposed permit includes 5 compliance conditions with compliance deadlines. The requirements 

include: 

Schedule C of the Permit includes a compliance condition requiring submittal a proposed program and 

time schedule for identifying and reducing inflow. This program is required because the winter period 

BOD5 and TSS mass limits are based on average wet weather flow. 

The second condition requires the permittee to submit to the Department a report concerning raw 

sewage overflows. 

The third condition requires submittal of an approvable plan and schedule for coming into compliance 

with the temperature waste load allocation by no later than one year after issuance of the Rogue River 

Total Maximum Daily Load (TMDL) or with the next permit renewal application (whichever is later). 

The plan must also evaluate the potential for impacts on the biological integrity of Threatened and 

Endangered Species that may be present during the discharge period. 

The fourth condition requires submittal of a report which assesses potential internal and external 

temperature management practices for the facility by December 31,2003. 

The fifth condition requires submittal of a reclaimed water use plan at least ninety (90) days prior to 

irrigation of any reclaimed water. 

The final condition states that the permittee is expected to meet the compliance dates established in this 

schedule or notify the Department within 14 days following any lapsed compliance date. 

Schedule D - Special Conditions 

The proposed permit includes 11 special conditions. The requirements include: 

The permittee must have the facilities supervised by personnel certified by the Department in the 

operation of treatment and/or collection systems. 

Schedule D of this permit includes a condition specifying the necessary procedures for conducting 

whole effluent toxicity testing. 

Department policy requires that all facilities of this size and complexity and with industrial 

pretreatment programs must regularly perform a priority pollutant scan. Schedule D of this permit 

includes a condition requiring such submittal and specifying the necessaiy procedures. 

Schedule D includes a condition requiring the development and implementation of a contingency plan 

for the prevention and handling of spills and unplanned discharges. 
City of Medford Evaluation Report 

Page 18 

Schedule D of this permit includes conditions requiring the permittee to manage the land application of 

biosolids in accordance with the approved biosolids management plan. Disposal of waste sludge in a 

landfill in accordance with solid waste rules is also allowed. 

The proposed permit includes a condition in Schedule D that prohibits any adverse impact on 

groundwater quality. 

Schedule D includes a condition requiring the permittee to comply with the rules concerning the use of 

reclaimed water and the Reclaimed Water Use Plan approved by the Department. 

A condition is included in Schedule D that requires the permittee to keep a cover crop on the irrigation 

site at all times unless otherwise approved by the Department in the Reclaimed Water Use Plan. 

The Department has included a limit on excess thermal load in Schedule A that identifies the currently 

permitted amount of thermal energy over and above the trigger temperature that may be discharged. 

The Department is proposing to include a prohibition against increasing thermal discharges beyond the 

currently permitted amount. That prohibition can be found in Schedule D. 

A Temperature Management Plan has been submitted by the permittee and is approved by the 

Department through this permit action. Schedule D includes a permit condition requiring the permittee 

to implement the provisions of the approved Temperature Management Plan. 

Schedule E - Pretreatment Program 

The proposed permit includes a Schedule E that requires implementation of the industrial pretreatment 

program. 

Schedule F - NPDES General Conditions 

All NPDES permits issued in the state of Oregon contain certain conditions that remain the same 

regardless of the type of discharge and the activity causing the discharge. These conditions are called 

General Conditions. These conditions can be changed or modified only on a statewide basis. 

ATTACHMENTS 

1) Location Map 

2) Reasonable Potential Analysis Spreadsheet 

3) Calculation of Permit Limits 

4) Antidegradation Review Sheet 

5) DEQ Biologist Memo 

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Attachment 4 

Appendix B; Antidegradation Review Sheet 

ANTIDEGRADATION REVIEW SHEET 

FOR A PROPOSED INDIVIDUAL NPDES DISCHARGE 

1. What is the name of Surface Water that receives the discharge? Rogue River 

Briefly describe the proposed activity: Wastewater Treatment 

Is this review for a renewal OR new (circle one) permit application? 

