System Management Program Element

Appendix A

Best Management Practices for Overall System Management

System Management Program Element

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BMPs for Overall System Management Page A-1 December 2006

Best Management Practices

for Overall System Management This section describes the best management practices (BMPs) that will be applied to the entire underground injection control (UIC) system on an ongoing basis to prevent, minimize, and control pollutants in stormwater prior to discharge to a UIC. These BMPs are part of the Systemwide Management program element of the UIC Management Plan (UICMP). The BMPs are grouped within five general action categories:

• System Inventory and Assessment (SA); • Pollution Control (PC); • Education and Training (ET); • Operations and Maintenance (OM); and • Policy and Regulation (PR).

The five BMP categories encompass a comprehensive range of actions that together will help ensure that UICs are constructed, operated, and maintained in a manner that meets the requirements of the Water Pollution Control Facility (WPCF) permit and protects groundwater for use as drinking water resource. The BMPs identify tasks that will be undertaken to address specific WPCF permit requirements. They also identify activities the City implements that are not required by the permit, but contribute to stormwater management, groundwater protection, and watershed health.


Category: System Inventory and Assessment (SA)

Overview Ongoing activities necessary to provide stormwater drainage infrastructure will include the registration and construction of new UICs, replacement and retrofit of existing UICs, and decommissioning of existing UICs. Ongoing system inventory and assessment activities are important to manage all known public UICs within the City of Portland and to assess drainage to each UIC for potential impacts to groundwater. The BMPs focus on updating and refining information related to the location and physical characteristics of existing and new public UICs. This BMP category fulfills two WPCF requirements: 1. Develop and implement a comprehensive UIC Registration Database. 2. Evaluate UICs relative to the factors that could present a risk to groundwater quality. The System Inventory and Assessment category includes the two BMPs identified below. • SA-1: Install, replace, retrofit, and decommission UICs as needed to provide public

infrastructure for stormwater management. Maintain a comprehensive system inventory/data management system to register new UICs and track the location, physical characteristics, and status of all public UICs.

• SA-2: Evaluate the location of public UICs relative to factors that may create

adverse impacts to groundwater. These activities generally relate to ongoing public infrastructure management; however, some activities may occur as a result of the Evaluation and Response program element (as described in Section 5 of the UICMP) or Corrective Action program element (as described in Section 6 of the UICMP).


SA-1: Install, replace, retrofit, and decommission UICs as needed to provide public infrastructure for stormwater management. Maintain a comprehensive system inventory/data management system to register new UICs and track the location, physical characteristics, and status of all public UICs. Introduction UICs are the only form of stormwater disposal available for many public rights-of-way located east of the Willamette River. Future public infrastructure needs will be satisfied through the construction of new UICs, replacement or retrofit of existing UICs, and decommissioning of existing UICs. As required by the UIC WPCF permit, the City has developed a UIC Registration Database that identifies the physical and spatial characteristics of known public UICs. The UIC database serves as the primary tracking mechanism and data source for public UICs. The database was completed and submitted to DEQ on September 1, 2005. Since that time, updates have been provided to DEQ quarterly. BMP SA-1 includes the following activities: • Tracking of data and information resulting from installation, replacement, retrofitting, or

decommissioning of UICs as needed to provide stormwater infrastructure for public facilities and rights-of-way. Examples include new public roads, road rehabilitation, UIC retrofit activities, and replacement of failed UICs.

• Registration of new UICs, and maintaining, updating, and reporting on the physical and

spatial characteristics of UICs as part of the UIC Registration Database for public UICs.

Links between SA-1 and Other UICMP Sections • BMP SA-2 generates data and information resulting from the evaluation of public UICs

relative to factors that could have and adverse impact on groundwater. • Decommissioning of UICs will follow the guidelines provided in Decommissioning

Procedure for Underground Injection Control Systems (included in the UICMP as Appendix D).


Permit-Required Activities [Relevant permit sections: C(5)(c), C(16), D(10)(a)—UIC Registration Database] The City will implement the following tasks to fulfill WPCF requirements: Task 1: Update the UIC Registration Database regularly to include new and decommissioned UICs and other relevant new information. Submit quarterly UIC Registration Database updates to DEQ.

Assignment: Bureau of Environmental Services Timeframe: First day of each quarter (December, March, June, September) Fiscal Year 2005-2006 to Fiscal Year 2014-2015


SA-2: Evaluate the location of public UICs relative to factors that may create adverse impacts to groundwater. Introduction The WPCF permit requires the City to evaluate public UICs for the following five factors that may present a risk for adverse impacts to groundwater: 1. Receives drainage from motor vehicle maintenance floor drains, indoor parking facilities,

fire station bay drains; 2. Receives drainage from Superfund Amendment and Reauthorization Act (SARA) Title

III facilities; 3. Receives drainage from commercial/industrial properties that have site activities that may

result in a permit violation; 4. Has inadequate separation distance to groundwater; or 5. Is within 500 feet of a drinking water well or within 2-year time of travel. The City submitted a Systemwide Assessment of all known public UICs to DEQ on July 15, 2006. Part of the assessment included identifying public UICs for which further evaluation/information was needed to make a conclusive determination about any of the five factors listed above. BMP SA-2 includes the following activities: • Developing and implementing a description of follow-up activities (e.g., additional field

investigations) for UICs identified in the Systemwide Assessment; and

• Evaluating proposed or newly identified UICs for the listed factors.

Links between SA-2 and Other UICMP Sections • BMP SA-1 provides regular database updates to incorporate data generated in BMP

SA-2. • BMP PC-1 includes ongoing systemwide activities to identify UICs that may drain

commercial/industrial properties or SARA Title III facilities where site activities could adversely impact stormwater.


Permit-Required Activities (Not in any order of priority) [Relevant permit sections: C(6), C(12), D(8)—Systemwide Assessment] The City will implement the following tasks to fulfill WPCF requirements: Task 1: Develop a workplan and implementation schedule for follow-up actions (e.g., additional field investigations) on UICs identified in the Systemwide Assessment.

Assignment: Bureau of Environmental Services Timeframe: Submitted the workplan to DEQ December 1, 2006

Task 2: Implement the workplan. Assignment: Bureau of Environmental Services Timeframe: Established in the workplan

Task 3: Evaluate proposed or newly identified UICs for the five listed factors. Incorporate the resulting information into the UIC Database and the Evaluation and Response process.

Assignment: Bureau of Environmental Services Timeframe: Fiscal Year 2005-2006 to Fiscal Year 2014-2015


Category: Pollution Control (PC)

Overview Activities and practices such as spills, illegal disposal, improper site management, and erosion, can increase the discharge of pollutants to public UICs, with potential negative impacts to groundwater. This BMP category focuses on reducing such pollutant discharges from both public and private sites and activities. It fulfills two WPCF permit requirements: 1. Implement a Spill Prevention and Pollution Control (SPPC) Plan.1 2. Identify activities conducted on commercial/industrial properties, or SARA Title III

facilities that may result in a violation of maximum allowable discharge limits (MADLs) in stormwater discharging to a public UIC.

The SPPC Plan describes the spill/emergency prevention and response activities the City implements to control the release of pollutants to UICs and protect groundwater. It focuses equally on spill prevention activities and spill response activities, and applies to all public rights-of-way and City properties with UICs. The SPPC plan also describes the roles of the City bureaus involved in controlling and responding to spills and emergencies: Environmental Services, Maintenance, Fire & Rescue, Water, Portland Parks & Recreation, General Services, Police, and the Office of Emergency Management. The City submitted a Systemwide Assessment of all known public UICs to DEQ on July 15, 2006. Part of the assessment included identifying public UICs that may drain private properties with site activities classified as commercial or industrial, or registered under SARA Title III. BMP PC-1 provides for ongoing identification of private properties that may have the potential to have an adverse impact on stormwater entering a public UIC. The City’s activities in this category are included under one best management practice: • PC-1: Identify, prevent, minimize, and control activities and practices that can

increase pollutant discharges to public UICs.

1 The SPPC Plan is included as Appendix C of the UICMP.


PC-1: Identify, prevent, minimize, and control activities and practices that can increase pollutant discharges to public UICs. Introduction Potential sources of pollutants that can impact public UICs include the following: • Spills and leaks. These include accidental or unplanned discharges. Examples include

fluids released from vehicle accidents, leaking storage containers, firefighting activities, and other emergency events where pollutants may enter a public UIC.

• Illegal disposal. This includes both solid and liquid wastes. Examples include dumping

used motor oil, garbage, or other materials into catch basins. • Improper site management. This includes discharges resulting from improper storage and

handling of materials and wastes or insufficient pollution prevention/control measures. Examples include the exposure of material or waste storage areas to stormwater.

• Erosion: If not properly managed, construction site activities can result in erosion and

the discharge of sediment and other pollutants into public UICs.

Links between PC-1 and Other UICMP Sections • BMP ET-1 and ET-2 include educational and outreach programs that address pollution

prevention. • The WPCF permit requires the City to identify commercial/industrial properties or SARA

Title III facilities where site activities could result in a violation of MADLs in stormwater discharging to a UIC. Based on information obtained through PC-1 activities, a UIC or group of UICs may be identified for further assessment in the Evaluation and Response program element.


Permit-Required Activities [Relevant permit section: D(10)(c): Spill Prevention and Control Plan] The City will implement the following task to fulfill WPCF permit requirements: Task 1: Implement the SPPC Plan which defines prevention and response activities for spills and emergency events where pollutants may enter a public UIC.


The SPPC Plan includes ongoing citywide pollution control activities to identify and control activities on private properties, including commercial/industrial properties or SARA Title III facilities where site activities could result in a violation of MADLs in stormwater discharging to a UIC (e.g., illegal disposal, improper storage and handling of materials, and erosion). The Spill Protection-Citizen Response (SPCR) staff responds immediately to emergency spills and investigates pollution complaints regarding spills, illegal disposal, improper site management and erosion. Citizens can call in reports on a dedicated hotline seven days a week, and staff is available 24 hours a day to respond to spills, slicks, and other suspicious or inappropriate discharges. The program refers problems to other enforcement agencies as appropriate. The SPCR team also provides education and technical assistance to property owners to improve site management and address work practices that may impact stormwater discharges.

Related Groundwater Protection Activities The City will continue to implement the activities included in this Section that are not required by the WPCF permit but that contribute to groundwater protection. These following actions are voluntary in nature and may be modified or discontinued at the City’s discretion:

• Participate in the Regional Spill Response Committee.

This multi-agency committee was established in 1995 to consult and debrief on spill response activities throughout the region. It also provides staff training and coordination. The committee meets quarterly and is chaired by Portland’s Bureau of Environmental Services. Member agencies include: o City of Portland – Bureaus of Environmental Services, Fire, Maintenance, and

Water o Oregon Department of Transportation o State Police o Oregon Department of Fish and Wildlife o National Marine Fisheries Service (NOAA Fisheries) o Clean Water Services o Clackamas County o Multnomah County o Port of Portland


Assignment: Bureau of Environmental Services

• Implement the Columbia South Shore Well Field Wellhead Protection Area Program.

Columbia South Shore Well Field (CSSW) groundwater is used as an emergency backup for the 800,000 Oregonians served by the Bull Run supply and also provides supplemental supply during the summer demand season. To protect this valuable drinking water resource, the cities of Portland, Gresham, and Fairview adopted a common set of wellhead protection regulations aimed at new and existing businesses that use and store hazardous materials that pose a threat to groundwater in the CSSW. Portland's City Council adopted the regulations on July 2, 2003. The new regulations require industrial sites that have hazardous materials to implement retrofits by 2008. Retrofits predominately include paving, covering, and berming of outdoor activity and storage areas, as well as retrofitting of UICs with sedimentation manholes for pretreatment and spill containment. The City provides oversight to ensure compliance with the mandated retrofit requirements and schedule (per Title 21 of City Code). The City also provides education and technical assistance to businesses to help them comply with the requirements. Assignment: Portland Water Bureau, Bureau of Environmental Services, Fire Bureau

• Require implementation of source control measures as specified in the City’s Stormwater

Management Manual (SWMM).

The SWMM requires storm and sanitary source controls for site uses and characteristics that generate, or have the potential to generate, specific pollutants of concern. These requirements apply to new development projects, redevelopment projects, tenant improvements, and existing sites proposing new off-site discharges. Assignment: Bureau of Environmental Services

• Implement the requirements of Title 10 and the Erosion Control Manual.

Title 10 of City Code and the City’s Erosion Control Manual (finalized in March 2000) provide a comprehensive, citywide erosion and construction site pollutant control program. The Title 10 regulations and the Erosion Control Manual cover site planning, use and adequacy of BMPs, and inspection and enforcement measures for any ground-disturbing activity. The manual includes BMPs for seven types of activities: site dewatering, spill prevention and control, solid waste management, vehicle and equipment fueling, vehicle and equipment maintenance, concrete waste management, and structure preparation and painting. Ongoing training and assistance on erosion, sediment, and pollutant control are provided to City staff and contractors/permit applicants.

The Bureau of Development Services operates an automated erosion control hotline to receive complaints about erosion, sediment, and pollutant problems. The bureaus of Development Services and Environmental Services then identify and implement an


appropriate response, including education, technical assistance, or enforcement. This process applies to both permitted construction activities and non-permitted/non-construction activities. Assignment: Bureau of Development Services, Portland Water Bureau, Bureau of Environmental Services, Portland Office of Transportation, and Parks and Recreation

• Implement solid waste programs to prevent illegal disposal.

The Office of Sustainable Development manages residential and commercial solid waste and recycling programs that prevent illegal disposal of solid and liquid wastes that could result in the discharge of pollutants into public UICs. These programs include curbside recycling, yard debris collection, and bulky waste collection. The programs link closely with neighborhood, non-profit, and regional agency programs for the management of almost any type of material, from construction debris to household hazardous waste. Assignment: Office of Sustainable Development

• Use the Neighborhood Inspections Program to help enforce the City’s property maintenance code.

This program uses enforcement, education, and referrals to help residential property owners comply with maintenance requirements and prevent nuisances such as trash, debris, and illegal dumping that can contribute to pollutant discharges into public UICs. Assignment: Portland Office of Neighborhood Involvement

• Track and coordinate with regional programs that provide pollution prevention and

materials control to minimize pollutant discharges to public UICs.

Examples of these programs include Metro’s Household Hazardous Waste Program and Information Resource Center, and Multnomah County Animal Control permitting (to ensure proper control of animal wastes). Assignment: Bureau of Environmental Services


Category: Education and Training Overview This BMP category fulfills the WPCF permit requirement for an employee training and public education program to educate City personnel and the public of the conditions and requirements of the permit. It includes the following two BMPs: • ET-1: Implement public education activities that will raise awareness of

groundwater protection and promote pollution prevention and control. • ET-2: Conduct employee training to ensure that UICs on public property are

designed, constructed, operated, and closed in ways that meet WPCF permit requirements and protect groundwater.

Key messages that will be conveyed through education and training are: • UICs are an element of an overall watershed strategy to protect and maintain the natural

hydrologic cycle. The City supports this overall watershed approach by emphasizing use of vegetated facilities to treat and infiltrate stormwater prior to discharge to a UIC.

• Source control and pollution prevention actions at the ground surface—by citizens as

well as by the City—can reduce pollutant loads entering UICs, protect groundwater, and meet permit requirements.

• Public and private UICs should be designed and sited in accordance with the City’s

SWMM and the WPCF permit. • Operations and maintenance activities are an essential component of ensuring the City

protects groundwater and meets permit requirements and protects groundwater. • Public and private UICs should be designed and sited in accordance with the City’s

SWMM and the WPCF permit.


ET-1: Implement public education activities that will raise awareness of groundwater protection and promote pollution prevention and control. Introduction The Bureau of Environmental Services (BES) currently conducts a number of public education programs and activities that convey information and messages relevant to stormwater, pollution prevention, source control, and environmental protection. These include the following: • Clean Rivers Education programs for grades K-12. These hands-on programs teach

students about the causes and effects of water pollution and what individuals can do to protect water resources. The programs also provide community service projects (e.g., marking storm drain inlets with “No Dumping, Drains to Stream”), teacher workshops, and curriculum resources. A number of the programs focus on stormwater and pollution prevention. An Education Advisory Committee (comprising educators from the Portland region) provides feedback and guidance on BES’s education programs and activities.

• Regional Coalition for Clean Rivers and Streams. BES is a member of this coalition

of agencies and municipalities in the Portland/Vancouver metro area dedicated to educating the public about the impacts of stormwater runoff pollution. The coalition develops an annual regionwide public awareness campaign that can reach more than 1.4 million people living in the four-county area.

• Watershed-specific education and stewardship activities. BES conducts watershed

planning and implements watershed programs in the Columbia Slough, Johnson Creek, Fanno Creek, Tryon Creek, and Willamette River Watersheds. The integrated watershed-based approach stresses comprehensive, multi-objective watershed management along geographical boundaries, coordinating the various jurisdictional and public interests within those areas. Each program includes a variety of public education and stewardship activities that focus on the specific needs of that watershed, including coordination and partnerships with watershed councils and other concerned community groups.

• Publications and signage. BES publishes and disseminates a variety of educational and

informational materials that address stormwater-related issues and activities and are targeted at numerous audiences. BES also develops signage that provides information about specific projects (e.g., stormwater demonstration projects).

• Coordination with other City programs. BES coordinates with other City projects and

programs (e.g., Endangered Species Act Program, Portland Parks and Recreation programs/ projects, Urban Forestry, River Renaissance) to integrate stormwater-related activities and messages.


Links between ET-1 and Other UICMP Sections • BMP PC-1 includes education activities targeted at specific audiences, including fact sheets

about spill control and response for industrial/commercial clients and technical assistance to businesses in the CSSW Wellhead Protection Area.

Permit-Required Activities (Not in any order of priority) [Relevant permit section: D(10)(d)—Employee Training and Public Education] The City will implement the following tasks to fulfill WPCF permit requirements: Task 1: Continue to implement existing public education programs and activities.


Task 2: Develop UIC-specific information and messages about groundwater protection to incorporate into existing and new education programs.

Assignment: Bureau of Environmental Services Timeframe: Fiscal Year 2007-2008 to Fiscal Year 2009-2010; thereafter as needed


ET-2: Conduct employee training to ensure that UICs on public property are designed, constructed, operated, and closed in ways that meet WPCF permit requirements and protect groundwater. Introduction Employee training focuses on providing information to City of Portland staff to raise their knowledge of the UIC permit requirements and to ensure that city practices related to UICs are protective of groundwater. City bureaus involved in UIC-related activities are:

• Bureau of Environmental Services • Portland Parks and Recreation • Fire Bureau • Bureau of Maintenance • Portland Office of Transportation • Portland Water Bureau • Bureau of General Services • Bureau of Development Services

Types of training currently conducted include:

• Training for relevant City staff members on spill prevention and response. • Training for Bureau of Maintenance staff members responsible for operations and

maintenance of UICs in public rights-of-way. • Training for Portland Office of Transportation staff members who pave roads or

who conduct activities in or near UICs to ensure that UICs do not get paved over and that material from road maintenance or construction activities do not enter UICs.

• Training for relevant staff members of bureaus with UICs on their property (e.g.,

City parks, fire stations, police stations). • Training for relevant Portland Water Bureau staff members regarding activities

where water may enter UICs (e.g., flushing of fire hydrants). • Training for development review staff members on requirements of the WPCF

permit and Oregon Administrative Rules for UICs (OAR 340-044). • Training for relevant City staff members on the application of the City’s SWMM

requirements for new development and redevelopment (e.g., regarding the stormwater management hierarchy and the installation of UICs in public rights-of-way).


• Training for staff from various City bureaus through the use of a City training

video, Stormwatch, an outreach and education tool that provides general pollution and response messages.

Links between ET-2 and Other UICMP Sections • BMP PR-1 includes tasks to evaluate the review and approval process for UICs registered on

private property and to develop consistent design standards and guidance for UICs on private and public property. Once this has been done, appropriate training will be provided to development review staff.


Permit-Required Activities (Not in any order of priority) [Relevant permit section: D(10)(d)—Employee Training and Public Education] The City will implement the following tasks to fulfill WPCF permit requirements: Task 1: Continue to implement existing staff training on stormwater management, pollution prevention, operations and maintenance, spill prevention and response, and development review.


Task 2: Maintain records of training locations/times, groups trained, and topics covered. Assignment: Bureau of Environmental Services Timeframe: Fiscal Year 2005-2006 to Fiscal Year 2014-2015

Task 3: Evaluate the existing training approaches and schedules and revise/update as needed.


Task 4: Provide enhanced training for development review staff on UIC design standards, and review and approval process for UICs registered on private property.



Category: Operations and Maintenance

Overview Operations and maintenance BMPs for City UICs are important in order to both remove pollutants from UICs (e.g., UIC cleaning) and prevent pollutant discharges into UICs (e.g., street sweeping). This BMP category identifies operations and maintenance practices to remove or prevent pollutants from entering public UICs located in City-managed rights-of-ways and on other City-owned property. This BMP fulfills the WPCF permit requirement to implement an Operations and Maintenance (O&M) Plan for public UICs. The City’s activities in this category are included under one BMP: • OM-1: Implement operations and maintenance practices to remove or prevent

pollutants from entering public UICs located in City-managed rights-of-ways and on other City-owned property.


OM-1: Implement operations and maintenance practices to remove or prevent pollutants from entering public UICs located in City-managed rights-of-ways and on other City-owned property. Introduction The City has developed an O&M Plan2 that describes the activities the City currently implements to effectively manage its public UICs and protect groundwater quality. The O&M Plan includes the following information:

• Goals and objectives; • Maintenance targets and schedules; • Maintenance practices for sedimentation manholes; • Maintenance practices for UICs; • Street sweeping and vector control; • Materials management; • Recordkeeping; • O&M for UICs on City-held and operated properties; and • Roles and responsibilities.

In addition to the activities currently implemented under the O&M Plan, additional assessment or procedures are needed in some areas. These items are summarized below: Traffic Volumes Maintenance inspection and cleaning targets for UICs in public rights-of-way are currently based on sediment accumulation rates, rather than on specific traffic counts. Additional City maintenance activities such as street sweeping, however, are adjusted to reflect differing traffic loads. The relationships between stormwater quality, maintenance frequency, and traffic volumes will initially be evaluated using data generated as part of the UIC compliance monitoring. If additional data are needed to fully evaluate these relationships, the data may be generated as part of the BMP Monitoring Program. Maintenance Access Out of the City’s total inventory of approximately 9,000 UICs, approximately 176 may have inadequate maintenance access (fully or partially obstructed by pavement) and have only a generalized location description. Most of these 176 are assumed to be old Multnomah County sumps (inherited by the City in the 1970s and 1980s) where there were no plans with construction details or the plans were lost in transfer. 2 The O&M Plan is included as Appendix B of this UICMP.


UICs on Other City Property City parks, fire stations, police stations, and other City properties have drywells and soakage trenches to infiltrate flows from impervious and pervious areas. As part of the Systemwide Assessment, the relevant City bureaus participated in locating and identifying these UICs. Some facilities on City-held and operated properties do not have standardized operations and maintenance procedures at this time. Maintenance templates in the City’s SWMM describe general maintenance practices established for soakage trenches and drywells. Permit-Required Activities (Not in any order of priority) [Relevant permit section: D(10)(b)—O&M Plan] The City will implement the following tasks to fulfill WPCF permit requirements: Task 1: Implement the O&M Plan. Assignment: Bureau of Environmental Services

Timeframe: Fiscal Year 2005-2006 to Fiscal Year 2014-2015 Task 2: Use UIC stormwater quality monitoring data to evaluate the relationship between cleaning schedules and traffic volume. Where appropriate, adjust current O&M Plan maintenance schedules and targets. Assignment: Bureau of Environmental Services

Timeframe: Fiscal Year 2007-2008 to Fiscal Year 2009-2010 Task 3: Standardize operations and maintenance procedures for UICs on City property, based on the O&M templates established in the SWMM. Develop applicable tracking systems.


Task 4: Evaluate UICs that have inadequate maintenance access and develop recommendations to address them.


Related Groundwater Protection Activities The City will implement the activities included in this Section that are not required by the WPCF permit but that contribute to groundwater protection. These following actions are voluntary in nature and may be modified or discontinued at the City’s discretion: • Evaluate Alternative Outlet Structures. The most commonly required repair of UIC

system components is replacement of the 90-degree elbow (inverted outlet) within the sedimentation manhole. Over the last year, the City has been experimenting with new snout or hood outlets that are expected to perform better than the 90-degree elbows. Assignment: Bureau of Environmental Services


Category: Policy and Regulation

Overview The development of policies, codes, and administrative rules is a key element in providing long-term protection of groundwater. The City’s activities in this category are included under one BMP: • PR-1: Review and modify City policies, codes, and regulations to enhance

groundwater protection.


PR-1: Review and modify City policies, codes, and regulations to enhance groundwater protection. Introduction This BMP includes City initiatives, such as policies that promote the implementation of green streets as alternatives or retrofits for UICs, as well as code and administrative rules pertaining to groundwater protection.

Links between PR-1 and Other UICMP Sections • BMP PR-1 includes tasks to evaluate the review and approval process for UICs registered on

private property and to develop consistent design standards and guidance for UICs on private and public property. Once this has been done, appropriate training will be provided to development review staff under BMP ET-2.

Permit-Required Activities There are no specific permit requirements relevant to this BMP. Related Groundwater Protection Activities The City will implement the activities included in this Section that are not required by the WPCF permit but that contribute to groundwater protection. These following actions are voluntary in nature and may be modified or discontinued at the City’s discretion: • Develop and implement a Green Streets Program.

In August 2005, the City formed the Green Streets Cross-Bureau Team, comprising staff members from 10 City bureaus and offices with expertise in stormwater engineering, transportation, planning, utilities, parks, sustainability, and maintenance. The team was charged with creating a programmatic approach to implementing green streets and identifying solutions to implementation issues. In April 2006, the team completed its Phase I Report that identifies opportunities and challenges and recommends solutions for key issues. Phase II work, underway in fiscal year 2006-07, will focus on developing a programmatic approach to implementing green streets. Assignment: Bureau of Environmental Services, Portland Office of Transportation


• Clarify and implement the stormwater hierarchy for development/redevelopment projects, as specified in the City’s SWMM.

The stormwater hierarchy is used to determine the ultimate discharge point for stormwater from a development/redevelopment site. It protects groundwater resources by requiring the use of onsite surface filtration facilities where practicable. Where infiltration at the ground surface is not possible, UICs may be used, along with the appropriate degree of pollution reduction (depending on the source of the stormwater runoff). The City is currently developing the 2007 SWMM, which will include revisions/ clarifications to the current hierarchy contained in the 2004 SWMM. Assignment: Bureau of Environmental Services, Portland Office of Transportation

• Evaluate the need to develop code restricting the conversion of existing irrigation wells to

drinking water wells to ensure adequate separation distance from public UICs. Assignment: Bureau of Environmental Services

• Evaluate the need to develop code restricting the installation of new private drinking

water wells or irrigation wells to ensure new drinking water and irrigation wells are not installed near public UICs. Assignment: Bureau of Environmental Services

• Work with the Bureau of Development Services and Oregon Department of

Environmental Quality (DEQ) to evaluate the review and approval process for UICs registered on private property. Assignment: Bureau of Environmental Services

• Work with the Bureau of Development Services and DEQ to develop consistent design

standards and guidance for UICs on private and public property. Assignment: Bureau of Environmental Services

Appendix B

Operations and Maintenance Plan



City of Portland, Oregon Water Pollution Control Facilities (WPCF) Permit For Class V Stormwater Underground Injection Control Systems Permit Number: 102830 Operations and Maintenance Plan Stormwater Underground Injection Control December 2006 Prepared By: City of Portland, Bureau of Environmental Services


Operations and Maintenance Plan Page i December 2006

TABLE OF CONTENTS

1 Introduction and Organization ...........................................................................1-1 1.1 Introduction.................................................................................................................. 1-1 1.2 Basis of O&M Plan...................................................................................................... 1-2 1.3 Regulatory Requirements............................................................................................. 1-2 1.4 O&M Plan Organization .............................................................................................. 1-3 1.5 Relationship to the UIC Management Plan and Other Permit Documents.................. 1-4

2 Goals and Objectives..........................................................................................2-1

2.1 Introduction.................................................................................................................. 2-1 2.2 Operations and Maintenance Goals ............................................................................. 2-1 2.3 Operations and Maintenance Objectives ..................................................................... 2-1

3 Development of UIC System Maintenance Targets and Schedules................3-1 4 Maintenance Practices for Sedimentation Manholes.......................................4-1

4.1 Facility Description...................................................................................................... 4-1 4.2 Typical Operation of Sedimentation Manhole............................................................. 4-1

4.2.1 Basic Purpose and Function................................................................................. 4-1 4.2.2 General Performance ........................................................................................... 4-1 4.2.3 Design Criteria ..................................................................................................... 4-1

4.3 Maintenance Targets and Schedule ............................................................................. 4-3 4.4 Inspection Procedure.................................................................................................... 4-4 4.5 Cleaning Procedure...................................................................................................... 4-4 4.6 Repair Procedure.......................................................................................................... 4-5

5 Maintenance Practices for UICs.........................................................................5-1

5.1 Facility Description...................................................................................................... 5-1 5.2 Typical Operation of UICs........................................................................................... 5-1

5.2.1 Basic Purpose and Function................................................................................. 5-1 5.2.2 General Performance ........................................................................................... 5-1 5.2.3 Design Criteria ..................................................................................................... 5-3

5.3 Maintenance Targets and Schedule ............................................................................. 5-3 5.4 Inspection Procedure.................................................................................................... 5-4 5.5 Cleaning Procedure...................................................................................................... 5-5 5.6 Repair Procedure.......................................................................................................... 5-5 5.7 Replacement................................................................................................................. 5-6 5.8 Decommissioning ........................................................................................................ 5-6

6 Other Maintenance Practices.............................................................................6-1

6.1 Street Sweeping ........................................................................................................... 6-1 6.2 Vector Control ............................................................................................................. 6-1

Operations and Maintenance Plan Page ii December 2006

7 Materials Management........................................................................................7-1

7.1 Overview...................................................................................................................... 7-1 7.2 Dewatering................................................................................................................... 7-1 7.3 Testing.......................................................................................................................... 7-2

7.3.1 Solids.................................................................................................................... 7-2 7.3.2 Decant .................................................................................................................. 7-2

7.4 Disposal and Reuse ...................................................................................................... 7-3 7.5 Ongoing Improvements ............................................................................................... 7-3

8 Recordkeeping ....................................................................................................8-1

8.1 Storm Manhole Inventory ............................................................................................ 8-1 8.2 Storm Manhole Inspection........................................................................................... 8-2 8.3 Maintenance Work Orders........................................................................................... 8-2

9 Other City Facilities and Drainage Systems .....................................................9-1

9.1 Soakage Trenches/Perforated Pipes............................................................................. 9-1 9.2 Drywells....................................................................................................................... 9-2 9.3 O&M for City Facilities............................................................................................... 9-2

10 Roles and Responsibilities...............................................................................10-1 Appendices A Vector Control Material Safety Data Sheets B Sample Work Orders C Maintenance Templates Tables 4-1 Sedimentation Manhole Maintenance………………………………………………….4-3 4-2 Target Work Calendar for Sedimentation Manhole Maintenance……………………..4-3 5-1 UIC Maintenance………………………………………………………………………5-3 5-2 Target Work Calendar for UIC Maintenance………………………………………….5-4 9-1 Other City Facilities with UICs………………………………………………………..9-1 10-1 Roles and Responsibilities for Operations and Maintenance……………………… 10-1 Figures 1-1 Typical UIC System Design……………………………………………………….…..1-1 4-1 Sedimentation Manhole Detail…………………………………………………….…. 4-2 5-1 Standard UIC Construction Design……………………………………………….….. 5-2 7-1 Inverness Dewatering Facility Plan Layout……………………………………….…..7-3

Operations and Maintenance Plan Page 1-1 December 2006

1 Introduction and Organization 1.1 Introduction This Operations and Maintenance Plan (O&M Plan) describes the inspection and maintenance, recordkeeping, and reporting protocols the City uses to manage public underground injection control systems (UICs) in the City of Portland. The O&M Plan is a requirement of the Water Pollution Control Facility (WPCF) permit issued to the City of Portland by the Oregon Department of Environmental Quality (DEQ) in June 2005. The City currently has an estimated 9,000 UICs that collect stormwater and discharge it to the subsurface. The majority of these UICs drain City rights-of-way in the eastern portion of the City, where the subsurface soils support greater stormwater drainage and infiltration rates. For many areas located east of the Willamette River, UICs are the only available form of stormwater disposal. Figure 1-1 illustrates a typical public UIC system. Some City parks, fire stations, police stations, and other properties also have private drywells and soakage trenches to infiltrate flows from impervious and pervious areas. UICs are an essential element of the City’s comprehensive watershed strategy to use stormwater as a resource by infiltrating it back into the ground. UICs quickly and efficiently reintroduce stormwater into subsurface soils, which filter and cool the runoff before it finds its way to groundwater and, eventually, helps recharge streams. UICs are an essential element of street-side swales and green street applications because they provide an overflow point during large storm events when stormwater cannot be fully infiltrated through swales, planters, or other surface infiltration systems. UICs also preclude the need to install or increase the capacity of piped stormwater infrastructure that eventually discharges into local surface water bodies, including Johnson Creek, the Columbia Slough, and the Willamette River. In the Portland area, groundwater serves as a backup drinking water supply to the Bull Run reservoirs. The WPCF permit establishes the UIC construction, operation, and maintenance requirements the City must implement to protect groundwater for use as a drinking water resource. The permit is designed to

Section

1 As used in this document, UIC means any Class V underground injection control system owned or operated by the City of Portland.

Figure 1-1 Typical UIC System Design


protect groundwater by implementing a comprehensive stormwater management strategy to prevent, minimize, and control pollutants at the surface before stormwater is discharged to the ground. The O&M Plan is an essential element of that strategy. 1.2 Basis of O&M Plan In 1997, the Bureau of Environmental Services (BES) developed a Surface Stormwater Facilities Maintenance Management Manual that provides detailed O&M practices and protocols for UICs and all other City storm and sanitary sewer infrastructure. This O&M Plan is based on the UIC sections of the 1997 manual, with updates incorporated to reflect current practices the City implements to effectively manage UICs and protect groundwater quality. This O&M Plan may be modified in the future, based on 1) annual compliance monitoring results 2) data obtained following compliance response actions, and/or 3) the results of BMP monitoring activities. All of these activities may provide data necessary to evaluate the relationship between traffic volumes, maintenance practices, and water quality. 1.3 Regulatory Requirements Congress enacted UIC rules in 1974 under the federal Safe Drinking Water Act (SDWA) and modified the rules in 1999. The U.S. Environmental Protection Agency (EPA) administers these rules under Title 40 of the Code of Federal Regulations (CFR) Parts 144 -148. In Oregon, EPA has delegated the regulation of UICs to DEQ. Oregon Administrative Rules (OAR) 340-044 regulate all groundwater as a potential source of drinking water and require municipalities with more than 50 UICs to operate under a permit. DEQ issued a WPCF permit to the City of Portland on June 1, 2005 (DEQ Permit Number 102830). Schedule D(1) of the WPCF permit requires the City to develop an O&M Plan to effectively manage public UICs. The O&M Plan must be designed and implemented in a manner that maximizes the effectiveness of the BMPs to meet the conditions of the permit. The O&M Plan must: • Provide documentation that supports maintenance intervals based on traffic volume and

patterns to track sediment levels and implement cleaning schedules accordingly to remove the accumulated sediment.

• Provide maintenance and inspection protocols. • Provide standardized maintenance and inspection logs to record maintenance activities.


1.4 O&M Plan Organization The O&M Plan is organized as follows: Section 1: Introduction and Organization, provides a brief description and purpose of the O&M Plan. It also summarizes relevant regulatory background information and permit requirements and describes the O&M Plan’s relationship to other permit requirements and documents. Section 2: Goals and Objectives, describes goals and objectives for the O&M Plan, as well as the City’s overall watershed goals. Section 3: Development of UIC System Maintenance Targets and Schedules, describes how the City prioritizes maintenance activities by setting targets for inspection and cleaning. Section 4: Maintenance Practices for Sedimentation Manholes, describes the City’s inspection, cleaning, and repair procedures for sedimentation manholes. Section 5: Maintenance Practices for UICs, describes the City’s inspection, cleaning, and repair procedures for UICs. It also discusses UIC replacement and decommissioning. Section 6: Other Maintenance Practices, describes the City’s street sweeping and vector control practices. Section 7: Materials Management, describes the City’s procedures for dewatering materials collected from UIC systems, testing solids and decanted liquids, and disposing of and reusing dewatered materials. Section 8: Recordkeeping, describes the City’s maintenance management system used to track and control UIC system inventory, inspection, and maintenance work orders. Section 9: Other City Facilities and Drainage Systems, addresses UICs found on City-held and operated properties, such parks, fire and police properties, and well areas. Section 10: Roles and Responsibilities, identifies the various staff positions involved with operations and maintenance and summarizes their responsibilities. Appendix A contains vector control material safety data sheets (related to Section 6). Appendix B contains sample work orders (related to Section 8). Appendix C contains maintenance templates (related to Section 9).

Sections 3 through 8 are relevant to UICs within public rights-of-way. Section 9 addresses UICs on other City properties (e.g., parks, fire stations, police stations).


1.5 Relationship to the UIC Management Plan and Other Permit Documents The City’s UIC Management Program comprises four major program elements: System Management, System Monitoring, Evaluation and Response, and Corrective Actions. The UIC Management Plan (UICMP) is the umbrella document that describes these four program elements and identifies the various documents the City has prepared to address specific program activities. The O&M Plan is a component of the System Management program element described in the UICMP. System Management includes best management practices (BMPs) that will be implemented to prevent, minimize, and control pollutants in stormwater prior to discharge to a UIC. Implementation of the O&M Plan is included in BMP OM-1: Implement operations and maintenance practices to remove and prevent pollutants from entering public UICs located in City-managed rights-of-way and on other City-owned property. As well as the activities currently implemented under the O&M Plan, OM-1 will serve to identify additional assessment or procedures that are needed throughout the life of the permit. In addition to the O&M Plan, other UIC program documents that have some relationship to operations and maintenance are: • UIC Registration Database (submitted September 1, 2005, and quarterly thereafter)

Includes repair and maintenance history for public UICs. • Stormwater Discharge Monitoring Plan (SDMP) (final submitted August 2006)

Describes the systemwide monitoring program that will be used to evaluate compliance with WPCF permit requirements and provide information regarding the effect of O&M and other systemwide activities on stormwater quality entering public UICs.

• Systemwide Assessment (submitted July 15, 2006)

Identifies UICs that should be evaluated to determine if adequate maintenance access exists for the UIC.

• Corrective Action Plan (submitted July 15, 2006)

Uses enhanced O&M as one option for addressing non-compliant conditions at a UIC. • BMP Monitoring Program (Appendix E of the UICMP)

Describes the BMP program that may be used to evaluate the relationships among factors that significantly affect stormwater quality, such as traffic volume, maintenance practices and frequency, and pollutant sources.


2 Goals and Objectives 2.1 Introduction The mission of the Bureau of Environmental Services is to:

• Protect the quality of surface and groundwater and conduct activities that promote healthy ecosystems in our watersheds, and

• Provide sewage and stormwater collection and treatment services to accommodate Portland’s current and future needs.

For many areas located east of the Willamette River, UICs are the only form of stormwater disposal available. UICs are also an essential element of a comprehensive watershed strategy to use stormwater as a resource by infiltrating it back into the ground. This section discusses the role the O&M Plan will play in ensuring that UICs continue to play an integral role in carrying out the bureau’s mission. 2.2 Operations and Maintenance Goals The primary goals of the O&M program are to: 1. Operate and maintain UICs as needed to serve as a critical component of the City’s

stormwater management infrastructure. 2. Operate and maintain UICs in a manner that meets the requirements of the WPCF and

protects groundwater quality for use as a drinking water resource. 3. Ensure that UICs contribute to achieving watershed goals established in the Portland

Watershed Management Plan (City of Portland 2005) and the Framework for Integrated Management of Watershed Health (City of Portland December 2005).

2.3 Operations and Maintenance Objectives The following UIC O&M objectives are based on the goals identified in the 1997 Surface Stormwater Facilities Maintenance Management Manual: 1. Protect the community’s investment in the sewer collection and stormwater management

facilities. A scheduled maintenance program will maximize the useful life and capacity of the sewer collection and stormwater management facilities.

2. Protect water quality. Adequate maintenance of stormwater management facilities will

minimize the discharge of pollutants and sediments from those facilities to receiving waters. 3. Provide for the public’s health and safety. A scheduled maintenance program will help meet

requirements of the permit, protect groundwater as a drinking water resource, and reduce potential hazards to the public.

Section

2


4. Protect fish and wildlife habitat. Maintenance procedures implemented with environmental awareness will help reduce negative impacts to fish, wildlife, and the environment.

5. Increase operational reliability and protect against flooding and system backups. Facilities

maintained to convey the design flows will minimize the potential for system backups and localized flooding.

6. Provide cost-effective operation and maintenance. Routine preventative maintenance will

help avoid costly emergency repair tasks and the damage that may result from system failures.

7. Provide effective customer service. Customer service activities performed in a timely matter will help reduce hazards to the public and minimize claims against the City.


3 Development of UIC System Maintenance Targets and Schedules

The City prioritizes maintenance activities based on the amount of sediment accumulated within a sedimentation manhole or UIC. The maintenance targets were developed based on standard citywide sediment accumulation rates, rather than on specific traffic counts or volumes. The targets are intended to minimize potential resuspension of collected materials and localized flooding resulting from system failure. Additional City maintenance activities, such as street sweeping, do account for differing traffic loads. (See Section 6.1: Street Sweeping). Adjustments to maintenance intervals and practices will be based on 1) annual compliance monitoring results, 2) data obtained following compliance response actions, and/or 3) the results of BMP monitoring activities. All of these activities may provide data necessary to evaluate the relationships among traffic volumes, maintenance practices, and water quality. Initial accumulation rates for sedimentation manholes and UICs are based on field observations and sediment removal history of approximately 700 facilities between 1996 and 2001. Although sediment accumulation is highly variable, an estimated average is used for work scheduling and budgeting. Based on the data obtained between 1996 and 2001, the current maintenance schedule assumes an average accumulation rate of 0.5 foot of sediment per year. Sediment accumulation depths continue to be measured and recorded prior to cleaning each UIC. These field-measured values are used to refine the initial estimated accumulation rates and to develop localized or site-specific cleaning cycles. Maintenance (inspection and cleaning) is currently targeted at the following sediment accumulation thresholds:

System Type/Area Amount of Sediment Accumulation

Sedimentation manholes 2.0 feet * UICs without sedimentation manholes 5.0 feet

*The City makes every effort to adhere to this schedule to preclude the need to clean the UIC itself.

The maintenance threshold is set at 2.0 feet of sediment for standard sedimentation manholes (with a 10-foot average construction depth) and 5.0 feet of sediment for UICs that do not have sedimentation manholes. Maintenance of UICs with sedimentation manholes is scheduled based on the 2.0 foot target for expected accumulation in the sedimentation manhole. By routinely maintaining the sedimentation manhole, the UIC will generally require very little maintenance. Specific individual UICs and sedimentation manholes may be maintained on alternative schedules, based on evidence of accumulation rates higher than the average or as a response to a materials release or drainage complaint inspection.

Section

3


Estimated sediment accumulation rates are paired with field-measured accumulation rates to establish 2-year, 4-year, or 6-year maintenance cycles. The length of the cycle is generally shorter (2-year or 4-year cycles) for sedimentation manholes and UICs in areas where sediment accumulates rapidly (e.g., major arterials with high traffic counts or areas with a high tree density) and longer (4-year or 6-year cycles) for sedimentation manholes and UICs that accumulate sediment at a slower rate. Access to some Multnomah County UICs is obstructed by pavement, and they do not fit into this standard schedule. These UICs have been identified for evaluation and will be rehabilitated or decommissioned as needed.


4 Maintenance Practices for Sedimentation

Manholes 4.1 Facility Description Sedimentation manholes are typically installed upstream of UICs. The sedimentation manholes are used to trap sediment from stormwater runoff before it discharges into a UIC. Most sedimentation manholes are made of standard precast reinforced concrete, with an interior diameter of 48 inches. The depth is variable, but most are 10 feet deep or less. Sedimentation manholes can also be placed in series to provide enhanced treatment of runoff before it is discharged to the UIC. Figure 4-1 shows a typical sedimentation manhole. 4.2 Typical Operation of Sedimentation Manhole

4.2.1 Basic Purpose and Function The primary purpose of a sedimentation manhole is to remove particulates (e.g., sand and silt) from stormwater runoff before the stormwater is discharged into a UIC. If the sediment is not removed, it eventually will clog the coarse gravel layer in the UIC and reduce the infiltration capacity.

