Variance Request - Standard Steel

From: Roy, Melanie

Sent: Thu Feb 22 08:54:49 2024

To: Nancy Fischer

Cc: Gage Martin

Subject: Variance Request - Standard Steel

Importance: High

Attachments: 24-02-22 Monitoring Variance Approval.pdf; image001.png;

Hi Nancy,

Please see attached the variance approval letter for Q1 and Q2 of 2023-2024. Requesting monitoring variances is not a one-and-done event. If two samples are not taken from ML-001 during Q3 and Q4, then you all need to submit another variance request by August 15, 2024, the same date that your Q4 DMR is due.

Looking at the photos you submitted, I noticed some moisture and sediment at the bottom of the manhole. This implies to me that there may be potential for discharge during heavy rain events. For that reason, I am requiring that you all take photos of ML-001 during heavy rain events (1” in 24 hours) for at least the next two variance requests. Below is the procedure you should follow moving forward:

1. Watch the forecast for rain events greater than 1” in 24 hours. Weather Underground has a great tool for this- scroll down to ‘Accumulation’ for the 24-hour rainfall forecast.
2. Once heavy rainfall is forecasted, head out during the rain and take a photo of ML-001. Keep a spare sample kit on hand- if there is discharge, you need to collect a sample.
3. Later that same day, go to the Mallory rain gauge webpage to see if the storm truly caused 1” in 24 hours as was forecasted. Look at ‘Today’s Total’ in the table to confirm. When you send me your next variance request, this is the data I will use to confirm if you all targeted heavy rain events.
4. Repeat the steps above as much as possible, taking as many photos (dated with timestamps) during as many heavy rain events as you can. We are trying to determine if and when we may see discharge. It may feel like trial and error at first, but you will begin to get a feel for what 1” of rain in 24 hours looks like.
5. I also recommend that you all keep a mat on top of the manhole cover to prevent rain from getting in through the holes.

Let me know if you have any questions about this requirement. I appreciate your efforts to get out there during heavy rain.

Best,

Melanie Roy

Permit Manager

Industrial Stormwater Program

(503) 865-6929

(she/her)

City of Portland Bureau of Environmental Services

6543 N Burlington Avenue, Portland, Oregon 97203

Melanie.Roy@portlandoregon.gov

www.portland.gov/bes

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