Go to Step 2. 

2. Is this surface water an Outstanding Resource Water or upstream from an 

Outstanding Resource Water? 

Yes. Go to Step 5. 

No. Go to Step 3. 

3. Is this surface water a High Quality Water? 

Yes. Go to Step 8. 

No. Go to Step 4; 

4. Is this surface water a Water Quality Limited Water? 

Yes. Go to Step 13.; 

No. Go to Step 2. Note; The surface water must fall into one of three (3) 

categories: Outstanding Resource Water (Step 2), High Quality Water 

(Step 3), or Water Quality Limited Water (Step 4). 

13. Will the proposed activity result in a Lowering of Water Quality in the Water 

Quality Limited Water? 

Yes. Go to Step 14. 

No. Proceed with Permit Application. Applicant should provide basis for 

conclusion. Go to Step 24. 

Renewal permit includes concentration and mass limits as allowed by rule and does not 

include any mass load increases subject to OAR 340-041-0026(3) 
24. On the basis of the Antidegradation Review, the following is recommended: 

_X_ Proceed with Application to Interagency Coordination and Public 

Comment Phase. 

Deny Application; return to applicant and provide public notice. 

Action Approved 

Section: 

Review Prepared By: Mark E. Hamlin 

Phone: 503-378-8240 x 239 

Date Prepared: May 17,2002 

Please provide the following information and submit with the completed application form 

to: 

Department of Environmental Quality 

Water Quality Division—Surface Water Management 

811 SW Sixth Avenue 

Portland, Oregon 97204-1390 

Name: 

Name of Company: 

Address: 

Phone: 

Fax: 
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State of Oregon 

Department of Environmental Quality Memorandum 

Date: 12 June 2002 

To: Mark Hamlin 

From: Rick Hafele 

Subject: Winter temperature effects on aquatic invertebrates 

A question has been raised about how a slight increase in water temperature (up to 1,5°F) during 

the winter months, when stream temperatures are naturally cold (below 50°F), might impact the 

biological integrity of aquatic invertebrates and thus food for listed juvenile salmon in the Rogue 

River. 

Water temperature is well known to influence many facets of aquatic invertebrate biology 

(Merritt and Cummins 1996), Temperature can directly influence metabolism, growth, 

emergence and reproduction. It has also been observed that stream invertebrates tolerate cold 

temperatures better than warm temperatures (Ward 1992). Many species survive and grow at 

near freezing temperatures, but few species can tolerate warm temperatures (>30°C). 

Current modeling indicates that discharges from Medford's sewage treatment facility will 

increase winter temperatures in the Rogue River by approximately 1.5°F when the river is at its 

coldest winter temperatures (near 40°F) and lowest discharge. Will this change in temperature 

impact the biological integrity of the aquatic invertebrates in the affected segment of the Rogue 

River? 

While changes in temperature, even small ones, can have subtle effects on stream invertebrates 

by slightly altering growth rates and metabolism, aquatic invertebrates have evolved to survive 

under variable natural conditions. An increase of one to one and a half degrees during minimum 

winter temperatures would be well within the natural variation of winter temperatures. In 

addition I do not believe subtle changes in growth, if any occur, could be measured by any of the 

current sampling techniques which look at species diversity and relative abundance. Biological 

integrity as currently assessed is based on the species composition (diversity and relative 

abundance) of the invertebrate assemblage. Therefore, I do not believe this slight increase in 

winter temperatures would alter the biological integrity of the invertebrate community or impact 

the food base for salmonids. 

Merritt, R. W. and K. W. Cummins. 1996, An Introduction to the Aquatic Insects of North 

America. 3rd Edition. Kendall/Hunt Publishing, Dubuque, Iowa. 862 pp. 

Ward, J. V. 1992. Aquatic Insect Ecology. 1. Biology and Habitat. J. Wiley & Sons, Inc. NY. 

438 pp.