4.2.2 General Performance Stormwater should be able to pass unrestricted into the sedimentation manhole. The storage volume in the manhole should be sufficient to minimize resuspension of materials in the sedimentation manhole. Dense granular material will settle out of the stormwater if turbulence in the manhole is minimized. The facilities are not as effective at removing fine suspended solids. Sedimentation manhole performance (i.e., the ability of the facility to trap sediment) will vary throughout the City. The variability is a result of many factors, including structure depth; particle size; sediment loading rates, which are dependent on the soil erodability potential and quantity of construction in the area; localized amounts and types of debris (e.g., organic matter and trash); and maintenance frequency. These factors are addressed through regularly scheduled maintenance activities.

4.2.3 Design Criteria Most sedimentation manholes are constructed using a standard design. The standard diameter is 4 feet, the standard depth is 10 feet, and the standard average sediment accumulation capacity is 6 feet in depth. A 90-degree inverted elbow on the outlet pipe helps prevent floating material (e.g., oil and debris) from passing into the UIC.

Section

4


Figure 4-1: Sedimentation Manhole Detail


4.3 Maintenance Targets and Schedule The primary maintenance function associated with sedimentation manholes is the periodic removal of sediment. Maximum performance of the facility can be realized with proper control of the sediment depth in the manhole. If the sediment level is allowed to get too high, turbulence from incoming stormwater may resuspend fine particulate material and allow it to discharge to the UIC. As discussed in Section 3, the maintenance threshold is set at 2.0 feet of sediment accumulation for standard sedimentation manholes, and most sedimentation manholes are placed on 2-year, 4-year, or 6-year maintenance cycles, based on historic sedimentation accumulation rates. Table 4-1 summarizes the primary maintenance activities and targets for sedimentation manholes.

Table 4-1 Sedimentation Manhole Maintenance

Facility Component

Maintenance Activity

Minimum Maintenance Target Expected Facility Performance

Sedimentation Manhole

Remove sediment.

Accumulation of approximately 2.0 feet of sediment.

Sediment removed; sedimentation manhole operates at maximum performance level.

90-degree Inverted Elbow

Repair/replace inverted elbow

as needed.

Inverted elbow missing or broken and may allow passage

of floating material.

Inverted elbow repaired: floating material is trapped in

manhole. Maintenance activities are conducted throughout the year. Typically, one BOM maintenance crew and vactor (vacuum) truck is working year-round to maintain UICs and sedimentation manholes. Cleaning is generally performed when the manhole is not in use— i.e., with little or no incoming stormwater to the manhole. For this reason, maintenance performed by this crew is scaled back in the fall and winter (October–May) during periods of moderate to heavy rainfall. This minimizes the amount of truck space filled by water, allowing more sedimentation manholes and UICs to be cleaned before the truck needs to be emptied at the Inverness dewatering facility. From late May through September, a second maintenance crew and vactor truck is activated to increase maintenance during dry-weather conditions. Table 4-2 shows the recommended timing of inspection and cleaning activities.

Table 4-2 Target Work Calendar for Sedimentation Manhole Maintenance

TARGET WORK CALENDAR SUMMER AUTUMN WINTER SPRING

JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUNE Inspection XXXX XXXX XXX XX X X X X X XX XXX XXXX Cleaning XXXX XXXX XXX XX X X X X X XX XXX XXXX Notes: Annual maintenance activities are divided into 13 equal time periods that coincide with the fiscal year. X = Target inspection and cleaning calendar: X = low, XX = medium, XXX = high, XXXX = very high


4.4 Inspection Procedure Bureau of Maintenance (BOM) cleaning staff conduct routine inspections immediately before cleaning begins, as part of normal preventive maintenance. Additional inspections may be conducted based on complaints, spill responses, or referrals from other City staff; BES Condition Assessment Team (CAT) staff performs these non-routine inspections. All inspections include the following criteria (which cover both manholes and UICs): 1. Pollution Presence

Visually inspect accumulated sediments and ponding waters within the manhole to assess at a gross level whether pollutant contamination is suspected. Staff look for evidence of sheens and odors that might be characteristic of illegal disposal (e.g., paint, oil, automotive fluids). If contamination is suspected, staff from BES Spill Protection-Citizen Response (SPCR) team visit the site to assess whether a specialized hazardous materials contractor is needed to clean out the UIC.

2. Water/Sediment Levels Measure and record water and sediment levels before and after cleaning operations. Staff also assess whether the system is functioning properly. Sedimentation manholes should hold water between storms, while UICs should be dry except for the bottom section that is not perforated. Staff also look for evidence of surcharge, which indicates the system is not adequately handling larger events.

3. Physical Condition Assess the manholes for structural integrity. Staff inspect for defects in the surrounding street surface (cavities), lid, riser rings, walls, pipe connections, and inverted outlets (sedimentation manholes only). Problems that need to be addressed are slated for corrective maintenance or repair.

The City’s maintenance procedures for sedimentation manhole inspection are shown on pages 4-7 and 4-8. These procedures are updated from the 1997 Surface Stormwater Facilities Maintenance Management Manual. 4.5 Cleaning Procedure The City’s cleaning procedure is based on the assumption that adequate cleaning of pretreatment devices, such as sedimentation manholes, prolongs or diminishes the need to clean the UICs themselves. Cleaning is aimed at restoring the sedimentation manhole to 100 percent of the designed treatment and storage capacity. The primary goal is to clean facilities as needed to treat stormwater and prevent clogging of the UIC.

The primary cleaning activity is sediment removal. Vacuum excavation trucks are used to remove sediment, oils, floatables, and stormwater present in the manhole. In addition, inlet leads and pipes are pressure washed and vacuumed out as needed. BOM conducts most of the routine maintenance of sedimentation manholes. Both solid and ponding liquids removed by BOM go to the City’s Inverness dewatering facility for materials processing (see Section 7). Some


independent contract services are used for spill response and specialized maintenance efforts. Those materials are processed through industrial waste treatment sites under permit by the City’s pretreatment program. The City’s maintenance procedures for sedimentation manhole cleaning are shown on pages 4-9 and 4-10. These procedures are updated from the 1997 Surface Stormwater Facilities Maintenance Management Manual. 4.6 Repair Procedure Repair usually occurs when there is a structural defect within the system or when new street grades require adjustment of the lid and lid frame. The commonly repaired UIC system components are: • Lids and lid frames, which become cracked or shift in soils and become misaligned. • Concrete rings and/or cones, which become cracked or shift in soils and become misaligned. • Inlet pipes, which shift in soils and become misaligned. • 90-degree inverted elbow fittings, which may break off from the outlet pipe draining to the

UIC. Shifting soils, vandalism, and breakdown of materials from age and wear cause the majority of repairs. Repairs are based on referrals by the BOM cleaning crew or the BES SOM team, or on citizen complaints. Repairs are performed by a specialized repair crew within BOM. Repairs of lids and frames, concrete rings and/or cones, and inlet pipes often include cutting of the street asphalt or concrete surface and excavation around the sedimentation manhole. Removal of concrete manhole sections, backfill, and surrounding soils may also be needed. All backfill is replaced with clean backfill that is compacted in 18-inch lifts for weight-bearing purposes. Removed materials are disposed of with other construction material and debris at the BES Wastewater Treatment Plant. Street paving crews then restore the street surface. Concrete patches or grouting is sometimes used to seal holes and cracks in the facility or pavement. Ninety-degree inverted elbows usually require reattachment to the outlet pipe with grout, screws, or flange materials, depending on the type of elbow materials used. Over the last year, maintenance staff has replaced broken elbows with new snout or hood outlets, which seem to perform better and stay attached longer than the inverted elbows. The City’s maintenance procedures for sedimentation manhole repair are shown on pages 4-11 and 4-12. These procedures are updated from the Surface Stormwater Facilities Maintenance Management Manual 1997.


Class No. Code No. 1218 Utility Worker 2.3 2423 Dump truck, 1.5 C.Y. 1

2.3

Code

FlashlightMirrorGas detector

NOTES:

MAINTENANCE PROCEDURESEDIMENTATION MANHOLE INSPECTION

CENTER CODE:DATE: REV:

DESCRIPTION

Classification Description

Inspection of sedimentation manholes to measure the depth of the sediment collected in the manhole and to determine the structure and operational condition of the facility. Use inspection and condition assessment tools to define the nature of defects.

Functioning units should trap oil, grease, sediments and other debris before the material reaches downstream infiltration sumps. * Manhole covers should be in place and in good condition. * Sediments should be removed from the manholes to prevent the sediments and debris from reaching and blocking downstream sumps.

Safety Issue: Protective Clothing and EquipmentChecking for Hazardous AtmospheresLiftingUnderground InstallationsTraffic Safety

Hazardous Situation:Confined SpacesVehicle Operation

MAINTENANCE GOAL

SAFETY ISSUES AND HAZARDOUS SITUATIONS (1)

TYPICAL CREW TYPICAL EQUIPMENT

Standard Crew SizeTYPICAL MATERIALS

TYPICAL DAILY ACCOMPLISHMENT12-20 units

(1) This list may not include all of the potential hazards associated with work in and around sedimentation manholes. When in doubt on how to proceed in a given situation, contact your immediate supervisor.

DescriptionInspection rod


JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAYXXXX XXXX XXX XX X X X X X XX XXX

Note: Annual maintenance activities are divided into 13 equal time periods that coincide with city fiscal year.

Bureau ManagerSupervisor Routine Supervisor Opn Manager

WORK CALENDAR

LEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVED

JUNXXXX

9. Report: * Number of sedimentation manholes inspected. * Significant evidence of pollution. * Types of defects observed.

2. Any work in roadways requires isolation of one or more lanes of traffic. Work immediately adjacent to roadways that potentially exposes an employee to traffic injuries also requires isolation of one or more lanes of traffic.

3. Follow confined space entry policy and procedures before entering the manhole.

4. Check that: * The cover is accessible. * The cover is in place in in good condition. * All bolts are in place. * The cover locks properly. * The cover is not difficult to remove.

5. Measure the sediment (in inches) in the manhole. Record depth to top of sediment from invert of inlet pipe. 6. Visually inspect for debris.

7. Note any particular structure problems at the manhole. Note any visual evidence of pollution or unusual odors. 8. NA

6. Check for plugging of the manhole inlet or outlet (leads to the infiltration sump). 7. Make notes for cleaning and repair of the sedimentation manhole

8. When the job is completed, remove the traffic safety devices and move 9. Report the work completed

2. Place traffic safety devices as needed prior to inspection of the sedimentation manhole.

3. Test the manhole for a hazardous atmosphere. Examine area for signs of pollution. 4. Inspect the manhole and cover. Use inspection and condition assessment tools to report defects.

5. Check the amount of sediment in the manhole.

Action Response/Remark1. Drive to the designated area. 1. Follow the normal inspection routes.

MAINTENANCE PROCEDURESEDIMENTATION MANHOLE INSPECTION


Class No. Code No. 1218 3 3257 11325 1 2423 1

4

Code

NOTES:

VactorDump truck, 1.5 C.Y.

NA 3 - 5 units (depends on sediment loading)

(1) This list may not include all of the potential hazards associated with work in and around sedimentation manholes. When in doubt on how to proceed in a given situation, contact your immediate supervisor. NA= Not applicable.

Crew SizeTYPICAL MATERIALS

Description TYPICAL DAILY ACCOMPLISHMENT


Sewer Vactor OperatorUtility Worker




Machine cleaning of sedimentation manholes with the Vactor truck to remove accumulated dirt, sand, and debris.MAINTENANCE GOAL

Sediments must be removed from the sedimentation manholes to prevent sediments and debris from reaching and blocking downstream sumps.


MAINTENANCE PROCEDURESEDIMENTATION MANHOLE CLEANING


DESCRIPTION




XXXXLEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVED

Supervisor Routine-Limited Supervisor Opn Manager Bureau Manager

WORK CALENDARJUN

10. Report the work completed. 10. Report: * Number of sedimentation manholes cleaned. * Amount of debris removed, in cubic yards. * Significant evidence of pollution.

8. Empty the holding tank on the Vactor when it is full. Dispose of material at approved facility.

8. Water and solids are hauled to the Inverness dewatering pad for disposal.

9. Clean and wash the inside of the Vactor at the end of the shift. 9. Follow the manufacturer's recommendations for maintenance of the Vactor equipment.

6. Make notes for repair or replacement of the sedimentation manhole. 6. The manhole cover should be in place and in good condition.

7. When the job is completed, stow the hoses, remove the traffic safety devices, and move to the next site.

7. NA

4. Test the manhole for a hazardous atmosphere. Examine area for signs of pollution.

4. Follow confined space entry policy and procedures before entering the manhole.

5. Use the Vactor to pump water and debris from the sedimentation manhole.

5. Note significant presence of pollution such as oil and grease, foam and unusual odors. Visually inspect for debris.

2. Drive to the designated area. 2. NA3. Place the traffic safety devices. 3. Any work in roadways requires isolation of one or more lanes of traffic. Work

immediately adjacent to roadways that potentially exposes an employee to traffic injuries also requires isolation of one or more lanes of traffic.

Action Response/Remark1. Check the operation and available capacity of the Vactor before leaving the maintenance building.

1. Start the rear engine to check for proper operation. Check the gear case and clamps on the Vactor pipe.

MAINTENANCE PROCEDURESEDIMENTATION MANHOLE CLEANING


Class No. Code No. 1218 2 2332 11316 1 2427 21230 1 5012 1

4

Code901890259030903590389040

NOTES:

Utility Worker

Sewer Construction Crew Leader

Pickup, Utility Body w/Hyd

Gravel, 1.5" minus - 1 CY 1-2 units


Concrete Grade Rings - 1 EachFlash - Sack

Flattop M Top - 1 Each Manhole Frame, 10" - 1 EachManhole Cover - 1 Each




Cons Equip. Operator II Dump Truck, 5-6 CYBackhoe, Small




Repair of sedimentation manholes. Activity includes installing new frames and covers to raise sedimentation manholes to match street grade. MAINTENANCE GOAL

To return sedimentation manhole to proper level of operation. Flow into manhole should not be restricted by broken or damaged inlet pipes, outlet pipes should be clear, and covers should not present safety hazard to public or vehicles.


MAINTENANCE PROCEDURESEDIMENTATION MANHOLE REPAIR


DESCRIPTION




LEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVEDSupervisor Routine-Limited Supervisor Opn Manager Bureau Manager

WORK CALENDARJUN

XXXX

8. When the job is complete, remove traffic control signs and devices. 8. NA

9. Report the work completed. 9. Report: * Number of stormwater sedimentation manholes repaired. * Significant evidence of pollution.

6. Place backfill and compact in 6 inch lifts. 6. Ensure that adequate compacting is provided. 7. Notify Street Paving Section of need for repaving. 7. NA

4. Test the stormwater sedimentation manhole for a hazardous atmosphere. Examine area for signs of pollution.

4. Follow confined space entry policy and procedures before entering the sedimentation manhole. Note any visual evidence of pollution or unusual odors. Visually inspect for debris.

5. Add new manhole section(s) and manhole frame (as required) to bring to grade. Repair inlet pipe as required. Patch manhole walls and replace steps as required.

5. Add appropriate number of sections to match street grade. Ensure that inlet and outlet pipes are clear and structurally sound.

2. Place traffic safety control signs and devices as needed prior to start of work.


3. To raise manhole and get access to outside of manhole - cut pavement, excavate and remove old manhole cover.

3. NA

Action Response/Remark1. Drive to the designated area. 1. NA

MAINTENANCE PROCEDURESEDIMENTATION MANHOLE REPAIR




5 Maintenance Practices for UICs 5.1 Facility Description UICs are cylindrical drywells used for subsurface infiltration of stormwater. UIC depths range between 10 and 30 feet, with the standard design depth being 30 feet. The UICs are typically made from a precast reinforced concrete cylinder with perforations (approximately 2 inches in diameter) in the sides of the UIC to allow exfiltration of stormwater into the surrounding soils. The UIC is constructed in sections that are approximately 3 feet high. The sections are grouted together as the UIC is installed. The perforations start approximately 2 feet above the concrete base of the UIC and extend to near the top of the 48-inch-diameter precast manhole sections. The 2-foot section without perforations at the bottom of the UIC acts as a sediment trap. Figure 5-1 shows the standard UIC construction design. 5.2 Typical Operation of UICs

5.2.1 Basic Purpose and Function UICs are used to infiltrate stormwater runoff into the soil. Stormwater disposal through UICs is an alternative to surface runoff discharging to a creek or stream. Percolation of the water through the soil helps recharge groundwater, provide base flow to surface waters, and limit piped discharges to local surface streams.

5.2.2 General Performance UICs retain stormwater so it can infiltrate into the underlying and surrounding soils. The rate of infiltration depends on the permeability of the surrounding soil. Sedimentation manholes are a recommended pretreatment that should be used to remove sediment from the stormwater prior to discharge to the UICs. If sediment is not prevented from entering the UIC, the sediment will reduce the infiltration efficiency and eventually clog the UIC. UIC performance will vary throughout the City. The variability is a result of many factors, including infiltration capacity of soil, structure depth, sediment loading rates, existence of an upstream sedimentation manhole, and maintenance frequency. Some of the older UICs within the City were constructed without a sedimentation manhole. These facilities will tend to have a sediment loading rate higher than that of UICs equipped with sedimentation manholes.

Section

5


Figure 5-1

Standard UIC Construction Design


5.2.3 Design Criteria As mentioned above, UICs vary in size and depth. The standard diameter is 48 inches and the standard depth 30 feet, but the depths may range from 10 to 30 feet. A clean 2-inch minus round drain rock is backfilled around the outer 18 inches surrounding the UIC. A porous soil is required for the UICs to be effective. A hydrologic soil type of A or B is recommended. UICs should not be constructed in areas that may be subject to spills that could contaminate the groundwater (e.g., industrial or commercial areas). 5.3 Maintenance Targets and Schedule The primary function of UICs are to retain surface runoff so the stormwater can infiltrate into the underlying and surrounding soils. To maintain maximum infiltration rates, sediment should be prevented from entering the UIC. Sedimentation manholes and established maintenance targets focus on keeping sediment loads to the UICs at a minimum. UICs will eventually require cleaning even if sedimentation manholes are used for pretreatment (sediment removal). As discussed in Section 3, the maintenance threshold is set at 5.0 feet of sediment accumulation for UICs that do not have sedimentation manholes. Maintenance of UICs with sedimentation manholes is scheduled using the 2.0 foot target for expected accumulation in the sedimentation manhole. By routinely maintaining the sedimentation manhole, the UIC will generally require very little maintenance. (See Section 4 for maintenance practices for sedimentation manholes.) Each UIC is placed on a 2-year, 4-year, or 6-year maintenance cycle, based on historic sedimentation accumulation rates. Table 5-1 summarizes the primary maintenance activities and targets for UICs.

Table 5-1 UIC Maintenance

Facility

Component Maintenance

Activity Minimum Maintenance Target Expected Facility

Performance UIC Remove

sediment. Accumulation of approximately

5.0 feet of sediment. Sediment removed;

sedimentation manhole operates at maximum performance level.

Sedimentation Manhole

See Section 4: Sedimentation Manholes.

Maintenance activities are conducted throughout the year. Typically, one BOM maintenance crew and vactor truck is working year-round to maintain UICs and sedimentation manholes. Cleaning is generally performed when the manhole is not in use— i.e., with little or no incoming stormwater to the manhole whenever possible. For this reason, maintenance performed by this crew is therefore scaled back in the fall and winter (October – May) during periods of moderate to heavy rainfall. This minimizes the amount of truck space filled by water, allowing more sedimentation manholes and UICs to be cleaned before the truck needs to be emptied at the Inverness dewatering facility. From late May through September, a second maintenance crew


and vactor truck is activated to increase maintenance during dry-weather conditions. Table 5-2 shows the recommended timing of inspection and cleaning activities.

Table 5-2 Target Work Calendar for UIC Maintenance

TARGET WORK CALENDAR SUMMER AUTUMN WINTER SPRING

JUL AUG SEP OCT NOV DEC JAN FEB MAR APR MAY JUNE Inspection XXXX XXXX XXX XX X X X X X XX XXX XXXX Cleaning XXXX XXXX XXX XX X X X X X XX XXX XXXX Notes: Annual maintenance activities are divided into 13 equal time periods that coincide with the fiscal year. X = Target inspection and cleaning calendar: X = low, XX = medium, XXX = high, XXXX = very high 5.4 Inspection Procedure BOM cleaning staff conduct routine inspections immediately before cleaning begins, as part of normal preventive maintenance. Additional inspections may be conducted based on complaints, spill responses or referrals from other City staff; BES Stormwater Operations and Maintenance (SOM) staff performs these non-routine inspections. All inspections include the following criteria (which cover both manholes and UICs): 1. Pollution Presence

Visually inspects accumulated sediments and ponding waters within the manhole to assess at a gross level whether pollutant contamination is suspected. Staff look for evidence of sheens and odors that might be characteristic of illegal disposal (e.g., paint, oil, automotive fluid). If contamination is suspected, Staff from the BES Spill Protection-Citizen Response (SPCR) team visit the site to assess whether a specialized hazardous materials contractor is needed to clean out the UIC.

2. Water/Sediment Levels Measure and record water and sediment levels before and after cleaning operations. Staff also assess whether the system is functioning properly. Sedimentation manholes should hold water between storms, while UICs should be dry except for the bottom section that is not perforated. Staff also look for evidence of surcharge, which indicates the system is not adequately handling larger events.

3. Physical Condition Assess the manholes for structural integrity. Staff inspect for defects in the surrounding street surface (cavities), lid, riser rings, walls, pipe connections, and inverted outlets (sedimentation manholes only). Problems that need to be addressed are slated for corrective maintenance or repair.

The City’s maintenance procedures for UIC inspection are shown on pages 5-7 and 5-8. These procedures are updated from the 1997 Surface Stormwater Facilities Maintenance Management Manual.


5.5 Cleaning Procedure The City’s cleaning procedure is based on the assumption that adequate cleaning of pretreatment devices, such as sedimentation manholes, prolongs or diminishes the need to clean the UICs themselves. Cleaning is aimed at restoring the UIC system to 100 percent of the designed storage and infiltration capacity. Although storage capacity can be restored, exfiltration capacity into the surrounding native soils cannot. The primary goal is to clean facilities as needed to treat stormwater and prevent clogging of the UIC. Maintenance can prolong the life of the facility, but not indefinitely. If a facility becomes clogged and does not drain properly even after maintenance, additional UICs may be added in series to manage stormwater flows. The UIC may also be decommissioned and replaced with a new UIC system or alternative stormwater management system. The primary cleaning activity for UICs is sediment removal. Vacuum excavation trucks are used to remove sediment, oils, floatables, and stormwater present in the UIC. In addition, inlet leads and pipes are pressure washed and vacuumed out as needed. BOM conducts most of the routine maintenance of UICs and sedimentation manholes. Both solid and ponding liquids removed by BOM go to the City’s Inverness dewatering facility for materials processing (see Section 7). Some independent contract services are used for spill response and specialized maintenance efforts. Those materials are processed through industrial waste treatment sites under permit by the City’s pretreatment program. The City’s maintenance procedures for UIC cleaning are shown on pages 5-9 and 5-10. These procedures are updated from the 1997 Surface Stormwater Facilities Maintenance Management Manual. 5.6 Repair Procedure Repair usually occurs when there is a structural defect within the system or when new street grades require adjustment of the lid and lid frame. The commonly repaired UIC components are: • Lids and lid frame, which become cracked or shift in soils and become misaligned. • Concrete rings and/or cones, which become cracked or shift in soils and become misaligned. • Inlet pipes, which shift in soils and become misaligned. Shifting soils, vandalism, and breakdown of materials from age and wear cause the majority of repairs. Repairs are based on referrals by the BOM cleaning crew or the BES Stormwater SOM team, or on citizen complaints. Repairs are performed by a specialized repair crew within BOM. Repairs of lids and frames, concrete rings and/or cones, and inlet pipes often include cutting of the street asphalt or concrete surface and excavation around the sedimentation manhole. Removal of concrete manhole sections, backfill, and surrounding soils may also be needed. All


backfill is replaced with clean backfill that is compacted in 18-inch lifts for weight-bearing purposes. Removed materials are disposed of with other construction material and debris at the BES Wastewater Treatment Plant. Street paving crews then restore the street surface. Concrete patches or grouting is sometimes used to seal holes and cracks in the facility or pavement. The City’s maintenance procedures for UIC repair are shown on pages 5-11 and 5-12. These procedures are updated from the Surface Stormwater Facilities Maintenance Management Manual 1997. 5.7 Replacement UICs should operate to the design standard of two times the flow of the design storm for the area (which is usually the 2-year storm event). When a UIC is unable to keep up with storm event flow, surcharging occurs, sometimes resulting in local street flooding. When this is discovered during inspection or reported in a complaint call, the first response is to clean the involved UIC system with a vacuum truck. If surcharging continues to occur after cleaning, actions are taken to repair or replace the system. An additional UIC may be installed in series downstream of the original UIC to augment disposal capacity. If UICs installed in series will not adequately infiltrate storm flows, the existing UIC(s) are decommissioned and replaced with a new, standard UIC and sedimentation manhole. BOM staff performs most minor replacement operations such as outlet pipe replacement and concrete crack sealing. When replacement costs exceed $50,000, the services are contracted out and managed by the BES Maintenance Engineering Division or the BES Engineering Services Group. 5.8 Decommissioning Decommissioning can occur if a UIC does not adequately infiltrate storm flows. Decommissioning activities will be conducted in accordance with the City’s Decommissioning Procedure (Final) for Underground Injection Control Facilities (2006). (See Appendix D of the UICMP.)


Class No. Code No. 1218 2.3 2423 1

2.3

Code

NOTES:

MAINTENANCE PROCEDUREUIC INSPECTION


DESCRIPTIONInspection of the UIC to measure the depth of the sediment collected in the UIC and to check for possible plugging of the stormwater infiltration sump inlet with debris. Use inspection and condition assessment techniques to record defects.

MAINTENANCE GOALFunction units which allow infiltration of the stormwater. * Covers should be in place and in good condition. * The UIC should not be clogged with excessive amounts of sediment. Inspection is used to assure efficiency of the Vactor crew in cleaning






Dump truck, 1.5 C.Y. Utility Worker


Description TYPICAL DAILY ACCOMPLISHMENTInspection rod 12 - 20 units


FlashlightGas detectorRescue gearMirror




XXXX

MAINTENANCE PROCEDUREUIC INSPECTION

Action Response/Remark1. Drive to the designated area. 1. Follow the normal inspection routes. 2. Place traffic safety devices as needed prior to inspection of the UIC. 2. Any work in roadways requires isolation of one or more lanes of traffic. Work


3. Test the UIC for a hazardous atmosphere. Examine area for signs of pollution.

3. Follow confined space entry policy and procedures before entering the UIC.

4. Inspect the UIC and cover. Use inspection and condition assessment procedures to report defects.

4. Check that: * The cover is accessible. * Check that the UIC cover is in place and in good condition. * All bolts and locks are in place. * The cover locks properly. * The cover is not difficult to remove.

5. Check the amount of sediment in the UIC. 5. Measure the depth of sediment. Record the distance from inlet to top of sediment. Cleaning is needed if more than 50 percent of the available storage is filled with sediment.

6. Check for plugging of the UIC inlet. 6. Visually inspect for debris. 7. Make notes for cleaning and repair of the UIC. 7. Note any particular structural problems at the UIC. Note visual evidence of

pollution or unusual odors. Report all problems immediately for follow-up action.

8. When the job is completed, remove the traffic safety devices and move 8. NA9. Report the work completed. 9. Record:

* Quantity of debris removed. * Significant evidence of pollution. * Types of defects observed.

Supervisor Routine Supervisor Opn Manager Bureau ManagerLEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVED

WORK CALENDARJUN


Class No. Code No. 1218 3 3257 11325 1 2423 1

4

Code

NOTES:

VactorDump truck, 1.5 C.Y.

NA 3 - 5 units

(1) This list may not include all of the potential hazards associated with work in and around sedimentation manholes. When in doubt on how to proceed in a given situation, contact your immediate supervisor. NA= Not applicable.




Sewer Vac OperatorUtility Worker




Machine cleaning of UIC with the Vactor to remove accumulated dirt, sand, and debris. MAINTENANCE GOAL

Sediment and debris removal to maintain the infiltration capacity of the UIC. * Sediments must be removed to prevent sediments and debris from block the UIC.


MAINTENANCE PROCEDUREUIC CLEANING


DESCRIPTION



Note: Annual maintenance activities are divided into 13 equal time periods that coincide with the fiscal year.

Action Response/Remark1. Check the operation and available capacity of the Vactor before leaving the maintenance building.

1. Start the rear engine to check for proper operation. Check the gear case and clamps on the Vactor pipe.

2. Drive to the designated area 2. NA3. Place traffic safety devices. 3. Any work in roadways requires isolation of one or more lanes of traffic. Work


4. Test the UIC for a hazardous atmosphere. Examine area for signs of pollution.

4. Follow confined space entry policy and procedures before entering the UIC. Note any visual evidence of pollution or unusual odors.

5. Follow vactor manufacturer guidelines to pump water and debris from the stormwater infiltration sump. Closely monitor the level of accumulating material in the holding tank (see #9).

5. Note any significant signs of pollution, such as oil and grease, foam and unusual odors.

6. Follow vactor manufacturer guidelines to flush the UIC. 6. Visuall inspect for debris.

7. Make notes for repair or replacement of the UIC. 7. The UIC cover should be in place and in good condition.

8. When the job is completed, stow the hoses, remove the traffic safety devices, and move to the next site.

8. NA

9. Empty the holding tank on the Vactor when it is full. 9. Water and solids are hauled to the Inverness dump site and dewatering facility for disposal.

10. Clean and wash the inside of the Vactor at the end of the shift. 10. Follow the manufacturer's recommendations for maintenance of the Vactor equipment.

11. Report the work completed. 11. Record: * Number of UICs cleaned. * Amount of debris removed, in cubic yards. * Significant signs of pollution.

WORK CALENDARJUN

Routine-Limited Supervisor Opn Manager Bureau ManagerLEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVED

Supervisor

XXXX


Class No. Code No. 1218 Utility Worker 2 2332 Pickup, Utility Body w/ Hyd 11316 1 2427 Dump Truck, 5-6 C.Y. 21230 Sewer Construction Crew Leader 1 5012 Backhoe, Small 1

4

Code90189025 Flash - 1 Sack9030 Concrete Grade Rings - 1 Each9035 Flattop MN Top - 1 Each (traffic-rated) 9038 Manhole Frame, 10" - 1 Each (traffic-rated)9040 Manhole cover - 1 Each (traffic-rated)

NOTES:

MAINTENANCE PROCEDUREUIC REPAIR


DESCRIPTIONRaise and repair of infiltration sumps. Activity includes installing new frames, covers, sump rings and/or cones to raise infiltration sumps to match street grade, or to restore structural integrity.

MAINTENANCE GOALTo return infiltration sump to proper level of operation. Flow into sump should not be restricted by broken or damaged inlet pipes and covers should not present safety hazard to public or vehicles.

SAFETY ISSUES AND HAZARDOUS SITUATIONS (1)Safety Issue: Protective Clothing and EquipmentChecking for Hazardous AtmospheresLiftingUnderground InstallationsTraffic Safety


TYPICAL CREW TYPICAL EQUIPMENTClassification Description

Cons. Equip. Operator II


Description TYPICAL DAILY ACCOMPLISHMENTGravel, 1.5" minus - 1 C.Y. 1 - 2 units




Note: Annual maintenance activities are divided into 13 equal time periods that coincide with the fiscal year.

JUNXXXX

1. Review repair order, pick up necessary tools, materials and equipment and drive to the designated area.

1. NA

2. Place traffic safety devices as needed prior to inspection of the stormwater infiltration sump.


3. To raise sump and get access to outside of sump - cut pavement, excavate and remove old sump cover.

3. Saw cut and break pavement activities are defined by separate maintenance procedure.

4. Test the stormwater infiltration sump for a hazardous atmosphere. Examine area of signs of pollution.

4. Follow confined space entry policy and procedures before entering the stormwater infiltration sump. Note any visual evidence of pollution or unusual odors. Visually inspect for debris.

5. Add new manhole section(s) and manhole frame (as required) to bring to grade. Repair inlet pipe as required.

5. Add appropriate number of sections to match street grade. Ensure that inlet pipe is clear and structurally sound.

6. Place backfill and compact in 6 inch lifts. 6. Ensure that adequate compaction is provided. 7. Notify Street Paving Section of need for repaving. 7. NA8. When the job is complete, remove traffic controls signs and devices. 8. NA

9. Report the work completed. 9. Record: * Stormwater infiltration sump repaired. * Significant evidence of pollution.

WORK CALENDAR

LEVEL OF CONTROL TYPE OF CONTROL PROCEDURE APPROVEDSupervisor Routine-Limited Supervisor Opn Manager Bureau Manager


6 Other Maintenance Practices 6.1 Street Sweeping Part of the City’s UIC maintenance program involves preventing pollution from entering UIC systems by using non-structural measures such as public education, solid waste disposal, and technical assistance for commercial and industrial enterprises. Perhaps the most directly linked non-structural pollution prevention measure is the City’s street sweeping program. Street sweeping protects water quality, prevents physical damage to pavements, and minimizes the burden on the sewer system from surface debris. The street sweeping program annually sweeps approximately 600 street miles (1200 curb miles) for rights-of way drained by UICs. That equates to sweeping all arterials 12 times a year and all residential streets 7 times a year. The City of Portland sweeps only streets with curbs. This policy was initiated after a 1979 street cleaning study found that 97 percent of street debris lies within 40 inches of the curb. The accumulation of debris at the curb is caused by the design of the street and by vehicular movement. Streets are designed with a crown in the middle sloping toward the sides. Water and debris move toward the curb and gutter areas. Vehicle movement scatters debris to the edges of traffic lanes. Streets with no curbs are affected by the same factors as curbed streets; with no curb, however, the debris is dispersed onto areas adjacent to the paved surfaces. Uncurbed streets are, in effect, self-cleaning, with materials collecting in the roadway shoulder sections or ditches, which are cleaned under separate City programs. 6.2 Vector Control Because of increasing concerns about vector-borne diseases, such as West Nile, the City expanded its contract with the Multnomah County Health Department in 2003 to abate mosquitoes in UIC systems. The City had previously contracted for mosquito tracking and larvacide application for surface water facilities; the expanded contract adds UICs and sedimentation manholes to the facilities needing mosquito abatement. County staff add S-Methoprene, an insect growth hormone, to sedimentation manholes during summer months to prevent larvae from hatching. The S-Methoprene pellet or briquette (Altosid®) is suspended in a small hammock-type brace. (See Appendix A for the materials safety data sheet.) Runoff entering the sedimentation manhole flows across the pellet, releasing the larvacidal agent into the UIC system. The pellets are non-toxic to non-target aquatic and terrestrial animals and insects. A second application is sometimes used in dry years to prevent adult mosquito emergence for approximately 90 days. After approximately 90 days, additional control (Bacillus sphaericus or B. thuringiensis var. israelensis (Bti) in various formulations) is applied to the sedimentation manholes where stagnant water remains (Vectobac® and Vectolex® products). (See Appendix A for the material safety data sheets.) These Bacillus species are naturally occurring soil bacteria that specifically

Section

6


target immature mosquitoes and some flies. All products have been tested and approved for use in open waterway applications.


7 Materials Management 7.1 Overview BES makes every effort to reuse the 2,000 tons (1,440 cubic yards) of materials collected from UICs and sedimentation manhole systems every year. These materials are typically 90 percent water by weight. Once materials are collected with a vactor truck, they are transported to the City’s Inverness dewatering facility for processing. An independent contractor hauls the dewatered materials offsite for reuse as daily cover a DEQ permitted landfill. 7.2 Dewatering

The Inverness dewatering facility is designed to manage and control materials removed from the City’s stormwater system including the UICs and sedimentation manholes.. As seen on Figure 7-1, the facility includes two dewatering pads. Each pad has two sides: an east and a west unit. The newer pad, built in 1999, has enhanced pretreatment and is used as the primary dewatering location. Solids are deposited on the east unit first until it is full (usually about 150 to 160 cubic yards of material), then on the west unit. Solids dewater over a period of a few days to a few weeks, depending on weather conditions and the consistency of the materials. When a unit is full, barricades are placed across the front to prohibit overtopping of the unit. When the west side is almost full, material on the east side is moved to a cell on the older pad for final drying. The total drying process between both pads usually takes 2 to 3 weeks. Front loaders may be used to turn materials to facilitate drying. As materials dewater, the decanted liquids are collected, treated, and monitored prior to batch discharge as a process wastewater into the City’s sanitary sewer system. The decanted liquids are routed through a series of troughs, catch basins, and three sedimentation manholes in series before being collected in an onsite holding tank. The decant tank has two cells; the north chamber free-flows into the south chamber, which has a vertical drain tube set at 3 feet high. The drain tube provides emergency overflow and acts as a gauge for staff to estimate the gallons of decant collected. It usually takes 6 to 7 days of dewatering materials to fill the decant tank to the top of the discharge tube, necessitating a batch discharge request from the BES Source Control Division. The northern cell is cleaned when more than 4 inches of sludge has settled. The entire dewatering facility area is swept to collect materials spilled in the transfer process. In addition, the sedimentation manholes used for retreating the decant discharge are cleaned when 1 foot of their 2-foot capacity is filled. The frequency of cleaning the manholes varies, depending on the workload and the drying rate of materials already on the pad.

Section

7


7.3 Testing

The primary purpose of testing is to characterize the materials to assure appropriate management and disposal of both solids and liquids. Representative samples of both the solids and liquids are collected and submitted to the City’s Water Pollution Control Laboratory for analytical testing using appropriate testing methods. The results are used to for profiling the materials for disposal at approved disposal facilities. Solids testing is intended to comply with DEQ’s Solid and Hazardous Waste regulations. The solids results are compared to Resource Conservation and Recovery Act (RCRA) disposal criteria, and the decant is judged on local limits and pretreatment standards for sanitary sewer disposal. These limits are established in Title 17.39 of City Code.

7.3.1 Solids The UIC and sedimentation manhole solids, often referred to as “collection system residuals,” are usually a combination of soils, with a high fraction of fines and lesser amounts of organic matter and trash. These materials traditionally have a contaminant profile that is characterized as petroleum-contaminated soils. On occasion, the sediment can contain heavy oils, polynuclear aromatic hydrocarbons (PAHs), volatile organic compounds, and metals. Solids testing results are generally compared to the protective residential soil cleanup levels to determine appropriate reuse or disposal methods. This testing information is important for ongoing maintenance efforts because it helps characterize the types of materials and pollutants normally found in sediments accumulating in UIC systems. The solids are normally tested once they reach the final drying stage on the old dewatering pad. A sample of solid materials is made on an as-needed basis (if the materials do not appear consistent with other fully characterized material loads). Representative samples are obtained by collecting numerous sub-samples throughout the pile and thoroughly mixing to create a composite. Sample aliquots are collected with a stainless steel hand auger and homogenized in a stainless steel bowl. Solids testing is performed to demonstrate compliance with Oregon Solid Waste and Hazardous Waste regulations.

7.3.2 Decant Decant liquid is stored in an onsite tank and is tested quarterly. The decant must meet pretreatment requirements established in City Code 17.39 before it is discharged to the City’s sanitary sewer. Decant is tested for the following parameters:

- pH, using a field meter - Total solids (SM 2540 B) - Total suspended solids (SM 2540 D) - Nonpolar oil and grease (EPA 1664) - Total metals: As, Cd, Cr, Cu, Pb, Hg, Mo, Ni, Se, Ag, Zn (EPA 200.8) - Semivolatile organic compounds (EPA 625)


The samples are collected next to the discharge standpipe. The oil and grease sample is collected by lowering the sample bottle directly into the basin to just below the surface. The remaining sample volume is collected with a peristaltic pump. The sampling head is lowered into the water to just below the surface (to a maximum depth of 6 inches). The individual sample containers are filled simultaneously by moving the sample tubing back and forth between the bottles. Decant liquid is disposed to the sanitary sewer system as a process wastewater, necessitating a batch discharge request from the BES Source Control Division. 7.4 Disposal and Reuse

A contractor hauls off fully dewatered materials to a DEQ permitted landfills for final disposal or beneficial reuse. Currently, the primary reuse is as a daily landfill cover. This is consistent with a 2001 ODOT/DEQ materials reuse study that evaluated the potential risks of solids reuse.

7.5 Ongoing Improvements The dewatering facility is constantly being assessed and fitted with additional materials, pretreatment units, or new operations to pilot test activities to enhance solids drying and solids removal from decant liquid. In May 2001, the City began testing the use of a free-floating marsh pennywort (Hydrocotyl ranunculoides) within the south cell of the decant tank to provide additional solids removal and total lead removal from the decanted liquid. Data collected after introduction of H. ranunculoides suggest that this plant is effective at reducing solids and lead concentrations in the decant. For the past few years, the City has not actively removed or propagated the plant, but is considering reestablishing the colony.




8 Recordkeeping As new UICs are installed or identified, they are investigated for a variety of inventory parameters, such as depth, width, material type, age, and detailed location. CADD as-built drawings for newly constructed UICs are recorded in the City’s maintenance database and Geographic Information System (GIS). UIC system inventory and maintenance is tracked primarily in a BES/BOM database system called Hansen. Hansen is a computerized maintenance management system used to control and track the maintenance and repair of the stormwater and wastewater collection systems. Hansen can be linked to the City’s GIS system (ArcMap) to produce maps relating to facility maintenance questions and needs. Hansen stores a large amount of data concerning maintenance activity details on UICs and sedimentation manholes and generally refers to them as “storm manholes.” Three main parts of Hansen concern UICs and sedimentation manholes: storm manhole inventory, storm manhole inspection, and maintenance work orders. 8.1 Storm Manhole Inventory

Each storm manhole is assigned a unique identifier that is used throughout Hansen and ArcMap. The inventory record for each storm manhole contains the following information, as available: 1. Location

• Address, with notes • Drainage basin • Quarter section • Location type (type of street, easement, private property, etc.)

2. Structural Information • Manhole type (sedimentation manhole, UIC, etc.) • Surface (asphalt, concrete, unpaved street, landscaped, etc.) • Depth • Diameter • Cover type • Construction material

3. Associated (Background) Information

• Install date • Service status (in service, abandoned, in construction, etc.) • Ownership • BES job number

4. Notes

• Abandonment data (date, BES job number) • Any special information about the manhole (e.g., date and reason for any updates)

Section

8


8.2 Storm Manhole Inspection

Hansen provides for work order scheduling and scheduling of preventive maintenance activities. When a storm manhole is inspected, the information is tracked on an inspection record in Hansen and is linked to the manhole inventory. 1. Date inspected 2. Condition of components

• Cover • Frame • Walls • Inverted outlet

3. Presence or absence of surcharge evidence 4. Presence or absence of debris and sediment 5. Measurements of water and debris levels 6. Comments (additional information or defects noted while at the site) 8.3 Maintenance Work Orders Hansen records and tracks customer service requests (including the party making the referral) and bases maintenance response on the immediacy of needed cleaning, with the following priorities:

Priority Description

A Emergency response, problem threatens life or property

B Urgent maintenance, time critical

C Corrective maintenance, not time critical

D Corrective maintenance, minor

E Special project, urgency depends on specific project

F Preventive maintenance

Each time a manhole undergoes maintenance work, the information is tracked on a work order record in Hansen. Each work order has a unique number and is linked to the manhole inventory via a unique identifier. Work orders contain the following information: 1. Dates initiated, scheduled, completed 2. Maintenance activity general description (clean, repair, etc.) 3. Maintenance type (unscheduled maintenance, unscheduled repair, preventive

maintenance) 4. Source (inspection, complaint, etc.) 5. Problem (broken manhole cover, cavity, cracked pipe, debris, flooding, vandalism)


6. Costs

• Labor • Materials • Vehicles

7. Accomplishments (feet of debris removed, number of manholes repaired) 8. Comments (additional information pertinent to the work done, such as pre-cleaning

measurements for water and debris, or defects noted while at the site) Appendix B includes sample routine sedimentation manhole and UIC maintenance work orders.




