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THE MEDFORD REGIONAL WATER RECLAMATION FACILITY OUTFALL ASSESSMENT STUDY
For some time those of us that fish past the Medford Regional Treatment Facility outfall to the Rogue River below TouVelle
have noticed a tremendous increase in algae and aquatic plants and a virtual absence of aquatic bugs in the gravel at High
Banks, a large salmon spawning riffle 0.4 miles below the outfall. We raised the money to do a scientific study by Rick
Hafele a retired Department of Environmental Quality entomologist. Based on the study results we filed a complaint to the
Oregon Department of Environmental Quality .The study is attached. More background to the study follows.
BACKGROUND
The Medford Regional Water Reclamation Facility( Facility) serves a population of about 150,000 people and treats an
average dry weather flow of 17 million gallons/day. The treated effluent is discharged to the Rogue River on the left
(south) bank 0.6 miles downstream of the TouVelle State Park bridge. It is 130.5 miles from the Pacific Ocean. For some
time boat anglers fishing past the discharge have noticed and objected to the visible and sometimes smelly, foamy discharge
stretching down the river. We have also observed a substantial increase in algal and aquatic plant growth downstream from
the discharge smothering the gravel, thereby greatly reducing the aquatic insect populations. We never took action or
called for a clean up because it was widely accepted that the discharge would have to some day come out of the river. The
beneficial uses in the river, including salmon spawning, could only be protected with restrictive instream temperature
standards. The warmer-than-the-river discharge had to be cooled or removed from the river. No municipal discharger in the
U.S. has cooling towers to cool effluent; the practical solution here was to remove the discharge and that is what we
expected them to do...someday. Approximately two years ago, the Oregon Department of Environmental Quality (DEQ) did a
study and determined the beneficial uses in the river would be protected with a higher temperature standard. The temperature
standard was relaxed. Now the Facility could meet the temperature requirement in the Rogue River on all but a few days and
DEQ determined this could be mitigated by planting 30 miles of trees to shade the river. The 30 miles of new trees can be
planted up to 60 miles downstream AND the Facility has 20 years to plant and grow the trees before the effectiveness of
the action will have to be proven. While this "solution" leaves substantial room for doubt, that will not be addressed
here. The important consideration for this study is the present discharge from the 17 million gallons/day Facility will now
stay at its present treatment level. The Rogue Flyfishers then committed funds and raised the balance to accomplish the
attached study.
SUMMARY
DEQ's recent water quality regulation changes on the Rogue River in Oregon will perpetuate an observed water quality problem
below the Facility discharge. A $5400 study was conceived and partially funded by the Medford Rogue Flyfishers to document
and measure this problem. The two major funders were the International Federation of Fly Fishers and the Oregon Council of
the International Federation of Fly Fishers. Other sources include the Grants Pass, Southern Oregon Fly Fishers and the
Klamath Falls, Klamath Country Fly Casters. The study, conducted by Rick Hafele, a retired DEQ entomologist, identifies
algal and macro invertebrate characteristics and populations in a riffle 0.3 miles upstream of the outfall(US1) and two
sites, 0.4 miles (LS1) and 1 mile(LS2) downstream of the outfall.
Study results show a shift in algal populations from low nutrient species above the outfall to higher nutrient
eutrophic-adapted taxa below. In summary, "The shift in dominant taxa to eutrophic-adapted species, plus the large increase
in cell density and biovolume, at both sites below the outfall, indicate high nutrient levels in the effluent." Similar
macroinvertebrate changes were observed. In eight methods of measuring macroinvertebrates, referred to as metrics, the
results show a substantial change at the first site 0.4 miles below(LS1) the out fall and some recovery but still
substantial change 1 mile downstream(LS2) when compared to the site 0.3 miles above the outfall(US1). One metric is herein
noted. Between the upstream site(US1) and the first downstream site(LS1) the abundance of mayfly, stonefly, and caddis fly
populations were reduced an astonishing 3,000%; between US1 and LS2 these populations had recovered some but there was
still a 500% reduction. "Such a large drop in macroinvertebrate abundance might also indicate toxic levels of ammonia
occurring below the outfall." The study concludes, "Given the consistent and significant changes observed in composition,
diversity, and abundance for both biological communities [algae & macroinvertebrates], this study confirms that the Medford
waste water discharge violated the [DEQ] bio criteria standard and its NPDES permit, which do not allow any detrimental
changes to the biotic community...." Fall Chinook salmon spawn in the riffles at all three of the sample areas.
Conservatively, there are probably 50 to 75 redds at the two impacted sites downstream of the outfall and many more hundreds
in riffles further downstream. "Given the sensitivity of developing salmon eggs to changes in dissolved oxygen and other
water quality parameters, the possibility that salmon egg survival is being impacted at sites below the outfall is a
legitimate concern."
UNANSWERED QUESTIONS
Algae numbers are substantially increased 0.4 mile below the outfall and macroinvertebrate numbers and species are equally
impacted. All the impact measurements have the same trend. A very significant negative impact was registered at the first
site downstream from the outfall (0.4 miles). Measurements 1 mile below the outfall showed significant degradation, but
there was some recovery. The river was returning to upstream of the outfall conditions. This begs the question, will the
downstream river conditions ever recover and resemble those at the site above the outfall? If it does recover, how far
downstream will it occur? In October this river is teeming with spawning wild Chinook salmon for many miles downstream;
how many of them are being impacted by the changes brought about by the outfall? And what about the millions of wild and
hatchery salmon and steelhead smolts migrating downstream past the outfall from tributaries and a hatchery upstream? Clearly their food supply and
probably oxygen are reduced for a long undefined stretch of the river.
ACTIONS
The study was sent to the regional engineer for the Department of Environmental Quality and the Public Works Director for
the City of Medford. Copies were sent to several interested parties including some environmental legal firms. D.E.Q. has
acknowledged receiving the report and complaint and they have assigned it Complaint # 13-348. The Hafele study is being
reviewed by DEQ's lab. in Hillsboro.
Our future action will depend on DEQ's action. What we want to see is the discharge cleaned up to protect the beneficial
uses of the Rogue. It appears that the treatment plant will have to reduce the nutrient load in the discharge which will
require additional costly treatment facilities. This will all take time and our goal is to monitor the situation to make
sure DEQ and Medford are moving at a responsible pace to implement a solution. The environmental legal firms are also
watching with a keen interest. They know the Federal Clean Water Act Law and they are ready to step in if necessary.