9 Other City Facilities and Drainage Systems

Other types of UICs are found on City-held and operated properties, such as parks, fire and police properties, and Portland Water Bureau facilities. Most City facilities drain stormwater runoff flows from rooftops, paved parking lots, and grassed areas. A few of them drain potable drinking water supply flows. Table 9-1 summarizes the types and numbers of property-specific UICs, as identified in the Systemwide Assessment (July 2006).

Table 9-1 Other City Facilities with UICs

Bureau Type of System Approximate

Number Typical Drainage Areas

BES Drywells 10 Rooftops from pump station buildings, etc.

Fire Drywells (some with lynch-style catch basins) Soakage Trenches

18 6

Roof and footing/ foundation drains, and some parking areas

Parks Soakage Trenches/ Perforated Pipes

Drywells Other

44 144 2 or 3

Grassed and field areas (≈ 32), parking lots, roof drain, drinking fountain overflows

Water (including well properties)

Aquifer Storage and Retrieval Structures (ASRs) Drywells

9 26

No stormwater flows – only potable water overflows

Others (managed by General Services, including police station, paid parking lots, etc.)

Drywells 20 Rooftops from three sites; some parking areas

9.1 Soakage Trenches/Perforated Pipes A soakage trench receives runoff from rooftops or other impervious surfaces and allows the water to gradually seep into the soil. A soakage trench is lined with filter fabric and backfilled with sand and coarse stone for removal of sediments, nutrients, floatable materials, oil, grease, and bacteria. Sometimes an additional silt basin is installed upstream of the soakage trench to provide enhanced sediment removal and prolong the life of the trench by removing sediment that could clog the trench. After the basin (if there is one), runoff enters the trench in a perforated pipe that allows it to drain through the backfill material and soaks slowly into the underlying

Section

9


soil. The trench and silt basin are covered by metal or plastic grating, stone, sand, grass, or other groundcover plants. Perforated pipes may act very similar to soakage trenches to intentionally discharge to the ground, or may discharge to the ground while conveying flows from one location to another. 9.2 Drywells A drywell, or private sump, is a precast pipe made from concrete, plastic or other material that collects stormwater runoff from rooftops and recharges it into the ground. It is installed underground and lined with gravel. Runoff is routed to the drywell by a drainpipe connected to a downspout or by a driveway trench drain that collects stormwater from roof gutters and paved areas. Silt basins are sometimes installed upstream from the drywell to remove sediment before the stormwater enters the drywell. This improves stormwater quality and prevents the drywell from plugging. 9.3 O&M for City Facilities Some facilities on City-held and operated properties do not have standardized operations and maintenance procedures at this time. Maintenance templates (Appendix C) describe general maintenance practices established for soakage trenches and drywells in the 2004 City of Portland Stormwater Management Manual (SWMM). BMP OM-1 in the UIC Management Plan includes a task for standardizing O&M procedures for UICs on City property and developing applicable tracking systems. These site-specific procedures will be modeled after the O&M templates established in the SWMM.


10 Roles and Responsibilities Table 10-1 summarizes the roles and responsibilities for the UIC operations and maintenance program by staff position. These roles and responsibilities are clearly defined and communicated citywide to ensure effective coordination and management. The WPCF permit designates BES as the bureau responsible for implementing the WPCF permit and for identifying and managing the regulatory and technical components of the UIC Program citywide and across bureaus. The City’s Bureau of Maintenance (BOM) conducts the majority of UIC maintenance activities. Contractors conduct certain maintenance activities that require specialized equipment and expertise.

Table 10-1 Roles and Responsibilities for Operations and Maintenance

Position/Staff

Member/Bureau Area of Responsibility and Authority

UIC Program Manager: Mary Stephens

• Develop, recommend, and oversee implementation of UIC Program, budget, and policies with assistance from the Division and Group Managers.

• Ensure UIC Program management and regulatory requirements are identified, implemented, and maintained in accordance with BES policy and the WPCF permit.

• Ensure that UIC Program personnel have the appropriate qualifications, knowledge, and experience.

• Report to BES management on UIC Program performance. • Liaison with DEQ and other interested parties regarding the UIC

Program. • Provide citywide coordination of UIC Program requirements. • Review and approve UIC plans and documents; ensure adequate

resources are allocated to the UIC Program.

System Management Project Manager: Joel Bowker

• Implement the UIC System Management program element to meet permit requirements and protect groundwater.

• Evaluate existing program activities; develop and recommend changes to the program element.

• Implement systemwide BMPs, including the O&M Plan and BMP OM-1.

• Develop and maintain the UIC Database. • Prepare annual UICMP reports and associated plans/reports as

required. • Help prepare corrective action strategies and priorities.

Section

10


Table 10-1 (continued) Bureau of Maintenance (BOM) Public Works Supervisor 2

• Coordinate UIC and sewer cleaning activities. • Schedule and prioritize facility cleaning activities. • Repair UICs.

PDOT Environmental Services Division Manager and Senior Public Works Supervisor Kelly Shepard

• Prepare and review detailed O&M budgets.

BES Wastewater Collection System Manager

• Prepare and approve O&M budget and BOM interagency agreement.

PDOT Environmental Systems Division (ESD) Field Crew

• Respond to complaints. • Conduct cleanup actions.

BES Spill Prevention and Citizen Response Section

• Implement the citywide spill response hotline, operated 24 hours a day, 365 days a year to investigate spills, slicks, and suspicious discharges.

• Work with Fire & Rescue to provide notification and response for materials released to public UICs.

• Investigate, track, and oversee cleanup of materials released to public UICs.

BES Stormwater Operations and Maintenance (SOM) team Steve Hazzard

• Conduct UIC and sewer inspections. • Respond to complaints.

Bureau of Fire & Rescue • Provide notification and response for materials released to public UICs.

Operations and Maintenance Plan December 2006

Appendix A: Vector Control Material Safety Data Sheets



MATERIAL SAFETY DATA SHEET PAGE 1 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION -----------------------------------------------

MATERIAL NAME: VectoLex WDG EPA Registration No.: 73049-57 Code Number: 82835 List Number: 60201

SYNONYMS: VectoLex WG MANUFACTURER: Valent BioSciences Corporation 870 Technology Way, Suite 100 Libertyville, Illinois 60048 EMERGENCY TELEPHONE NUMBERS Emergency Health or Spill:

Outside the United States: 651-632-6184 Within the United States: 877-315-9819

2. COMPOSITION/INFORMATION ON INGREDIENTS ------------------------------------------ INGREDIENT NAME: Bacillus sphaericus CONCENTRATION: 51.20%

CAS NUMBER: N/A OSHA-PEL 8HR TWA: N/L STEL: N/L CEILING: N/L ACGIH-TLV 8HR TWA: N/L STEL: N/L CEILING: N/L OTHER 8HR TWA: N/A LIMITS STEL: N/A CEILING: N/A INGREDIENT NAME: Other/Inert Ingredients - identity withheld as a Trade Secret CONCENTRATION: 48.80%

CAS NUMBER: N/A OSHA-PEL 8HR TWA: N/L STEL: N/L CEILING: N/L ACGIH-TLV 8HR TWA: N/L STEL: N/L CEILING: N/L OTHER 8HR TWA: N/A LIMITS STEL: N/A CEILING: N/A

MATERIAL SAFETY DATA SHEET PAGE 2 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 3. HAZARDS INFORMATION ----------------------- EMERGENCY OVERVIEW: Product is non-toxic by ingestion, skin contact, or

inhalation. Direct contact with eyes may cause mild irritation. ROUTE(S) OF ENTRY: Skin: No Inhalation: No Ingestion: No SKIN CONTACT: Non-irritant SKIN SENSITIZATION: Non-sensitizer EYE CONTACT: Non-irritant TARGET ORGANS: N/D CARCINOGENICITY RATING: NTP: N/L IARC: N/L OSHA: N/L ACGIH: N/L None SIGNS AND SYMPTOMS: Direct contact with eyes may cause mild irritation. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: N/D 4. FIRST AID MEASURES ---------------------- EYES: Remove from source of exposure. Flush with copious amounts of water. If irritation persists or signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. SKIN: Remove from source of exposure. Flush with copious amounts of water. If irritation persists or signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. INGESTION: Remove from source of exposure. If signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. INHALATION: Remove from source of exposure. If signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary.

MATERIAL SAFETY DATA SHEET PAGE 3 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 5. FIRE FIGHTING PROCEDURES ---------------------------- FLASH POINT: N/A FLASH POINT METHOD: N/A LOWER EXPLOSIVE LIMIT(%): N/A UPPER EXPLOSIVE LIMIT(%): N/A AUTOIGNITION TEMPERATURE: N/A FIRE & EXPLOSION HAZARDS: Non-flammable and no explosive properties. EXTINGUISHING MEDIA: Use appropriate medium for the underlying cause of the fire. FIRE FIGHTING INSTRUCTIONS: Wear protective clothing and self-contained breathing apparatus. 6. ACCIDENTAL RELEASE MEASURES ------------------------------- SPILL OR RELEASE PROCEDURES: Recover product and place in an appropriate container for disposal. Avoid breathing dust. Ventilate and

wash the spill area. 7. HANDLING AND STORAGE ------------------------ HANDLING: N/D STORAGE: Store product in closed container in a cool and dry place. SPECIAL PRECAUTIONS: N/D 8. EXPOSURE CONTROLS/PERSONAL PROTECTION ----------------------------------------- ENGINEERING CONTROLS: Use local exhaust. RESPIRATORY PROTECTION: Not usually required. If necessary, use a

MSHA/NIOSH approved (or equivalent) respirator with a dust/mist filter. Mixer/loaders and applicators not in enclosed cabs or aircraft must wear a dust/mist filtering respirator meeting NIOSH standards of at least N-95, R-95, or P-95.

SKIN PROTECTION: Impervious gloves, clothing to minimize skin contact. EYE PROTECTION: Not usually required. If necessary, use safety glasses or

goggles. OTHER PROTECTION: Wash thoroughly with soap and water after handling.

MATERIAL SAFETY DATA SHEET PAGE 4 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 9. PHYSICAL AND CHEMICAL PROPERTIES ------------------------------------ APPEARANCE/PHYSICAL STATE: Fine brown granules ODOR: Faint organic/malt/musty odor BOILING POINT: N/A MELTING/FREEZING POINT: N/A VAPOR PRESSURE (mm Hg): N/A VAPOR DENSITY (Air=1): N/A EVAPORATION RATE: N/A BULK DENSITY: 0.4 ± 0.1 g/mL SPECIFIC GRAVITY: N/D SOLUBILITY: Suspends readily in water. pH: 4.5-6.5 as an aqueous solution. VISCOSITY: N/A 10. STABILITY AND REACTIVITY ---------------------------- CHEMICAL STABILITY: Stable. No oxidizing or reducing properties. INCOMPATIBILITIES: Alkalinity inactivates product. HAZARDOUS DECOMPOSITION PRODUCTS: None that are known. HAZARDOUS POLYMERIZATION: Will not occur. 11. TOXICOLOGICAL INFORMATION ----------------------------- Acute Toxicity ORAL LD50: LD50 (rat) > 5,050 mg/kg DERMAL LD50: LD50 (rabbit) > 5,050 mg/kg INHALATION LC50: No lethality was observed in rats after a 4 hour exposure

at the highest obtainable inhalation exposure chamber concentration. CORROSIVENESS: N/D. Not expected to have any corrosive properties. DERMAL IRRITATION: Transient, slight or mild irritation noted in a dermal

toxicity study with this product. OCULAR IRRITATION: Transient, redness and conjunctival irritation

observed in test animals in a study with this product. No positive ocular effects were observed. Classified as a mild irritant.

MATERIAL SAFETY DATA SHEET PAGE 5 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 11. TOXICOLOGICAL INFORMATION, continued ----------------------------- DERMAL SENSITIZATION: In a study with this product, no skin sensitization

was observed. SPECIAL TARGET ORGAN EFFECTS: N/D CARCINOGENICITY INFORMATION: N/D. None of the components are classified as carcinogens. 12. ECOLOGICAL INFORMATION -------------------------- ECOLOGICAL INFORMATION: N/D 13. DISPOSAL CONSIDERATIONS --------------------------- WASTE DISPOSAL METHODS: Dispose of product in accordance with federal, state and local regulations. 14. TRANSPORTATION INFORMATION ------------------------------ DOT STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A IATA/ICA0 STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A IMO STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A FLASH POINT: N/D

MATERIAL SAFETY DATA SHEET PAGE 6 VectoLex WDG MSDS# BIO-0035 Rev. 1 ISSUED 12/23/03 ----------------------------------------------------------------------–––– 15. REGULATORY INFORMATION -------------------------- TSCA STATUS: Exempt RCRA STATUS: N/D CERCLA STATUS: N/D PROP 65 (CA): N/D SARA STATUS: N/D 16. OTHER INFORMATION ---------------------

REASON FOR ISSUE: Updated Hazard Information (Section 3) and Toxicological Information (Section 11).

APPROVAL DATE: 12/23/03 SUPERSEDES DATE: 06/12/01

LEGEND: N/A = Not Applicable N/D = Not Determined N/L = Not Listed L = Listed C = Ceiling S = Short-term = Registered Trademark of Valent BioSciences (TM) = Registered Trademark of Valent BioSciences The information and recommendations contained herein are based upon tests believed to be reliable. However, Valent BioSciences does not guarantee their accuracy or completeness nor shall any of this information constitute a warranty, whether expressed or implied, as to the safety of the goods, the merchantability of the goods, or the fitness of the goods for a particular purpose. Adjustment to conform with actual conditions of usage may be required. Valent BioSciences assumes no responsibility for results obtained or for incidental or consequential damages arising from the use of these data. No freedom from infringement of any patent, copyright or trademark is to be inferred. 870 Technology Way, Suite 100 Libertyville, IL 60048 – 800-323-9597 December 2003 © Valent BioSciences Corporation

MATERIAL SAFETY DATA SHEET PAGE 1

VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- 1. CHEMICAL PRODUCT AND COMPANY IDENTIFICATION ----------------------------------------------- MATERIAL NAME: VectoBac® 12AS Biological Larvicide EPA REG. NO.: 73049-38 List Number: 5605 Code Number: 15576, 15577, 21894 MANUFACTURER: Valent BioSciences Corporation 870 Technology Way, Suite 100 Libertyville, Illinois 60048 EMERGENCY TELEPHONE NUMBERS Emergency Health or Spill:

Outside the United States: 651-632-6184 Within the United States: 877-315-9819

2. COMPOSITION/INFORMATION ON INGREDIENTS ------------------------------------------ INGREDIENT NAME: Bacillus thuringiensis, subsp. israelensis CONCENTRATION: 11.61 %

CAS NUMBER: 68038-71-1 OSHA-PEL 8HR TWA: N/L STEL: N/L CEILING: N/L ACGIH-TLV 8HR TWA: N/L STEL: N/L CEILING: N/L OTHER 8HR TWA: N/A LIMITS STEL: N/A CEILING: N/A INGREDIENT NAME: Inert Ingredients - identity withheld as a Trade Secret CONCENTRATION: 88.39 %

CAS NUMBER: N/A OSHA-PEL 8HR TWA: N/L STEL: N/L CEILING: N/L ACGIH-TLV 8HR TWA: N/L STEL: N/L CEILING: N/L OTHER 8HR TWA: N/A LIMITS STEL: N/A CEILING: N/A


VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- 3. HAZARDS INFORMATION ----------------------- EMERGENCY OVERVIEW: Product is non-toxic by ingestion, skin contact, or

inhalation. May be irritating to skin and eyes, and may be a skin sensitizer.

ROUTE(S) OF ENTRY: Skin: No Inhalation: No Ingestion: No SKIN CONTACT: Mild irritant SKIN SENSITIZATION: Possible mild sensitizer EYE CONTACT: Mild irritant TARGET ORGANS: N/D CARCINOGENICITY RATING: NTP: N/L IARC: N/L OSHA: N/L ACGIH: N/L None SIGNS AND SYMPTOMS: Direct contact with eyes or skin may cause mild irritation. MEDICAL CONDITIONS AGGRAVATED BY EXPOSURE: N/D 4. FIRST AID MEASURES ---------------------- EYES: Remove from source of exposure. Flush with copious amounts of water. If irritation persists or signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. SKIN: Remove from source of exposure. Flush with copious amounts of water. If irritation persists or signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. INGESTION: Remove from source of exposure. If signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary. INHALATION: Remove from source of exposure. If signs of toxicity occur, seek medical attention. Provide symptomatic/supportive care as necessary.


VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- 5. FIRE FIGHTING PROCEDURES ---------------------------- FLASH POINT: N/A (Aqueous suspension) FLASH POINT METHOD: N/A LOWER EXPLOSIVE LIMIT(%): N/A UPPER EXPLOSIVE LIMIT(%): N/A AUTOIGNITION TEMPERATURE: N/A FIRE & EXPLOSION HAZARDS: Non-flammable and no explosive properties. EXTINGUISHING MEDIA: Use appropriate media for underlying cause of fire. FIRE FIGHTING INSTRUCTIONS: Wear protective clothing and self-contained breathing apparatus. 6. ACCIDENTAL RELEASE MEASURES ------------------------------- SPILL OR RELEASE PROCEDURES: Recover product and place in appropriate container for disposal. Ventilate and wash area. 7. HANDLING AND STORAGE ------------------------ HANDLING: N/D. STORAGE: Store in a cool (59-86° F or 15-30° C), dry place. SPECIAL PRECAUTIONS: Wash thoroughly with soap and water after handling.

Keep impervious gloves on until all potentially contaminated personal protective equipment is removed.

8. EXPOSURE CONTROLS/PERSONAL PROTECTION ----------------------------------------- ENGINEERING CONTROLS: Use local exhaust. RESPIRATORY PROTECTION: Not usually required. If necessary (Mixers/loaders

and applicators not in enclosed cabs or aircraft), use a MSHA/NIOSH approved (or equivalent) respirator with a dust/mist filter (N-95, R-95, or P95).

SKIN PROTECTION: Impervious, waterproof gloves and clothing to minimize

skin contact. EYE PROTECTION: Not usually required. If necessary, use safety glasses

or goggles. OTHER PROTECTION: Wash thoroughly with soap and water after handling.


VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- 9. PHYSICAL AND CHEMICAL PROPERTIES ------------------------------------ APPEARANCE/PHYSICAL STATE: Light brown aqueous suspension. ODOR: Typical fermentation (malt) odor. BOILING POINT: Approx. 100° C MELTING/FREEZING POINT: Approx. 0° C VAPOR PRESSURE (mm Hg): N/D VAPOR DENSITY (Air=1): N/D EVAPORATION RATE: N/D BULK DENSITY: 1.06-1.1 g/mL SPECIFIC GRAVITY: N/D SOLUBILITY: Disperses well in water pH: 4.6-5.0 VISCOSITY: 250-1000 cps at 25 C 10. STABILITY AND REACTIVITY ---------------------------- CHEMICAL STABILITY: Stable. INCOMPATIBILITIES: Diluted or undiluted product can cause corrosion if

left in prolonged contact with aluminum surfaces (e.g. spray equipment, aircraft components).

HAZARDOUS DECOMPOSITION PRODUCTS: N/D. HAZARDOUS POLYMERIZATION: Will not occur. 11. TOXICOLOGICAL INFORMATION ----------------------------- Acute Toxicity ORAL LD50: > 5,000 mg/kg (rat) DERMAL LD50: > 5,000 mg/kg (rabbit) INHALATION LC50: > 5.34 mg/l (rat) No lethality was observed in rats

after a 4 hour whole body exposure to this concentration of the product as an undiluted aerosol.

CORROSIVENESS: N/D. Not expected to have any corrosive properties. DERMAL IRRITATION: Transient, mild to moderate redness was observed at

the site of application in a skin irritation test in rabbits.


VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- OCULAR IRRITATION: Transient, redness and conjunctival irritation

observed in test animals in a study with this product. No positive ocular effects were observed.

DERMAL SENSITIZATION: Eight of ten animals positive in a dermal sensitization study in guinea pigs. Considered to be a mild

sensitizer. SPECIAL TARGET ORGAN EFFECTS: N/D. CARCINOGENICITY INFORMATION: N/D. None of the components are classified

as carcinogens. 12. ECOLOGICAL INFORMATION -------------------------- ECOLOGICAL INFORMATION: N/D 13. DISPOSAL CONSIDERATIONS --------------------------- WASTE DISPOSAL METHODS: Dispose of product in accordance with federal, state, and local regulations. 14. TRANSPORTATION INFORMATION ------------------------------ DOT STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A IATA/ICA0 STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A IMO STATUS: Not Regulated PROPER SHIPPING NAME: N/A HAZARD CLASS: N/A UN NUMBER: N/A PACKING GROUP: N/A REPORTABLE QUANTITY: N/A FLASH POINT: N/D


VectoBac® 12AS MSDS# BIO-0031 Rev. 2 ISSUED 12/16/03 ----------------------------------------------------------------------- 15. REGULATORY INFORMATION -------------------------- TSCA STATUS: Exempt RCRA STATUS: N/D CERCLA STATUS: N/D PROP 65 (CA): N/D SARA STATUS: N/D 16. OTHER INFORMATION ---------------------

REASON FOR ISSUE: Updated Composition Information (Section 2) and Phys/Chem. Properties (Section 9).

APPROVAL DATE: 12/16/03 SUPERSEDES DATE: 07/03/03

LEGEND: N/A = Not Applicable N/D = Not Determined N/L = Not Listed L = Listed C = Ceiling S = Short-term = Registered Trademark of Valent BioSciences (TM) = Registered Trademark of Valent BioSciences The information and recommendations contained herein are based upon tests believed to be reliable. However, Valent BioSciences does not guarantee their accuracy or completeness nor shall any of this information constitute a warranty, whether expressed or implied, as to the safety of the goods, the merchantability of the goods, or the fitness of the goods for a particular purpose. Adjustment to conform with actual conditions of usage may be required. Valent BioSciences assumes no responsibility for results obtained or for incidental or consequential damages arising from the use of these data. No freedom from infringement of any patent, copyright or trademark is to be inferred. 870 Technology Way, Suite 100 Libertyville, IL 60048 – 800-323-9597 December 2003 © Valent BioSciences Corporation

Page 1 of 4

Date Issued: May, 2001 Supersedes: November,2000

MATERIAL SAFETY DATA SHEET ALTOSID XR EXTENDED RESIDUAL BRIQUETS

Manufacturer: Wellmark International

Address: 1100 East Woodfield Road, Suite 500 Schaumburg, IL 60173

Emergency Phone: 1-800-248-7763

Transportation Emergency Phone: CHEMTREC: 1-800-424-9300

1. CHEMICAL PRODUCT INFORMATION

Product Name: Altosid XR Extended Residual Briquets

Chemical Name/Synonym: (S)-Methoprene; isopropyl (2E,4E,7S)-11-methoxy-3,7,11-trimethyl-2,4-dodecadienoate

Chemical Family: Terpenoid

Formula: C19 H34 O3

EPA Registration No.: 2724-421

RF Number: 292A 2. COMPOSITION / INFORMATION ON INGREDIENTS

Component (chemical, common name) CAS Number

Weight Tolerance

(S)- Methoprene: Isopropyl (2E,4E,7S)-11-methoxy-3,7,11-trimethyl-2,4-dodecadienoate

65733-16-6 2.1% Not established

Inert ingredients (non-hazardous and/or trade secret) 97.9%

3. HAZARD INFORMATION

PRECAUTIONARY STATEMENT

Caution: Keep out of the reach of children.

SIGNS AND SYMPTOMS OF OVEREXPOSURE No adverse reactions have resulted from normal human exposure during research and testing. Adverse animal reactions to this product have not been shown.

PRIMARY ROUTE OF ENTRY Dermal/Eye: Yes Oral: Yes Inhalation No

ACUTE TOXICITY Oral: LD50 (rat): >34,000 mg/kg (highest dose level tested)(Based on (S)-

Methoprene)

Dermal: LD50 (rabbit): >2,000 mg/kg (Hot) (highest dose level tested) (Based on (S)-Methoprene)

Inhalation: LC50 (rat): Not applicable to this product form

OTHER TOXICOLOGICAL INFORMATION Skin Irritation: Non-irritating (rabbit) (Based on (S) Methoprene)

Eye Irritation: Mild/moderate irritation, corneal opacity at 1 hour - all animals clear by 72 hours (rabbit) (Based on (S) Methoprene)

Sensitizer: Not a sensitizer (guinea pig) (Based on (RS) Methoprene)

Page 2 of 4

4. FIRST AID MEASURES

Eye: Immediately flush with plenty of water.. See a physician if irritation persists.

Skin: Wash material off with soap and water. Remove contaminated clothing and footwear. See a physician if symptoms persist.

Ingestion: Drink 1-2 glasses of water and try to induce vomiting. Seek medical attention. Never give anything by mouth to an unconscious person.

Inhalation: Although this is not a primary route of entry, remove victim to fresh air. See a physician if cough or other respiratory symptoms develop

Note to Physician: Treat symptomatically

5. FIRE FIGHTING MEASURES

NFPA Rating: Health: 0 Fire: 0 Reactivity: 0

Flammability Class: N/A

Flash Point: Does not flash

Explosive Limits (% of Volume): N/A

Extinguishing Media: Water, foam, dry chemical

Special Protective Equipment: Firefighters should wear protective clothing, eye protection, and self contained breathing apparatus.

Fire Fighting Procedures: Normal procedures. Do not allow run-off to enter waterways inhabited by aquatic organisms

Combustion Products: None known

Unusual Fire/Explosion Hazards: None

6. ACCIDENTAL RELEASE MEASURES

Steps to be taken: Sweep up material and place in a container for disposal. Do not allow spill to enter waterways inhabited by aquatic organisms

Absorbents: Not necessary due to product form and packaging

Incompatibles: None

7. HANDLING AND STORAGE

Handling: Avoid contact with eyes or clothing. Do not remove briquets from container except for immediate use. Avoid breathing dust. Wash thoroughly with soap and water after handling.

Storage: Store in a cool, dry place. Do not contaminate food or feed by storage or disposal. Keep away from children.

8. EXPOSURE CONTROL / PERSONAL MEASURES

Exposure Limits: Not Applicable

Ventilation: Use with adequate ventilation.

Personal Protective Equipment: Under ordinary use conditions, no special protection is required. If prolonged exposure is expected, it is recommended to wear a MSHA/NIOSH approved organic vapor/pesticide respirator, impervious gloves, chemical goggles or safety glasses with side shields.

Page 3 of 4

9. PHYSICAL AND CHEMICAL PROPERTIES

Appearance and Odor: Grey to black solid with slight hydrocarbon odor.

Boiling Point: N/A

Melting Point: N/A

Vapor Pressure (mm Hg): N/A

Vapor Density (Air = 1): N/A

Specific Gravity: 1.04 g/cc

Bulk Density: N/A

Solubility: 1 ppm

Evaporation Rate: N/A

pH: N/A

10. STABILITY AND REACTIVITY

Stability: Stable

Reactivity: Non-reactive

Incompatibility w/ Other Materials:

None

Decomposition Products: None

Hazardous Polymerization: Will not occur

11. TOXICOLOGICAL INFORMATION

CHRONIC TOXICITY [Specific to Active Ingredient(s)] Methoprene is not considered as an oncogenic compound. The NOEL for non-carcinogen effects in an 18-month mouse study was 250ppm.

DEVELOPMENTAL/REPRODUCTIVE TOXICITY [Specific to Active Ingredient(s)] Methoprene is not a teratogenic compound. The NOEL for maternal and embryo toxicity in rabbits was 200/mg/kg/day. The NOEL for reproductive effects in rats was 500 ppm.

MUTAGENICITY [Specific to Active Ingredient(s)] Methoprene is not a mutagenic compound.

12. ECOLOGICAL INFORMATION

ENVIRONMENTAL FATE [Based on (RS)-Methoprene]

Hydrolysis: T1/2 > 4 weeks

Photolysis: T1/2 < 10 hours

Soil half life: ~ 10 days

Water solubility: < 2 ppm

ECOTOXICITY [Based on (S)-Methoprene] Acute Toxicity: fish:LC50 (trout): 760 ppb, (bluegill): > 370 ppb ((S)-Methoprene); aquatic

invertebrates:LC50 (Daphnia): 360 ppb ((S)-Methoprene This product is toxic to aquatic dipteran. )

Page 4 of 4

13. DISPOSAL CONSIDERATIONS

Dispose of empty bag in sanitary landfill or by incineration, or, if allowed by state and local authorities, by burning. If burned, stay out of smoke.

14. TRANSPORT INFORMATION

DOT49CFR Description: Not regulated as hazardous by D.O.T.

Freight Classification: Insecticides, NOI other than poison in boxes or drums. NMFC 102120

15. REGULATORY INFORMATION

CERCLA (Superfund): Not regulated

RCRA: Not regulated as hazardous

SARA 311/312 HAZARD CATEGORIES Immediate Health: Yes (irritation)

Delayed Health: No

Fire: No

Sudden Pressure: No

Reactivity: No

The information presented herein, while not guaranteed, was prepared by technically knowledgeable personnel and to the best of our knowledge is true and accurate. It is not intended to be all inclusive and the manner and conditions of use and handling may involve other or additional considerations.


Appendix B: Sample Work Orders

• Sedimentation Manhole—Completed Work Order Sample • UIC—Completed Work Order Sample




Sedimentation Manhole Completed Work Order Sample


UIC Completed Work Order Sample


Appendix C: Maintenance Templates





Appendix C

Spill Prevention and Pollution Control Plan



City of Portland, Oregon Water Pollution Control Facilities (WPCF) Permit For Class V Stormwater Underground Injection Control Systems Permit Number: 102830 Spill Prevention and Pollution Control Plan Stormwater Underground Injection Control

December 2006

Prepared By: City of Portland, Bureau of Environmental Services

This page is intentionally left blank.

Spill Prevention and Pollution Control Plan i December 2006

Table of Contents 1 Introduction and Organization ...........................................................................1-1

1.1 Introduction.................................................................................................................. 1-1 1.2 Regulatory Requirements............................................................................................. 1-2 1.3 Relationship of SPPC Plan to Other Documents ......................................................... 1-3

1.3.1 Relationship to Spill Response, Containment, and Prevention Handbook.......... 1-3 1.3.2 Relationship to UIC Management Plan ............................................................... 1-3

1.4 SPPC Plan Organization .............................................................................................. 1-4 2 Goals and Objectives..........................................................................................2-1

2.1 Introduction.................................................................................................................. 2-1 2.2 Spill Prevention and Pollution Control Goals.............................................................. 2-1 2.3 Spill Prevention and Pollution Control Goals.............................................................. 2-1

3 Overview of Spill Prevention and Response Activities ...................................3-1 3.1 Introduction.................................................................................................................. 3-1 3.2 Spill Protection-Citizen Response Hotline .................................................................. 3-3 3.3 Spill Response.............................................................................................................. 3-3 3.4 Emergency Response ................................................................................................... 3-3 3.5 Employee Training....................................................................................................... 3-4 3.6 Public Education .......................................................................................................... 3-4

3.6.1 General Public Education and Outreach .............................................................. 3-4 3.6.2 Fact Sheets ........................................................................................................... 3-4

3.7 Spill Prevention Materials............................................................................................ 3-5 3.8 Containment Facilities ................................................................................................. 3-6 3.9 Contaminated Media Management Plan...................................................................... 3-7 3.10 Tracking Systems......................................................................................................... 3-7

4 Typical Spill Response Actions.........................................................................4-1 4.1 Typical Spill Response Actions for UICs in the.......................................................... 4-1 Public Right-of-Way................................................................................................................ 4-1 4.2 Typical Spill Response Actions for UICs on Other Public.......................................... 4-2 Properties ................................................................................................................................. 4-2

4.2.1 Typical Procedures for All City-owned Properties.............................................. 4-2 4.2.2 Parks Integrated Pest Management Program ....................................................... 4-3

5 Emergency Preparedness, Prevention, Mitigation, and Response ................5-1 5.1 Introduction.................................................................................................................. 5-1 5.2 Fire ............................................................................................................................... 5-2 5.3 Flood ............................................................................................................................ 5-2 5.4 Earthquake ................................................................................................................... 5-3 5.5 Volcano ........................................................................................................................ 5-3 5.6 Severe Weather ............................................................................................................ 5-4

6 Roles and Responsibilities.................................................................................6-1

Spill Prevention and Pollution Control Plan ii December 2006

Attachments………..……………………………………………………….following Section 6 Tables 3-1 Spill Prevention and Response Activities………………………………………………3-1 6-1 Roles and Responsibilities for City Bureaus…………...………………………………6-1 Figure 1-1 Typical UIC System Design……………………………………………………………1-1

Spill Prevention and Pollution Control Plan Page 1-1 December 2006

1 Introduction and Organization 1.1 Introduction This Spill Prevention and Pollution Control Plan (SPPC Plan) describes the spill/emergency prevention and response activities the City of Portland implements to prevent and control the release of pollutants to underground injection control systems (UICs). The SPPC Plan is a requirement of the Water Pollution Control Facility (WPCF) permit issued to the City by the Oregon Department of Environmental Quality (DEQ) in June 2005. The City currently has an estimated 9,000 UICs that collect stormwater and discharge it to the subsurface. The majority of these UICs drain City rights-of-way in the eastern portion of the City, where the subsurface soils support greater stormwater drainage and infiltration rates. For many areas located east of the Willamette River, UICs are the only available form of stormwater disposal. Figure 1-1 illustrates a typical public UIC system. Some City parks, fire stations, police stations, and other properties also have private drywells and soakage trenches to infiltrate flows from impervious and pervious areas. UICs are an essential element of the City’s comprehensive watershed strategy to use stormwater as a resource by infiltrating it back into the ground. UICs quickly and efficiently reintroduce stormwater into subsurface soils, which filter and cool the runoff before it finds its way to groundwater and, eventually, helps recharge streams. UICs are an essential element of street-side swales and green street applications because they provide an overflow point during large storm events when stormwater cannot be fully infiltrated through swales, planters, or other surface infiltration systems. UICs also preclude the need to install or increase the capacity of piped stormwater infrastructure that eventually discharges into local surface water bodies, including Johnson Creek, the Columbia Slough, and the Willamette River. In the Portland area, groundwater serves as a backup drinking water supply to the Bull Run reservoirs. The WPCF permit establishes the UIC construction, operation, and maintenance requirements the City must implement to protect

Section


Figure 1-1 Typical UIC System Design


groundwater for use as a drinking water resource. The permit calls for a comprehensive stormwater management strategy that will prevent, minimize, and control pollutants at the surface before stormwater is discharged to the ground. The SPPC is an essential element of that strategy. 1.2 Regulatory Requirements Congress enacted UIC rules in 1974 under the federal Safe Drinking Water Act (SDWA) and modified the rules in 1999. The U.S. Environmental Protection Agency (EPA) administers these rules under Title 40 of the Code of Federal Regulations (CFR) Parts 144 -148. In Oregon, EPA has delegated the regulation of UICs to DEQ. Oregon Administrative Rules (OAR) 340-044 regulate all groundwater as a potential source of drinking water and require municipalities with more than 50 UICs to operate under a permit. DEQ issued a WPCF permit to the City of Portland on June 1, 2005 (DEQ Permit Number 102830). Schedule A(3)(d) of the WPCF permit requires that the permittee must operate all public UICs in a manner that protects groundwater from accidental or illicit disposal of wastes or contaminants. Public UICs must have the ability to be temporarily blocked to prevent discharge into the public UIC in the event of an accident, spill, or emergency firefighting activity. New public UICs must be designed to meet this condition. If an existing public UIC fails to meet this condition, it must: i. Have the ability to be blocked with a sealing mat or other device adequate to prevent flow

from entering the UIC; ii. Be retrofitted; or iii. Be closed. Schedule A(3)(g) of the WPCF permit states that underground injection of fluids to public UICs is prohibited, except as authorized under the permit. The permittee is allowed to discharge stormwater and other fluids, as specifically identified in the permit, to public UICs. Permitted other fluids, which are consistent with other fluids authorized in the permittee’s National Pollution Discharge Elimination System (NPDES) Municipal Separate Storm Sewer System (MS4) permit include: vii. Emergency firefighting activities. The Permittee shall take necessary precautions to the

extent practicable to protect public UICs during emergency firefighting activities. Wash down of spills into any underground injection system is expressly prohibited. In the event of an inadvertent discharge to an underground injection system of pollutants that may endanger groundwater quality during firefighting activities, the City will undertake appropriate response and corrective actions to assure groundwater is protected.

Schedule D(10)(e) of the WPCF Permit requires a Spill Prevention and Pollution Control (SPPC) Plan in accordance with OAR 340-044-0018(3)(b)(C)(ii). The permittee may amend its existing NPDES MS4 SPPC plan to incorporate public UICs to meet this requirement. The SPPC Plan must provide the protocols and procedures for emergency response to spills, fires, or other emergency circumstances where pollutants may enter a public UIC.


1.3 Relationship of SPPC Plan to Other Documents 1.3.1 Relationship to Spill Response, Containment, and Prevention Handbook The City’s spill prevention and response activities are identified in a Spill Response, Containment, and Prevention Handbook, developed in 1995 as part of the City’s NPDES MS4 discharge permit requirements. This SPPC Plan updates the general response duties identified in that handbook and adds emergency situations, including fire, flood, earthquake, volcano eruption, and severe weather events. This SPPC Plan also provides UIC-specific activities to ensure protection of groundwater resources. This SPPC Plan applies to all public rights-of-way and City properties with UICs. It addresses both spill prevention activities and spill response activities. In general, the City’s response procedures focus on communication, logistics, and response activities linked to the type of event, regardless of the destination of the polluted runoff. Many programs were generated as part of the MS4 permit work to focus on pollution prevention rather than disposal controls based on the disposal system. Implementation of the SPPC Plan will be coordinated through the Regional Spill Response Committee, which was formed in 1995 to consult and debrief on spill response activities throughout the region. The committee meets quarterly and is chaired by Portland’s Bureau of Environmental Services (BES). 1.3.2 Relationship to UIC Management Plan The City’s UIC Management Program comprises four major program elements: System Management, System Monitoring, Evaluation and Response, and Corrective Actions. The UIC Management Plan (UICMP) is the umbrella document that describes these four program elements and identifies the various documents the City has prepared to address specific program activities. The SPPC Plan is a component of the System Management program element of the UICMP. System Management includes best management practices (BMPs) that will be implemented to prevent, minimize, and control pollutants in stormwater prior to discharge to a UIC. Implementation of the SPPC Plan is included in BMP PC-1: Identify, prevent, minimize, and control activities and practices that can increase pollutant discharges to public UICs. That BMP focuses on reducing pollutant discharges from activities and practices, such as spills, illegal disposal, improper site management, and erosion, that can increase the discharge of pollutants to UICs, with potential negative impacts to groundwater.


1.4 SPPC Plan Organization The SPPC Plan is organized as follows: Section 1: Introduction and Organization, provides a brief description and purpose of the SPPC Plan. It also summarizes relevant regulatory requirements and describes the SPPC Plan’s relationship to other documents. Section 2: Goals and Objectives, describes goals and objectives for the SPPC Plan, as well as the City’s overall watershed goals. Section 3: Overview of Spill Prevention and Response Activities, describes the general categories of spill prevention and response activities, along with the City bureaus responsible for conducting the activities. Section 4: Typical Spill Response Actions, describes how the City responds to spills that have potential impacts to UICs located in the right-of-way and on other City-owned properties. Section 5: Emergency Preparedness, Prevention, Mitigation, and Response, addresses fires, floods, earthquakes, volcano eruption, and severe weather. Section 6: Roles and Responsibilities, identifies the roles and responsibilities assigned to City bureaus for controlling and responding to spills and emergencies. The Attachments provide examples of educational and tracking materials.


2 Goals and Objectives 2.1 Introduction The mission of the Bureau of Environmental Services is to:



For many areas located east of the Willamette River, UICs are the only form of stormwater disposal available. UICs are also an essential element of a comprehensive watershed strategy to use stormwater as a resource by infiltrating it back into the ground. This section discusses the role the SPPC Plan will play in ensuring that UICs continue to play an integral role in carrying out the bureau’s mission. 2.2 Spill Prevention and Pollution Control Goals The primary goals of spill prevention and pollution control activities are to: 1. Protect groundwater by preventing and/or controlling spills or illicit discharges to public

UICs. 2. Ensure that UICs are operated and maintained in a manner that meets the requirements of the

WPCF permit and protects groundwater quality for use as a drinking water resource. 3. Ensure that UICs contribute to achieving watershed goals established in the Portland

Watershed Management Plan (City of Portland 2005) and the Framework for Integrated Management of Watershed Health (City of Portland December 2005).

2.3 Spill Prevention and Pollution Control Goals The primary objectives of the spill prevention and pollution control activities are to: 1. Implement spill prevention and response practices related to UICs that manage flows from

public rights-of-way. 2. Implement spill prevention and response practices related to UICs that manage flows from

publicly owned properties. 3. Implement emergency preparedness, prevention, mitigation, and response activities. 4. Identify the roles and responsibilities assigned to City bureaus for spill/emergency prevention

and response.

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3 Overview of Spill Prevention and

Response Activities 3.1 Introduction This section describes the general categories of spill prevention and response activities, along with the City bureaus responsible for conducting the activities. Table 3-1 summarizes the activities, followed by additional information about each category.

Table 3-1 Spill Prevention and Response Activities

Category Prevention and Response Activities Responsible City

Bureaus/Agencies

Spill Protection-Citizen Response Hotline

1. A citywide spill response hotline is operated 24 hours a day, 365 days a year.

2. The spill response duty officer notifies appropriate agencies to initiate response.

3. Information about the spill response is entered into the City’s Aquarius database.

• Environmental Services

Spill Response

1. Fire & Rescue is an initial City responder to spill emergencies.

2. Fire and Rescue staff notify BES, address life and safety issues, and initiate spill containment if appropriate.

3. BES assesses the drainage system and works with Fire & Rescue to add the appropriate containment or pretreatment controls (e.g., oil booms) to the site.

4. Cleanup and further evaluation is performed as appropriate.

• Fire & Rescue [1,2,3 only]*

• Environmental Services [3,4 only]

*The numbers in brackets link bureaus to the activities described in the second column.

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Table 3-1 (continued)

Category Prevention and Response Activities Responsible City Bureaus/Agencies

Emergency Response

1. City staff operate under the National Incident Management System (NIMS) during all emergency conditions in Portland.

2. The City’s Office of Emergency Management serves as the interagency coordinator for emergencies and disaster response and manages the City’s Emergency Operations Center (EOC).

3. Staff emergency preparedness is coordinated and in compliance with the Oregon State Office of Emergency Management.

4. City response operations are detailed in the City’s Basic Emergency Services Plan (2006) and the Natural Hazard Mitigation Plan (August 2005).

• Office of Emergency Management

• Maintenance [1,3,4] • Environmental

Services [1,3,4] • Water Works [1,3,4]

Employee Training

1. Maintenance staff are trained on the importance of spill prevention and control.

2. City-owned and operated facilities are required to have operating procedures for spill prevention and control.

3. Employees view the Stormwatch training video.

• Maintenance • Parks and Recreation • Water Works

Public Education

1. Spill prevention messages are routinely included in City educational and outreach materials.

2. Fact sheets are provided for industrial and commercial clients.

• Maintenance • Environmental

Services • Fire & Rescue • Parks and Recreation • Water Works

Spill Prevention Materials

1. Staff response vehicles and work vehicles are supplied with spill prevention and containment kits.

2. Some bureaus control releases from staff operations and vehicles only.

3. Some bureaus control releases by other parties.

4. Every Bureau of Maintenance maintenance vehicle carries a spill kit.

• Maintenance [1,2,4 only]

• Environmental Services [1,3 only]

• Fire & Rescue [1,2,3 only]

• Parks and Recreation [1,2 only]



Category Prevention and Response Activities Responsible City Bureaus

Containment Features

1. Specific containment pond facilities take street runoff from Airport Way infrastructure in high-risk areas in the Columbia South Shore Well Field.

2. The Stormwater Management Manual and Wellhead Protection Manual require certain facilities to construct containment areas.

3. The City’s standard construction specification for UICs in public rights-of-way includes a sedimentation manhole to provide treatment and spill containment.

• Maintenance • Environmental

Services • Water Works [1,2

only]

Contaminated Media Management Plan (2005)

1. Pretreatment procedures are required at contaminated sites.

2. Contractors must update their site spill response plans upon discovery of site contamination.

• Environmental Services

Tracking Systems

1. Spill and emergency response records are maintained in a variety of City systems.

2. The Annual UICMP Report includes information on spills and unintended discharges.

• Environmental

Services

3.2 Spill Protection-Citizen Response Hotline BES staff from the Spill Protection-Citizen Response (SPCR) team monitor a citywide spill response hotline 24 hours a day, 365 days a year to investigate spills, slicks, and suspicious discharges. Hotline calls are answered directly during business hours; after hours and on weekends, callers leave a voice mail and the on-call duty officer monitoring the hotline responds within half an hour. The spill response duty officer notifies appropriate agencies to initiate response. The spill response duty officer also notes in the Aquarius database (see section 3.9) whether spill response is complete or if there is a need for additional follow-up evaluations. Information about the spill hotline is included in the Attachments section at the end of this document. 3.3 Spill Response Additional information about spill response activities is provided in Section 4 of this plan. 3.4 Emergency Response Additional information about emergency response activities is provided in Section 5 of this plan.


3.5 Employee Training The City has made great strides over the last decade in educating both public workers and private citizens about the negative impacts that can result from spills and other material releases. The City began to develop education and training activities and materials in the 1990s in response to requirements of its NPDES MS4 permit, and education and training BMPs are included in the Stormwater Management Plan the City implements under the MS4 permit. General pollution prevention and response messages are provided on an informal basis during routine staff meetings and safety meetings. These meetings reach City personnel from managers to line employees. Specialized training events are scheduled as needed. In 2006, the City created a training video called Stormwatch, which serves as an outreach and education tool for various City bureaus. City maintenance staff in the Bureaus of Maintenance (BOM), Water, and Parks and Recreation receive training on spill prevention and control. The training focuses on the prevention or retention of materials onsite as the primary best management practice to prevent releases. Many City-owned and operated facilities have been modified and have put operating procedures in place to ensure spill prevention and control. 3.6 Public Education 3.6.1 General Public Education and Outreach The City routinely includes spill prevention messages in educational and outreach materials. The spill prevention and control messages are usually linked to a “Working for Clean Rivers” message, which is the guiding principle for all activities carried out to achieve the BES mission. City education efforts emphasize pollution prevention activities, but also typically include information on spill control and response, along with the City’s spill response hotline number. An example of an educational fact sheet is included in the Attachments section at the end of this plan. 3.6.2 Fact Sheets BES provides business owners with a fact sheet that identifies general spill response actions and specific prevention guidelines for creating an appropriate Emergency Response and Spill Control Plan. Each plan is specific to the types of onsite activities that take place. Businesses are responsible for implementing their plans. The fact sheet BMP 4: Emergency Response and Spill Control Plan is included in the Attachments section at the end of this plan.

The full set of fact sheets can be downloaded from the BES Industrial Stormwater Program website: www.portland.online.com/ bes/index/cfm?c=dbiee


BES also provides businesses with specific BMP fact sheets that supplement BMP 4. Two of these fact sheets are provided in the Attachments section at the end of this plan. BMP 7: Fueling Stations provides site plan recommendations for preventing contamination in stormwater runoff from fueling areas. BMP 3: Loading and Unloading Materials provides site plan recommendations for loading and unloading materials and guidelines for the activity area setup and management. Additional fact sheets that BES provides to commercial and industrial businesses are: • Outside Storage of Raw Materials and Intermediate Products, By-Products, or Finished

Products • Outside Container Storage and Waste Disposal • Emergency Response and Spill Cleanup Plans • Aboveground Tank Storage • Outside Manufacturing Activity • Vehicle and Equipment Washing • Vehicle and Equipment Maintenance • Sandblasting and Painting Operations • Inspection and Monitoring Activities • Dust Control • Erosion and Sediment Control • Non-Stormwater Related Discharges • Employee Training • Mobile Fueling Activities • Maintaining Catch Basins A City of Portland Accidental Spill Prevention Plan (ASPP) may be used in place of an Emergency Response and Spill Cleanup Plan. An ASSP Worksheet identifies ASPP requirements (see Attachments section). DEQ provides a fact sheet titled Your Role in Spill Response: What to Do if You Have a Spill (see Attachments section). The fact sheet defines reportable quantities, provides information for reporting spills and guidelines for general spill response actions, and describes DEQ’s role in ensuring that cleanup has been properly completed. 3.7 Spill Prevention Materials City staff are often first on-scene at the site of a spill or materials release. Fire & Rescue and BES are the primary responders to spills in the City’s rights-of-way. BOM is the lead responder in the case of sewer overflows and sewage releases. Staff response vehicles and work vehicles are supplied with varying degrees of spill prevention and containment kits. For BOM and Parks & Recreation, spill kits provide the equipment necessary to control materials releases from their own operations and vehicles. For Fire & Rescue and BES, spill kits are designed to provide the equipment necessary to contain materials released by other parties.


The following sample list identifies the types of supplies contained in the spill kits carried by every BOM maintenance vehicle. • White 6-gallon bucket with lid and red plastic opener • One 32-gallon heavy-duty garbage bag • ½ gallon of specialized absorbent material in heavy-duty garbage bag • Three 3x3-foot oil absorbent booms • Four 18x18-inch oil absorbent pads • One pair of safety glasses • Two pairs of rubber gloves • One dust mask • Six zip ties • Metal staples (for holding pads) • One aluminum pie pan The following list identifies the primary types of supplies contained in the spill kits carried by Fire & Rescue trucks and engines. These supplies can be used to prevent flows from reaching inlets, contain flows that have reached the ground surface or surface water, or to clean up small amounts of fluid. • 24x24-inch absorbent pads • Dux seal for slowing or stopping minor leaks • Rubber mats to block flows to catch basin inlets or manholes • Cat litter or other clay-based sorbents • Visqueen and hand tools for diking purposes Fire & Rescue also manages boat stations, HAZMAT team stations, and shipboard stations, which carry a larger inventory of the supplies listed above, along with sorbent booms for land or water-based pooled products. 3.8 Containment Facilities Containment facilities exist in many areas of the City. In the high-risk areas in the Columbia South Shore Well Field, the City constructed specific containment pond facilities for street runoff from the Airport Way infrastructure built in the 1980s and 1990s. Containment is also a primary element for all new development that has activities or areas of concern for spills and materials releases. The Stormwater Management Manual (2004) and Columbia South Shore Well Field Wellhead Protection Area Reference Manual (2003) require certain facilities to construct containment areas for their materials storage, outside processing, and washing operations. In addition, since the early 1980s, the City’s standard construction specification for UICs in the public right-of-way has included a sedimentation manhole to provide some spill containment capacity. These containment elements all work in concert to prevent spills and materials releases into City-owned UICs.


3.9 Contaminated Media Management Plan BES created a Contaminated Media Management Plan (CMMP) in 2005 for controlling contaminated media. The plan is used to manage contaminated media that may be discovered during standard construction projects. The plan describes general pretreatment procedures for sampling, zone exclusion, decontamination, dewatering, and materials management practices at contaminated sites. It requires contractors to report any suspicious findings (e.g., odor, stains), including potential contamination, and to update applicable plans (e.g., spill response, health and safety, sampling and analysis) upon discovery of site contamination. The CMMP is used as a framework for developing site-specific plans to ensure protection of human health and the environment. These plans are designed to reduce or eliminate the introduction of contaminated media to public UICs, or other stormwater collection systems, during construction activities. 3.10 Tracking Systems Spill and emergency response records are maintained in a variety of systems within the City, but most critical information located in the BES Spill Prevention-Citizen Response (SPCR) Section’s Aquarius database. As discussed in Section 3.2, the SPCR Section implements the City’s spill response hotline. The database identifies the location, time, and response measures implemented to address specific spill incidents or other emergencies. It also identifies the impacted system and attempts to estimate the amount and type of materials released. SPCR staff complete a Materials Release Incident Form (included in the Attachments section) during onsite response and evaluation. All calls received on the City spill response hotline are entered into the Aquarius database, regardless of the size of the spill. The Aquarius database fields include but are not limited to: • Organization ID • Organization name, address, and phone • Permit classification (industrial, stormwater) • Complaint date and time • Pollution complaint type (residential, commercial, project) • Pollution type (collection system, runoff) • BES case assignment (staff member name) • Satisfied? (Y/N) • Referred? (Y/N) • Referred to? (BOM, BDS, Contractor, State, Federal) An example of an Aquarius database pollution complaint data entry form is included in the Attachments section. In addition to tracking through the Aquarius database, information about any spills and response actions will be included in each Annual UICMP Report.




4 Typical Spill Response Actions 4.1 Typical Spill Response Actions for UICs in the Public Right-of-Way Spills can include accidental, unintentional, and intentional releases of waste materials to any of the City’s four types of drainage systems: combined sewer, separated sanitary sewer, separated storm sewer, and UICs. These unintentional releases can occur from activities that occur on public or private properties. Spills are the most routine emergency events with potential impacts to UICs in the public rights-of-way. Responsibility for spill response activities within the City of Portland is shared between City, State, and Federal governments, depending on the location of the release and the resource that may be impacted. Both City and State agencies operate spill response hotlines within the City of Portland. As discussed in Section 3.2, BES staff from the Spill Protection-Citizen Response (SPCR) team monitor the City hotline 24 hours a day, 365 days a year to investigate spills, slicks, and suspicious discharges. Hotline calls are answered directly during business hours; after hours and on weekends, callers leave a voice mail and the on-call duty officer monitoring the hotline responds within half an hour. When a spill is reported to the BES hotline, the duty officer who receives the call may also notify the Bureau of Fire & Rescue and DEQ via the Oregon Emergency Response System (OERS). All three parties require notification when spilled materials exceed reportable quantities,1 and they work together to ensure that the cleanup is done in a way that protects human health and the environment. Approximately 1,200 calls regarding pollution complaints, spills, sanitary sewer overflows, dye tests, and seepage discharges are reported to City staff each year. Some oil or hazardous material spills require a separate notification to the National Response Center. The Center’s website provides information necessary to determine whether a spill needs to be reported to the federal system. Contact information for the National Response Center is provided in the DEQ fact sheet included in the Attachments section at the end of this document. Fire & Rescue is an initial City responder to spill emergencies. Fire & Rescue notifies BES of any release of materials and, once life and safety are preserved, takes steps toward spill containment, using adsorbents, socks, material booms, and inlet mats. When BES receives a Fire & Rescue referral or receives the initial spill call, it assesses the drainage system to determine the need for containment or pretreatment controls. BES works with Fire & Rescue, OERS, and other appropriate agencies to add containment or pretreatment controls (e.g., oil booms) to the site. After the initial emergency response, BES is responsible for cleaning any remaining quantities of pollutants that have discharged to City facilities and have the potential to harm groundwater or surface water. For discharges to UICs, BES evaluates the site and either requests immediate

1 Reportable quantities are defined by EPA as a spilled material in excess of 42 gallons, any material that could create a sheen on local receiving waters, and anything that could enter the City’s storm sewer system.

Section

4


cleaning by an outside contractor or requests a work order for the Bureau of Maintenance (BOM) to clean out the UIC. BES also evaluates the need for response actions that go beyond cleaning of the UIC. The following factors are considered when evaluating the potential for impacts to groundwater and the appropriate cleaning procedures or response actions: • Chemical constituent: If the spill is of a hazardous or toxic chemical, petroleum product, or

other dangerous chemical, BES hires an outside emergency cleanup contractor for immediate cleaning of the sedimentation manhole and UIC and disposal of associated residuals.

• Solubility of constituent: If a chemical consistently adheres to particulates, there may be a

likelihood that pollutants would be concentrated in the sediment manhole or UIC. BES hires an outside emergency cleanup contractor to clean the facility and properly dispose of residuals.

• Volume: If the spill volume exceeds the sedimentation manhole and enters a UIC system, an

emergency response is triggered. • Pending weather conditions: If a spill event occurs during dry weather, the response may be

different than when a release will be mobilized by active or pending rainfall. New City enforcement rules passed in 2006 allow for enhanced cost recovery from known responsible parties. For spills that do not have an identifiable responsible party and have low risk features (e.g., a sewer sludge spill), a standard BOM cleanup work order is issued. The final step is completed when the assigned SPCR permit manager notes in the Aquarius database (see section 4.7) that he or she is satisfied with the spill response and there is no need for any additional follow-up evaluations—i.e., there is no longer the potential for negative impacts to groundwater from the spill. 4.2 Typical Spill Response Actions for UICs on Other Public Properties The majority of City facilities, especially those that operate, maintain, and store equipment and supplies, have active site-specific spill plans. These plans typically identify pollution control, spill prevention, and spill response procedures aimed at minimizing any release of materials. 4.2.1 Typical Procedures for All City-owned Properties BES provides business owners with a fact sheet that identifies general spill response actions and specific prevention guidelines for creating an appropriate Emergency Response and Spill Control Plan. The fact sheet BMP 4: Emergency Response and Spill Control Plan is included in the Attachments section at the end of this plan. Each City spill plan is developed to be consistent with the information and activities recommended in this fact sheet. Each City facility is responsible for implementing its site-specific plan.


. Spill prevention and response plans for City-owned properties generally provide the following site-specific information: • Notification procedures and contact information for emergency and first responders. • Procedures for immediate containment of the spilled or released materials, usually with

berms, mats, cat litter, or other materials, to prevent released materials from entering nearby catch basins or other discharge locations.

• Location and content of site-specific spill kits for materials transportation trucks, storage

yards, and other City facilities. • Use of cleanup staff and/or outside contractors to collect, process, and appropriately dispose

of released materials. • Training and education for employees about the above procedures. 4.2.2 Parks Integrated Pest Management Program The Parks Integrated Pest Management (IPM) Program specifically calls out procedures for spill prevention and control of pesticides, fertilizers, and other horticultural materials used by Parks staff. Spill prevention is predominantly concerned with the control of pesticide-related materials. All pesticide application trucks are equipped with spill kits. Spill kits also exist in many of the storage yard areas on Parks properties. Specifically trained staff are available to respond to any site spill event. Most spilled materials are collected, transported, processed, and disposed of by outside contractors.




5 Emergency Preparedness, Prevention, Mitigation, and Response

5.1 Introduction The City operates under the National Incident Management System (NIMS) during all emergency conditions in Portland. The City’s Office of Emergency Management serves as the interagency coordinator for emergencies and disaster response, in partnership with local, state, federal, and private entities, and manages the City’s Emergency Operations Center (EOC). Emergency preparedness is coordinated and in compliance with the Oregon State Office of Emergency Management. A number of other City bureaus are also active in the NIMS system, especially BES, Water, and the Office of Transportation (including the Bureau of Maintenance— BOM). City Code (Title 15: Emergency Code) outlines the powers of the mayor and successors. City response operations are detailed in the City’s Basic Emergency Services Plan (2006) and its associated annexes (appendices) and in the Natural Hazard Mitigation Plan (August 2005) that was completed to comply with the Disaster Management Act of 2000. Each of the individual annexes (hazard-specific plans) within the Basic Emergency Services Plan is routinely updated. These plans address the following hazards that could cause an emergency situation:

Hazard Addressed in Basic Emergency Services Plan

Addressed in Natural Hazard Mitigation Plan

Earthquake Fire and Wildfire (Wildfire) Landslide Extreme/Severe Weather Snow and Ice Water Flood Drought Volcano Terrorism Riot/Demonstration Chemical, Biological, or Hazardous Materials Release

Dam and Levee Failure While all of the above emergencies could have an impact on UICs, the highest-risk, non-spill- related emergencies are floods, fires, earthquakes, volcano eruptions, and severe weather.

Section

5


5.2 Fire Fires can have two main impacts on UICs: the dispersal and runoff of fire wastes and the erosion of soils bared by fires. The Portland Bureau of Fire and Rescue is the lead responder for both urban fires and wildfires. After arriving onsite, they assess the situation for appropriate response. Once life and safety are preserved, they will also take steps toward spill containment, using adsorbents, socks, material booms, and inlet mats. For larger commercial or industrial site fires or for a two-alarm or greater fire, Fire & Rescue contacts the BES Spill Prevention-Citizen Response (SPCR) hotline. The SPCR team responds by alerting the permit manager who is most likely to be familiar with the site activities and business practices. The spill response duty officer responds to calls that come in after hours. SPCR staff and permit managers rotate in filling the role of the after-hours duty officer. BES staff assess which drainage system the fire wash-off may enter and what level of containment and response may be needed. In some cases where industrial solvents or fertilizer products are present, the fire may be allowed to burn itself out without exposing the site to water, which could mobilize these products. For UICs, BES notes the location and type of material potentially released from the fire site. If there is a material of concern on the fire site, BES may call out an emergency hazardous materials response cleanup crew to prevent materials from entering outlets or for immediate material removal. If the material is of lower concern, BES will try to prevent flow to inlets and UICs and, if necessary, a BOM work order is issued to clean the sedimentation manhole and UIC on a priority schedule, usually within 2 to 5 days. For unvegetated slopes, the City strives to reestablish vegetation quickly, preferably through coordination with the responsible party. Additional street sweeping may be required to adequately clear air deposition materials. BES always strives to identify responsible parties and ensure quick cleanups. 5.3 Flood BOM is the lead responder in the case of floods caused by system clogging, rainfall exceeding system capacity, levee breakage, or stream bank overtopping. A number of locations within the City limits are prone to flooding and have UICs. These areas are predominantly in inner and outer SE Portland, especially along Johnson Creek. The majority of pollutants released during flood events are sediment and debris; however, floods also mobilize petroleum products and can create releases of other more hazardous materials, depending on the extent and level of the flooding. The City has had a great deal of practice with flood response and has provided some flood prevention and cleanup activities for City residents for over four decades. The City’s Basic Emergency Procedures Flood Response Plan (2003) lays out the procedures and goals of the


City’s emergency response to floods. That plan includes the 2002 Consolidated Drainage Districts Emergency Plan for reference and coordination. The Flood Response Plan identifies eight prioritized goals. Goals one and two address life and safety goals; goal three addresses environmental protection; goals four and five concern the protection of street and drainageway systems; and the remaining three goals are prioritized flood-fighting activities. During flooding events, the City tries to keep hazardous or toxic materials on public or private property away from anticipated flood waters. The City sand bags and, in some cases, provides cleaning operations. City personnel work around the clock to try to keep all types of drainage systems in operation. After waters recede, enhanced cleaning of UIC systems that have been impacted or clogged by flood debris occurs. 5.4 Earthquake The Basic Emergency Services Plan calls for a unified command among the Fire, Police, Maintenance, and Water bureaus to manage earthquake events. A major earthquake is likely to have significant impacts on UICs. At least three crustal faults underlie the region and could generate earthquakes as large as 6.5 on the Richter scale. A Cascade plate subduction zone quake could be as high as magnitude 9.0. Both are predicted to happen sometime in the future. The City’s Earthquake Plan (2003) specifies that responders will prepare a report on the status of City resources, including structures, as a first step after a major earthquake. Because they are underground, UICs will not likely be assessed in this initial report unless they cause a significant impact to a roadway (e.g., a sink hole). The Earthquake Plan specifically notes that it may take days to fully assess the damage. Perhaps the largest impact of an earthquake will be structural damage to UICs or sedimentation manholes. UICs may fail and collapse, and drainage connections between sedimentation manholes or inlets and sumps may be severed. Given the potential for significant infrastructure damage, there are likely to be releases of sewage, water, and mobilized materials from rights-of-way and private sites overflowing into City UICs. Primary priorities for earthquake response will be for human health and safety. UIC system protection and restoration will be prioritized relative to overall citywide life and safety issues. 5.5 Volcano BOM is the lead responder in the event of a volcanic eruption. The most likely impacts to the City and its UIC systems come from airborne ash. Ash not only clogs system inlets and sumps, but also negatively affects the pH, total suspended solids (TSS), and metals levels in the materials collected by UICs. Approximately 14 percent of the winds surrounding Mount St. Helens blow toward the Portland area and have the ability to deposit significant amounts of ash. Mount Hood is even closer and could have an even more significant ash impact. When Mount St. Helens erupted in 1980, the City took on a huge ash recovery effort that was not fully planned out. In 1982, the City completed a formal Volcanic Ash Removal Plan for Portland. This plan specified the following impacts of ash in the urban area:


• Health impacts to individuals breathing air. • Vehicular and pedestrian accidents from low visibility. • Clogged and damaged City sewerage systems. • Mechanical equipment failure caused by the abrasive nature of the ash. • Economic losses caused by business slowdowns and the cost of ash removal.

The 1982 plan called for differing response actions, depending on the level of ash accumulation. Small amounts would be managed by the City’s street sweeping program. For larger amounts, the City instituted a policy requiring private properties to clean sidewalks and roofs within 48 hours after the notice requiring cleaning. All materials would be stockpiled behind curbs or hauled to designated dumpsites. City street sweepers would give priority to business districts and along arterials, sandbagging necessary storm sewer inlets in areas with UICs or other stormwater facilities. Citizens would be asked to clean residential streets, stockpile materials behind the curb; the National Guard provides support for collection and disposal of materials. City sweepers would assist after priority areas were cleaned. During the minor Mount St. Helens eruptions of 2004, the City revisited the elements of the 1982 plan to ensure ash collection and disposal needs were in place. This 2004 effort identified the need to find designated disposal sites away from the standard solid waste stream. It also recognized that streets without curbs, even if they are arterials, would not be cleaned until after improved streets. The 2004 work also created a map with priority stormwater facility areas. The map identifies sumps without sedimentation manholes as a priority for protection measures. Both the 1982 and 2004 plans acknowledge that it is critical to educate the citizens of Portland not to wash ash into drainage systems. All written and verbal communication materials (fact sheets, newspapers, broadcast messages, etc.) and messages associated with an impending event would include this information. 5.6 Severe Weather BOM updates the City’s Snow and Ice Plan annually. The plan goes into effect by November 1 and includes an equipment and supplies inventory and personnel training in methods and safety. Storm response activities are implemented on varying levels, depending on the severity of the snow or ice accumulation. The fundamental goals of the program are to reduce life-threatening and injury-producing conditions and to reduce the interruption to the economic life of the City. Sanding, plowing, snow removal, and the use of anti-icing chemicals are used in various locations throughout the City. Sanding of the public right-of-way is the primary method of snow and ice response implemented within the City of Portland. BOM is responsible for sanding all major arterial routes: 1,259 lane miles. The City does not generally sand individual residential streets. Snow and ice response is prioritized on certain roadways throughout the City, including an established road network needed to access emergency services and hospitals. Specific staff members are assigned to these primary routes and designated hazard areas (such as bridges).


BOM enhances street sweeping after the ice or snow event has passed to reclaim materials for reuse. BOM operates a recycling facility where sanding material is washed and stored for reuse.

When conditions do not favor the use of sand, BOM uses limited anti-icing chemical products on about 225 miles of roadways that are crucial transportation routes. Anti-icing is the practice of preventing the formation or development of bonded snow and ice. Calcium magnesium acetate (CMA) is the standard anti-icing agent used for these applications. Potassium acetate may also be added in the rare instances of weather dropping below 17 degrees F. Both anti-icing agents add to the effectiveness of sanding. The decision of what type of product to use (CMA or potassium acetate) is driven by the objectives of the Snow and Ice Plan: • Provide a street surface free enough of ice, snow, or slush to allow reasonable traffic. • Discourage private vehicles, encourage mass transit. • Reduce accidents, bottlenecks, known hazard locations. • Improve emergency response. • Accommodate commerce.




6 Roles and Responsibilities This section describes the roles and responsibilities assigned to City bureaus for controlling and responding to spills and emergencies. These roles and responsibilities are clearly defined and communicated citywide to ensure effective coordination and management. The WPCF permit designates BES as the bureau responsible for implementing the WPCF permit and for identifying and managing the regulatory and technical components of the UIC Program citywide and across bureaus. BES will work with other bureaus and stakeholders to implement the SPPC Plan, meet permit conditions, and oversee implementation of other UIC Management Plan programs. Table 6-1 summarizes the roles and responsibilities for spill prevention and pollution control by each City bureau. [Section 3 provides additional information about specific activities, with cross-references to the responsible bureau(s).]

Table 6-1 Roles and Responsibilities for Spill Prevention and Pollution Control

Bureau/Staff Member Area of Responsibility and Authority

UIC Program Manager: Mary Stephens

• Develop, recommend, and oversee implementation of UIC Program, budget, and policies with assistance from the Division and Group Managers.

• Ensure UIC Program management and regulatory requirements are identified, implemented, and maintained in accordance with BES policy and the WPCF permit.

• Ensure that UIC Program personnel have the appropriate qualifications, knowledge, and experience.

• Report to BES management on UIC Program performance. • Liaison with DEQ and other interested parties regarding the UIC

Program. • Provide citywide coordination of UIC Program requirements. • Review and approve UIC plans and documents; ensure adequate

resources are allocated to the UIC Program.

System Management Project Manager: Joel Bowker

• Implement the UIC System Management program element to meet permit requirements and protect groundwater.

• Evaluate existing program activities; develop and recommend changes to the program element.

• Implement systemwide BMPs, including the SPPC Plan and BMP PC-1.

• Develop and maintain the UIC Database. • Prepare annual UICMP reports and associated plans/reports as

required. • Help prepare corrective action strategies and priorities.

Section

6



Bureau Role/Responsibilities

Office Of Emergency Management

• Centralizes leadership and coordination responsibilities for emergency management into a single organization under the direction of the mayor.

• Conducts planning, training, exercises, and educational outreach programs related to natural and manmade disasters to assist and prepare citizens, government agencies, and private/nonprofit organizations prior to, during, and after a local emergency or disaster.

• Manages the City’s Emergency Operations Center (EOC) during any major emergency or disaster and activates emergency warning systems.

• Works as an interagency coordinator in partnership with local, state, federal, and private entities to provide comprehensive planning, response, mitigation, and recovery capabilities for all hazard potentials facing the City of Portland.

Portland Fire & Rescue

• Acts as a first responder in almost all emergency situations. Its first site responsibility is to life, environment, and property.

• Performs an initial evaluation of emergency conditions, assessing needs to contain and control the emergency and the initial emergency response.

• Maintains a variety of facilities where spill prevention is a primary goal.

Bureau of Environmental Services (BES)

• Acts as a first responder in coordination with Fire & Rescue. Spill Protection-Citizen Response staff respond immediately to emergency spills and investigate pollution complaints. A duty officer monitors messages 7 days/week, 24 hours/day.

• Provides stormwater drainage services and works in Portland’s watersheds to reduce stormwater pollution, restore native vegetation, and improve the quality of water in rivers and streams. Determines the potential impact of polluted stormwater flows reaching the system.

• Works with other bureaus and stakeholders to implement the UIC Program and SPPC Plan, and meet permit objectives.

• Provides a variety of educational and regulatory programs aimed at spill and waste prevention.



Bureau Role/Responsibilities

Bureau of Maintenance (BOM)

• Responsible for preserving the public investment in transportation facilities and in sewer infrastructure by inspecting, cleaning, maintaining, and repairing all transportation and sewer- related infrastructure within the City of Portland.

• Performs around-the-clock response to emergencies such as storms, floods, and other incidents that inhibit safe transportation.

• Leads severe weather response, volcano response, flood and levee failure response, and shares the lead in a unified command for earthquake response.

Bureau of Water Works Bureau of Parks and Recreation

• Not first responders unless the emergency occurs on their sites or as a result of their field activity.

• Field operations and maintenance staff work to prevent, respond to, and clean up after spills and other emergencies.

• Target resource areas (reservoirs, wellhead areas, natural stream areas) for enhanced protection during various emergencies.

Bureau of General Services Portland Police Bureau

• Operate and maintain a variety of facilities where spill prevention is critical.

• Provide important logistical support during emergency situations.



Attachments


Spill Prevention and Pollution Control Plan A-1 December 2006









Aquarius Database Pollution Complaint Data Entry Form

Appendix D

Decommissioning Procedure (Final) for UIC Systems



City of Portland, Oregon Water Pollution Control Facilities (WPCF) Permit For Class V Stormwater Underground Injection Control Systems Permit Number: 102830 Decommissioning Procedure Stormwater Underground Injection Control Version: Final December 2006 Prepared By: City of Portland, Bureau of Environmental Services

UIC Decommissioning Procedure Page i December 2006 Version: Final

Summary of Revisions to Draft 1 UIC Decommissioning Procedure December 1, 2006

Description Corrected

Document Major Amendments

Decommissioning Procedure Final General minor text amendments. Figure 1—Sampling Flowchart Deleted

Step 3 Identify UIC Type and Determine Sampling Requirements

Final - Information for previous Step 3 has been replace with Appendix A—UIC Decommissioning Sampling and Analysis Plan

- Appendix A provides detailed sediment and water sampling procedures and analytical laboratory methods for use when decommissioning a UIC

Step 4 Collect Required Samples

Final - Step now references Appendix A—UIC Decommissioning Sampling and Analysis Plan

Step 5 Review Sample Analytical Results

Final - Step now references Appendix A—UIC Decommissioning Sampling and Analysis Plan

1 “UIC Decommissioning Plan (Draft)” submitted to DEQ in October 2005. Prepared by the City of Portland.

UIC Decommissioning Procedure Page ii December 2006 Version: Final

TABLE OF CONTENTS Page 1 Introduction and Organization ............................................................................................. 1-1

1.1 Purpose and Applicability .............................................................................................. 1-1 1.2 Regulatory Requirements ............................................................................................. 1-1

2 UIC Decommissioning Procedure and Work Sequence .................................................... 2-1 3 Key Personnel for UIC Decommissioning ........................................................................... 3-1

Appendices A UIC Decommissioning—Sampling and Analysis Plan Attachments 1 Stormwater Management and Disposal Hierarchy

2 DEQ UIC Pre-Closure Notification Form 3 City of Portland UIC Inventory 4 Waste Profile Sheet 5 Batch Discharge Permit Request Form

UIC Decommissioning Procedure Page iii December 2006 Version: Final

This page intentionally left blank.

UIC Decommissioning Procedure Page iv December 2006 Version: Final

EXECUTIVE SUMMARY

This UIC Decommissioning Procedure provides the general steps and requirements for decommissioning (i.e., taking out of operation) Class V public underground injection control systems (UICs) in the City of Portland. This procedure is a requirement of the Water Pollution Control Facility (WPCF) permit issued to the City of Portland by the Oregon Department of Environmental Quality (DEQ) on June 1, 2005. All City personnel and contractors conducting UIC decommissioning activities should comply with this procedure to the extent that the requirements apply to the nature and scope of their work. The procedure has the following twelve steps:

Step 1: Describe General Characteristics of UIC to be Decommissioned. Step 2: Conduct Site Inspection of UIC; Note Any Contaminants of Potential Concern. Step 3: Determine Sampling Requirements. Step 4: Collect Required Samples. Step 5: Review Sample Analytical Results. Step 6: Prepare Follow-up Site-Specific Sampling Plan (if required). Step 7: Prepare Site-Specific Contaminated Media Management Plan (if required). Step 8: Develop Alternative Stormwater Management Design for UIC. Step 9: Prepare and Submit DEQ UIC Pre-Closure Notification Form. Step 10: Prepare Decommissioning Scope of Work and Select Contractor. Step 11: Decommission UIC (Field Procedure). . Step 12: Prepare Closure and Decommissioning Report.

Key personnel for the UIC permit program and their areas of responsibility are identified in Section 3.0

UIC Decommissioning Procedure Page v December 2006 Version: Final


UIC Decommissioning Procedure Page 1-1 December 2006 Version: Final

1 Introduction and Organization 1.1 Purpose and Applicability The purpose of this document is to provide the procedure and general requirements for decommissioning Class V public underground injection control systems (UICs) in the City of Portland. The procedure is a requirement of the Water Pollution Control Facility (WPCF) permit issued to the City of Portland by the Oregon Department of Environmental Quality (DEQ) on June 1, 2005. It is part of the comprehensive City of Portland UIC Management Plan (submitted December 2006). The procedure applies to standard City-owned Class V UICs identified for decommissioning. As defined by the DEQ permit, a standard City UIC is generally considered to be a UIC constructed in accordance with City construction specifications and having adequate separation between the UIC and groundwater. Decommissioning of non-standard UICs will generally follow this procedure, but may require additional information in a site-specific closure work plan. Examples of non-standard UICs are those that intercept groundwater or have been determined to have adversely impacted soil or groundwater. This procedure has been developed for use by the designated project mangers from all City bureaus. All City personnel and contractors conducting decommissioning activities must comply with the procedure to the extent that the requirements apply to the nature and scope of their work. 1.2 Regulatory Requirements Under Oregon Administrative Rules (OAR) 340-044, DEQ developed and issued a WPCF permit for the City of Portland in June 2005. The permit regulates the construction, operations, and maintenance (including alterations and decommissioning) of all of the City’s Class V public UICs. The City currently has approximately 9,000 UICs that collect stormwater from public rights-of-way and discharge it to the subsurface. UIC structures are most prevalent in the eastern portion of the City, where the subsurface soils support greater drainage and infiltration rates. For many areas east of the Willamette River, UICs are the only form of stormwater disposal available. The WPCF permit contains specific criteria and conditions that City-owned UICs must meet [Schedule F, Section 5gg. and OAR 340-044-0015(2)]. Under the permit, the City must identify UICs that are non-compliant with permit conditions and implement corrective actions to address any system deficiencies. Under the City’s UIC Management Plan (UICMP), the City will continue to track, update, and refine information related to the UIC system, as part of the System Inventory and Assessment Best Management Practice (BMP) under the System Management

Section

1 As used in this document, UIC means a Class V underground injection control system owned or operated by the City of Portland.


program element. This information will be used to identify and apply the management practices specified in the UICMP to ensure the UIC system meets permit requirements. If a City-owned UIC cannot meet the criteria provided in the WPCF permit and cannot be upgraded or altered to meet the criteria, then the UIC system must be decommissioned and stormwater managed using an alternative method. Alternative stormwater management methods must be consistent with watershed health goals and developed in accordance with the stormwater management and disposal hierarchy (Attachment 1) established in the City’s Stormwater Management Manual (SWMM). UICs that need to be decommissioned may be identified during the course of city projects to upgrade or retrofit facilities, during the comprehensive UIC System Inventory and Assessment BMP (e.g., Systemwide Assessment Report, submitted to DEQ on July 15, 2006), or during routine program management activities. DEQ and the Oregon Water Resources Department (WRD) have regulatory requirements for the decommissioning of subsurface wells. UICs must be decommissioned in a manner that complies with the federal and state prohibition of fluid (stormwater) movement, as outlined in 40 CFR 144.12 and 144.82a and OAR 340-44-0040. Oregon well-abandonment standards are designed to prevent contamination of the well or aquifer beneath the well by surface and subsurface leakage that may carry harmful chemicals or bacteria. This Decommissioning Procedure has been developed using the following guidance and reference documents.

• WPCF Permit (No. 102830) for Class V Stormwater Underground Injection Control Systems; Schedule C, Section 17 and Schedule D, Section 10 (issued by DEQ in June 2005)

• Oregon Administrative Rules (OAR) 340-044-0040: Decommissioning and Conversion Requirements for Underground Injection Systems

• Federal 40 CFR 144.12 and 144.82a: Underground Injection Control Regulations for Class V Injection Wells

• Guidelines for Characterizing, Closing and Abandoning Shallow Injection Wells (EPA Region 10 closure manual, March 2001)

• Underground Injection Wells for Stormwater Best Management Practices Manual (Oregon Association of Clean Water Agencies, January 2003)

• City of Portland, Bureau of Environmental Services: UIC decommissioning work plans approved by DEQ, as follows:

− Underground Injection Control Decommissioning Work Plan, SE 60th and Steele, BES Project No. 7097, April 20, 2005

− Shallow Underground Injection Control Decommissioning Work Plan and Closure Report, BPA St. Johns Substation, BES Project No. 6781, November 2003

• Oregon Department of Environmental Quality Class V Pre-Closure Notification Form (DEQ\WQ\document # UICclosure-1000, 07/02)


2 UIC Decommissioning Procedure and Work Sequence This section provides the procedure and work sequence for decommissioning Class V public UICs within the City of Portland. NOTE: The City must fill out and submit a Class V UIC Pre-Closure Notification Form to DEQ at least 30 days before conducting any onsite physical decommissioning work. The form is provided as Attachment 2 to this procedure. The procedure steps identified below include gathering the information needed to fill out and submit the form.

Section

2


UIC Decommissioning Procedure and Work Sequence Step 1 Obtain and Document General Information of UIC Facility to be Decommissioned.

Action/Information Required Responsibility

Obtain the following information, as necessary and appropriate: • UIC Facility name (legal name and/or common name) • Owner/operator of UIC—include legal contact and contact information

(phone, email, fax). • Location of UIC including

• Address of UIC (physical and mailing address if available) • Latitude and longitude

• UIC BES Hansen Node number (if available and registered) • DEQ Identification Number • Identify commercial or industrial facilities that may discharge to the subject

UIC (also see Step 2) • Identify potential facilities using DEQ’s Facility Profiler

(http://deq12.deq.state.or.us/fs20/). • Nature of business using UIC (if any); SIC/NAICS code if known

• Year of construction/installation • UIC design and size (sump, drywell, floor drain, septic tank, drill hole, other) • UIC construction depth (total depth of UIC from ground surface and

estimated location of perforations) • Geologic (soil type) and hydrologic conditions (depth to groundwater) • Water level and sediment depth present in the UIC (referenced to bottom of

UIC) • Vicinity and site maps • Zoning designation • Size and type of drainage area • Average annual stormwater flow into UIC, based on drainage area • Tested UIC infiltration design capacity

Note: This information will be used to complete and submit the DEQ UIC Pre-Closure Notification Form (Attachment 2). (See Step 9.) Note: Please contact UIC Program staff and the BES Coordinated Site Assessment (CSA) team to obtain the information required in this step.

Designated Project Manager in coordination with BES CSA team and BES UIC Project Manager


Step 2 Conduct Site Inspection of UIC; Note Any Contaminants of Potential Concern.


A detailed UIC Site Inspection Checklist has been developed for this activity (see Attachment 3). Experienced BES CSA or UIC staff should perform the inspection. The purpose of the inspection is to observe the UIC and surrounding area to identify potential pollutant sources (e.g., utility poles, land use activities (gas stations, auto garage, etc)) that may discharge to the subject UIC and identify potential constraints for UIC sampling or decommissioning activities. As noted on Attachment 3, contact BES CSA staff to have them conduct a review of relevant city, state, and federal databases to identify DEQ Environmental Contaminant Site Information (ECSI) sites, State Fire Marshall hazardous substance lists, spill reports, leaking underground storage tanks (LUSTs), SARA Title III facilities, and other contaminated sites that could have a direct impact on site drainage. Current and past land use history at the site, as well as interviews with current and past staff, can be used to help identify any contaminants of potential concern.

Designated Project Manager in Coordination with BES CSA or BES UIC Project Manager

Step 3 Determine Sampling Requirements.


One sediment (i.e., accumulated stormwater particulate) and one water sample will be collected from within the subject UIC, if present in sufficient amounts, to assure proper management and disposal of contaminated media and to assess potential adverse impacts to groundwater quality.

See Appendix A—UIC Decommissioning Sampling and Analysis Plan for detailed sampling procedures and analytical test methods.

Designated Project Manager in coordination with BES Water Pollution Control Lab (WPCL), BES CSA, or contractor

Step 4 Collect Required Samples.


Collect appropriate water and sediment sample from within the subject UIC, in accordance with Standard Operating Procedures included in Appendix A—UIC Decommissioning Sampling and Analysis Plan, and them to submit the BES Water Pollution Control Laboratory (WPCL)—or the appropriate lab--for required analysis. It is recommended that samples be collected and submitted no later than 30-days prior to decommissioning activities so that analytical results are available to assure proper management of any materials removed from the UIC and to assess is the subject UIC has adversely impacted groundwater quality

BES CSA or WPCL


Step 5 Review Sample Analytical Results.


Compare analytical results with applicable screening criteria identified in Appendix A--and City of Portland’s batch discharge requirements.

• If all sample results are below applicable screening standards, skip steps 6 and 7 and go to step 8.

• If any sample results are above applicable screening standards, determine based on available data and best professional judgement if operation of the UIC has likely adversely impacted soil or groundwater quality (see Appendix A) or if additional investigation is needed (see Step 6). Potential impacts will be evaluated using DEQ’s risk-based protocols or other applicable DEQ risk assessment guidance. Detection of soil or groundwater contamination from the UIC will be reported to DEQ within fourteen (14) days of observation or receipt of sampling results. Go to steps 6 and/or 7 below as appropriate.

WPCL Staff

BES CSA staff

UIC Program staff

Step 6 Prepare Follow-up Site-Specific Sampling Plan (If Required—See Step 5 Above).


Any UIC sample results significantly above applicable screening criteria may require a site-specific follow-up sampling plan. If sampling results are above criteria--consult with UIC program staff and BES Coordinated Site Assessment team before decommissioning activities commence.

Any required follow-up sampling plan should be approved by DEQ before additional sampling begins. A registered professional geologist, engineering geologist, or professional engineer must oversee development of the plan.

If UIC conditions (e.g. non aqueous phase liquid) or sediment/water analytical results indicate that groundwater or soil outside the UIC may have been impacted at a level that would adversely impact the beneficial uses of groundwater:

• BES will determine, in consultation with DEQ, if any additional investigation or response actions are required for compliance with the WPCF permit (see UIC Management Plan—Evaluation and Response program element).

• BES will, if appropriate, prepare a site-specific Sampling and Analysis Plan to assess potential adverse impacts to groundwater from the UIC (see UIC Management Plan—Evaluation and Response program element).

The BES UIC, WPCL and CSA staff will assist, as appropriate, in preparing and implementing follow-up sampling plan requirements

Designated Project Manager in coordination with WPCL Staff, BES CSA staff and UIC Program Staff


Step 7 Prepare Site-Specific Contaminated Media Management Plan if Required


If UIC samples detect contaminant concentrations above naturally occurring background concentration, materials removed from the subject UIC during decommissioning must be managed in accordance with applicable solid and hazardous waste regulations. A Contaminated Media Management Plan (CMMP) describing how impacted media will be excavated, handled, stored, transported, or disposed of off-site should be prepared, if needed. This plan should specify where media would ultimately be disposed of and authorization for disposal should be initiated. A Waste Profile Sheet for solid waste disposal at a DEQ permitted landfill is provided as Attachment 4. This form can also be obtained at http://wmnorthwest.com/landfill/faqs.html

Contact BES Coordinated Site Assessment Team at 503-823-6820 to obtain CMMP form aninstructions on developing a CMMP. The CMMP will be provided to the contractor performing the onsite decommissioning work (see Step 10). Consult with DEQ, as necessary, during preparation of a CMMP.

BES CSA Team and UIC Project Engineer

Step 8 Develop Alternative Stormwater Management Design for UIC.


Prior to UIC decommissioning, a plan to manage the stormwater currently discharged to theUIC system should be developed (UIC replacement, swale, etc.) and implemented. This “alternative plan” will assure proper stormwater management and controls. Alternative storm water management design should consider, but not be limited to, the following: • Stormwater management and disposal hierarchy established in the Stormwater

Management Manual (Attachment 1), • BES policy, • Protection of human health and the environment, • Permit requirements, • Watershed benefits, • Compliance with applicable federal, state and local standards, • BMP short and long-term effectiveness, stormwater flow, long-term reliability,

constructability, implementability, and cost The BES Chief Engineer must approve the alternative stormwater management design(s) prior to UIC decommissioning.

Stormwater management facilities must be properly implemented before on-site decommissioning activities commence. Allow a minimum of 30 days for DEQ design approval.

Designated Project Manager

UIC Engineer with BES Engineering Services (concept and final design)

Step 9 Prepare and Submit DEQ UIC Pre-Closure Notification Form.


The DEQ UIC Pre-Closure Notification Form (Attachment 2) for the UIC must be filled out and submitted to DEQ at least 30 days prior to decommissioning a UIC.

For any additional information, contact Jen Berry at 823-6820, or John O’Donovan at 503-823-7881.

BES CSA Team or Project Manager


Step 10 Prepare Decommissioning Scope of Work and Select Contractor.


BES Engineering (Designated Project manager) and the UIC Project Manager prepare a scope of work for the bid package. The scope of work will be based on the field procedure identified in Step 11.

A contractor is selected in accordance with BES contract procurement procedures.

In accordance with BES construction requirements, the selected contractor will prepare and submit a site-specific work plan to BES that includes the following, as necessary and appropriate: decommissioning work methods and sequence of work, a health and safety plan, a transportation management plan, a contaminated medial management plan, an emergency response plan, and any other information requested or required. The site-specific work plan must be consistent with the field procedure shown in Step 11 and with any other project specifications. BES approves the contractor work plan.

CSA on-call contracts

BES Engineering Services if required

Step 11 Decommission UIC (Field Procedure). Responsibility

The following steps show the general sequence of work for decommissioning standard public UICs. All UICs will be decommissioned in accordance with this procedure and OAR 340-044-0040: Decommissioning and Conversion Requirements for Underground Injection Systems.

Before beginning onsite work, ensure completion of all pre-decommissioning activities (#1 and #2, below).

1) Perform required sediment or water sampling (sediment, water, soil) in accordance with Step 4 of this procedure. Evaluate results to assess if groundwater quality is impacted (see Appendix A) and to characterize sediment and water for disposal purposes. Detection of soil or groundwater contamination from the UIC will be reported to DEQ within fourteen (14) days of observation or receipt of sampling results.

2) Prior to decommissioning a UIC, ensure that approved temporary or permanent alternative stormwater management facilities are in place in accordance with City standard construction specifications.

3) Remove sediment, soil, and water from, or associated with, the UIC (e.g., sediment manhole, lines, inlets) and properly handle, store, transport, and dispose of these materials in accordance with all federal, state, and local regulations and requirements (see Contaminated Media Management Plan).

4) For standard city UICs—remove top cone and first solid concrete section to a depth of approximately 8-10 feet below ground surface—or to a depth approved by the Chief Engineer. Backfill UIC void with Controlled Low-Strength Materials (CLSM), concrete slurry, or other materials appropriate for the site conditions that meet DEQ and WRD requirements.

5) Cover the top of the backfilled UIC with approved geo-fabric material to extend beyond outside of UIC and surrounding backfill. Backfill excavation (approximately 8-10 feet below the ground surface) to access the UIC to the

Designated Project Manager or Contractor


appropriate grade using materials approved by the Chief Engineer. Clean road-base rock material or pea gravel—or other material, may be placed to an appropriate depth for future utility or road construction, as approved by the Chief Engineer. Compact backfill material to design specifications and pave over.

6) Render the UIC system completely inoperable by disconnecting, plugging, and sealing all associated UIC piping in accordance with City standard construction specifications. Wherever feasible and practical (will not cause significant impacts to project budget and schedule or significant impacts to traffic flow), pipe leads directly associated with the UIC and/or sedimentation manhole may be removed during decommissioning activities. Any associated piping or structures left in place will be noted and clearly identified on the City’s mapping systems. This information must be documented in the UIC Closure Report and Hansen Database, as required in Step 12 below.

7) Prepare a closure report at the conclusion of decommissioning activities (Step 12).

Note: If dewatering is required, it may be necessary to apply for a batch discharge permit (see Attachment 5) from the City of Portland and obtain approval prior to decommissioning or dewatering activities. This permit can be obtained from BES’s CSA team. Contact Jen Berry at (503) 823-6820 or Brett Hulstrom at (503) 823-7807.

Step 12 Prepare Closure and Decommissioning Report. Responsibility

At the conclusion and closeout of each UIC decommissioning project, a UIC closure report will be prepared by BES staff and filed in the UIC Program filing system, per permit requirements. The closure report should include the following information:

• Brief summary of UIC condition prior to closure--reason for decommissioning.

• Brief discussion of UIC closure actions taken to ensure the UIC is no longer injecting fluids into the subsurface.

• Documentation of proper disposal of contaminated media.

• Certify by a registered professional geologist, engineer, or approved designated person that the UIC has been properly closed.

• Pertinent documentation of UIC decommissioning (maps, photographs, waste disposal permits if required, transportation manifests, analytical data, etc).

• Clearly document and record in the City’s mapping system database any associated UIC piping that is not removed, and is left in place. This information must also be entered noted the City’s Hansen Database as well

• All other required decommissioning documentation and information identified by the UIC program system assessment project manager entered into the Hansen Database.

Designated Project Manager in coordination with BES Engineering and

BES UIC Project Manager

UIC Program Staff




3 Key Personnel for UIC Decommissioning This section presents the key personnel for the UIC decommissioning activities and their areas of responsibility. The UICMP (Section 7) presents the staff roles and responsibilities for the UIC Program leadership and major program elements.

KEY PERSONNEL AND AREAS OF RESPONSIBILITY Name Bureau Contact

Phone Email Address Areas of Responsibility

Bill Ryan BES 503 823-7203 [email protected]

Engineering Services Chief Engineer Review and approve UIC corrective action design, UIC decommissioning design and construction documents. Approve decommissioning backfill materials.

Mary Stephens BES 503 823-7580 [email protected]

UIC Program Manager Develop, recommend and oversee implementation of UIC program and policies. Ensure UIC Program management and regulatory requirements are identified, implemented, and maintained in accordance with BES policy and the WPCF permit. Liaison with DEQ and other interested parties regarding the UIC Program. Provide citywide coordination of UIC program requirements. Review and approve UIC plans and documents; ensure adequate resources are allocated to UIC Program

Water Resources Program Manager

BES To Be Determined (TBD)s

TBD

Corrective Actions Project Manager Develop UIC corrective action strategies and plans. Develop and implement UIC decommissioning process and procedures. Prepare annual reports and plans as required.

Joel Bowker BES 503 823-6997 [email protected]

System Management Project Manager Implement UIC System Management program element to meet permit requirements and protect groundwater. Develop and main UIC Database. Prepare annual UICMP report and associated plans/reports as required. Assist in preparation of corrective action strategies and priorities. .

Rod Struck BES 503 823-5762 [email protected]

System Monitoring Project Manager Implement System Monitoring and Evaluation and Response program elements to meet permit requirements and protect groundwater. Coordinate and communicate UIC Program and WPCF permit needs (stormwater sampling, source investigations, response actions) with applicable BES UIC personnel. Develop sampling and analysis plans for decommissioning and corrective actions. Coordinate and communicate sampling and analytical requirements to field (CSA or WPCL) and analytical laboratory staff; and assist with data evaluation and reporting Prepare annual UICMP reports. .

Jennifer Berry

BES CSA 503-823-6820 [email protected]

Coordinated Site Assessment Team. Assist with preparation of DEQ UIC Pre-Closure Forms and Contaminated Media Management Plans. Provides general direction for UIC site assessments.

John O’Donovan

BES CSA 503-823-7881 [email protected] Coordinated Site Assessment Manager

Review and approve CSA plans and procedures as required.

Brett Hulstrom

BES (WPCL) 503-823-7807 [email protected]

Review and approve water batch discharge requests and permits. Assist with water quality sampling and analysis requirements.

Section

3


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UIC Decommissioning Procedure Page A-1 December 2006 Version: Final

Appendix A

UIC DECOMMISSIONING SAMPLING AND ANALYSIS PLAN




UIC DECOMMISSIONING SAMPLING AND ANALYSIS PLAN

A 1.0 PURPOSE This sampling and analyses plan (SAP) presents the procedures that BES staff and contractors will follow for collecting and analyzing sediment and water samples prior to decommissioning city-owned underground injection control systems (UIC). This purpose of this SAP is to assure samples are collected in a consistent manner prior to decommissioning UICs. This plan was developed in response to the City of Portland Water Pollution Control Facilities (WPCF) permit, issued by the Oregon Department of Environmental Quality (DEQ) (No. 102830). A 2.0 SCOPE AND APPLICABILITY The UIC decommissioning sampling strategy, presented in this document, was developed based on conversations between the UIC Program, BES Coordinated Site Assessment (CSA) team, BES Water Pollution Control Laboratory (WPCL), Engineering Services, and DEQ. The primary purposes of the sampling strategy are to meet permit requirements, assure proper management and disposal of any material (e.g., sediments or water) removed during decommissioning activities, and provide guidelines for consistent data interpretation. This SAP supercedes the following documents:

• UIC Decommissioning Sampling Plan: Category 1 Corrective Actions – City of Portland. Letter from BES to DEQ, dated February 6, 2006.

• Decommissioning Activities and Sampling Plan. Letter from BES to DEQ, dated January 10, 2005.

• Decommissioning Procedure for Underground Injection Control Systems (Draft). City of Portland, October 2005.

The WPCF permit requires the City to prepare numerous other plans describing how permit conditions will be implemented. This SAP should be used in conjunction with the following documents, as necessary and appropriate:

• Decommissioning Procedure for Underground Injection Control Systems (Final). City of Portland (submitted to DEQ December 2006).

• Final Stormwater Discharge Monitoring Plan – consists of Sampling and Analysis Plan and Quality Assurance Project Plan. City of Portland, August 2006.

• UIC Management Plan. City of Portland, December 2006.


A 3.0 SAMPLE COLLECTION PROTOCOLS This SAP specifically addresses anticipated soil and water sampling to be performed in City-owned UICs prior to UIC decommissioning activities (i.e., completion of DEQ’s Pre-Closure Notification form).

• UICs should not be cleaned before water or sediment samples are collected from the UIC.

• The field sampling and decommissioning work should be conducted under a site-specific health and safety plan.

A 3.1. Sediment Sampling Collect one (1) sediment sample from inside the UIC, in accordance with appropriate BES Standard Operating Procedures (SOP) for soil or sediment sampling, if sediment is present in sufficient amount. SOPs include:

• UIC Program SOP #1.00 – Sediment Sample Collection Procedures for UIC Decommissioning (see attached); or

• BES Water Pollution Control Laboratory (WPCL) Field Operations SOP #5.01a – Sampling of Soil and Sediment (modified as needed for UIC sampling).

If sediment is not present2, or there is an insufficient volume for analysis, no sample will be collected. It is not recommended that soil samples be collected outside the UIC unless specifically required by DEQ. The sample will be submitted to the City of Portland’s Water Pollution Control Laboratory (supported by City-approved contract laboratories) for analyses (see Section 3.4). A 3.2. Water Sampling Collect one (1) water sample from the UIC, in accordance with appropriate BES SOP(s) for water sampling, if standing water is present within the UIC3. SOPs include:

• UIC Program SOP #2.00 – Water Sample Collection Procedures for UIC Decommissioning (see attached); or

• Field Operations SOP #2.02b Grab Sample Collection with Stainless Steel Beaker (modified as needed for UIC sampling);

• Field Operations SOP #2.02c – Grab Sample with a Peristaltic Pump (modified as needed for UIC sampling)

If water is not present4, or there is an insufficient volume for analysis, no sample will be collected.

2 If there is not enough sediment in the UIC to collect a sample, consult with UIC Program staff for additional

sampling that might be required. At this time, for UICs located in and receiving drainage from City right-of-ways, it is not recommended that soil samples be collected outside the UIC.

3 To the extent practicable, the field team should assess whether the standing water is a) stagnant water held by the bottom of the sump; b) groundwater (i.e., water level within perforated zone of UIC); or c) stormwater (i.e., slowly infiltrating UIC).

4 If there is not enough water in the UIC to collect a sample, additional sampling is not required for UICs located in and receiving drainage from City right-of-ways.


The sample will be submitted to the City of Portland’s Water Pollution Control Laboratory (supported by City-approved contract laboratories (e.g., Test America) for analyses (see Section 3.4). A 3.3. Additional Sampling UIC Program, BES Coordinated Site Assessment (CSA), or Field Operations (FO) teams may recommend additional sampling be performed on a case-by-case basis, based on the results of a site inspection or other information reviewed. For example, UICs that collect runoff from industrial or commercial facilities may warrant additional analytical testing, based on pollutants known to be present or suspected at those facilities. No additional sampling should be undertaken without discussion with the decommissioning project manager and UIC Program staff. In addition, field staff may modify the field sampling methods, as needed and appropriate, to optimize the potential of collecting a representative sample. Sampling procedures will be documented in the Daily Field Report. Changes or deviations from the SOPs will be discussed in the UIC closure report. A 3.4. Recommended Sample Analysis Table A-1 presents the recommended sample containers, volumes, preservation requirements, and holding times based on standard EPA-approved methodologies for decommissioning sampling. The analytical laboratory (e.g., WPCL and Test America) will provide all appropriate sample containers and supplies (e.g., bottle labels, custody seals, coolers) required for sample collection and transport. A 3.4.1. Sediment Analysis Analyze one-sediment sample collected from within the UIC (if adequate amounts are available for analyses) for the following:

• Total petroleum hydrocarbons (TPH). TPH-Dx (i.e., reported as diesel, lube oil, and heavy oil) and TPH-Gx (gasoline) by Northwest Methods5. Because sediment may contain organic matter that can inadvertently influence sample results, the use of a silica gel cleanup, or equivalent cleanup is recommended for NWTPH-Dx analyses. The analytical chemist will determine the need for sample cleanup. The silica gel cleanup removes potential polar organic compound interferences from naturally occurring organic matter (vegetable [pine needles, decomposing leaves, etc] and animal products [oils, sugars, and fatty acids]) but does not affect petroleum hydrocarbons, since most are non-polar. Silica Gel Cleanup is recommended for sediments because it removes contributions that are due to algae and decomposing organic matter.

• Polycyclic Aromatic Hydrocarbons (PAHs), Phthalates, and Pentachlorophenol. DEQ is currently requiring analyses of polycyclic aromatic hydrocarbons (PAHs). Sample cleanup (e.g., silica gel) should be performed as determined necessary by the analytical chemist on the sediment sample and associated quality control samples. While DEQ is not currently requiring analyses of phthalates or pentachlorophenol, we recommend these be included in the EPA 8270-SIM analyses, due to the frequent detection of these compounds in Year 1 of the stormwater discharge monitoring program. Target method reporting limits (MRLs) for these compounds are presented in Table A-2.

• Metals. RCRA-8 metals (i.e., arsenic, barium, cadmium, chromium, lead, mercury, selenium and silver), copper, and zinc by EPA Methods 3051/6020. Target MRLs for these compounds are presented in Table A-3.

5 See http://www.deq.state.or.us/wmc/tank/newtph.htm for a description of Northwest TPH Methods.


• Toxicity Leaching Characteristic Procedure (TCLP) or the Synthetic Precipitation Leaching Procedure (SPLP) may be needed for disposal of sediments in a municipal (sanitary) landfill. One of these methods should be considered if the total metal concentration in sediment is greater than 20 times EPA’s TCLP concentration for determining if a waste should be considered a RCRA regulated characteristic waste. The TCLP (EPA SW-846 Method 1311) is a more aggressive extraction developed to estimate the mobility of specific contaminants disposed of in municipal landfills. The SPLP (EPA SW-846 Method 1312) was developed to assess the leaching potential of contaminated material when exposed to rainfall. If either leaching procedure is acceptable to the landfill, it is recommended the SPLP be used. Check with the landfill to determine if the analysis is required or if knowledge based on the BES Inverness sediment is acceptable for disposal.

A 3.4.2. Water Analysis Analyze one water sample collected from within the UIC (if adequate amounts are available for analyses) for the following:

• PAHs, phthalates, and pentachlorophenol by EPA Method 8270-SIM. Target MRLs for these compounds are presented in Table A-2. The analytical chemist will determine the need for sample cleanup.

• RCRA-8 metals (total metals), copper and zinc (total and dissolved metals) by EPA Methods 200.8. Target MRLs for these compounds are presented in Table A-3.

• Oil and grease by EPA Method 1664. • Total suspended solids (TSS) by Standard Method SM 2540 D.

If petroleum product (i.e., non-aqueous phase liquid (NAPL)) is observed in the UIC, a sample will be collected and analyzed for volatile organic compounds (VOCs - EPA method 8260), semivolatile organic compounds (SVOCs - EPA method 8270), hydrocarbon characterization (TPH-HCID), and polychlorinated biphenyls (PCBs - EPA Method 8082). A 4.0 QUALITY ASSURANCE & QUALITY CONTROL The target method reporting limits (MRL) for water and sediment samples are presented in Tables A-2 and A-3. Sample weights used for extraction and analysis should be adjusted so that these MRLs are met on a dry weight basis. If these limits cannot be met for non-detected analytes in a sample, the laboratory report should note why these limits were not met (e.g., matrix interference) and the actual MRL achieved for non-detect analytes. Sample cleanup techniques (silica gel or sulfuric acid) may be employed as determined appropriate by the analytical chemist. Sample cleanup may be performed if the requested MRLs for non-detect analytes cannot be met due to interferences. Sample dilution must be not be used as a substitute for sample cleanup. The laboratory must take extra care to ensure that phthalate contamination is not a problem during analysis. Steps taken may include extra rinses of glassware with solvent before use, segregation of glassware used for high- and low-level samples, and ensuring that plastic materials such as gloves do not come in contact with the samples.


A 5.0 DATA INTERPRETATION The analytical sample results will be interpreted by UIC Program or CSA staff to characterize materials removed from the UIC for appropriate disposal and to evaluate whether operation of the UIC may have adversely impacted groundwater quality. Data interpretation is discussed in the following sections. A 5.1. Sediment Results A 5.1.1. Adverse Impacts to Groundwater DEQ is currently requiring that soil/sediment sample results be compared to EPA Region 9 Preliminary Remedial Goals6 (PRGs) for soil “migration to groundwater” using a dilution/attenuation factor (DAF). DEQ is requiring that a DAF of 1 (i.e., no dilution) be used when groundwater is present in the UIC or within 10 feet of the bottom of the UIC and a DAF of 20 when the separation distance (i.e., distance between groundwater and the bottom of the UIC) is greater than 10 feet to assess if groundwater may be impacted. Sediment sample results should also be compared to the Risk-Based Concentrations (RBCs) presented in DEQ’s guidance (2003) for Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites. DEQ’s RBCs for potential leaching of contaminants in soil to groundwater are based on a DAF of approximately 60. The analytical data presentation and subsequent evaluation should focus primarily on the common and priority pollutants, presented in Table 1 of the permit. BES considers the EPA PRG and DAF values to be too conservative for many situations. Therefore, BES will be working with DEQ to develop screening values that are more appropriate for examining potential impacts to soil or groundwater outside of the UIC. The uncertainties associated with comparing detected concentrations to conservative screening values should be presented (e.g., see page B-52 of DEQ’s guidance document) with the data comparison (i.e., written closure report). Metal concentrations may also be compared to region background7 values, if appropriate. A 5.1.2. Waste Disposal The primary purpose of the sediment sampling is for waste characterization to assure appropriate management and disposal of any material removed from the UIC during closure activities. If any sediment sample concentrations are above the waste disposal criteria for disposal to a DEQ permitted solid waste landfill (e.g., Waste Management-Hillsboro Landfill), BES will notify DEQ, as required, by Oregon statute. Waste disposal will be documented in the UIC closure report. A 5.2. Water Results A 5.2.1. Adverse Impacts to Groundwater The WPCF permit requires stormwater discharged to City-owned UICs meet concentrations protective of drinking water. If the maximum allowable discharge limits, (MADLs), defined in Table 1 of permit, are met, groundwater should by definition not be adversely impacted by stormwater discharges. Water sample results should be compared to the MADLs presented in Table 1 of the permit. The comparison 6 EPA Region 9 PRGs can be obtained from: http://www.epa.gov/region9/waste/sfund/prg/ 7 For metals, DEQ typically uses soil concentrations for Clark County presented in Washington Department of

Ecology’s report “Natural Background Soil Metals Concentrations in Washington State” (Publication #94-115, October 1994) for screening purposes.


should be limited to only those compounds listed in Table 1 of the permit. BES believes this direct comparison is overly conservative, since the UIC water concentrations are not representative of stormwater water discharged from the UIC to the subsurface. The water samples are most likely representative of stagnant water in direct contact with sediments collected in the bottom of the UIC sump. Water concentrations may also be compared to the RBCs presented in DEQ’s guidance (2003) for Risk-Based Decision Making for the Remediation of Petroleum-Contaminated Sites. The uncertainties associated with comparing detected concentrations to conservative screening values should be presented (e.g., see page B-52 of DEQ’s guidance document) with the data comparison (i.e., written closure report). A 5.2.2. Waste Disposal The primary purpose of water sampling is to assure appropriate characterization and disposal of any water (or other liquids) removed during closure activities. Results should be compared to the BES batch discharge requirements (City of Portland, Decommissioning Procedure for UICs—Step 3). If water sample results do not meet the requirements for discharge to the City’s sanitary sewer system, BES will dispose of the water in an appropriate manner and in accordance with local, state or federal laws. BES will document and report this to DEQ in the UIC closure report.

A 5.3. Need for Additional Investigation If UIC conditions (e.g., non aqueous phase liquid) or sediment/water analytical results indicate that groundwater or soil outside the UIC may have been impacted at a level that would adversely impact the beneficial uses of groundwater:

• BES will determine, in consultation with DEQ, if any additional investigation or response actions are required for compliance with the WPCF permit (see UIC Management Plan – Evaluation and Response Program Element).

• BES will, if appropriate, prepare a site-specific Sampling and Analysis Plan to assess potential adverse impacts to groundwater from the UIC (see UIC Management Plan –Evaluation and Response Program Element).

A 6.0 REPORTING UIC SAMPLING RESULTS The results of the UIC sampling will be presented in a brief report (UIC Pre-Closure Report or UIC Closure Report) in accordance with Step 12 of the Decommissioning Procedure for Underground Injection Control Systems (December 2006). The report will document decommissioning activities, the results of additional samples, if any, and disposal documentation.


Table A-1: Recommended Sample Containers, Lab Method, Volumes, Preservation, and Holding Times

Media Compound/Compound Class EPA Method Analytical

Laboratory Container

Type Container Volume

Preservation Requirements

Technical Holding Time

3- 1 Liter PAH, Phthalates &

Pentachlorophenol EPA 8270SIM Test America Amber Glass (1 extra in case of

breakage)

Cool to 4oC +2oC 7 days (extraction)40 days (analysis)

RCRA-8 Total Metals HNO3 to pH<2; + Copper & Zinc

EPA 200.8 WPCL Wide-mouth Nalgene 500-mL

Cool to 4oC +2oC 6 months

Dissolved Metals HNO3 to pH<2; + Copper & Zinc

EPA 200.8 WPCL Wide-mouth Nalgene 500-mL

Cool to 4oC +2oC 6 months

Oil & Grease EPA 1664 WPCL Wide Mouth Clear Glass 1 Liter HCl to pH<2;

Cool to 4oC +2oC 28 days

Wat

er

Total Suspended Solids SM2540 D WPCL Plastic 1 pint with handle Cool to 4oC +2oC 7 days

Diesel Range Hydrocarbons NWTPH-Dx WPCL Amber Glass 1 - 4oz Cool to 4oC +2oC 14 days

Gasoline Range Hydrocarbons NWTPH-Gx Test America Amber Glass 1 - 4oz Cool to 4oC +2oC 14 days

PAH, Phthalates & Pentachlorophenol EPA 8270SIM Test America Amber Glass 1 - 4oz Cool to 4oC +2oC 7 days (extraction)

40 days (analysis) RCRA 8 Total Metals + Copper and Zinc

EPA 3051/6020 WPCL Amber Glass 1 - 4oz Cool to 4oC +2oC 6 months

Sed

imen

t

TCLP EPA 1311 WPCL Use total metals jar NA 6 months




Table A-2: UIC Decommissioning Method Reporting Limits PAHs, Phthalate and Pentachlorophenol Analyses 8

8 Polycyclic aromatic hydrocarbons (PAH), phthalates, and pentachlorophenol will be analyzed using EPA Method 8270-SIM

(selected ion monitoring)

Sediment Water Analyte CAS Number MRL (µg/kg) MRL (µg/L) Acenaphthene 83-32-9 10 0.1

Acenaphthylene 208-96-8 10 0.1

Anthracene 120-12-7 10 0.1

Benzo(a)anthracene 56-55-3 10 0.1

Benzo(a)pyrene 191-24-2 10 0.1

Benzo(g,h,i)perylene 191-24-2 10 0.1

Benzofluroanthenes 20 0.1

Chrysene 218-01-9 10 0.1

Dibenzo(a,h)anthracene 53-70-3 10 0.1

Fluoranthene 2-6-44-0 10 0.1

Fluorene 86-73-7 10 0.1

Indeno(1,2,3-cd)pyrene 193-39-5 10 0.1

Naphthalene 91-20-3 10 0.1

Pentachlorophenol 87-86-5 50 1.00

Phenanthrene 85-01-08 10 0.1

Pyrene 129-00-0 10 0.1

Di(2-ethylhexyl)phthalate 117-81-7 20 2.0

Butyl benzyl phthalate 85-68-7 20 2.0

Diethyl phthalate 84-66-2 20 1.0

Dimethyl phthalate 131-11-3 20 1.0

Di-n-butyl phthalate 87-74-2 20 2.0

Di-n-octyl phthalate 117-84-0 20 1.0


Table A-3: UIC Decommissioning Method Reporting Limits Metals Analyses

________________________________________________ SEDIMENTS (EPA METHOD 3051/6020) EPA Sediment Analyte Method MRL (mg/kg) Arsenic 6020 0.50 Barium 6020 0.10 Cadmium 6020 0.10 Chromium 6020 0.50 Copper 6020 0.25 Lead 6020 0.10 Mercury 6020 0.010 Selenium 6020 1.00 Silver 6020 0.10 Zinc 6020 0.50 TCLP Lead 1311/6010 0.10 mg/l ________________________________________________ WATER (EPA METHOD 200.8) EPA Water Analyte Method MRL (µg/L) Arsenic 200.8 0.045 Barium 200.8 0.1 Cadmium 200.8 0.1 Chromium 200.8 0.4 Copper 200.8 0.2 Lead 200.8 0.1 Mercury 200.8 0.005 Selenium 200.8 0.5 Silver 200.8 0.1 Zinc 200.8 0.5


City of Portland Bureau of Environmental Services UIC Program

SOP No.: 1.00 Revision No.: 0

Date: 12/01/06 Author: RGS

UIC PROGRAM STANDARD OPERATING PROCEDURE

SEDIMENT SAMPLE COLLECTION PROCEDURES

FOR UIC DECOMMISSIONING 1.0 PURPOSE This Standard Operating Procedure (SOP) describes the procedures for collecting sediment samples from an Underground Injection Control (UIC) sump using a direct-push probe or non-mechanical sampling devices. The samples generated using these procedures may be submitted for laboratory analysis as grab samples or may be composited, as needed. 2.0 SCOPE AND APPLICABILITY The methodologies discussed in this SOP are applicable to using hand sampling equipment or direct-push technologies to sample UIC sediments, potentially beneath standing water. 3.0 EQUIPMENT AND MATERIALS The following is a list of required equipment for collecting UIC sediment samples:

• Bucket Auger (Hand Auger) • Stainless steel spoon • Large stainless steel bowl • Site files detailing UIC locations and UIC construction information • Latex or vinyl gloves (analyte specific) • Chain-of-Custody, Field Data Sheets, or Daily Field Record forms • Laboratory-supplied sampler containers • Cooler and ice (“wet ice” or blue ice) • Tape measure

4.0 PROCEDURE The following procedures explain how to collect UIC sediment samples with a bucket auger; or direct-push sampler. All sampling equipment and containers used in this SOP should be


decontaminated prior to any sampling activities. Proper decontamination procedures are described in BES Field Operations SOP 7.01a -Decontamination of Sampling Equipment.


4.1 Sampling UIC Sediment Using a Bucket Auger Common types of bucket augers (hand augers)

The following procedures define steps to be taken when using a bucket auger to collect a sediment sample from a UIC sump. Sampling should not occur outside of the sump, unless all subsurface utility lines in the vicinity are marked. Hand auger methods are described below: 1. Determine the depth to water in the UIC using BES Field Operations SOP 3.01a - Groundwater Level

Measurement, and record on the Sampling Record form.

2. Determine the depth to the top of sediment using a weighted measuring tape or tape measure; record depth on the Sampling Record form. Determine if there is enough sediment to sample by subtracting the “depth to sediment” measurement from the estimated total depth of the UIC sump. Sampling should be attempted if more than 0.5 feet of sediment are present. If there is not enough sediment in the UIC sump to collect a sample, record on Sampling Record form.

3. To the extent practicable, the field team should assess whether the standing water is a) stagnant water held by the bottom of the sump; b) groundwater (i.e., water level within perforated zone of UIC); or c) stormwater (i.e., slowly infiltrating UIC).

4. Assemble the appropriate sampling containers.

5. Put on new clean gloves.

6. Lower the bucket auger into the UIC until it encounters sediment. Advance the auger using a clockwise twisting motion being sure to keep auger aligned vertically. When auger is full remove from the UIC and empty sediment into the stainless steel bowl or stainless steel bucket (for sample compositing).

7. Record notes and observations of the soil conditions on the Field Data Sheet or Daily Field Record forms. Observations should include a description of the sediment (consistency, grain-size, etc.), depth below ground surface from where sediment is extracted, and any discoloration or odors.

8. Repeat Steps 6 and 7 as necessary to the appropriate depth. Continue advancing the auger to total depth of the UIC sump, to the extent practicable.

9. After advancing the auger hole and logging the sediment cuttings, determine the appropriate depth of the sediment sample(s) for chemical analyses. Advance the auger to the appropriate sampling depth for discrete sample collection, withdraw sampler from the boring. Place sampler in the boring and advance as before, using a twisting motion. Withdraw auger from the hole.

10. With as little agitation as possible, place soil sample in the appropriate lab-supplied sample container(s) and place into chilled cooler for delivery to the laboratory

11. If collecting a composite sample, use auger to collect subsamples or aliquots from the desired depth range, and place into a clean decontaminated stainless steel bowl or bucket. Use a stainless steel spoon to homogenize the portions of the sample, by thoroughly mixing the material, and transfer into sample containers.

12. When the boring is completed, place soil cuttings back into the UIC.


13. Record the sampling date and time on the Chain-of-Custody, and a description of sampling location(s) and conditions encountered on the Field Data Sheet and/or Daily Field Record forms.

14. If proceeding to another sampling location, decontaminate auger per Field Operations SOP 7.01a - Decontamination of Sampling Equipment.

4.1 Sampling UIC Sediment Using a Direct-Push Probe The following procedures define steps to be taken when using a direct-push technology rig (e.g. GeoprobeTM) to collect a sediment sample from a UIC sump. Sampling should not occur outside of the sump, unless all subsurface utility lines in the vicinity are marked. Direct-push methods are described below:

1. Determine the depth to water in the UIC using BES Field Operations SOP 3.01a - Groundwater Level Measurement, and record on the Sampling Record form.

2. Determine the depth to the top of sediment using a weighted measuring tape or tape measure; record depth on the Sampling Record form. Determine if there is enough sediment to sample by subtracting the “depth to sediment” measurement from the estimated total depth of the UIC sump. Sampling should be attempted if more than 1 foot of sediment are present. If there is not enough sediment in the UIC sump to collect a sample, record on Sampling Record form.

3. Assemble the appropriate sampling containers.

4. Put on new clean gloves.

5. Have driller lower the drill rod and split spoon or equivalent sampler into the UIC until it encounters sediment. Push or drive the sampler into the sediment the length of the sampler (e.g., 2.5 feet). When sampler is full, retract sampler from the UIC.

6. Open the sampler on a clean surface (e.g., visqueen).

7. Record notes and observations of the soil conditions on the Field Data Sheet or Daily Field Record forms. Observations should include a description of the sediment (consistency, grain-size, etc.), depth below ground surface from where sediment is extracted, and any discoloration or odors.

15. Repeat Steps 6 and 7 as necessary to the appropriate depth. Continue advancing the sampler to the total depth of the UIC sump, to the extent practicable.

16. After advancing the auger hole and logging the sediment cuttings, determine the appropriate depth of the sediment sample(s) for chemical analyses. Advance the sampler to the appropriate sampling depth for discrete sample collection.

17. If collecting a composite sample, use auger to collect subsamples, or aliquots, from the desired depth ranges, and place into a clean decontaminated stainless steel bowl. Use a stainless steel spoon to homogenize the portions of the sample, by thoroughly mixing the material, and transfer into sample containers.

18. When the boring is completed, place sediment cuttings back into the UIC.

19. Record the sampling date and time on the Chain-of-Custody, and a description of sampling location(s) and conditions encountered on the Field Data Sheet and/or Daily Field Record forms.

20. If proceeding to another sampling location, decontaminate auger per Field Operations SOP 7.01a - Decontamination of Sampling Equipment.


5.0 POTENTIAL PROBLEMS When collecting sediment samples, it may be impossible to drive a hand auger or other hand sampling equipment through hard material or surfaces. If refusal is encountered, a sample will not be collected. When collecting sediment samples, a common problem is failure of the sampler to retain the sample. This will result in the sediment falling out while the sampler is raised to the surface. If this occurs, re-attempt the sample or use sample catchers, as appropriate. If sediment conditions in the UIC preclude the use of a hand auger or a direct-push probe, other collection methods may be required. Refer to Field Operations SOP 5.01a – Sampling of Soil and Sediment for additional sample collection techniques and associated equipment. 6.0 QUALITY ASSURANCE AND QUALITY CONTROL The sampler and drill rod should be decontaminated thoroughly with Alconox, or equivalent, prior to lowering it into the UIC. Care should be taken to keep the sampler from being cross contaminated, placed on the ground surface, etc.


City of Portland Bureau of Environmental Services UIC Program

SOP No. 2.00 Revision No.: 0

Date: 12/01/06 Author: RGS

UIC PROGRAM STANDARD OPERATING PROCEDURE

WATER SAMPLE COLLECTION PROCEDURES FOR UIC DECOMMISSIONING

1.0 PURPOSE This Standard Operating Procedure (SOP) provides guidelines for the collection of a representative water sample from an Underground Injection Control (UIC) sedimentation manhole or sump UIC using a disposable bailer. 2.0 SCOPE AND APPLICABILITY The following procedure pertains to the proper methods for using disposable bailers (or equivalent) to collect water samples that represent water quality within the UIC system. The method for the collection of a representative sample of water from a UIC is described below. 3.0 EQUIPMENT AND MATERIALS The following is a list of required equipment for sampling a UIC using a disposable bailer:

• Disposable (weighted polyethylene or Teflon) bailers (or equivalent container such as a stainless steel bucket, or polyethylene jar)

• Bailer emptying device • 5-gallon bucket • Sampling Record form for each UIC • Site files detailing UIC information and location • Braided nylon string • Latex gloves • Groundwater Level Indicator • Chain-of-Custody, Field Data Sheets, or Daily Field Record forms • Laboratory-supplied sampler containers • Cooler and ice (“wet ice” or blue ice)


4.0 PROCEDURE The following procedures define steps to be taken when sampling an individual UIC: 1. Determine the depth to water in the UIC using BES Field Operations SOP 3.01a – Groundwater

Level Measurement, and record on the Sampling Record form. If there is not enough water in the UIC to collect a sample, record on Sampling Record form.

2. To the extent practicable, the field team should assess whether the standing water is a) stagnant water held by the bottom of the sump; b) groundwater (i.e., water level within perforated zone of UIC); or c) stormwater (i.e., slowly infiltrating UIC).

3. Put on clean, unused latex gloves. Tear open plastic covering at top of bailer and tie braided nylon line to bailer using a bowline or other secure knot. Take bailer out of bag and place into the UIC, lowering to the water level. Allow the bailer to fill up and sink below the water level, however do not allow bailer to touch the bottom of UIC, if possible. Cut braided nylon line allowing enough line to work with, and tie the end to your wrist. Using braided nylon line, pull up bailer from the UIC looping the line around both hands. Do not let the line touch any surfaces, other than the inside of the UIC casing. Replace line if it contacts any surface other than the UIC casing. Pour bailer full of water into 5-gallon bucket. Do not allow bailer to touch bucket. Repeat using the same procedure.

4. To collect the sample from the bailer, raise the filled bailer to surface and use friction fit bailer-emptying device to release water from bottom into appropriate sample containers. If collecting samples for VOC analyses, use the VOC sample removal device to minimize sample disturbance. Use the following order to collect samples: VOCs (if collected), other organics, nutrients (if collected), and metals.

5. Place samples in chilled cooler for delivery to the laboratory for analysis. Fill out and complete attendant chain of custody documentation.

5.0 POTENTIAL PROBLEMS Careful attention should be employed during the extraction of purge volumes so as to avoid possible contamination of the UIC. By not following specified requirements pertaining to decontamination and proper sampling methodology, the accuracy of the sampling procedure can be jeopardized. Cross contamination of the UIC itself may occur through the introduction of unclean sampling equipment and by introducing foreign material (e.g., dust, dirt, and organic material) into the UIC from ground level. Such activity will negatively affect the representiveness of the samples If a bailer or other equipment falls down an open UIC attempt to recover the equipment by using a fishing hook attached to the nylon line to hook the item. 6.0 QUALITY ASSURANCE & QUALITY CONTROL The probe on the water level indicator should be decontaminated thoroughly with Alconox, or an equivalent nonphosphate cleaner, and deionized water prior to lowering it into the UIC. Use a new bailer for each UIC. Use only clean, unused bailers, and string at each UIC.



UIC Decommissioning Procedure December 2006 Version: Final

Attachment 1

STORMWATER MANAGEMENT AND DISPOSAL HIERARCHY



EXHIBIT 1-1: STORMWATER DESTINATION/DISPOSAL HIERARCHY Using Exhibit 1-1: For approval of a stormwater destination/disposal method in the City of Portland, the highest (1= high, 4=low) technically feasible category for the project must be used. All appropriate technical design criteria must be met to receive approval. Information provided in this chart does not guarantee that there will be an approvable destination for stormwater.

City of Portland Stormwater Destination/ Disposal Hierarchy Category 1: On-site infiltration with a surface infiltration facility. Under this category, a vegetated swale, grassy swale, street swale, vegetated infiltration basin, or infiltration planter shall be used, sized in accordance with the Surface Infiltration Facility design procedure in Section 2.2.2. This sizing procedure results in larger facilities than the simplified approach, which is used to meet pollution reduction and flow control goals only. This category is not required if any of the following conditions exist:

1) Where subsurface soils infiltrate adequately, runoff from rooftops may be directed to underground injection control facilities, such as soakage trenches and drywells.

2) Soils do not infiltrate well enough for surface infiltration facility design. This exception includes projects on the west side of the Willamette River. Soils must achieve a minimum infiltration rate of 2 inches per hour.

3) Adequate space is not available for surface infiltration facility design (see Surface Infiltration Facility design methodology in Section 2.2.2). For facilities serving public street drainage and located within the street right-of-way, this is generally determined by comparing the amount of available pervious surface area (usually located between the curb and sidewalk) with the size of the required infiltration facility. Resident basements must have adequate setbacks. A minimum setback of 10 feet is required on private property, as approved by BDS. Additional right-of-way width may be dedicated by the applicant if needed, as approved by PDOT (for public streets) or BDS (for private streets). For surface infiltration facilities located outside of the street right-of-way, adequate space is determined by the applicant’s ability to meet minimum density requirements, as determined by City of Portland zoning code, after the infiltration facility has been located on-site.

4) Contaminated soils are present on site such that DEQ will not permit stormwater infiltration. Documentation showing DEQ assessment must be submitted.

5) Slope instability conditions exist on site, as documented by a geotechnical investigation, which stormwater infiltration may exacerbate. Slopes must not exceed 10% in the facility area.

6) Site is located within the Columbia South Shore Wellhead Protection Area (see Exhibit 2-33), where on-site infiltration is not accepted for stormwater disposal.

7) For half-street improvements, existing utilities or street trees make it impractical to construct a surface infiltration facility within the street right-of-way.

ATTACHMENT 1

City of Portland Stormwater Destination/ Disposal Hierarchy (Cont.)

Category 2: On-site infiltration with a public infiltration sump system, private drywell or soakage trench. These facility types are classified as UICs (underground injection control structures) and must be rule-authorized or permitted by DEQ (see Section 1.4.4). The degree of pollution reduction required depends on the source of the stormwater runoff. Rooftop runoff does not require pollution reduction, runoff from residential low-use streets or parking lots (< 1,000 average daily trips) requires the use of sedimentation/ spill control manholes, and high-use streets and parking lots (> 1,000 average daily trips) require full pollution reduction. A surface retention facility is required to the maximum extent practicable (MEP) to meet applicable pollution reduction requirements (see Section 1.6.2 for MEP criteria). This category is not required if any of the following conditions exist:

1) Project does not meet DEQ UIC rule authorization or permitting criteria (see Section 1.4.4 for list of criteria, or go to: http://www.deq.state.or.us/wq/groundwa/RAStormwaterRequirements.pdf).

2) Sub-surface soils do not infiltrate well enough for on-site infiltration, as approved by BES (for public streets) or BDS (for private streets).

3) Slope instability conditions exist on site, which stormwater infiltration may exacerbate. If this exception is claimed, a geotechnical investigation must be conducted and submitted, as approved by BES (for public facilities) or BDS (for private facilities).

4) Site is located within the Columbia South Shore Wellhead Protection Area (see Exhibit 2-33), where on-site infiltration with UICs is not allowed.

Category 3: Off-site flow to drainageway, river, or storm-only pipe system. Pollution reduction is required. Flow control is required in most cases (see Section 1.6.2). A surface retention facility is required to the MEP to meet pollution reduction and flow control requirements (see Section 1.6.2 for MEP criteria). This category is not required if any of the following conditions exist:

1) System does not exist or does not have available capacity, as determined by BES. 2) Sensitivity of the water resource justifies connection to an alternative destination method, as

determined by BES. Category 4: Off-site flow to a combined sewer. Pollution reduction and flow control are required. A surface retention facility is required to the MEP to meet pollution reduction and flow control requirements (see Section 1.6.2 for MEP criteria). This category is not accepted if the following condition exists:

1) System does not exist or does not have available capacity, as determined by BES.


Attachment 2

DEQ UIC PRE-CLOSURE NOTIFICATION FORM



UIC 1000SW-CLO (04/05) 1 of 4

DEQ USE ONLY

Registration #:

File #:

Mail ID #2/#9:

DOC Conf.:

Notes:

Oregon Department of Environmental Quality

DEQ USE ONLY

Received:

IND DOM UIC:

Notes:

UIC PRE-CLOSURE NOTIFICATION FORM

1. Facility Legal Name: 2. Common Name:

3. Facility Physical Address:

City, State, Zip Code:

4. Facility Mailing Address:


5. Name of Owner/Operator:

Address:


6. Phone Number:

Fax Number:

e-mail address:

7. Legal Contact: Phone Number:

FACILITY DESCRIPTION (ATTACH DOCUMENTS AS NEEDED)

1. Latitude (decimal format – see page 3): _______________ Longitude (decimal format – see page 3): _______________

2. If registered, list UIC number, e.g., 11117-05. Type of UIC System(s): ___________________ Number of injection systems: _________

3. Injection/Disposal System Design (check all that apply):

Drywell or sump Auto floor drain Cesspool Sewage drill hole Septic tank/drainfield/leachfield Other

4. Attach a site map showing UIC location(s), facility buildings and their use, parking areas, roads and water features. Attached

5. Year of UIC construction: Proposed date of injection system closure: List all UICs on page 2.

6. SIC/NAICS Code: ______________________ Nature of business at facility: __________________________________________________

7. Type of closure (check all that apply, or attach a brief description of how the UIC[s] will be closed, associated with types): Sample Fluids/sediments Attach to a municipal system Appropriate disposal of remaining fluids/sediments Clean out Remove contaminated soil Install permanent plug Conversion to other well type Other (describe): Pump out/fill with rocks and seal

8. A sampling plan for UIC closure is required and must be approved by DEQ before closure may commence. The plan must also be overseen by a registered Professional Geologist, Engineering Geologist, or Professional Engineer. Sampling plan attached

9. List any other DEQ or public agency permits applied for or issued to this facility:

10. Note past site uses: _____________________________________________________________________________________________________

11. If SARA Title III facility: List materials handled, stored, or used: ________________________________________________________________

11. Note nearest brownfield or remediation site within one-half mile: _____________________________________ ESCI/LUST # and name (attach map from Profiler – see reverse side): _________________________________

12. DEQ regional contact person:

SIGNATURE OF LEGALLY AUTHORIZED REPRESENTATIVE

I hereby certify that the information contained in this registration is true and correct to the best of my knowledge and belief.

_____________________ _______ _________ Name of Legally Authorized Representative (type or print) Title

Signature of Legally Authorized Representative Date

ATTACHMENT 2

UIC 1000SW-CLO (04/05) 2 of 4

UIC REGISTRATION FOR STORM WATER DRAINAGE SYSTEMS

Oregon Department of Environmental Quality (Submit two copies of this form to DEQ.)

LEGAL NAME:

C. UNDERGROUND INJECTION CONTROL INFORMATION Attach a facility map that clearly identifies the location of each UIC system by name or number.

Provide the information requested below for each UIC storm water drainage system. Attach additional copies of this sheet if necessary.

UIC SYSTEM # or NAME: INSTALLATION YEAR:

1. Lat: degrees min. sec. or Decimal: Long: degrees min. sec. or Decimal:

2. Type: Dry well/sump Drill hole Drainfield Infiltration trench Other discharge

3. Drainage Area: Roof drain only Parking area only

Other, specify:

4. Distance to nearest: Domestic/public water well:

Wetland: Surface water(s): Depth to winter high water table: feet If not available, average depth to groundwater: feet Attach well log(s) for the nearest water wells. Attached

5. Status: (see instructions for status definition) Planning stage Under construction Active Not in use or Temporarily Abandoned Permanently Abandoned/Decommissioned (date & method):

7. Located in a delineated source water area

6. Characteristics: Depth: ft Diameter: ft Design drainage rate: Size of impervious area drained: Type of treatment prior to discharge:





Other, specify:










Other, specify:






UIC 1000SW-CLO (04/05) 3 of 4

UIC PRE-CLOSURE NOTIFICATION FORM INSTRUCTIONS 1. Enter the legal name of the applicant. This name must be the legal Oregon corporate name (i.e., Acme Products, Inc.) or the

legal representative of the company if the company operates under an assumed business name (i.e., John Smith, dba Acme Products). The name must be a legal, active name registered with the Oregon Department of Commerce, Corporation Division (503) 378-4752, unless otherwise exempted by the Department of Commerce regulations.

2. Enter the common name of this facility if different than the legal name. 3. Enter the physical location of the facility (not mailing address), including city, state, and zip code. 4. Enter the facility mailing address, if different than the physical location of the facility. 5. Enter the name, address, telephone and fax number of the facility owner; this would be the person to call in case there are any

questions about this closure form. 6. Enter the phone number, fax number and e-mail address of the facility owner. 7. Enter the name and phone number of the legal or DEQ contact or responsible official or organization, if different from #5.

FACILITY DESCRIPTION 1. Enter the latitude and longitude of the approximate center of the facility or site in decimal degrees if possible. Latitude and

longitude can be obtained from United States Geological Survey (USGS) quadrangle or topographic maps by calling 1-888 ASK-USGS, or by accessing DEQ’s Profiler at http://deq12.deq.state.or.us/fp20/. If a GPS unit is used to determine lat/long, set the datum to the state standard, NAD83; otherwise, location data will not be accurate.

EPA Well Types 5A19 Cooling Water Return 5R21 Aquifer Recharge (ASR) 5W12 Water Treatment Plant Effluent 5X26 Aquifer Remediation 5D2 Stormwater 5D3 Stormwater Drill Hole 5W9 Untreated Sewage/Drill Hole

5W20 Industrial Process Water 5X27 Other Wells 5D4 Industrial Storm Runoff 5W10 Cesspool 5W31 Septic System (well disposal) 5X28 Motor Vehicle Waste 5G30 Special Drainage Water

5W11 Septic System (gen) 5W32 Septic System (drainfield) 5A7 Closed Loop Heat Pump 5X29 Abandoned Drinking Well 5A5 Electric Power Generator 5A6 Geothermal Heat Return

2. Enter the type and number of the injection system(s) from the list above and, if registered, note UIC number. 3. Indicate the basic UIC design. Check all that apply 4. Attach a site map with UICs noted, also showing the other features listed. 5. Enter the year the UIC was constructed, and the proposed date of closure. 6. Note depth of existing UICs and attach a drinking water well log with a soil profile. Logs are available at the Water Resources

Department (WRD) web site, http://www.wrd.state.or.us/groundwater/index.shtml, or by calling (503) 786-0900. 7. Enter the Standard Industrial Classification (SIC) four-digit code or North American Industry Classification System five or

six-digit code (NAICS) for the facility. These codes are used to describe the primary activity at the facility that generates the most money and may be found on fire marshal reports, insurance papers, or tax forms. The NAICS codes replaced the SIC system in 1997, however, it is usually easy to convert between the two systems so either code is acceptable. SIC or NAICS information is also available from the U.S. Census Bureau at 1-888-756-2427 or at http://www.naics.com/search.htm. Include a secondary code if applicable, and indicate the nature of business being conducted at the facility.

8. Briefly describe the types of materials, products, and wastes handled at the facility. For example, from a service station one might expect "new and used gasoline, diesel, transmission oil, brake fluid, antifreeze, solvents and tires; general cleaners (409, Simple Green, etc.); office wastes; and general garbage." Submit a list of materials which are water soluble from the facilities material safety data sheets (MSDS) OR a copy of the Fire Marshall survey (if required for your facility or if a hazardous waste generator).

9. Check the method(s) that are being used to close the well, or attach a brief written description of the decommissioning process. 10. Provide data from sediment/water sampling prior to removal, based on the site use and likely contaminants. 11. In order for DEQ to coordinate with other DEQ offices and public agencies, list all permits applied for or issued to this facility. 12. Note past cleanup site number, provide “no-further-action” letter, or provide data regarding past uses of the site which may

have locally contaminated the soils or groundwater. 13. Note distance to nearest cleanup site within one-half mile from the closure site. This data can be obtained from the DEQ LQ

Profiler utility at http://deq12.deq.state.or.us/fp20/ and print out a copy of the Profiler map showing cleanup sites within one-half mile of the site.

14. If applicable, identify the DEQ contact for your facility.

http://www.naics.com/search.htm

http://deq12.deq.state.or.us/fp20/


http://www.wrd.state.or.us/groundwater/index.shtml

UIC 1000SW-CLO (04/05) 4 of 4

Page 2: UNDERGROUND INJECTION CONTROL (UIC) INFORMATION Please submit a locational map (preferably a topographical map from USGS) as well as a facility map that clearly identifies the location of each UIC system (specific point of discharge or injection, e.g. dry well, sump, drain hole, infiltration trench, etc.) by number or name. The facility design map should indicate treatment strategies and grading information to help determine direction of water flow. For each UIC system, provide the number or name and its installation date. The installation date will be on your city/county permit. Also, for each UIC system provide the following: 1. Enter the latitude and longitude of the approximate center of the facility or site in decimal degrees. Latitude and longitude

can be obtained from United States Geological Survey (USGS) quadrangle or topographic maps by calling 1-888 ASK-USGS, or by accessing DEQ’s Profiler at http://deq12.deq.state.or.us/fp20/. If a GPS unit is used to determine lat/long, set the datum to the state standard, NAD83; otherwise, location data will not be accurate.

2. Type of UIC system (listed on DEQ's UIC webpage). Storm water systems can be 5D2 (regular), 5D3 (drillhole), or 5D4 (industrial).

3. Where the drainage into the UIC system is coming from. Please note: You may need to document no toxic exposure. 4. Estimated distance in feet of the UIC system to the nearest domestic or public water supply well, wetland, and other surface

water. This information is used by DEQ to evaluate the risk to sensitive sites and drinking water that could be impacted by accidental spills or contaminated storm water drainage. Provide the depth in feet to the winter high water table. Acquire the newest well logs that show the soil profile for the closest water well. Well logs and water table information are available through the Water Resources Department (WRD): http://www.wrd.state.or.us/groundwater/index.shtml or (503) 786-0900. The Natural Resource Conservation Service or U.S. Geological Survey in your area may also have groundwater information. Note if the site has had past contamination problems, is located on steep shores, in the floodplain, a groundwater management area or a known hazard area. This information should be available at your local planning agency or the Oregon Department of Geology, (503) 731-4100.

5. Indicate status (whether the UIC system is being planned, under construction, active, inactive, temporarily abandoned, or permanently abandoned [closed or decommissioned]). A UIC system is considered "temporarily abandoned" when it is taken out of service but still exists. Owners of temporarily abandoned UICs intend to bring them back into service at a future date. A watertight cap or seal that prevents any materials from entering the UIC must cover temporarily abandoned UICs. A UIC is considered "permanently abandoned" when it is completely filled so that movement of water within the UIC is permanently stopped. With the exception of hand-dug UIC systems, a licensed water well constructor, or the landowner under a Landowner's Water Well Permit, must perform a permanent abandonment. Please see Oregon Administrative Rule (OAR) 690-220-0005 or visit WRD’s web page for the rule at http://arcweb.sos.state.or.us/rules/OARS_600/OAR_690/690_220.html. WRD has also developed a well guide that may be of use: A Consumer's Guide to Water Well Construction, Maintenance and Abandonment available at http://www.wrd.state.or.us/publication/wellcon99/index.shtml#abandoning. You may also contact WRD at (503) 768-0900. If the UIC system has been permanently abandoned/decommissioned, provide the date and method of closure. If you are planning to decommission the system, submit a DEQ Pre-Closure Notification Form 30 days before proposed closure.

6. The following design characteristics: 7. Depth and diameter in feet.

Design drainage rate if known. (DEQ requires a 24-hour/2-year design storm be addressed.) 8. Size of the impervious area in square feet drained by the UIC system. An impervious area is an area that does not allow rain

to soak into the ground. It includes paved areas, concrete pads, buildings, roofs, and compacted areas such as graveled or dirt roads.

9. Type of treatment prior to subsurface discharge or best management practices (BMPs) to protect groundwater. For storm drainage systems, this could be a grassy swale, detention pond, sediment traps, catch basin inserts, treatment trains, or other pre-treatment designs. It does not include the rocks inside a dry well. If there is no treatment prior to the UIC system, write "no treatment." Please visit DEQ's UIC webpage for more information about pretreatment systems under Storm water Guidelines. Not all proprietary treatment systems satisfy federal and state water quality standards. Call DEQ to see if your proposed system can be rule authorized.

10. Call Department of Human Services (DHS) Drinking Water Program at (541) 726-2587 to determine if your UIC is in a delineated 2-year time of travel area of a public water system or your local municipal water purveyor.

REGISTRATION SUBMITTAL AND QUESTIONS Submit this form to:

Barbara Priest, DEQ WQ Division 811 SW 6th Avenue, Portland, OR 97204

Phone (503) 229-5945 Fax: (503) 229-6037

DEQ’s UIC web page: http://www.deq.state.or.us/wqgroundwa/uichome.htm

http://arcweb.sos.state.or.us/rules/OARS_600/OAR_690/690_220.html


http://www.wrd.state.or.us/groundwater/index.shtml

http://www.deq.state.or.us/wqgroundwa/uichome.htm


Attachment 3

CITY OF PORTLAND UIC SITE CHECKLIST



CITY OF PORTLAND

ENVIRONMENTAL SERVICES Environmental Policy Division: Underground Injection Control Management Program

1120 SW 4th Ave Room 1000 Portland, OR 97204

UNDERGROUND INJECTION CONTROL (UIC) DECOMMISSIONING FIELD DATA AND INSPECTION SHEET

Date: Time: UIC No: Inspector Name:

SITE CONDITIONS Site Name and Address: *UIC Type:

Observed Traffic Volume/Type:

Weather Conditions: Observed Stormwater Flow:

Street Drainage Type:

Curb and Gutter

No Curb

Gravel/Dirt Road

Other: .

UIC Condition/Contents: Presence of water--depth Presence of sediment--depth Oily sheens/staining Unusual odors (solvents, etc) Floatable objects Garbage/debris/foreign

materials Other:_____________________

____

Sed-Manhole Condition/Contents: Presence of water--depth Presence of sediment--depth Oily sheens/staining Unusual odors Floatable objects Garbage/debris/foreign materials Other: ____________________

Describe other conditions or any potential environmental contaminants of potential concern (COPCs) likely to impact soil, groundwater or stormwater. Other environmental features of concern or sources of potential contamination may include:

Staining on site or street Presence of gasoline, grease or oil Telephone poles (treated wood) Commercial /Industrial activities draining to UIC Materials in drums, tanks, bags or plastic containers stored near UIC Presence of fuel and chemical storage or similar within the drainage area Vehicle maintenance and repair PCB containing trasformers Poor housekeeping Other

Note current and past land uses at the site. Please contact BES CSA staff for relevant database review including DEQ ECSI sites, leaking underground storage tanks (LUSTs) facilities and other contaminated sites that could have a direct impact on site drainage. Photo(s) Taken? Y / N (Include photo numbers and description)

*UIC TYPE TYPE 1 UIC: Residential UIC— Residential land-use within drainage area plus low traffic (< 1000 trips per day).

TYPE 2 UIC: Residential UIC—Residential land-use within drainage area plus high traffic (> 1000 trips per day)

TYPE 3 UIC: Commercial or Industrial UIC – Commercial or industrial land use within the drainage catchment

File pathway and name.doc

ATTACHMENT 3




Attachment 4

WASTE PROFILE SHEET



Columbia Ridge, Hillsboro, Riverbend, Graham Road, Capitol, WenatcheeProfile Number:___________________Expiration Date:___________________

WASTE PROFILE SHEETTERMS & CONDIT IONS

Service Agreement on File? Profile Addendum Attached?■ Yes ■ No This form is to be used to comply with the requirements of governmental waste screening criteria. ■ Yes ■ NoA. Waste Generator Information1. Generator/Site Name:__________________________________ 2. SIC Code: _________________________________________

3. Site Address: ________________________________________ 4. Site City: __________________________________________

5. Site State: ____________ 7. Zip Code: ___________________ 6. Site Country: _______________________________________

8. Generator USEPA/Federal ID#: __________________________ 9. Site Phone: ________________________________________

10. Customer Name: _____________________________________ 11. Customer Phone: ____________________________________

12. Customer Contact: ____________________________________ 13. Customer FAX: ______________________________________

B. Waste Stream and Billing Information

1. Waste Description, Category : ___________________________

2. State Waste Code: ____________________________________

3. Billing Address: ______________________________________

_______________________________________________________

4. Process Generating Waste: _________________________________________________________________________________________

____________________________________________________________________________________________________________________

5. Transporter/Transfer Station: _________________________________ 6. Shipping Method: ____________________________________

7. Estimated Quantity (Weight & Vol.) : ____________________________________________ per ■ Job ■ Year ■ Other _______________

8. Delivery Date(s): __________________________________________ ____________________________________________________

9. Personal Protective Equipment Requirements: __________________________________________________________________________

10. Is this a US Dept. of Transportation (USDOT) Hazardous Material?■ Yes ■ No (If no, skip 10, 11 and 12)

11. Reportable Quantity: ________________________________

12. Hazard Class / I.D. #: ______________________________________ 13. Shipping Name: ___________________________________

■ Check if additional information is attached. Indicate the number of attached pages: __________

C. Generator’s Certification (Please check appropriate responses, sign and date reverse side)

Yes No

1. Is the waste represented by this waste profile sheet a “Hazardous Waste” as defined by USEPA,Canadian, Mexican, State, or Provincial regulation?

■ ■

2. Does the waste represented by this waste profile sheet contain regulated radioactive material orregulated concentrations of Polychlorinated Biphenyls (PCBs)?

■ ■

3. Does this waste profile sheet and all attachments contain true and accurate descriptions of the wastematerial?

■ ■

4. Has all relevant information within the possession of the Generator and Customer regarding known orsuspected hazards pertaining to the waste been disclosed to the Contractor?

■ ■

5. Is the analytical data attached hereto derived from testing a representative sample in accordance with 40CFR 261.20(c) or equivalent rules?

■ ■ ■ N/A

6. Will all changes that occur in the character of the waste be identified by the Generator and disclosed tothe Contractor prior to providing the waste to the Contractor?

■ ■

D. WM Management’s Decision

1. Management Method: __________________________________________________________________________________________

2. Designated Facility: ___________________________________________ 3. Hours of acceptance: __________________________ ____ ■ N/A

4. Precautions, Special Handling Procedures, or Limitations on Approval:_______________________________________________________

____________________________________________________________________________________________________________________

Generic Approval: ■ Yes ■ No Special Waste Decision: o Approved o Disapproved

Sales Person: ______________________ Date: ____________ Technical Manager: ______________________ Date: _______________

GENERATOR AND CUSTOMER MUST READ AND SIGN REVERSE HEREOF INITIAL __________ INITIAL __________

ATTACHMENT 4

Columbia Ridge, Hillsboro, Riverbend, Graham Road,Capitol, Wenatchee

PAYMENT INFORMATIONPlease check one of the following:

■ Landfill Account**

** Land fill account provide the following: Account number or name: ___________________________________________________

PO Number_______________________________________________________________

■ Cash

■ Business Check

■ Visa/Mastercard (Wenatchee does not accept Credit Cards)

Please return the payment information sheet with the Waste Profile, Laboratory results and chain of custody to Kristin Castner at Fax: (503)493-7822 or Phone: (503) 493-7834.


Attachment 5

BATCH DISCHARGE REQUEST FORM



BATCH DISCHARGE REQUEST FORM

Batch Discharge Number:

____________ -- _________

(For City use only)

Date of Request: ________________________________

Requested by:

Contact Name: _______________________________________________________________________

Company Name: ______________________________________________________________________

Company Address: ____________________________________________________________________

City: _____________________________________ State: ____________ Zip: __________________

Telephone: _____________________________________ Cellular: ____________________________

Facsimile: ______________________________________ Pager: _____________________________

Waste Generator:

Facility Name: _______________________________________________________________________

Facility Address: ______________________________________________________________________

City: _____________________________________ State: ____________ Zip: __________________

Facility Contact: ___________________________________ Telephone: ______________________

Description of Wastewater (attach analytical data report): _____________________________________

____________________________________________________________________________________

____________________________________________________________________________________

____________________________________________________________________________________

Proposed Date(s) of Discharge: __________________________________________________________

Estimated Volume: _________________ gallons City Project Number: _____________________

Proposed point of disposal (attach diagram): ________________________________________________

____________________________________________________________________________________

____________________________________________________________________________________________

________________________________________________________ _________________________ Signature Date

revised: 14 January 2004

ATTACHMENT 5



Appendix E

Best Management Practices Monitoring Program

System Monitoring Program Element


City of Portland, Oregon Water Pollution Control Facilities (WPCF) Permit For Class V Stormwater Underground Injection Control Systems Permit Number: 102830 Best Management Practice Monitoring Program Stormwater Underground Injection Control December 2006 Prepared By: City of Portland, Bureau of Environmental Services


BMP Monitoring Program Page i December 2006

TABLE OF CONTENTS 1 Introduction and Overview 1-1

1.1 Introduction...................................................................................................................... 1-1

1.2 Regulatory Requirements................................................................................................. 1-2

1.3 Goals and Objectives ....................................................................................................... 1-3

1.4 Relationship of the BMP Monitoring Program to Other Documents .............................. 1-5

1.5 BMP Monitoring Program Modifications........................................................................ 1-5

1.6 Organization of the BMP Monitoring Program............................................................... 1-6

2 Water Quality BMPs 2-1

2.1 BMP Monitoring Program Development......................................................................... 2-1

2.2 General Stormwater BMPs .............................................................................................. 2-1

2.2.1 BMP Categories 2-1

2.2.2 Applying the Effectiveness Evaluation Results to UICs 2-2

2.3 Water Quality UIC BMPs................................................................................................ 2-3

2.3.1 Non-structural BMPs 2-3

2.3.2 Structural BMPs 2-4

2.4 BMP Effectiveness........................................................................................................... 2-5

2.5 Data Gaps 2-5

3 Separation Distance BMPs 3-1

3.1 Separation Distance BMPs .............................................................................................. 3-1

3.2 BMP Effectiveness........................................................................................................... 3-1

3.3 Data Gaps 3-1

4 UIC BMP Monitoring Strategy 4-1

4.1 Selection of UIC BMPs for Monitoring........................................................................... 4-1

4.2 Development of Specific BMP Monitoring..................................................................... 4-2

4.2.1 Water Quality BMP Monitoring 4-2

4.2.2 Separation Distance BMP Monitoring 4-4

4.3 Monitoring and Testing Protocols ................................................................................... 4-4

4.4 BMP Monitoring Schedule .............................................................................................. 4-4

4.5 Other Monitoring ............................................................................................................. 4-4

5 Annual Reporting 5-1

BMP Monitoring Program Page ii December 2006

Appendices

A Summary of City of Portland BMP Effectiveness Evaluation –Water Quality BMPs B City of Portland BMP Development and Evaluation – UIC Separation Distance BMPs C Summary of Available Stormwater BMP Monitoring Information

BMP Monitoring Program Page 1-1 December 2006

11 IInnttrroodduuccttiioonn aanndd OOvveerrvviieeww 1.1 Introduction The City of Portland (City) has prepared this Best Management Practice Monitoring Program (BMP Monitoring Program) report in compliance with the Water Pollution Control Facility (WPCF) permit issued to the City by the Oregon Department of Environmental Quality (DEQ) on June 1, 2005 for the City’s underground injection control systems (UICs). The report describes the BMP Monitoring Program the City will implement throughout the permit term (June 1, 2005 – May 31, 2015) to protect groundwater quality and meet WPCF permit requirements. The City currently has approximately 9,000 UICs that collect stormwater from public rights-of-way and discharge it to the subsurface. UICs are most prevalent in the eastern portion of the City (east of the Willamette River), where subsurface soils support greater stormwater drainage and infiltration rates. For many areas, UICs are the only available form of stormwater disposal. UICs are also an essential element of a comprehensive watershed strategy to use stormwater as a resource by infiltrating it back into the ground. UICs quickly and efficiently reintroduce stormwater into subsurface soils, which filter and cool the runoff before it finds its way to groundwater and, eventually, helps recharge streams. The WPCF permit establishes the UIC construction, operation, and maintenance requirements the City must implement to protect groundwater for use as a drinking water resource. The permit is designed to protect groundwater by implementing a comprehensive stormwater management strategy to prevent, minimize, and control pollutants at the surface before stormwater is discharged to the ground. The WPCF permit requires the City to implement corrective actions for any UICs that do not comply with permit requirements. BMPs are one type of corrective action that can be taken. The City’s strategy, to implement the permit, is described in the UIC Management Plan (UICMP), submitted to DEQ in December 2006. The UICMP describes the BMPs that will be applied to the entire UIC system on an ongoing basis to meet WPCF permit requirements, protect groundwater, and support overall watershed health goals. BMPs implemented to address non-compliant UICs are described in this document and in the Corrective Action Plan1. Information obtained though the implementation and evaluation of BMPs may also be used to improve actions performed under the UICMP (e.g., System Management) such as operations and maintenance procedures, education and training.

1 The Corrective Action Plan (CAP), submitted to DEQ in July 2006, describes the process the City will use to identify, evaluate, select, implement and document corrective actions for UICs identified as noncompliant.

Section



1.2 Regulatory Requirements Congress enacted UIC rules in 1974 under the federal Safe Drinking Water Act (SDWA) and modified the rules in 1999. The U.S. Environmental Protection Agency (EPA) administers these rules under Title 40 of the Code of Federal Regulations (CFR) Parts 144 -148. In Oregon, EPA has delegated the regulation of UICs to DEQ. Oregon Administrative Rules (OAR) 340-044 regulate all groundwater as a potential source of drinking water and require municipalities with more than 50 UICs to operate under a permit. DEQ issued a WPCF permit to the City of Portland on June 1, 2005 (DEQ Permit Number 102830). The permit requires that the UICMP include the following:

• UIC registration database; • Operations and Maintenance Plan; • BMP Monitoring Program; • UIC Monitoring Program; • Employee training and public education; Spill Prevention and Pollution Control Plan;

and • UIC Decommissioning Plan.

The permit requires that City identify and discuss a range of BMPs (e.g., structural, non-structural, and institutional controls) that may be employed to meet permit conditions. The BMP Monitoring Program is required by Schedule D, Section 10 of the permit which reads:

c. BMP Monitoring Program. The Permittee must include a BMP monitoring program. BMP performance is dependent upon effective public UIC maintenance. Therefore, the BMP monitoring program may be a part of the O&M Plan. The BMP monitoring Program shall be on going for the duration of the permit. The BMP monitoring program must:

i. Evaluate the effectiveness of BMPs prior to the discharge of fluids into a public UIC to meet the discharge limits established in Table 1;

ii. Be designed to assess the effectiveness and limitations of applying a range of structural and non-structural BMPs in accordance with the conditions established in Table 2 and the various settings that occur throughout the City of Portland;

iii. Provide protocols for monitoring and testing BMPs. These protocols may be linked to the SDMP of Schedule B; and

iv. Provide BMP monitoring results in the annual UICMP reports. The WPCF permit contains specific conditions that all UICs must meet. In general, a UIC is non-compliant if it meets any of the following conditions:

1. It is within 500 feet of a domestic or irrigation well and does not meet the water quality limits established in the permit.

2. It is within 500 feet or the two-year time-of-travel of a public water system and the water quality of the discharge does not meet the water quality limits established in the permit.

3. It does not meet the water quality discharge limits at the end-of-pipe discharge point into the UIC.


4. It has insufficient separation distance between the bottom of the injection well and groundwater to protect the natural water quality.

5. It is constructed into groundwater. 6. It does not meet other general permit conditions.

The WPCF permit requires the City to implement corrective actions, in accordance with a DEQ approved Corrective Action Plan, for any UICs that do not comply with permit requirements. Corrective actions may include a range of responses, technologies, or BMPs constructed or implemented to address or resolve the non-compliant condition. The BMP Monitoring Program describes two types of BMPs that will be implemented to address non-compliant conditions and evaluate the need for overall system improvement:

• Water Quality BMPs. These BMPs address UICs that do not meet water quality limits (see conditions 1-3 listed above). In other words, stormwater quality discharged at the end-of-pipe into the UIC does not meet maximum allowable discharge limits (MADLs) specified in Table 1 of the WPCF permit.

• Separation Distance BMPs. These BMPs address UICs that have an insufficient

separation distance (see conditions 4 and 5 listed above). The WPCF permit requires that UICs more than 5 feet deep must have a minimum vertical separation distance of 10 feet between the UIC and seasonal high groundwater. UICs less than 5 feet deep must have a minimum vertical separation distance of 5 feet.

The permit requires the City to implement corrective actions for non-compliant UICs throughout the life of the permit (10 years or permit term). Non-compliant UICs must be corrected within three full Capital Improvement Program (CIP) cycles after the UIC is determined to be non-compliant. The permit recognizes and anticipates there may be situations where common problems or issues apply to a number or group of UICs within a geographic area. Regional corrective actions may be identified and performed under a permit modification or DEQ Order. 1.3 Goals and Objectives A primary goal of the City’s UIC Program and the BMP Monitoring Program is to operate, manage, and monitor the City’s UIC system to ensure permit requirements are met and groundwater quality is protected. In addition, the programs help achieve the Bureau of Environmental Services’ (BES) mission to:




Two goals are central to the BMP Monitoring Program: • Protect groundwater as a drinking water resource by ensuring that stormwater

discharging to UICs meets the MADLs established in Table 1 of the WPCF permit.

The most straightforward way to ensure that UICs will not adversely impact groundwater over time is to meet the MADLs established in the permit as being protective of groundwater quality. Where MADLs are not being met, BMPs can be used as corrective actions to improve the quality of stormwater discharges to the UIC system.

• Protect groundwater quality by ensuring that UICs have adequate separation distance between the bottom of the UIC and seasonal high groundwater.

The permit requires adequate separation distance as the primary mechanism to remove pollutants (e.g., bacteria) from stormwater before reaching groundwater. Where adequate separation is not present, the BMP Monitoring Program provides methods to modify the UIC to bring it into compliance.

The BMP Monitoring Program has the following objectives designed to address the BES mission, meet the above goals, and facilitate corrective actions:

1. Identify technologies that are most likely or most promising to correct non-compliant conditions (exceedance of stormwater MADLs or insufficient separation distance).

2. Demonstrate that certain types of BMP technologies are likely to meet stormwater

MADLs. For example, demonstrate that stormwater planters generally provide a certain range of water quality, rather than monitor each site-specific planter used as a corrective action.

3. Identify the potential limitations of selected BMP technologies to allow for permit

modifications (see Section 1.5) when best available technologies are unable to meet permit conditions.

4. Support the overall UIC Program by identifying factors that significantly affect the

quality of stormwater entering the UIC system. In summary, the BMP Monitoring Program is designed to identify and assess the effectiveness and limitations of a range of structural and non-structural BMPs. The results from the program will be used to improve the overall management of the City’s UIC system.


1.4 Relationship of the BMP Monitoring Program to Other Documents The City’s UIC Management Program comprises four major program elements: System Management, System Monitoring, Evaluation and Response, and Corrective Actions. The UICMP is the umbrella document that describes these program elements and identifies the various documents the City has prepared to address specific program activities. The BMP Monitoring Program is a component of the System Monitoring program element. The WPCF permit requires the City prepare a variety of documents that together describe the programmatic actions and management practices the City will implement to meet permit conditions and to protect groundwater. The relationship of these documents is described in the UICMP. Key documents include, but are not limited to, the following:

• Systemwide Assessment (July 2006); • Corrective Action Plan (July 2006); • Final Stormwater Discharge Monitoring Plan (August 2006); • UIC Decommissioning Procedure (December 2006); • Operations and Maintenance Plan (December 2006); and • Spill Prevention and Pollution Control Plan (December 2006).

1.5 BMP Monitoring Program Modifications Potential modifications to the BMP Monitoring Program may be identified during implementation of the program, sampling activities, or review and evaluation of the field and/or analytical data. Modifications will be addressed by revising this report or preparing addenda. Any revisions or addenda will describe the need for the modification and describe the planned activity and how it will be implemented (e.g., sampling and analyses). Potential modifications may include but are not limited to:

• Change in BMPs that may be monitored;

• Sampling design;

• Field procedures or analytical methods;

• Collection of groundwater data; and

• Collection of specific BMP effectiveness monitoring data. Proposed modifications to the DEQ-approved BMP Monitoring Program will be submitted to DEQ for review and approval in accordance with the permit modification requirements (OAR 340-045-0055). The City will:

BMPs BMPs refer to a range of structural and non-structural BMPs. These include specific actions taken to address non-compliant UICs and those BMPs applied system wide as described in the UICMP. The UICMP includes BMPs as part of the System Management element; those BMPs are actions applied to the entire UIC system on an ongoing basis to prevent, minimize, and control pollutants in stormwater prior to discharge to a UIC.


• Submit any proposed modification to DEQ for approval within 30 days of the modification.

• Have DEQ approval before implementing a modification, unless the modification is directed by DEQ.

• Include a summary of any modifications in the Annual UICMP Report. 1.6 Organization of the BMP Monitoring Program The BMP Monitoring Program Report is organized into six main sections, as described below: Section 1 provides an introduction, regulatory and permit requirements, BMP Monitoring Program goals and objectives and report organization. Section 2 reviews available information about water quality BMPs and their applicability to UIC pollutants and conditions of concern. Recommendations are made regarding the application of those BMPs to UICs. Section 3 assesses the various options for managing UICs with inadequate separation distances to groundwater and provides recommendations regarding their application. Section 4 provides the basic elements of a BMP monitoring strategy to address information deficiencies concerning the effectiveness of water quality BMPs for UIC stormwater management. Monitoring protocols are included as part of the strategy. Section 5 describes the annual reporting requirements applicable to the BMP Monitoring Program.


22 WWaatteerr QQuuaalliittyy BBMMPPss 2.1 BMP Monitoring Program Development Development of UIC water quality BMPs began as part of the City’s response to requirements of Portland’s National Pollutant Discharge Elimination System (NPDES) municipal separate storm sewer (MS4) permit. The MS4 permit required the City to develop a Stormwater Management Plan (SWMP) and a monitoring program. To quantify the impacts and effectiveness of BMPs, implemented under the SWMP, to reduce or remove stormwater pollutants, the City conducted a BMP effectiveness evaluation (Effectiveness Evaluation of Best Management Practices for Stormwater in Portland, Oregon, September 2006). The Effectiveness Evaluation focused on the removal of total suspended solids (TSS) to demonstrate reductions in pollutant discharges. This evaluation was the basis for selecting water quality BMPs for the UIC BMP Monitoring Program and is summarized in Appendix A. 2.2 General Stormwater BMPs

2.2.1 BMP Categories The Effectiveness Evaluation assessed a wide variety of stormwater BMPs. Some of the BMPs are in current use within the City of Portland, while others have found some success in other parts of the country and/or are being considered for use in Portland. The Effectiveness Evaluation examined BMPs in the following two categories:

Structural BMPs

• Swales • Wet Pond • Dry Pond • Revegetation (e.g., tree planting) • Stream Restoration • Treatment Wetlands • Planter Boxes • Filters • Sedimentation Box or Vault

• Centrifugal Separators • Sediment Manholes • Green Streets • Porous Pavement • Soakage Trenches • Catch Basins • Catch Basin Inserts • Green Roofs

Section

2


Non-Structural BMPs • Zoning, E-Zones • Operations and Maintenance (O&M) • Buffer Protections • Street Sweeping • Facility Cleaning • Technical Assistance • Stewardship • Education Programs – Business and

Residents • Education Programs – City Employees

and Other Agencies

• Impervious Surface Reduction • Downspout Disconnect • Erosion Prevention • Parks Vegetation Management Practices • Truck Washing • Spill Response • Ditch and Channel Maintenance • Leaf and Needle Pickup • Landscape Management Practices

2.2.2 Applying the Effectiveness Evaluation Results to UICs The Effectiveness Evaluation focuses on evaluating BMPs where stormwater is discharged to a receiving surface water body. For the BMP Monitoring Program, the BMPs were screened to identify BMPs that were likely to be used and technically feasible for use in conjunction with a UIC and on their estimated effectiveness in addressing the pollutants identified in Table 1 of the WPCF permit. Appendix A of this report summarizes the screening process. Stormwater and its associated water quality pollutants are generally expected to be similar throughout the Portland area. The nature of stormwater is assumed to be independent of the point of discharge (surface water body versus UIC). BMPs that are effective for stormwater discharging to a surface water body (e.g., stream, river) therefore are generally expected also to be effective for stormwater discharged to a UIC system. However, differences may include, but are not limited to:

• The acceptable quality of stormwater at the point of discharge.

For surface waters, the acceptable water quality limits are typically set to be protective of both human and ecological health (aquatic and terrestrial receptors) under the Clean Water Act. For UICs, the acceptable water quality limits are typically set to be protective of human use of groundwater (i.e., drinking water) under the Safe Drinking Water Act. Portland’s WPCF permit limits are based on groundwater protection standards established at the point of discharge (i.e., MADLs).

• The fate of stormwater particulates.

For surface water, particulates are transported to and potentially deposited in the receiving surface water body and may result in sediment contamination. For UICs, stormwater particulates are removed by pretreatment (e.g., sedimentation manhole) if present, or settle in the bottom of the UIC. These sediments are typically contained in a sediment manhole or concrete sump base, where they are inaccessible to humans or ecological receptors. In addition, these sediments are removed on a periodic basis as described in the UIC Operations and Maintenance Plan (see Appendix B of the UICMP).


2.3 Water Quality UIC BMPs In selecting water quality BMPs, the first priority was to identify BMPs that can address pollutants that exceeded MADLs2 in year 1: pentachlorophenol, di(2-ethylhexyl)phthalate (DEHP), and lead. The second priority was to identify BMPs that can address other pollutants listed in Table 1 of the permit that were detected but did not exceed MADLs. Some generalizations can be made about the nature of the various pollutant types, indicating the stormwater management mechanism to which they may respond:

• Organics tend to be readily adsorbed to particulate matter. Whatever mechanisms remove sediment and other particulars will be efficient in removing the associated organics. Solvent-type organics can also be stripped by aeration because of their volatile nature.

• Metals are also associated with particulate matter in large part, although significant and more bioavailable fractions of some metals can be in dissolved forms as well.

• Nutrients are removed by biological processes where conditions allow, but can also be removed by physical processes of filtration and settling when in particulate form.

2.3.1 Non-structural BMPs The most effective way to address pollutants of any type is to prevent their release. The UICMP Evaluation and Response program element includes guidelines for pollutant source identification, source control, and source monitoring. The intent is to control pollutants at their source to prevent discharge into the City’s UIC system. Because of the endemic nature of some pollutant sources (e.g., automobiles, utility poles, plastics, air deposition), however, it may take significant effort, public involvement, and many years to effect a change. Several non-structural stormwater BMPs evaluated in the Effectiveness Evaluation are recommended to reduce pollutant concentrations discharging to UICs, as shown below:

Stormwater Management Improvements

Non-Structural BMPs

Total suspended solids (TSS) removal (used also as a surrogate for organics and total metals removal)

• Street sweeping • Maintenance of UIC system components • Erosion control • Development regulation

Dissolved metals management • Street sweeping • Downspout disconnection

Nutrient reduction • Street sweeping • Maintenance of UIC system components

Pollutant reduction

• Source identification • Source control • Spill prevention and control • Public education and training

2 The results of permit year 1 stormwater discharge monitoring are summarized in Appendix A.


These BMPs can be implemented citywide or tailored to specific problem areas where pollutants of concern are entering UICs above MADLs. Examples include, but are not limited to:

• Frequent street sweeping is areas determined to pose a higher risk to groundwater to reduce the potential for pollutants to be transported to the UIC system.

• Maintenance of sediment manholes, UIC sumps and catch basins (and any associated inserts) can be implemented as described in the O&M Plan (see Appendix B of the UICMP) to remove accumulated sediment (i.e., accumulated stormwater particulate) and debris that be transported to the UIC sump.

Non-structural BMPs may be important in reducing pollutants in stormwater. Non-structural controls may be evaluated by documenting compliance with specific corrective action goals, objectives, or requirements. The type of performance demonstration will depend on the specific action that is implemented. Examples of how performance may be documented and assessed include, but are not limited to:

• Documenting that a pollutant source has been terminated.

• Documenting the content of and number of attendees at public education events.

• Collecting feedback on the effectiveness of education or training (e.g., through surveys).

• Providing copies of public outreach materials.

• Documenting the content of in-house City training, the number of people trained, the learning objectives, etc.

• Providing copies of applicable land use restrictions, code, or policy changes. Evaluating the effectiveness of non-structural BMPs is complicated by different measures of success or effectiveness in implementing the BMP. These measures do not typically correlate directly to pollutant removal or reduction (see Section 2.5). Before selecting and implementing a BMP for a non-compliant UIC, the process described in the Corrective Action Plan (submitted July 15, 2006) will be followed to identify, evaluate, and select an appropriate protective action.

2.3.2 Structural BMPs Several structural stormwater BMPs evaluated in the Effectiveness Evaluation are recommended to reduce pollutant concentrations discharging to UICs, as shown below.


Structural BMPs

TSS removal (used also as a surrogate for organics and total metals removal)

• Sedimentation manholes • Stormwater planters • Swales • Vegetated infiltration basins (e.g., curb

extensions) • Filters



Structural BMPs

• Wet ponds

Dissolved metals management

• Swales • Planters • Filters • Riparian restoration

Nutrient reduction • Treatment wetlands • Wet ponds • Swales

2.4 BMP Effectiveness Based on the results of the Effectiveness Evaluation, it is expected that the BMPs listed in Sections 2.3.1 and 2.3.2 will provide a significant degree of management for the majority of the pollutants (common and priority pollutant screen (PPS)) identified in the permit. Additional BMPs may be identified in the future for further evaluation (e.g., emerging or innovative technologies). Because of the variability in BMPs, pollutants, and site-specific conditions, it is not possible to definitely determine how effective a specific BMP will be in achieving MADLs or reducing pollutant concentrations with the available data. However, the BMPs identified, in the previous sections, are those anticipated to be the most effective in improving stormwater quality. Selected BMPs will be further evaluated and/or monitoring, as described in Section 4, to demonstrate their effectiveness in meeting permit conditions and protecting groundwater. It should be noted, that before a BMP is applied to a non-compliant UIC, it will be further evaluated based on site-specific considerations, following the process described in the Corrective Action Plan to assure permit requirements are met and groundwater is protected. 2.5 Data Gaps The Effectiveness Evaluation focused on the removal of total suspended solids (TSS) to demonstrate pollutant reduction, and TSS removal is the basis of stormwater facility design in the City’s Stormwater Management Manual. At this time, however, it is not known if TSS is a representative surrogate for UIC pollutants such as pentachlorophenol and DEHP. It is anticipated that TSS removal would likely decrease the concentrations of these pollutants. Further evaluation is needed to demonstrate the effectiveness of the proposed structural and non-structural BMPs in achieving MADL concentrations. TSS may be a representative surrogate for total lead, but the nature of dissolved lead relative to BMPs is less well understood. The ranges of total lead concentrations in BMP effluent (filters, swales, sediment manholes, infiltration and flow–through planters, and vegetated infiltration basins) appear to meet the total lead MADL.


Second-priority organics, metals, and nutrients should be further evaluated if they start to appear at higher levels during the stormwater discharge monitoring that will be conducted as part of the UIC Program. Non-structural BMPs appear to be important in managing stormwater discharges. Of particular interest is the use of street sweeping to intercept pollutants on road surfaces. In addition, maintenance of stormwater facilities such as catch basins and sediment manholes will keep those facilities operating at optimum levels. Further evaluation of those practices is needed to quantify their impacts on stormwater discharges.


33 SSeeppaarraattiioonn DDiissttaannccee BBMMPPss The estimated 9,000 UICs in the public UIC inventory were built over many years, to a variety of design standards, and in some cases by other jurisdictions before City annexation. As a result, some UICs have been built with inadequate separation between the bottom of the UIC and seasonal high groundwater, as defined by the permit. This section identifies BMPS for addressing inadequate separation distance. 3.1 Separation Distance BMPs BMPs that may be used to address inadequate separation distance are developed and screened in Appendix B. Most of these BMPs focus on methods that increase the separation distance. The BMPs are listed below in the recommended order for consideration.

• Fill the UIC with various types for backfill materials to achieve separation. • Fill the UIC with various types of fill or filter materials to achieve separation and

treatment. • Fill the UIC with compactable material or grout to the appropriate level. • Plug the openings in the UIC rings. • Decommission the UIC; replace with a shallower UIC. • Decommission the UIC; discharge stormwater to the piped stormwater system or

combined sewer system. The focus for the BMPs is on existing UICs, since new UICs will be constructed to be compliant with the WPCF permit. 3.2 BMP Effectiveness The recommended BMPs listed above are considered to be effective for addressing inadequate separation distance. Before selecting and applying a BMP to a non-compliant UIC, the BMP will be further evaluated based on site-specific considerations, following the process described in the Corrective Action Plan. 3.3 Data Gaps Further evaluation will be needed to determine the best methods and materials for implementing the BMPs listed above. Fill materials may be selected to provide treatment of a specific stormwater pollutant(s), if necessary, to meet MADL concentrations; in these cases, monitoring may be needed to demonstrate the effectiveness of treatment. Possible questions to explore when initiating the use of each of these BMPs include:

• What type of backfill material will provide the most protection for groundwater when used to elevate a UIC?

Section

3


• How frequently must that filter material be replaced to retain filtration and infiltration capacity?

• How does filling the UIC with filter material, or raising the base of the UIC using impermeable materials, affect flow capacity? Is there a rule curve that can be developed to guide design decisions?

• How effective is plugging the openings in a UIC, both in initial installation and over time?

• What are the structural considerations and remedies (if needed) for a UIC with a portion of its openings plugged?

BMP Monitoring Program Page 4-1

December 2006

44 UUIICC BBMMPP MMoonniittoorriinngg SSttrraatteeggyy Section 2.3 of this report identifies water quality BMPs expected to provide a significant degree of management for the majority of pollutants (common and priority pollutant screen) identified in the WPCF permit. As discussed in Section 2.4, however, the estimated effectiveness of these BMPs is based primarily on TSS removal, and it is not known at this time if TSS is a representative surrogate for UIC pollutants such as pentachlorophenol and DEHP. Therefore, further evaluation is needed to demonstrate the effectiveness of the BMPs in achieving MADL concentrations. The monitoring strategy is intended to meet the requirements established in Schedule D, Section 10(c)(ii - iii) of the WPCF permit (see Section 1.2). The UIC BMP monitoring strategy discussed below focuses on:

• Assessing the effectiveness and limitations of a range of structural and non-structural BMPs;

• Demonstrating that BMP implementation results in achieving: o MADLs at the point of stormwater discharge into a UIC; or o Adequate separation distance.

• Evaluating the feasibility of BMP implementation (e.g., site specific versus system wide) • Supporting the overall UIC Program by identifying factors that significantly affect the

quality of stormwater entering the UIC system to facilitate program improvements. 4.1 Selection of UIC BMPs for Monitoring This section presents list of BMPs that may be further evaluated and/or monitoring under the BMP Monitoring Program. This list was developed using the BMPs identified in Section 2.3 and were represent a subset of BMPs anticipated to be the most effective in achieving stormwater discharges that meet the permit specified MADLs. In addition, the listed BMPs are those that are or are anticipated to be implemented within Portland’s UIC system include:

• Improving stormwater discharge quality using: o Sedimentation manholes; o Street sweeping; o Maintenance of sedimentation manholes and catch basins; o Pollution reduction (e.g., source identification and controls; spill prevention and

control; public education and training); o Swales (typically roadside vegetated or grass lined swales); o Stormwater planters; o Vegetated infiltration basins (i.e., curb extensions).

• Increasing Separation Distances using: o Filling the UIC with various types for backfill materials to achieve separation. o Decommission the UIC; replace with a shallower UIC(s).

Section

4


December 2006

In addition, additional two additional BMPs are identified that could be implemented, if necessary and appropriate, on a site-specific basis to address unique pollutant sources.

• Catch basin filters (e.g., inserts); and • Sedimentation manhole filters (e.g., inserts).

The above lists will be used as a starting point for identifying which BMPs should be further evaluated and/or monitored under the BMP Monitoring Program to document their effectiveness and determine if they meet MADLs. Limited data are currently available on the effectiveness of these BMPs in achieving MADLs for the pollutants specified in the permit and specifically, the three primary pollutants identified in year 1 monitoring: pentachlorophenol, DEHP, and lead (see Section 2.3). Appendix C summarizes the available monitoring information for the BMPs, based on information included in the Effectiveness Evaluation report. In addition to these BMPs, the recommended non-structural BMPs or additional structural BMPs (e.g., emerging or innovative technologies) may also be evaluated, as appropriate and practicable. Selection of specific BMPs that will be evaluated or monitored will be determined, based on a consideration of the following factors:

• Known or anticipated use (e.g. widespread or site-specific implementation); • Nature and extent of the issue the BMP is addressing; • Site-specific or issue-specific information; • Pollutant characteristics; • Specific BMP design (including consideration of variations in BMP design); and • BMP space requirements (e.g., available land, rights-of-way); and • Special operations and maintenance needs of the BMP (as well as the needed

maintenance guidance and scheduling).

BMPs selected for evaluation or monitoring will be identified in the annual UICMP report (see Section 5). 4.2 Development of Specific BMP Monitoring

4.2.1 Water Quality BMP Monitoring Monitoring stormwater discharge quality will be conducted on selected BMPs that are or are anticipated to be widely implemented, to reduce pollutant concentrations in stormwater discharges to City-owned UICs. Specific BMP monitoring parameters will be developed on the specific objectives of the study, nature of the issue (e.g., pollutant type), and BMP design and operation. A key objective of the monitoring is to demonstration that specific types of BMPs can meet permit specific MADLs (i.e., a technology-specific demonstration of compliance rather than site


December 2006

specific monitoring). For example, monitoring may be performed to demonstrate that stormwater planters provide a certain range of effluent water quality or pollutant reduction at the technology level (i.e., BMP type), instead of monitoring each planter that may be used as pretreatment. BMPs selected for monitoring will be identified in the annual UICMP report. The monitoring program for the selected BMPs will be developed, based on consideration of the available effectiveness data (Appendix C) and site- or issue specific information. The primary elements of the BMP-specific monitoring program will include:

A. A description of the specific goal(s) and/or objective(s) of the BMP monitoring.

B. A description of the scope of the planned BMP monitoring, including but not limited to: i. Sample location(s); ii. Sampling frequency; iii. Sampling method(s); iv. Analytical method(s); and v. QA/QC requirements.

Monitoring will be performed in accordance with the Stormwater Discharge Monitoring Plan (August 2006), to the extent practicable and feasible. The sampling program will be designed to meet the requirement of the permit (e.g., method detection and reporting limits, notification of concentrations exceeding MADLs).

C. A description of how the results of the BMP monitoring will be evaluated. This may include, but not be limited to:

i. Evaluating the effectiveness and general performance of the BMP;

ii. Determining if the BMP demonstrates permit compliance;

iii. Determining if additional monitoring is needed to meet the objectives of the BMP effectiveness investigation or to address data gaps identified by the investigation; and

iv. Initiating BMP design changes to increase the effectiveness of the BMP. The results of BMP effectiveness monitoring may be used to demonstrate that UIC corrective actions are protective of groundwater quality. However, some corrective actions may require specific sampling and analyses to document their effectiveness or performance. If site-specific data are needed, the data will be collected and analyzed to the extent required and feasible to be consistent with the Corrective Action Plan, the Stormwater Discharge Monitoring Plan, and the BMP Monitoring Program. Performance data and/or sampling results collected to demonstrate the effectiveness of a corrective action will be reported to DEQ in the Annual UICMP Report submitted in November of each year and will be used to the extent applicable to evaluate the BMPs described in this report.


December 2006

4.2.2 Separation Distance BMP Monitoring The Separation Distance BMPs are considered effective at increasing the distance of the floor of the UIC from the seasonal high groundwater table to meet permit requirements. Therefore, the BMP Monitoring Plan will focus on developing potential UIC backfill alternatives, defining criteria to identify UICs where these BMPs are applicable and evaluating the feasibility of broad application based on consideration of:

• Constructability (e.g., permitting issues, material availability, construction methods, vertical separation needed, site constraints, design limitations, utilities);

• Effectiveness (e.g., ability of UIC to handle quantity of flow with reduced infiltration capacity);

• Acceptability (e.g., legal constraints, political considerations);

• Unit Costs (e.g., operational and capital present worth expense); and

• Operational impacts (e.g., difficulty of operating and maintaining). 4.3 Monitoring and Testing Protocols To the extent practicable, BMP monitoring data will be collected in accordance with the following documents, as applicable and appropriate:

• Stormwater Discharge Monitoring Plan (SDMP; August 2006), including: o Sampling and Analyses Plan (SAP) o Quality Assurance Project Plan (QAPP)

• Decommissioning Procedure (December 2006), including:

o UIC Program Standard Operating Procedure (SOP) #1.00 – Sediment Sample Collection Procedures for UIC Decommissioning

o UIC Program SOP #2.00 – Water Sample Collection Procedures for UIC Decommissioning

4.4 BMP Monitoring Schedule The BMP monitoring schedule will be presented in the annual UICMP report submitted to DEQ each November. 4.5 Other Monitoring Because of the ubiquitous nature of several pollutants detected in stormwater discharged to the City’s UIC system (e.g., pentachlorophenol, DEHP, and total lead), specific studies may be needed to identify and document the source(s) of these pollutants. The UICMP Evaluation and Response program element includes guidelines for identifying potential pollutant sources,


December 2006

performing various investigations to determine UIC compliance, and evaluating groundwater protection, as needed. Data collected under these guidelines may in some instances inform the BMP monitoring and evaluation process. To the extent practicable and feasible, similar monitoring protocols, analyte lists, and analytical methods/detection limits will be used so the data between the program elements are comparable. Stormwater monitoring conducted as part of the Corrective Action process will also be collected using similar monitoring protocols, analyte lists, and analytical methods/detection limits to facilitate the BMP monitoring and evaluation process, to the extent practicable and feasible. The City may collect stormwater-monitoring data associated with other programs, issues, or priorities. Those data will be incorporated into the evaluation of specific BMPs if appropriate and if the data are of known and verifiable quality.


December 2006



55 AAnnnnuuaall RReeppoorrttiinngg This section is intended to meet the requirements of Schedule D, Section 10(c)(iv) of the permit. BMP monitoring data and/or sampling results collected to demonstrate the effectiveness of a BMP will be reported to DEQ in appropriate technical memorandum or reports, as necessary and appropriate, and will be summarized in the annual UICMP report submitted in November of each year. The annual UICMP report will include the following information as necessary and appropriate:

1. Information accumulated during the annual reporting period, such as:

a. A summary and analysis of BMP monitoring information accumulated during the annual reporting period;

b. Type of BMP(s) evaluated;

c. Characteristics of the UIC drainage basin(s) where the BMP(s) are evaluated (e.g., location, traffic type and volume, and nature of land use); and

d. Conclusions regarding BMP performance or effectiveness,

2. Summary of monitoring or activities planned for the upcoming permit year such as:

a. Monitoring elements (e.g., objectives, protocols, analytical methods); and

b. Schedule. BMP monitoring data, performance data, records, and reports will be maintained in the UIC Program files and will be available for review upon request.

Section

5



BMP Monitoring Program December 2006

Appendix A

Summary of City of Portland BMP Effectiveness Evaluation

Water Quality Based BMPs



BMP Monitoring Program Page A-1 December 2006

Summary of City of Portland BMP Effectiveness Evaluation

Water Quality Based BMPs A-1 General Stormwater BMPs The Effectiveness Evaluation of Best Management Practices for Stormwater in Portland, Oregon (Effectiveness Evaluation), dated September 2006, assessed a wide variety of stormwater BMPs, some of which are in current use within the City of Portland, others that have found some success in other parts of the country and or are being considered for use in Portland. The team participating in the development of the Effectiveness Evaluation examined BMPs in two primary categories as follows:

Structural BMPs • Swales • Wet Pond • Dry Pond • Revegetation (e.g., tree planting) • Stream Restoration • Treatment Wetlands • Planter Boxes • Filters • Sedimentation Box or Vault

• Centrifugal Separators • Sediment Manholes • Green Streets • Porous Pavement • Soakage Trenches • Catch Basins • Catch Basin Inserts • Green Roofs

Non-Structural BMPs

• Zoning, E-Zones • Operations and Maintenance (O&M) • Buffer Protections • Street Sweeping • Facility Cleaning • Technical Assistance • Stewardship • Education Programs—Business and

Residents • Education Programs—City Employees

and Other Agencies

• Impervious Surface Reduction • Downspout Disconnect • Erosion Prevention • Parks Vegetation Management Practices • Truck Washing • Spill Response • Ditch and Channel Maintenance • Leaf and Needle Pickup • Landscape Management Practices


A-2 Stormwater BMP Effectiveness The Effectiveness Evaluation provides a “tool box” of stormwater management BMPs currently in use or planned for use in the Portland area, along with supporting information about how the effectiveness estimates were derived, and the certainty of those estimates. The Effectiveness Evaluation results are intended to facilitate stormwater management design and decision-making. The evaluation develops and documents the range of effectiveness (e.g., percent removal) and preferred values (default) for numerous stormwater BMPs. Effectiveness is described as a range for each BMP, as well as the location-specific or application-specific conditions that may affect BMP effectiveness. In addition, default effectiveness values (“typical” or “representative” effectiveness values within the range) that can be used when there is limited information about the use of a BMP, or when standard conditions apply when the BMP is functioning as expected. Information for the Effectiveness Evaluation came from a variety of sources. Each source was evaluated for its significance, and the best available information was used. The process included both the use of prior studies (as they can be applied locally) and the judgment of BES staff and other professionals. Where directly measured information was unavailable, staff used professional judgment to extrapolate from available data and use various estimation techniques as appropriate. The values presented in the Effectiveness Evaluation report represent the best available current information and professional judgment. The values should be considered “a work in progress” and a starting point for further discussion. The comprehensive list of BMPs evaluated enables the BMPs to be compared against each other. It also helps identify significant elements of unavailable data and resulting uncertainty regarding BMPs. If some pollutants or conditions have few effective BMPs associated with them, future study or development of BMPs can be directed at those pollutant or conditions, if necessary. A compilation of BMPs can also frame assumptions regarding the interrelatedness of BMPs and how those BMPs may (or may not) work in series. The report also documents the decision-making and effectiveness estimation process and provides necessary qualifiers regarding the quality and reliability of the effectiveness estimates. This information is important to decision makers so they can assess levels of confidence in the evaluation and effectively manage risk and uncertainty in applying the effectiveness values. A summary of the water quality based UIC BMPs identified as applicable to stormwater discharged to UICs and included in the Effectiveness Evaluation is provided in Table A-1, presented at the end of this appendix. The spreadsheet in Table A-1 identifies: BMP type, applicable contaminant class, BMP effectiveness range, qualifiers, and certainty estimates.


A-3 Water Quality Based UIC BMPs A-3.1 BMP Screening This section describes the process that was used to develop a list of stormwater management BMPs that would be expected to effectively protect groundwater quality from adverse impacts associated with stormwater discharges to UICs. This list represents a subset of the BMPs evaluated in the Effectiveness Evaluation, described above and was developed based on consideration of the types of pollutants detected in stormwater discharged to the UIC system. A-3.2 UIC Stormwater Water Quality Criteria Table 1 of the WPCF permit specifies the maximum allowable discharge limits (MADL) allowed in stormwater discharges to UICs and groundwater compliance limits. The BMPs selected for evaluation in the BMP Monitoring Program must be relevant to the pollutants of concern in the permit. Common pollutants identified in the permit are analyzed in all stormwater discharge samples collected in accordance with the Stormwater Discharge Monitoring Plan (SDMP, City of Portland, 2006). Priority pollutant screen (PPS) analytes are analyzed in permit years 1, 4, and 9. This document focuses on common pollutants. The annual mean stormwater discharge concentrations to UICs must stay below the permit specified MADLs. In the event, a PPS analyte is detected above it respective MADL, many of the BMPs used for the common pollutants are expected to effective as well, due to similar chemical properties and anticipated pollutant fate and transport. As described in the Annual Stormwater Discharge Monitoring Report for permit year 1 (City of Portland, July 15, 2006), five UIC sampling events were completed as required by the permit, between October 2005 and May 2006. Stormwater samples from discharges to City owned UICs were analyzed for both common pollutant and PPS analytes (e.g., metals, volatile organic compounds, semivolatile organic compounds, and pesticides) as defined by the permit. Thirteen of the 14 common pollutants were detected during Year 1 including: benzene, toluene, xylenes, benzo(a)pyrene, di(2-ethylhexyl)phthalate (DEHP), pentachlorophenol, arsenic, cadmium, chromium, copper, lead, zinc, and total nitrogen. Ethylbenzene was not detected in Year 1. Seven of the 27 PPS analytes were detected during Event 1 and included: antimony, barium, beryllium, mercury, selenium, 2,4-D, and dinoseb. These seven PPS analytes were monitored during Events 2 through 5 to obtain a total of five samples as required by the permit. Thirty-five ancillary pollutants3 were detected at low concentrations (generally less than 1 µg/L) in Year 1. Twenty-one of these were detected at a frequency of less than 9% including 16 that were detected at a frequency of less than 3% during individual sampling events. The nine compounds that were detected at the highest frequencies during the individual sampling events were polycyclic aromatic hydrocarbons (PAHs). Of these naphthalene had the highest

3 Ancillary pollutants are defined as analytes detected by the DEQ approved analytical methods in the SDMP. The

permit requires these pollutants be included in the annual monitoring report.


concentration (3.61 µg/L); the maximum concentrations of the other PAHs were, in general, less than about 0.6 µg/L. Three common pollutants were detected in Year 1 at concentrations above their respective MADLs during individual sampling events:

1. Pentachlorophenol (nine UIC locations),

2. DEHP (four UIC locations), and

3. Lead (three UIC locations) Annual mean concentrations were all below their respective MADLs, with the exception of pentachlorophenol, which exceeded the MADL at five UIC locations. The detected concentrations of PPS analytes were below their respective MADLs for both individual events and annual mean concentrations. For purposes of this report, the common pollutants detected in Year 1 above their respective MADLs, pentachlorophenol, DEHP, and lead, constitute the first priority for identification of BMPs to address those COCs. The second priority for identification of associated BMPs is the other common pollutants detected but not exceeding MADLs The pollutants selected as priorities in the prior section are listed in Table A-2 below along with some chemical characteristics, as appropriate, as clues to the stormwater management mechanisms to which they might respond. Some generalizations can be made about the nature of the various pollutant types:

i. Organics tend to be readily adsorbed to particulate matter. Whatever mechanisms remove sediment and other particulars will be efficient in removing the associated organics. Solvent-type organics can also be stripped by aeration due to their volatile nature.

ii. Metals, in large part, are particulate associated as well, although significant and more bioavailable fractions of some metals can be in dissolved forms as well.

iii. Nutrients are removed by biological processes where conditions allow, but can also be removed by physical processes of filtration and settling when in particulate form.

A-3.3 Potential BMP Constraints for Application to UICs The great majority of City-owned UICs are located within paved public rights of way (ROW). Typically these are areas with limited space, being very visible to adjacent properties and competing with other ROW utilities as well as parking demands. BMP application to address stormwater pollutants must consider traffic safety and be amenable to the rigors of vehicle and pedestrian intrusions. Depending on the pollutant of concern, the BMP itself may not be designed with high rates of infiltration to assure groundwater protection.


A-4 Effectiveness Evaluation Data Limitations

TSS has been extensively monitored and so has relatively high quality information about pollutant removals. Those results, however, are expressed in a variety of ways for the BMP and pollutants of concern including pounds per year for specific application, percent removals and effluent concentrations. For purposes of evaluating the applicability and sufficiency of particular BMPs to meeting MADLs, effluent concentrations are needed. There is no information about how various BMPs might influence effluent concentrations when used as part of a treatment train (rather than just individually). Due to space limitations at the typical UIC (sump) site, use of series BMP may be impractical. So this issue may be of less concern. Also, the specific relationship between TSS, as a surrogate, and the two organic constituents of concern, pentachlorophenol and DEHP, has not been established. A correlation between each organic pollutant and TSS is needed to convincingly use the available TSS effluent concentrations. No information was available about the impact of sediment manhole maintenance on effluent concentrations for the three pollutants of concern. Measurements of “before” and “after” maintenance are needed for a series of “full” conditions for the manholes to evaluate the optimum maintenance trigger condition for each type of pollutant. Total lead reduction has much more information associated with it. Conversion of pounds per year information to effluent concentrations is still required for street sweeping and catch basin maintenance. As noted above, there were no studies of sediment manholes identified in the Effectiveness Evaluation for total lead removal. The MADLs for PCP, DEHP and total lead are 1.0 ug/L, 5.0 ug/L, and 50.0 ug/L, respectively. The only BMPs that can be directly related to those MADLs on an effluent concentration basis, based on information from the Effectiveness Evaluation, are total lead reductions using swales, curb extensions, stormwater planters, sediment manholes, and catch basins. All of those BMPs, even at the high effluent concentration end of the ranges, reduced total lead concentrations below the MADL. That was true also of sediment manholes and catch basins with or without the addition of filters: based on the general effluent concentrations for filters there was little benefit to including insert filters to either of those BMPs. Significant amounts of TSS can be removed by all the chosen BMPs, but whether that would result in concentrations low enough to achieve MADLs cannot be determined. Typical stormwater influent concentrations of the three pollutants of concern tend to be low to begin with (even when exceeding MADLs), so attaining any level of removal may be difficult and potentially unpredictable.



Table A-1 Summary of BMP Effectiveness

BMP Type

Specific BMPs Included in

TypeContaminant/

Condition Class

Specific Contaminant/

Conditions Included in Class Units

Low Positive Impacts

Conditions Favoring Low Positive Impacts

High Positive Impacts

Conditions Favoring High Positive Impacts

Default Positive Impact Qualification

Certainty (H, M, L, or %)

Flow-through Stormwater

Planters

Flow-through planterPlanter boxes (Filterra, New Columbia)

Metals Dissloved Copper ug/L 75 High influent concentrations, low metal content in soil 55 Low influent concentrations, high

metal content in soils 63 Based on synthetic stormwater for 1 facility (Inglewood, Maryland). 10%

Infiltration Stormwater

PlantersInfiltration Planters Metals Dissloved Copper ug/L 75 high influent concentrations, low

metal content in soil 55 Low influent concentrations, high metal content in soils 63 Based on synthetic stormwater for 1 facility

(Inglewood, Maryland). 10%

Vegetated Infiltration

Basins

Veg Infil Basins, Rain Gardens, Curb Extensions

Metals Dissloved Copper ug/L 75 high influent concentrations, low metal content in soil 55 Low influent concentrations, high


Filters

Sand, gavel, compost, peat or other media systems: Flow through planters, Stormfilter, sand filters, vegetated filters

Metals Dissolved Copper ug/L 5.8

Extreme local conditions, e.g. erosion; low O&M frequency; incorrect match of media to pollutants, e.g. inert media to dissolved pollutants

2.2

Low influent concentrations;high O&M frequency; correct match of media to pollutants, e.g. sorptive media to dissolved parameters

3.7 Use high values for sand, low values for compost, activated carbon, zeolite. L

Swales

Broad, shallow, vegetated channels and infiltration swales

Metals Dissolved Copper ug/L 7.5High velocities, poor infiltration, low facility size to drainage area ratio

4.3

Low velocities, good infiltration, use of mulch (adsorption), presence of some clay fines for adsorption, high facility size to drainage area ratio

5.7 M

Sediment Manholes

In-line sedimentation manholes and vaults/boxes

Metals Dissolved Copper ug/L 9.1

Extreme local conditions, e.g. erosion; low O&M frequency; relatively shallow depth below outlet

3.7Low influent concentrations;high O&M frequency; adequate depth below outlet

6.2 L

Filters


Metals Dissolved Lead ug/L 0.16


0.11



Filters Ecoroofs Metals Dissolved Lead ug/L 0.64 Soil media with high mineral content, thinner soil(?) ND Soil media with high organic

content, thicker soil(?) 0.20 Default value is the average of the concentrations for both soil media for all events. L

Sediment Manholes


Metals Dissolved Lead ug/L 0.42



0.26 L

Swales


Metals Dissolved Lead ug/L 0.69High velocities, poor infiltration, low facility size to drainage area ratio

0.34


0.5 M

BMP Effectiveness RangeBMP Group: Structural

BMP Monitoring PlanDecember 2006 Structural BMPs Appendix A


BMP Type


TypeContaminant/

Condition Class











Planters


Metals Dissolved Lead ug/L 25 high influent concentrations, low metal content in soil 6.7 Low influent concentrations, high



PlantersInfiltration Planters Metals Dissolved Lead ug/L 25 high influent concentrations, low

metal content in soil 6.7 Low influent concentrations, high metal content in soils 11 Based on synthetic stormwater for 1 facility



Basins


Metals Dissolved Lead ug/L 25 high influent concentrations, low metal content in soil 6.7 Low influent concentrations, high


Filters


Metals Dissolved Zinc ug/L 13


4.8



Swales


Metals Dissolved Zinc ug/L 24High velocities, poor infiltration, low facility size to drainage area ratio

17


20 M

Sediment Manholes


Metals Dissolved Zinc ug/L 50


26Low influent concentrations;high O&M frequency; adequate depth below outlet

38 L

Filters Ecoroofs Metals Dissolved Zinc ug/L 66.2

Soil media with high mineral content, galvanized metal on roof, use of moss control chemicals, larger storms

7.7 Soil media with high organic content, smaller storms 24.3 Default value is the average of the

concentrations for both soil media for all events. L


Planters


Metals Dissolved Zinc ug/L 560 high influent concentrations, low metal content in soil 110 Low influent concentrations, high

metal content in soils 240Based on synthetic stormwater for 1 facility (Inglewood, Maryland). Values not indicative of local, Portland conditions.

10%


PlantersInfiltration Planters Metals Dissolved Zinc ug/L 560 high influent concentrations, low

metal content in soil 110 Low influent concentrations, high metal content in soils 240

Based on synthetic stormwater for 1 facility (Inglewood, Maryland). Values not indicative of local, Portland conditions.

10%


Basins


Metals Dissolved Zinc ug/L 560 high influent concentrations, low metal content in soil 110 Low influent concentrations, high

metal content in soils 240Based on synthetic stormwater for 1 facility (Inglewood, Maryland). Values not indicative of local, Portland conditions.

10%



BMP Type


TypeContaminant/

Condition Class











Planters


Metals Metals, general % Removal 43

Low influent concentrations, faster draining soils (gravels & sands), high metal content in soils, runoff from roofs

98

High influent concentrations, slower draining soils (silts & clays), low metal content in soil, runoff from streets

90

Literature seldom gives effluent concentrations; consistent removals for dissolved and total > 90%; not much difference with depth. Roof runoff typically contains much higher proportions of dissolved metals.

M


PlantersInfiltration Planters Metals Metals, general %

Removal 43Low influent concentrations, faster draining soils (gravels & sands), high metal content in soils

98High influent concentrations, slower draining soils (silts & clays), low metal content in soil

90Literature seldom gives effluent concentrations; consistent removals for dissolved and total > 90%; not much difference with depth.

M


Basins


Metals Metals, general % Removal 43

Low influent concentrations, faster draining soils (gravels & sands), high metal content in soils

98High influent concentrations, slower draining soils (silts & clays), low metal content in soil

90Literature seldom gives effluent concentrations; consistent removals for dissolved and total > 90%; not much difference with depth.

M

Filters


Metals Total Copper ug/L 8.4


3.4



Swales


Metals Total Copper ug/L 14.7High velocities, poor infiltration, low facility size to drainage area ratio

8.4


11.4 M

Filters Ecoroofs Metals Total Copper ug/L 27.1Soil media with high mineral content, newer ecoroof, unestablished vegetation

4.9Soil media with high organic content, older ecoroof, established vegetation

11.5 Default value is the average of the concentrations for both soil media for all events. L

Sediment Manholes


Metals Total Copper ug/L 19.7



14.7 L


Planters


Metals Total Copper ug/L 85 high influent concentrations, low metal content in soil 55 Low influent concentrations, high



PlantersInfiltration Planters Metals Total Copper ug/L 85 high influent concentrations, low




Basins


Metals Total Copper ug/L 85 high influent concentrations, low metal content in soil 55 Low influent concentrations, high




BMP Type


TypeContaminant/

Condition Class










Filters Ecoroofs Metals Total Lead ug/L 0.88 Soil media with high mineral content, thinner soil(?) ND Soil media with high organic

content, thicker soil(?) 0.30Default value is the average of the concentrations for both soil media for all events minus one outlier on west side.

L

Swales


Metals Total Lead ug/L 8.8High velocities, poor infiltration, low facility size to drainage area ratio

5.6


7.2 M

Filters


Metals Total Lead ug/L 10.2


6.1


8 Use high values for sand, low values for compost, activated carbon, zeolite. L

Sediment Manholes


Metals Total Lead ug/L 12.3



9.1 L


Planters


Metals Total Lead ug/L 26 high influent concentrations, low metal content in soil 6.7 Low influent concentrations, high



PlantersInfiltration Planters Metals Total Lead ug/L 26 high influent concentrations, low

metal content in soil 6.7 Low influent concentrations, high metal content in soils 16 Based on synthetic stormwater for 1 facility



Basins


Metals Total Lead ug/L 26 high influent concentrations, low metal content in soil 6.7 Low influent concentrations, high


Filters


Metals Total Zinc ug/L 185


10


15 Use high values for sand, low values for compost, activated carbon, zeolite. L

Swales


Metals Total Zinc ug/L 58High velocities, poor infiltration, low facility size to drainage area ratio

39


48 M

Sediment Manholes


Metals Total Zinc ug/L 119



92 L



BMP Type


TypeContaminant/

Condition Class











Planters


Metals Total Zinc ug/L 1400 high influent concentrations, low metal content in soil 120 Low influent concentrations, high



PlantersInfiltration Planters Metals Total Zinc ug/L 1400 high influent concentrations, low




Basins


Metals Total Zinc ug/L 1400 high influent concentrations, low metal content in soil 120 Low influent concentrations, high


Swales


Nutrients Total Phosphorus mg/L 0.26

High velocities, high P content in native soils, low infiltration rates (or none), low facility size to drainage area ratio

0.17

Low velocities, low P content in native soils, good infiltration rates, high facility size to drainage area ratio

0.21 Values exceed TMDL for Fanno Creek; function of inflow concentration. M

Sediment Manholes





0.22 M

Filters




0.19


0.15High effluent concentrations with sand or compost. Low effluent with zeolite, activated carbon.

L


Planters


Nutrients Total Phosphorus % Removal 16 Shallow soil (< 12"), high P levels

in soil, flow-through system 70 Greater soil depth (> 24"), low P levels in soil, infiltration system 50 Assumes 18-24" of soil L


PlantersInfiltration Planters Nutrients Total Phosphorus %

Removal 50 Shallow soil (< 12"), high P levels in soil, flow-through system 87 Greater soil depth (> 24"), low P

levels in soil, infiltration system 70 Assumes 18-24" of soil L


Basins


Nutrients Total Phosphorus % Removal 50 Shallow soil (< 12"), high P levels

in soil, flow-through system 87 Greater soil depth (> 24"), low P levels in soil, infiltration system 70 Assumes 18-24" of soil L



BMP Type


TypeContaminant/

Condition Class










Swales


Sediment TSS mg/L 29

Channelized flow, poor infiltration rates, steep (> 5%), > 3:1 side slopes, sparsely vegetated or grass too tall (little or no mowing), high intensity storm events

19

Non-channelized flow, good infiltration rates, gentle slope (<= 5%), <= 3:1 side slopes, heavily vegetated, routinely mowed resulting in high stem density, check dams, low intensity storm events

24 M

Filters


Sediment TSS mg/L 52.7


32.9


42

Removal rates are heavily dependent on filter material and pollutant form. Inert media, such as sand, removes only particulates and associated pollutants. Sorptive media (compost, activated carbon, zeolite) can remove both particulates and dissolved substances.

L

Sediment Manholes


Sediment TSS mg/L 90



66 L


Planters


Sediment TSS % Removal 81 Faster draining soils (gravels &

sands) 90 Slower draining soils (silts & clays) 85 M


PlantersInfiltration Planters Sediment TSS %

Removal 81 Faster draining soils (gravels & sands) 90 Slower draining soils (silts & clays) 85 M


Basins


Sediment TSS % Removal 81 Faster draining soils (gravels &

sands) 90 Slower draining soils (silts & clays) 85 M



BMP TypesSpecific BMPs

Included in TypeContaminant/

Condition Class

Contaminant/ Conditions Included

in Class Units






Certainty (H,M,L or

%)

Impervious cover disconnect (Roofs)

Downspout disconnect multi-family residential Metals Total Copper lbs reduced/year 1.0

These values were calculated using the lowest concentration of metals found in roof runoff.

19These values were calculated using the highest concentration of metals found in roof runoff.

2 Assume that 100 multi-family residential buildings had the rooftops disconnected and that the average rooftop is 15000 sf. H


Downspout disconnect single-family residential Metals Total Copper lbs reduced/year 31



54 Assume that 22400 single family homes had the rooftops disconnected and that the average rooftop is 1500 sf. H

O & M Catch Basin Cleaning Metals Total Copper lbs reduced/year 0.000011655 0.005326668 Assume a cleaning frequency of once a month (12 times per year) 0.00058275

The default assumes cleaning once a year. The effectiveness of pollutant removal depends on the frequency of cleaning. Pollutant removal is low if catch basins are not cleaned at least every 15-20 months and there is a steep decline is effectiveness if cleaned more than once every six months.

M

O & M

Maintenance and cleaning of MS4 components (ditch and channel maintenance

primarily)

Metals Total Copper % 20 23 22 Not directly analogous, since they're comparing different maintenanceschemes and don't have a "do nothing" control L

O & M


primarily)

Metals Total Copper lbs reduced/year 18 Assume that 5,000 feet of ditch are cleaned per year 55 Assume that 15,000 feet of ditch are

cleaned per year. 43

Assume that for every foot of ditch that is cleaned there is one cubic foot of sediment removed. The default assumes that 11,727 feet of ditch are cleaned per year based on the City of Portland annual submittal year 10. The high and low values are estimates based on best professional judgment.

L

O & M Street Sweeping Residential Area Metals Total Copper lbs reduced/year 34 Assume a street sweeping frequency

of 6 times per year. 57 Assume a street sweeping frequency of 49 times per year. 47 Default assumes a street sweeping frequency of 12 times per year.

Assume that there are 10,000 lane miles swept per year M

O & M Street Sweeping Industrial Area Metals Total Copper lbs reduced/year 42 Assume a street sweeping frequency


Assume that there are 5,000 lane miles swept per year. M

O & M Street Sweeping Commercial Area Metals Total Copper lbs reduced/year 160 Assume a street sweeping frequency



O & M Catch Basin Cleaning Metals Total Lead lbs reduced/year 0.000042 0.0191952 Assume a cleaning frequency of once a month (12 times per year) 0.0021


M


Downspout disconnect multi-family residential Metals Total Lead lbs reduced/year 0.1





Downspout disconnect single-family residential Metals Total Lead lbs reduced/year 2




O & M Street Sweeping Residential Area Metals Total Lead lbs reduced/year 73 Assume a street sweeping frequency



O & M


primarily)

Metals Total Lead lbs reduced/year 66 Assume that 5,000 feet of ditch are cleaned per year 198 Assume that 15,000 feet of ditch are



L

O & M Street Sweeping Industrial Area Metals Total Lead lbs reduced/year 90 Assume a street sweeping frequency



O & M Street Sweeping Commercial Area Metals Total Lead lbs reduced/year 340 Assume a street sweeping frequency



O & M


primarily)

Metals Total Lead % No data No data Not directly analogous, since they're comparing different maintenanceschemes and don't have a "do nothing" control

Effectiveness RangeBMP Group: Non-Structural

BMP Monitoring ProgramDecember 2006

Non-Structural BMPs Appendix A




Condition Class


in Class Units






Certainty (H,M,L or

%)



Downspout disconnect multi-family residential Metals Total Zinc lbs reduced/year 0.2




O & M Catch Basin Cleaning Metals Total Zinc lbs reduced/year 0.0000644 0.02943264 Assume a cleaning frequency of once a month (12 times per year) 0.00322


M

O & M Street Sweeping Residential Area Metals Total Zinc lbs reduced/year 101 Assume a street sweeping frequency



O & M


primarily)

Metals Total Zinc lbs reduced/year 101 Assume that 5,000 feet of ditch are cleaned per year 304 Assume that 15,000 feet of ditch are



L

O & M Street Sweeping Industrial Area Metals Total Zinc lbs reduced/year 125 Assume a street sweeping frequency




Downspout disconnect single-family residential Metals Total Zinc lbs reduced/year 5




O & M Street Sweeping Commercial Area Metals Total Zinc lbs reduced/year 472 Assume a street sweeping frequency



O & M Catch Basin Cleaning Nutrients Total Phosphorus lbs reduced/year 0.0003003 0.13724568 Assume a cleaning frequency of once a month (12 times per year) 0.015015


M

O & M Street Sweeping Residential Area Nutrients Total Phosphorus lbs reduced/year 538 Assume a street sweeping frequency



O & M


primarily)

Nutrients Total Phosphorus lbs reduced/year 472 Assume that 5,000 feet of ditch are cleaned per year 1,416 Assume that 15,000 feet of ditch are

cleaned per year. 1,107


L

O & M Street Sweeping Industrial Area Nutrients Total Phosphorus lbs reduced/year 666 Assume a street sweeping frequency

of 6 times per year. 1,723 Assume a street sweeping frequency of 87 times per year. 1,448 Default assumes a street sweeping frequency of 23 times per year.


O & M Street Sweeping Commercial Area Nutrients Total Phosphorus lbs reduced/year 2,511 Assume a street sweeping frequency



O & M Catch Basin Cleaning Sediment TSS lbs reduced/year 0.35 Assume a cleaning frequency of 0.01 times per year . 159.96 Assume a cleaning frequency of

once a month (12 times per year) 17.5


M

O & MNew developments and redevelopments - post-construction condition

Sediment TSS lbs/year 71,023 710,227 213,068 Assumes the SWMM is effective as currently designed and written. Intensity and volume is managed at 90%.

O & M Street Sweeping Residential Area Sediment TSS lbs reduced/year 253,333 Assume a street sweeping frequency



O & M Street Sweeping Industrial Area Sediment TSS lbs reduced/year 313,333 Assume a street sweeping frequency








Condition Class


in Class Units






Certainty (H,M,L or

%)


O & M


primarily)

Sediment TSS lbs reduced/year 550,000 Assume that 5,000 feet of ditch are cleaned per year 1,650,000 Assume that 15,000 feet of ditch are

cleaned per year. 1,289,970


L

O & M Street Sweeping Commercial Area Sediment TSS lbs reduced/year 1,181,818 Assume a street sweeping frequency

of 23 times per year. 1,795,152 Assume a street sweeping frequency of 6 times per year. 1,558,788 Default assumes a street sweeping frequency of 49 times per year.


O & M Erosion from construction sites Sediment - West Portland TSS lbs/year 109,379

Assumes erosion controls are ineffective at some sites due to unusually poor soils, steep slopes, poor installation, and ineffective inspection and enforcement. (10% removals??)

1,053,150

Erosion control program is completely effective and implemented at every site where soil disturbance occurs (100% removals).

514,796 Assumes the existing Erosion Control Program (Title 10) is in place and effective (70% removals??)

O & M Erosion from construction sites Sediment -East Portland TSS lbs/year 54,690

Assumes erosion controls are ineffective at some sites due to unusually poor soils, steep slopes, poor installation, and ineffective inspection and enforcement. (10% removals??)

526,575

Erosion control program is completely effective and implemented at every site where soil disturbance occurs (100% removals).

257,398 Assumes the existing Erosion Control Program (Title 10) is in place and effective (70% removals??)



BMP Monitoring Program Appendix A

December 2006

rorth

Text Box


Table A-2 Summary of Pollutant Characteristics and Treatment Technologies Priority for BMP Selection

Pollutant Type Pollutant Name

H2O Solubility

(mg/L) Log Kow Potential Treatment Technologies

Organic Pentachlorophenol 2,000 5.1 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation

Organic 0.34 5.1 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation

First

Metal Lead 870 0.73 Sedimentation, filtration, adsorption

Organic Benzene 1,800 2.1 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation, volatilization

Organic Toluene 530 2.7 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation, volatilization

Organic Xylenes 180 3.1 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation, volatilization

Organic Benzo(a)pyrene 0.0016 5.1 Sedimentation, filtration, adsorption, biological uptake and conversion, degradation

Metal Arsenic 120,000 0.68 Sedimentation, filtration, adsorption Metal Cadmium 1,700 - 0.07 Sedimentation, filtration, adsorption Metal Chromium 600,000 0.23 Sedimentation, filtration, adsorption Metal Copper 570 -0.57 Sedimentation, filtration, adsorption Metal Zinc 1,400 NR Sedimentation, filtration, adsorption

Second

Nutrient Total Nitrogen High in soil & Water NR Sedimentation, filtration, adsorption,

biological uptake




Appendix B

City of Portland BMP Development and Evaluation

UIC Separation Distance BMPs



BMP Monitoring Program Page B-1 December 2006

City of Portland BMP Development and Evaluation

UIC Separation Distance BMPs B-1 BMP Screening This section provides an assessment of the various options for managing UIC with inadequate separation distances to groundwater and provides recommendations regarding their application. B-2 Identification of Problem The 9,000 UICs in the public UIC inventory were built over many years, to a variety of design standards, and in some cases by jurisdictions prior to City annexation. As a result some of those UICs may have been built with inadequate separation distance as defined by the permit. The focus of this discussion is on existing sumps, since new sumps or other UICs will be constructed to be compliant with the WPCF. A UIC (i.e., sump) is a specialized injection system used by the City predominantly in the right-of-way to manage stormwater discharges. Most sumps are pre-cast reinforced concrete structures similar to a typical sewer manhole. Sumps are constructed using 48-inch-diameter perforated rings stacked in sections to a total depth of between 10 and 30 feet. Newer systems have a two- or three-foot section at the bottom of a pre-cast sump that is not perforated and has a solid concrete floor. This section collects sediments, keeping the sump from clogging the surrounding native soils and keeping pollutants that adhere to those sediments out of the groundwater. The middle and upper rings (except the manhole cone, if present) are perforated to allow for infiltration. Water is directed into the UIC sumps from sedimentation manholes and inlets at the street surface. Stormwater discharged into an UIC sump (without a sedimentation manhole) falls to the bottom, settles out larger sediment, and then infiltrates through the perforations in the ring sections to flow through the backfilled gravels into the surrounding native soil structure. This configuration is not universal, but the most common feature is significant depth. The Systemwide Assessment (City of Portland, July 15, 2006) identified approximately 400 UICs with potentially inadequate separation distance. Therefore, potential methods of increasing separation distance were evaluated to identify BMPs to address this issue.


B-3 Identification and Evaluation of Potential Technologies to Increase Separation Distance

Four basic technologies and their associated BMPs were identified to increase separation distances to meet permit requirements. The BMPs were screened against basic criteria used in the corrective action process (see Corrective Action Plan, July 2006), including:

• Constructability – space available to build, potential utility conflicts, permitting issues, construction methods available, room vertically to get out of groundwater

• Effectiveness – able to handle quantity of flow while meeting MADLs

• Acceptability – aesthetics, legal constraints, political considerations

• Unit Costs – operational and capital present worth expense

• Operational impacts – difficulty of operating and maintaining The evaluation of the technologies and BMPs are presented below. The basis for retaining or rejecting the BMP for further evaluation or consideration is included.

1. Decommission the UIC altogether or replace it with a shallower UIC o Decommission the UIC (see UICMP and UIC Decommissioning Plan submitted

December 2006);

Evaluation: BMP rejected. Decommissioning a UIC without provisions for ongoing stormwater management (infiltration or transport) is not acceptable.

o Decommission the UIC, replace with a shallower UIC or horizontal UIC (e.g., infiltration gallery)

Evaluation: BMP retained. Because a shallower UIC facility will require much more space to provide the same amount of infiltration, the likelihood of utility conflicts is higher and available sighting is lower. Such as facility is also more likely to create disruptions in traffic and inconvenience to neighbors. Maintenance of such a UIC depends on the particular design, but may be problematic. Costs of decommissioning and the new installation could be significant. In specific circumstances, however, a shallower UIC may be a viable and necessary option.

o Decommission the UIC, discharge to piped stormwater system or combined sewer

Evaluation: BMP retained. Technically this alternative uses fairly conventional piped solutions for management of stormwater. Practically, however, an alternate discharge point in not likely to be very convenient to the UIC location. UICs have historically been used in areas where stormwater systems are distant or non-existent. Their more recent use in combined sewer areas has been to remove stormwater volume from the combined system to reduce the potential for combined sewer overflows. Both stormwater system or combined sewer discharge are expensive options involving either installation of lengthy stormwater conveyance systems, expansion of system capacity (stormwater or combined), or both. Only in very limited and unusual circumstances will this alternative be considered.


2. Artificially lower the groundwater table using groundwater extraction Evaluation: BMP rejected. Groundwater extraction not feasible or practical due to operation and maintenance costs, lack of facility for extracted water disposal, and political and legal constraints.

3. Elevate the lowest point of discharge from the UIC to a depth that achieves the required separation distance o Plug the openings in the sump rings

Evaluation: BMP retained. The construction of this alternative is more complicated, potentially requiring confined space entry and specialized equipment. Obtaining a watertight seal to the level required might not be possible, especially with older UIC installations. There may also be hydraulic loading concerns in that the UIC will extend below the water table creating external pressure not considered in the original UIC design. Concerns regarding loss of effective infiltration capacity and volume apply. An advantage to this design is the retention of the deepest part of the UIC as a settling chamber, similar to a sediment manhole providing additional water quality capacity.

o Fill the sump with compactable material or grout to appropriate level

Evaluation: BMP retained. As with 4A filling the UIC with compactable materials or grout is a relatively simple operation. Grout is more expensive than compactable material, but probably more effective as a barrier assuming that is a design objective. The loss of infiltration area and water storage volume in the UIC is more likely than 4A. This configuration may require an additional facility (and associated costs and potential area disruption) to manage excess stormwater rates and volumes. Operational expense for this design is less once the facility is modified, but if another facility is needed to augment the original, overall operational expenses will increase. Space may not be available if another facility is needed.

o Install a new, higher floor in the sump

Evaluation: BMP rejected. This alternative would have the same overall effect as 3B, but absent filling the UIC first with materials upon which the new floor could be built, would require significant structural modification of the UIC to support the new floor. Maintaining an inaccessible void space below the new floor is operationally impracticable.

o Install a slip-liner in the sump, but with a base at the level of adequate separation

Evaluation: BMP rejected. This is essentially the same as 3C but using an unproven, and potentially unavailable, technology for this purpose. Such a liner is unlikely to be installed without fill underneath it for structural support.


4. Fill the UIC with appropriate backfill or filter materials o Filling the sump with various types for backfill materials (e.g., sand, gravel) to get

separation

Evaluation: BMP retained. Selected backfill materials could retain the UICs flow management capacity while providing the same water quality management characteristics as the native soil surrounding the UIC. No additional space is required at ground level, and assuming the necessary infiltration capacity and storage volume for flows served; no other facilities must be constructed. Filling of the UIC is a relatively low cost operation once the appropriate level of fill is determined. The presence of the backfill materials must be documented for maintenance purposes to prevent inadvertent removal, and the materials may need to be replace periodically assure filtration and infiltration capacities.

o Fill the sump with various types of fill or filter materials (e.g., total organic carbon, activated carbon, organoclay) to get separation and treatment.

Evaluation: BMP retained. Same as 4A, however material also selected to provide some stormwater treatment.


Appendix C

City of Portland Summary of Available Stormwater

BMP Monitoring Information



BMP Monitoring Program Page C-1 December 2006

Summary of Available Stormwater BMP Monitoring Information

Status of Available Information Stormwater BMP Pentachlorophenol DEHP Total Lead

Street sweeping Information limited to TSS reduction (as a surrogate for organic pollutant removal) in pounds per year

Information limited to TSS reduction (as a surrogate for organic pollutant removal) in pounds per year

Directly measured reduction values in pounds per year, with differentiation by residential, commercial and industrial land use areas

Maintenance of sediment manholes

No direct measurement or surrogate estimates of effectiveness



Maintenance of catch basins



Directly measured reduction values in pounds per year

Swales

Information limited to TSS effluent concentration (as a surrogate for organic pollutant removal) ranging from 19 mg/L to 29 mg/L

Information limited to TSS effluent concentration (as a surrogate for organic pollutant removal) ranging from 19 mg/L to 29 mg/L

Directly measured effluent concentrations ranging from 5.6 ug/L to 8.8 ug/L

Curb extensions (identified as vegetated infiltration basins)

Information limited to TSS reduction (surrogate for organic pollutant removal) as percent removals of TSS ranging from 81 to 90%

Information limited to TSS reduction (as a surrogate for organic pollutant removal) as percent removals of TSS ranging from 81 to 90 %

Directly measured effluent concentrations ranging from 6.7 ug/L to 26.0 ug/L, and in another study as percent removals for general metals removal from 43 to 98%.

Stormwater planters

Information limited to TSS reduction (surrogate for organic pollutant removal) as percent removals of TSS ranging from 81 to 90 %

Information limited to TSS reduction (as a surrogate for organic pollutant removal) as percent removals of TSS ranging from 81 to 90%

Directly measured effluent concentrations ranging from 6.7 ug/L to 26.0 ug/L, and in another study as percent removals for general metals removal from 43 to 98%.

Sediment manhole filters (inserts)

Information limited to TSS effluent concentrations (as a surrogate for organic pollutant removal). Sediment manholes without filters range from 45 mg/L to 90 mg/L for TSS. General filter values for TSS range from 32.9 mg/L to 52.7 mg/L

Information limited to TSS effluent concentrations (as a surrogate for organic pollutant removal). Sediment manholes without filters range from 45 mg/L to 90 mg/L for TSS. General filter values for TSS range from 32.9 mg/L to 52.7 mg/L

Directly measured effluent concentrations for sediment manholes without filters ranging from 6.2 ug/L to 12.3 ug/L. Generally filter effluent concentrations range from 6.1 ug/L to 10.2 ug/L

Catch basin filters inserts

Information limited to TSS effluent concentrations (as a surrogate for organic pollutant removal). General filter values for TSS range from 32.9 mg/L to 52.7 mg/L

Information limited to TSS effluent concentrations (as a surrogate for organic pollutant removal). General filter values for TSS range from 32.9 mg/L to 52.7 mg/L

Generally filter effluent concentrations range from 6.1 ug/L to 10.2 ug/L

BMP Monitoring Program Page C-2 December 2006


Appendix F

UIC Compliance Determination Procedure

Evaluation and Response Program Element


UIC Management Program Compliance Determination Procedure City of Portland

Page 1 of 16 UIC Compliance Determination Instructions

Bureau of Environmental Services

UIC Compliance Determination Procedure PURPOSE This City of Portland Bureau of Environmental Services (BES) Compliance Determination procedure is a tool for determining if an individual City-owned Underground Injection Control (UIC) system (i.e., sump, injection point; injection well) is constructed and operated in compliance1 with the conditions in the DEQ issued Water Pollution Control Facility (WPCF) permit (No. 102830) and applicable2 rules and regulations. The intent of the procedure is to define the criteria and types and quality of data (i.e., weight-of-evidence) needed to determine UIC permit compliance. Non-compliant conditions will be defined based on known and verifiable information that is determined to have a high or medium confidence level, as described below. The quality and verifiable nature of the data used to determine compliance status can be generally described by three data categories, based on the level of confidence that can be placed on the information:

Level of Confidence

Description

High Data and information that is based on the following: field verification of the characteristic(s) being evaluated; direct observations; written professional reports; or contained in files, field notes, etc., prepared by an appropriate professional.

Medium

Data and information obtained from a reliable professional that is based on the following: limited field verification; casual observations or indications; anecdotal information passed by word-of-mouth but not documented in written professional reports; files, field notes, etc. prepared by an unknown author with known original study objectives (limited data quality); or data interpreted or extrapolated, based on best professional judgment, from nearby sites or information.

Low

Data and information is based on the following: no field verification; no direct observations; third party anecdotal information; limited or no written documentation; files, field notes, etc. prepared by an unknown author with unknown original study objectives (unknown data quality); or other data or information that cannot be directly verified or confirmed.

Completion of the Compliance Determination worksheets will separate UICs into three categories:

1. Compliant: UICs are compliant with WPCF permit conditions and will continue be managed (i.e., operated and maintained) in accordance with the System Management (UIC Management Plan (UICMP) Section 3) and System Monitoring (UICMP Section 4) program elements.

2. Non-Compliant: UICs determined to be non-compliant will be referred to the Corrective Action program element, described in Section 6 of the UICMP for selection and implementation of an appropriate corrective action(s).

3. No Determination: No conclusive determination can be made. Additional data, of known and verifiable quality and of high or medium confidence is needed, or further evaluation is needed to make a UIC compliance determination. In this case, the UIC will be evaluated using the UIC Evaluation and Response (UICER) guidelines, described in Section 5 of the UICMP, as necessary and appropriate.

1 Defined in Schedule F, Section 5(gg), of DEQ Water Pollution Control Facilities (WPCF) permit No. 102830. 2 The permit requires compliance (Schedule F Section 1(f)) with State statutory laws and administrative rules applicable to

the UIC program.

December 2006



APPLYING THE COMPLIANCE DETERMINATION PROCEDURE The Compliance Determination procedure consists of five (5) following worksheets and a final compliance determination form provided at the end of the procedure. The worksheets include:

1) Adequate Separation Distance; 2) Annual Mean MADL Exceedance; 3) Proximity to Drinking Water Wells; 4) Direct Discharge of Prohibited Fluids; and 5) Motor Vehicle Drains.

Worksheets 1 through 5 should be completed, as needed, for each UIC or group of UICs identified as potentially non-compliant. The worksheets should be completed using the best available information (see following section). Worksheets 1 through 3 should be completed using data collected in accordance with the following UICER guidelines. Specific guidelines that should be considered include:

• Separation Distance (UICER Guideline No. 1); • MADL Exceedances (UICER Guideline No. 2); and • UIC Proximity to Drinking Water Wells (UICER Guideline No. 3).

Information used for compliance determinations should be referenced and copies of data should be attached to the individual worksheets, as appropriate. The purpose of these worksheets is to identify non-compliant UICs that meet a known and verified standard. If verifiable data are not available to confirm a non-compliant condition, the UIC will be referred for further evaluation, described in Section 5 of the UICMP, to address identified data gaps or to collect confirming information in accordance with the UICER guidelines. The Compliance Determination Procedure is anticipated to be an iterative process. In order to achieve a high or medium level of confidence that a UIC does not meet permit conditions, data gaps need to be addressed and further investigation or evaluation performed. It is the City’s goal to limit the number of iterations of the Compliance Determination Procedure to less than three, including the initial identification of the UIC through the UICMP System Management or the System Monitoring program elements. DATA SOURCES USED IN COMPLIANCE DETERMINATION The UIC Compliance Determination worksheets use a wide variety of information or data collected with varying levels of associated confidence in data quality, depending on the purpose of collecting the information. In general, data and information for completing the Compliance Determination Procedure worksheets comes from one of three sources, which are described in more detail in the following subsections:

1) Data or information collected while implementing comprehensive System Inventory and Assessment or other activities performed under the UICMP System Management program element (UICMP Section 3);

2) Information collected as part of the UICMP System Monitoring program element (UICMP Section 4); and 3) Subsequent assessments or investigations (i.e., UICER guideline implementation) to evaluate and

document UIC compliance status. The activities listed above will be performed throughout the duration of the WPCF permit (June 1, 2005 through June 1, 2015). Data collected during the UICMP System Management and the System Monitoring program elements are described below. Data and information that may be collected through UICER guideline implementation are included in the individual UICER guidelines.

December 2006



1) System Management. In accordance with the WPCF permit, the City conducted a comprehensive system inventory and assessment, which evaluated the spatial and physical characteristics of City-owned UICs relative to WPCF permit requirements, and assessed the drainage to each UIC. This systemwide assessment was required as part of the WPCF permit as a mechanism to identify UICs that may present a risk of adverse impacts to groundwater. Results were presented in an initial comprehensive Systemwide Assessment report (City of Portland 2006) and included lists of UICs with the following characteristics:

1) Receive drainage from motor vehicle maintenance floor drains, indoor parking facilities, and fire station bay drains.

2) Receive drainage from SARA Title III facilities. 3) Receive drainage from commercial/industrial properties that have site activities that could result in a

violation of MADLs in stormwater entering City-owned UICs. 4) Are in areas of high (i.e., shallow) groundwater and potentially have inadequate separation distance

between the bottom of the UIC and groundwater. 5) Are within 500 feet of a drinking water or irrigation well or within the 2-year time of travel.

A work plan for the further evaluation of these UICs was submitted to DEQ on December 1, 2006. The work plan builds on several of the UICER guidelines described in Section 5 of the UICMP.

System Inventory and Assessment will occur over the lifetime of the WPCF permit through on-going application of the best management practices (BMPs) that constitute the UICMP System Management program element (UICMP Section 3). These BMPs will serve as a continual means to identify, investigate, evaluate, and characterize the physical and spatial characteristics of City-owned UICs.

The types of information and data that will be drawn from the Systemwide Assessment for use in the Compliance Determination Procedure include information on physical and spatial parameters that could present an adverse impact to groundwater.

2) System Monitoring. The Stormwater Discharge Monitoring Plan (City of Portland 2006), described in Section 4 of the UICMP, provides the procedures for monitoring the quality of stormwater discharged to UICs and analyzing the results. Stormwater monitoring results will be submitted to DEQ each July in annual Stormwater Discharge Monitoring reports and summarized in the annual UICMP reports submitted each December. These reports will identify UICs that exceed a MADL concentration either for an individual storm event concentration or for the annual mean concentration.

A list of UICs (Year 1) with annual mean stormwater discharge concentrations that exceeded the MADLs specified in the WPCF permit was presented in the Annual Stormwater Discharge Monitoring Report (City of Portland 2006) submitted to DEQ in July 2006. A list of UICs that exceed MADLs in permit years 2 through 10 will be included in the annual UIC reports submitted to DEQ in July and December of each permit year.

Monitoring information and data (e.g., detected concentrations of pollutants as compared to their respective MADLs) will be drawn from the annual Stormwater Discharge Monitoring reports for use in the Compliance Determination Procedure.

December 2006



NON-COMPLIANT CONDITIONS DEFINED BY THE WPCF PERMIT This section summarizes key portions of the WPCL defining non-compliant UIC conditions: Schedule C, Section 12a, Corrective Actions. a. A corrective action must be implemented under the following conditions: i. For public any (sic) UIC that is non-compliant as defined in Schedule F(5)(gg), ii. For public UICs that fail to meet permit conditions; or iii. For public UICs within domestic, irrigation or public water well setbacks as defined in Schedule F(5)(gg),

the Permittee must demonstrate through monitoring data that the quality of stormwater discharged into the public UIC meets the annual mean MADLs specified in Table 1.

Schedule D, Section 11, Non-compliant Public UICs. A public UIC is non-compliant if it fails to meet the conditions of this permit or meets the definition in Schedule F(5)(gg). Schedule D, Section 13 (e). The Permittee may exclude any public UIC authorized by this permit from the non-compliant conditions for domestic well or public water system well setbacks, if the Permittee demonstrate any of the following conditions are met, and the Department concurs in writing with the exclusion. The Permittee must demonstrate:

i. The stormwater is pre-treated prior to discharge to the public UIC to meet limits established in Table 1; and/or

ii. Irrigation wells cannot be used as a drinking water supply source through enforceable ordinance, plumbing code or other legal process.

Schedule F, Section 1 (f). This permit is issued pursuant to OAR Chapter 340, Division 44 (revised and adopted by the Environmental Quality Commission in September 2001), OAR Chapter 340, Division 40 and OAR Chapter 340, Division 45. In implementing the State UIC Program, the Department requires compliance with applicable State statutory laws and administrative rules applicable to the UIC program and Department issued WPCF permits. Schedule F, Section 5 (gg).

i) UIC is within 500 feet of a domestic or irrigation well and does not meet the water quality limits established in the permit (Schedule F, Section 5(gg)(i)).

ii) UIC is within 500 feet of a public water well serving a public water system and does not have a Department of Human Services groundwater time-of-travel (TOT) delineation and the water quality of the discharge does not meet the water quality limits established in the permit (Schedule F, Section 5(gg)(ii)).

iii) It is within the 2-year TOT delineated by the Department of Human Services (DHS) for a public water well or wells serving a public water system and the water quality of the discharge does not meet the water quality limits established in the permit; (Schedule F, Section 5(gg)(iii)).

iv) Any public UIC that does not meet the water quality discharge limits established in the permit at the end-of-pipe discharge point into the public UIC (Schedule F, Section 5(gg)(iv)).

v) Any public UIC that has insufficient separation distance, as determined by the DEQ, between the bottom of the injection well and groundwater to protect the natural water quality (Schedule F, Section 5(gg)(v)).

vi) Any public UIC that is constructed into groundwater, causes direct discharge of fluids into groundwater, or causes a violation of OAR 340-040-0014(1) (Schedule F, Section 5(gg)(vi)).

December 2006


Page 5 of 16 UIC Compliance Determination Worksheet No.1

COMPLIANCE DETERMINATION WORKSHEET NO. 1 ADEQUATE SEPARATION DISTANCE

GENERAL UIC INFORMATION

BES UIC Sump Hansen Node Number(s):

UIC Address(es):

DEQ UIC Number(s):

Site Evaluator’s Name:

Date:

Applicable UICER: Guideline No.1 – Separation Distance CIRCLE APPROPRIATE DETERMINATION

NA = Not Applicable (i.e., not an identified issue for subject UIC(s)) NC = Non-compliant ND = No Determination – Further Evaluation Needed C = Compliant

UIC Separation Distance: (Schedule F, Section 5(gg)(v))

A) Based on the Systemwide Assessment Report3, UICMP System Management program element, or the results of UICER Guideline No. 1, is the distance between the seasonal high groundwater level and the bottom perforation of the UIC less than: 1) 10 feet for UICs greater than 5 feet in total depth? Yes / No 2) 5 feet for UICs less than 5 feet in total depth? Yes / No

If either A(1) or A(2) are Yes, the UIC is potentially non-compliant; go to Step B. If No, UIC is compliant.

B) Is the separation distance, calculated using field-verified UIC construction information (e.g., location, measure total depth), less than 10 feet for UICs greater than 5 feet in total depth or less than 5 feet for UICs less than 5 feet in total depth? Yes / No

If Yes, UIC is potentially non-compliant. Proceed to Step C if groundwater is anticipated to occur within the perforated section of the UIC or proceed to Step D if the groundwater is anticipated within 10 feet of the bottom of the UIC. Consult UICER Guideline No. 1 – Separation Distance for additional considerations.

If No, UIC is compliant.

C) Has groundwater been observed4 within the UIC system under seasonal high water conditions? Yes / No

If Yes, UIC is non-compliant. If No, proceed to Step D if the groundwater is anticipated within 10 feet of the bottom of the UIC.

Consult UICER Guideline No. 1 – Separation Distance for additional considerations. 3 The initial Systemwide Assessment report was submitted to DEQ in July 2005 and based on information contained in the City’s Hansen

database and U.S. Geological Survey depth to groundwater map. 4 Based on available UIC construction data, groundwater is present within UIC perforation (i.e., >2 feet of water measured in

UIC sump during period of seasonal high water).

Rev 6 – November 14, 2006


Page 6 of 16 UIC Compliance Determination Worksheet No.1

D) Does the weight-of-evidence developed in accordance with UICER Guideline No. 1 – Separation Distance indicate that separation distance meets permit requirements? Yes / No

If Yes, UIC is compliant. If No, UIC is non-compliant. SEPARATION DISTANCE NOTES:



Page 7 of 16 UIC Compliance Determination Worksheet No. 2

COMPLIANCE DETERMINATION WORKSHEET NO. 2 ANNUAL MEAN MADL EXEEDANCE

GENERAL UIC INFORMATION BES UIC Sump Hansen Node Number(s):

UIC Address(es):

DEQ UIC Number(s):


Date:

Applicable UICER: Guideline No. 2 - MADL Exceedances CIRCLE APPROPRIATE DETERMINATION


Annual Mean MADL Exceedance (Schedule F, Section 5(gg)(iv))

A). Mean Annual5 Stormwater Concentrations (1st wet season MADL6 Exceedance): Permit Year Compound MADL Concentration7 Reference8

_____ _________ ______ ___________ ________

B) Mean Annual Stormwater Concentrations (2nd wet season following exceedance): Permit Year Compound MADL Concentration Reference _____ _________ ______ ___________ ________

C) Was the annual mean MADL(s) exceeded in the second 9 consecutive year of sampling? Yes / No

If Yes, UIC is non-compliant. If No, continue monitoring and/or address remaining data gaps and re-evaluate in

accordance with UICER Guideline No. 3 – MADL Exceedances.

5 Annual concentration based on geometric mean of five individual sampling events (see QAPP; BES, 2006). 6 MADL = Maximum Allowable Discharge Limit (MADL) defined in Table 1 of the permit. 7 If the mean annual concentration does not exceed its respective MADL the UIC would be considered compliant under this criterion. 8 Provide reference to where applicable information is documented (attach copies of information if appropriate). 9 Annual mean concentration must be exceeded for two consecutive wet seasons before UIC is determined to be non-compliant and

corrective action is required (Schedule C, Section 10(b)).




MADL EXCEEDANCE NOTES:




COMPLIANCE DETERMINATION WORKSHEET NO. 3 PROXIMITY TO DRINKING WATER WELLS



UIC Address(es):

DEQ UIC Number(s):


Date:

Applicable UICER: Guideline No. 3 Proximity to Drinking Water Wells CIRCLE APPROPRIATE DETERMINATION


Note: Step 2 of this guideline requires the results from Work Sheet No. 2 – Annual Mean MADL Exceedances

for in order to determine the compliance status. Step 1) UIC Proximity to Drinking Water Well (Schedule F, Section 5(gg)(i thru iii))

A. Is the estimated distance to the nearest domestic, irrigation well, or public10 well, based on Systemwide Assessment11 or UICMP System Management program element less than 500 feet? Yes / No If Yes, UIC is potentially non-compliant; go to Step 1B. If No, UIC is compliant.

B. Is the field-verified distance between the UIC and nearest domestic, irrigation, or public well less than 500 feet? Yes / No If Yes, UIC is potentially non-compliant; go to Step 2. If No, UIC is compliant.

C. Is the UIC located within a Oregon Department of Health Services (DHS) 2-year groundwater time-of-travel (TOT), based on Systemwide Assessment or UICMP System Management program element? Yes / No If Yes, UIC is potentially non-compliant; go to Step 1D. If No, UIC is compliant.

D. Is field-verified location of UIC within the verified (see UICER Guideline No. 2) 2-year TOT of a public well? Yes / No If Yes, UIC is potentially non-compliant; go to Step 2. If No, UIC is compliant.

10 A public water means a water supply well serving a public water system that provides piped water for human consumption (See

Permit Schedule F, Section 5 (qq) and (rr). 11 The initial Systemwide Assessment report was submitted to DEQ in July 2005.




Step 2) Annual Mean MADL Exceedance (Schedule F, Section 5(gg)(iv)) A. Complete Compliance Determination Worksheet No. 2 “Annual Mean MADL Exceedance”.

1) If the annual mean MADL is not exceeded, the UIC is compliant.

2) If the annual mean MADL is exceeded for two consecutive wet seasons, the UIC is non-compliant and the appropriate relationship to domestic, irrigation, or public well or a 2-year TOT should be identified from one of the following using the results of Worksheet No. 3 “UIC Proximity to Drinking Water Wells” regarding the following statements):

a) If the answer to Step 1B is Yes and UIC located within 500 feet of a domestic or irrigation well, the UIC is non-compliant (Schedule F, Section 5(gg)(i)).

b) If the answer to Step 1B is Yes and UIC located within 500 feet of a public well, the UIC is non-compliant (Schedule F, Section 5(gg)(ii)).

c) If the answer to Step 1D is Yes and UIC located within 2-year TOT, the UIC is non-compliant (Schedule F, Section 5(gg)(iii)).

PROXIMITY TO DRINKING WATER WELL NOTES:




COMPLIANCE DETERMINATION WORKSHEET NO. 4 DIRECT DISCHARGE OF PROHIBITED FLUIDS



UIC Address(es):

DEQ UIC Number(s):


Date:

Applicable UICERs: Guideline No. 4 –Source Identification Guideline No. 5 –Source Specific Investigation Monitoring

CIRCLE APPROPRIATE DETERMINATION

NA = Not Applicable (i.e., not an identified issue for subject UIC) NC = Non-compliant ND = No Determination – Further Evaluation Needed C = Compliant

Direct discharge of prohibited fluids into groundwater or causes a violation of OAR 340-040-0014(1) (Schedule F, Section (5(gg)(vi)).

A) Have any of the following permit prohibited discharges, identified in Schedule A, Section 3(e) of the permit, been documented, to a City-owned UIC :

1) Any fluid from industrial or commercial facilities where hazardous substances or toxic materials including petroleum products are stored, handled or used, except as allowed under OAR 340-044-0018(3)(d) of the WPCL permit? Yes / No

2) Non-incidental fluids, or stormwater mixed with non-incidental fluids not covered under the WPCL permit, including but not limited to, runoff from: (a) Uncovered public trash compactor and associated storage area?; Yes / No (b) Uncovered public garbage or trash dumpster and associated storage areas?; and Yes / No

(c)Public facility loading docks that discharge to a public UIC?; Yes / No

3) Fluids from motor vehicle drains (MVDs) including MVDs in public repair or maintenance facilities, fire station bays or in-door parking areas?; Yes / No

4) Municipal wastewater for the purpose of effluent disposal, unless such disposal is allowed under a separate Department-issued permit?; and Yes / No

5) Fluids that fail to meet the conditions and requirements of the WPCL permit; except as listed in Schedule A(3)(h)? Yes / No

B) If A1 through A5 are all No, the UIC is compliant.




C) If any of the responses to A1 through A5 are Yes and the discharge(s) is expected to be ongoing and potentially result in an exceedance of a MADL (or adversely impact groundwater quality) and the finding is based on either unverifiable information or data with unknown or unacceptable quality; then the UIC is potentially non-compliant and will be further evaluated in accordance with the UICER Guidelines or equivalent, presented in the UIC Management Plan (submitted December 2006).

Fluid Description: _______________________________________________

Reference 12: _____________________________________________________

D) If any of the responses to A1 through A5 are Yes and the discharge(s) is documented to be ongoing and to result in an exceedance of a MADL (or adversely impact groundwater quality) and the finding is based on verifiable information of known and acceptable quality; then the UIC is non-compliant.

Fluid Description: _______________________________________________

Reference: _____________________________________________________ DIRECT DISCHARGE NOTES:

12 Provide reference to where applicable information is documented (attach copies of information if appropriate).




COMPLIANCE DETERMINATION WORKSHEET NO. 5 MOTOR VEHICLE DRAINS13



UIC Address(es):

DEQ UIC Number(s):


Date:

Applicable UICERs: Guideline No. 4 –Source Identification Guideline No. 5 – Source Specific Investigation Monitoring

CIRCLE APPROPRIATE DETERMINATION

NA = Not Applicable (i.e., not an identified issue for subject UIC) NC = Non-compliant ND = No Determination – Further Evaluation Needed C = Compliant

“A motor vehicle waste disposal well is a type of Class V injection well. Typically they are shallow disposal systems that receive or have received fluids from vehicular repair or maintenance activities, such as an auto body repair shop, automotive repair shop, new and used car dealership, specialty repair shop (e.g., transmission and muffler repair shop), or any area where vehicular repair work is performed.” Source: EPA UIC Program “What Should I Know About Motor Vehicle Waste Disposal Wells?”

http://www.epa.gov/safewater/uic/cl5oper/motorveh.html

Motor vehicle floor drains - In accordance with OAR 340-044-0015(2)(e), motor vehicle floor drains that discharge to public UICs or directly to the subsurface are prohibited. (Schedule C, Section 13).

A). Does the motor vehicle floor drain discharge directly to a UIC or the subsurface? 1) If Yes, based on verifiable information of known or acceptable quality, the UIC

is non-compliant and actions under the WPCF permit (Schedule C, Section 13) must be implemented.

2) If No or unknown, , then the UIC is potentially non-compliant and will be further evaluated in accordance with the UICER Guidelines, presented in the UIC Management Plan (submitted December 2006).

3) If Yes, based on verifiable information of known and acceptable quality; then the UIC is non-compliant.

13 Non-motor vehicle floor drains that discharge to UICs will be evaluated in Worksheet 4 – Direct Discharge of Prohibited Fluids.




MOTOR VEHICLE DRAIN NOTES:



Page 15 of 16 Final UIC Compliance Determination Work Sheet

FINAL COMPLIANCE DETERMINATION



UIC Address(es):

DEQ UIC Number(s):


Date: This Final Compliance Determination form should be completed, based on the results of Worksheets 1 – 5. CHECK ONE � Compliant – UIC is compliant, based on consideration of available data and the factors listed in Schedule

F, Section 5(gg) of the WPCF permit and as identified in Worksheets 1-5. No further evaluation or action required at this time.

� Compliant – Corrective Action Recommended. UIC is compliant, based on consideration of available

data and the factors listed in Schedule F, Section 5(gg) of the WPCF permit and as identified in Worksheets 1-5. However, corrective action is recommended to address the following:

1) 2) � Non-compliant – Corrective Action Required. UIC is non-compliant, based on consideration of

available data and the factors listed in Schedule F, Section 5(gg) of the WPCF permit and as identified in Worksheets 1-5. UIC should be referred for corrective action (See City of Portland, Corrective Action Plan, dated July 2006) due to the following non-compliant conditions:

1) 2) � No Determination - Further Evaluation Needed -- Additional data or evaluation is needed before a non-

compliance determination can be made (i.e., insufficient information available). Site should be referred for further evaluation in accordance with Section 5 of the UIC Management Plan (December 2006). Briefly describe the scope of the further evaluation:

1) 2) 3) EVALUATOR DISCUSSION

Describe the overall impression of the compliance determination for the subject UIC(s). Include a brief discussion of the confidence and/or the uncertainty of the data used in this determination. Add discussions of other relevant permit conditions, factors, or considerations not addressed in these worksheets.

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Page 16 of 16 Final UIC Compliance Determination Work Sheet


December 2006

Appendix G

UIC Prioritization Procedure



UIC Management Program UIC Prioritization Procedure City of Portland

Page 1 of 8 UIC Prioritization Procedure Instructions


UIC Prioritization Procedure Instructions

(Note: To be used for completing the Scoresheet for UIC Prioritization) PURPOSE The Underground Injection Control (UIC) Prioritization Procedure was developed as a means of assessing potential adverse impacts to groundwater quality that may be associated with individual UICs or groups of UICs and categorizing them by priority for attention. The UIC Prioritization Procedure is modeled after the Oregon Department of Environmental Quality (DEQ) Cleanup Program’s site assessment priority system (SAPs). This decision-making tool is intended to assist the City in meeting the requirements of the Water Pollution Control Facility (WPCF) permit (DEQ Permit No. 102830) and assuring groundwater protection. This procedure is a self-contained and integral component of the comprehensive UIC Management Plan (UICMP; see UICMP Section 5). APPLYING THE PRIORITIZATION PROCEDURE The UIC Prioritization Procedure consists of a numerical scoresheet (attached) and these instructions for completing the scoresheet. The scoring system includes 9 UIC prioritization criteria and an evaluator’s assessment of potential adverse impacts of UIC. The individual criteria scores are slightly weighted to reflect their relative importance is assessing potential impacts associated with a given UIC. Adding the scores from each of the 9 individual prioritization criteria results in the total numeric score for the UIC, placing it in a high, medium or low category. Because a generic scoring process can overlook or overstate site-specific factors, the total score may not reflect the evaluator’s subjective appraisal of a site’s priority. In such cases, the evaluator(s) should justify and document his/her final priority assignment in the narrative portion of the scoresheet provided. City staff familiar with the WPCF permit and UICMP will complete the scoresheet. Evaluators are typically Bureau of Environmental Services (BES) UIC Program Staff, with assistance from other qualified personnel or consultants as required. The UIC Program Manager, with assistance from other BES managers or UIC or Coordinated Site Assessment (CSA) staff, will make the final priority determination. The results of the UIC Prioritization Procedure can be used by the City for identifying, ranking1, categorizing, or grouping UICs that require further evaluation or corrective action and for managing the UIC Program work load. The UIC Prioritization Procedure was developed as a decision-making tool to categorize corrective actions or Evaluation and Response actions according to the UIC(s) potential to adversely impact groundwater. Implementation of the UIC Corrective Actions and UIC Evaluation and Response (UICER) guidelines will consider, to the extent feasible and practicable, the results of the UIC Prioritization Procedure. The overall goal is to address those UICs with the greatest likelihood of adversely impacting groundwater quality or violating permit conditions first. However, implementation of Corrective Action or the UICER guidelines will also consider other factors, including, but not limited to the following:

• Permit requirements; • Scope of evaluation (e.g., number of UICs to be evaluated);

1 Ranking is defined in the Corrective Action Plan as an ongoing, dynamic process to generate an ordered list of non-compliant UICs for

the initiation and implementation of corrective action projects. The ranking process considers several factors, including, but not limited to: prioritization results; scope and complexity of corrective action design; extent of problem; estimated costs; availability of funding; permit compliance schedules; relationship to other City projects (e.g., sewer, transportation, watershed), etc.

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• Staff, equipment, and funding availability; • Relationship to watershed or other citywide projects (e.g., sewer, transportation); • Other BES and Capital Improvement Program (CIP) priorities or ongoing or planned projects; and • Opportunities to streamline or more efficiently perform further evaluation activities (e.g., grouping

similar problems, geographic approach). DATA SOURCES USED IN THE PROCEDURE The prioritization scoresheet will be completed using readily available data and information from, but not limited to, the following as necessary and appropriate:

• Systemwide Assessment Report (July 2006) or results of ongoing System Inventory and Assessment Best Management Practice (BMP; see UICMP Section 3);

• UIC Hansen Database; • Stormwater discharge monitoring program (see UICMP Section 4); • Site inspections; • U.S. Geological Survey (USGS) reports; and • Oregon Department of Water Resource well logs.

INSTRUCTIONS FOR PRIORITIZATION SCORESHEET COMPLETION Use the directions and data sources identified in Sections 1a – 1i below for each relevant prioritization criteria to determine the appropriate category (High, Medium, Low or No Impact) that identifies the potential impact to groundwater, and then circle the accompanying numerical value on the scoresheet. If the criteria listed are not applicable to the UIC(s) being evaluated, note “Not Applicable” under the No Impact value. For some criteria, data or information may not be readily available, therefore, for the sake of simplicity and completeness assumed default values assumed based on available monitoring data, Systemwide Assessment Results, etc. For Section 2, determine the appropriate category to identify your personal assessment of the potential adverse impacts posed to groundwater from the UIC. For Sections 1 and 2, fill in the confidence value on the scoresheet for those criteria. Assign confidence values of A, B, or C for each of the criteria on the scoresheet, according to the description listed below. These confidence values will provide persons who might later review the scoresheet with information about the relative certainty of the evaluator. Whenever possible, use “A” and “B” rated information; scores based largely on questionable information or conjecture are less reliable. CONFIDENCE VALUE DESCRIPTION A Information is known--either from sampling results, system assessment data,

research, or other verified information and knowledge. B Best estimate-- based on the best available information and on in-house

knowledge relevant to the criteria being considered. C Best professional judgment or educated guess--based on experience, but little

or no verification or specifics. When there is insufficient information available to evaluate a particular criterion, use the available information, as well as best professional judgment, to assign a priority and associated confidence value.

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1. UIC PRIORITIZATION CRITERIA a. Stormwater discharge does not meet permit water quality limits -- Maximum Allowable

Discharge Limits [MADLs] Use stormwater discharge quality analytical results or estimate potential water quality based on data or knowledge from a UIC with similar characteristics to evaluate this criterion. Select a value that reflects potential for impacts to groundwater. Potential data sources could include the following: UIC monitoring data, System Inventory and Assessment results, Hansen database, land use, traffic category, file information, etc. HIGH: Mean annual stormwater concentration of one or more analytes exceeds MADLs (Table 1 WPCF

Permit) by more than a factor of 3 (i.e., >300%) OR UIC is known to contain non-aqueous phase product OR verified releases to groundwater are attributable to the UIC.

MEDIUM: Mean annual stormwater concentration of one or more analytes exceeds MADLs (Table 1 WPCF

Permit) by more than a factor of 1.5 (i.e., >150%) but less than a factor or 3 (i.e., <300%). LOW: Mean annual stormwater concentrations of one or more analytes exceed their respective MADLs

(Table 1 WPCF Permit) by more than a factor of 1 (i.e., 100%) but by less than a factor of 1.5 (i.e., <150%).

NO IMPACT: Mean annual stormwater concentrations do not exceed MADLs (Table 1 WPCF Permit) and are

protective of groundwater. (Assumed Default Value, based on Annual Stormwater Monitoring Discharge Monitoring Report – Year 1 (City of Portland, 2006)).

b. Separation Distance between Seasonal High Groundwater and Bottom of UIC The separation distance from the bottom of the UIC to seasonal high groundwater can affect how quickly, and how likely, potential pollutants might reach the water table. Use the separation distance, which is estimated from the bottom perforations of a standard City sump--or UIC-- to the estimated or known seasonal high water table, to evaluate this criterion. Data sources could include the following: USGS and BES depth to groundwater maps, site inspections, well logs (available from the Oregon Water Resources Department’ GRID database) or regional geological reports. HIGH: Automatically assign a HIGH priority to UICs known or estimated to be constructed in

groundwater MEDIUM: Estimated separation distance to groundwater > 0 ft and < 5 ft LOW: Estimated separation distance to groundwater > 5 and <10 feet NO IMPACT: Depth to groundwater is > 10 feet OR UIC discharges potable water OR an identified regional

hydraulic barrier (confining layer) prevents vertical migration of contaminants to groundwater. (Assumed Default Value, based on Systemwide Assessment Report (City of Portland, 2006)).

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c. Distance to Nearest Drinking Water or Irrigation Well Estimate the distance from the UIC to the location of the nearest domestic (e.g., drinking, irrigation) or public water supply well to evaluate this criterion. The distance should be determined based on the UIC and specific well location (not from the center of the property or the property boundary). Data sources may include the following: USGS and BES depth to groundwater maps, well logs (available from the WRD GRID database), UIC System Inventory and Assessment results, and regional geological reports. HIGH: UIC is <500 feet from the nearest active domestic water well or within a 2 year time-of-travel

(TOT) of a public drinking water well AND well is completed (e.g., shallow depth, shallow well intake based on review of well construction record, if available) such that it may withdraw groundwater from the uppermost water-bearing zone that could potentially be impacted by the UIC (e.g., shallow well intake based on review of well construction record, if available)..

MEDIUM: UIC is <500 feet from the nearest active domestic water well or within a 2 year TOT AND well is

completed such that it may not withdraw groundwater from the uppermost water-bearing zone (e.g., deep well intake based on review of well construction record, if available); OR current well use and construction are unknown and public water supply is not readily available.

LOW: UIC is < 500 feet from the nearest domestic well that is not currently or actively used OR well is

completed in a deeper or distinct water bearing zone OR current well use and construction are unknown and public water supply is readily available.

NO IMPACT: UIC is > 500 feet from the nearest domestic or public supply well (Assumed Default Value,

based on Systemwide Assessment Report (City of Portland, 2006) and Annual Stormwater Monitoring Discharge Monitoring Report – Year 1 (City of Portland, 2006)).

d. Predominant Land Use Determine the predominant land use with the highest potential to impact the UIC catchment area (i.e., drainage basin area) or the predominant land use within a 500-foot radius of the UIC (assuming the UIC catchment area has not been determined) to evaluate this criterion. Site-specific land use—and specific site activities draining to the UIC--should be used to the extent available. Land uses associated with potentially adverse impacts to groundwater, higher pollutant loads, or known pollutant sources should be considered in the ranking. Data sources include the following: DEQ Environmental Cleanup Database, State Fire Marshall list, DEQ Facility Profiler, BES zoning maps, USGS topographic maps, aerial photographs, housekeeping , site visit/drive-by, city/county zoning maps. HIGH: Industrial land use OR facilities with outdoor storage of raw materials, supplies, product or

operations that could impact stormwater discharges to public UICs at concentrations exceeding MADLs. High priority assumes stormwater quality from nearby facility is adversely impacted by site activities or conditions. Consider housekeeping at facilities draining to UIC.

MEDIUM: Commercial land use (commercial complexes OR commercial and services complexes (e.g.,

petroleum fueling stations)) OR agricultural land OR transportation and communication infrastructure and utilities OR large parking complexes (e.g., shopping centers) that could impact stormwater runoff to public UICs at concentrations exceeding MADLs. Medium priority assumes stormwater quality from nearby facility may be potentially adversely impacted. Consider housekeeping at facilities draining to UIC.

December 2006



LOW: Residential land use OR mixed urban and built-up OR parks and open space. Low priority assumes stormwater quality from nearby properties has a lower potential for adverse impacts. Consider housekeeping at facilities draining to UIC. (Assumed Default Value, based on Systemwide Assessment Report (City of Portland, 2006)).

NO IMPACT Not defined at this time. e. Traffic Volume To evaluate this criterion, determine the predominant traffic volume in the UIC catchment (i.e., drainage basin) draining to the subject UIC. Data sources include the following: PDOT database, BES zoning maps, USGS topographic maps, aerial photographs, site visit/drive-by, city/county zoning maps. HIGH: Traffic volume >15,000 vehicle trips per day MEDIUM: Traffic volume >5,000 - <15,000 vehicle trips per day LOW: Traffic volume >500 - <5,000 vehicle trips per day (Assumed Default Value) NO IMPACT: Isolated areas with no significant traffic volumes (e.g., < 500/day) or no tributary areas with

transportation facilities f. UIC Pre-Treatment To evaluate this criterion, determine the basic construction and design of the UIC system to identify if the system includes any pre-treatment. Data sources include the following: As-built reviews, Hansen database, system assessment reports, UIC inspection reports. HIGH: Not defined at this time. MEDIUM: No sedimentation manhole or other stormwater pretreatment OR known system damage (e.g.

leaking sedimentation manhole) LOW: Sedimentation manhole and catch basins or inlets present OR other effective stormwater

management provided. (Assumed Default Value) NO IMPACT Not defined at this time g. Mobility of Pollutant This criterion is applied if monitoring data is available from the subject UIC or a UIC in a similar environmental setting (e.g., catchment size, land use, traffic category, source) or a unique pollutant source can be identified. This criterion will be set to the default value unless site or issue specific data is available. The mobility criterion is used to assess the potential for a pollutant to have a complete migration pathway from the “source” to groundwater (i.e., source to stormwater through subsurface soils to groundwater). The assigned scores reflect the relative mobility of pollutants, based on laboratory conditions and theoretical data. These values are conservative and do not consider chemical or physical processes (variable source concentrations, dilution, pollutant degradation, sorption, etc) that control pollutant fate and transport in the environment. Therefore, the estimated mobility ratings contain uncertainties and are intended to provide relative information for assessing

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potential impacts to groundwater associated with pollutants exceeding MADLs in a given UIC (or UIC in a similar setting); or that may be associated with a known or potential pollutant source. Use Table 1 (Common Pollutants) or Table 2 (Priority Pollutants), presented at the end of this procedure, to estimate the potential mobility of pollutants (included in the WPCF permit). The potential mobility of a pollutant is estimated based on water solubility and the Octanol-Water partition coefficient the (Kow). The Kow is a measure of whether a pollutant is more likely to adsorb to soil particles or dissolve in water. Special Considerations:

• Assign a HIGH priority, regardless of the compound's solubility, if the substance is present as a free liquid or separate layer in the UIC or groundwater.

• Decrease the mobility priority to the next level (e.g., medium to low) for a metal in areas with alkaline soils (pH >8), or if it can be determined that the metal is present in a solid form. This does not apply to selenium and arsenic, which are more mobile under alkaline conditions.

HIGH: See Tables 1 and 2

MEDIUM: See Tables 1 and 2

LOW: See Tables 1 and 2 (Assumed Default Value, based on observed stormwater concentrations presented in the Annual Stormwater Monitoring Discharge Monitoring Report – Year 1 (City of Portland, 2006)).

NO IMPACT: No pollutants or sources present (i.e., potable water, drinking fountain overflow).

h. Soil Permeability Soil permeability is a measure of how easily and quickly water can be transmitted through soil. Soil permeability can be used in a relative manner to estimate how quickly water discharged into a UIC will reach the water table and the likelihood that pollutants may reach groundwater. Soils with a higher percentage of fines (silts, clays, grain coatings) will generally have a lower permeability (i.e., be less likely to readily transmit water) and a higher likelihood of adsorbing, filtering, or containing pollutants. Soils with a high percentage of sand or gravel are more likely to transmit water and less likely to adsorb, filter, or contain pollutants. Published literature regarding shallow lithology in the Portland Basin indicates that coarse sand and gravel deposits have clayey silt coatings (Trimble, 1963). The coatings likely provide additional adsorption and absorption treatment of stormwater derived pollutants within the unsaturated zone before the discharge reaches groundwater (DEQ, June 2005. Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation). For the purpose of this procedure, the permeability of soil between the bottom of the UIC and groundwater is estimated using the sand content of the C soil horizon. The C Horizon is defined as slightly weathered geologic parent material. Properties of the C Horizon over the sumped regions of Portland are estimated using data from the USDA Natural Resources Conservation Service (NRCS) Soil Survey Geographic (SSURGO) database. SSURGO is the most detailed level of soil mapping done by the NRCS (see (http://www.ncgc.nrcs.usda.gov/products/datasets/ssurgo/description.html). Figure 1 presents a map of the C Horizon sand content in the Portland area.. Figure 2 presents a map illustrating the approximate depth of where the C Horizon is encountered in the Portland area. The SSURGO C Horizon data indicates that the C Horizon is typically encountered at a depth between 90 – 120 inches (approximately 8-10 feet). The vertical extent of this soil horizon is not defined. However, UICs are typically 30 feet deep. Therefore, there is uncertainty in the assumption that soils present in the C Horizon extend

December 2006

http://www.ncgc.nrcs.usda.gov/products/datasets/ssurgo/description.html



to the water table (or to a minimum depth of approximately 40 feet (30 foot UIC plus 10 permit required separaton distance). As an example of the uncertainty in this assumption would that use of the C-Horizon sand content, may not reflect the importance of clayey/silt coatings on sand and gravel grains and the importance of fines may be underestimated (i.e., the soil permeability may be overestimated and the soils ability to adsorb sediments may be underestimated). Additional data or information can be used to further define or assess subsurface soil permeability. Individual geologic boring log data can be used to more accurately identify lithology in the vicinity of the subject UIC(s). The results of UIC infiltration tests can also be used, as available, to estimate soil permeability. To the extent practicable, the soil permeability ranking should be based on the predominant soil type between the bottom of the UIC and the water table. Data sources include the following: USGS lithologic maps, well logs (available available from the WRD GRID database), BES data, UIC system assessment report(s), and regional geological reports, and NRCS soil survey. Figure 1 can be is used to estimate the sand content of the C soil Horizon to roughly estimate soil permeability, if better site specific data in not available, to assign the follow priorities: HIGH: Sandy loam or sand (e.g., > 75% or more total sand) (Assumed Default Value) MEDIUM: Sandy loam, sandy clay loam, loam, clay loam (e.g., 40-75% total sand) LOW: Clay, silt loam, silty clay loam, silty clay, silt loam, silt (e.g., <40% total sand) NO IMPACT Not defined. i. Distance to Surface Water Approximate the distance to the nearest surface water that could potentially be impacted by UIC discharges via groundwater recharge to evaluate this criterion. Man-made lakes, irrigation canals, sloughs or ditches are considered surface waters. Intermittent streams and wetlands are also considered surface water. Data sources include the following: USGS maps, aerial photographs, site assessment, etc. HIGH: < 150 feet to surface water body MEDIUM: > 150- <300 feet to surface water body LOW: > 300 -<500 feet to surface water body NO IMPACT: >500 feet to surface water body (Assumed Default Value)

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2. EVALUATOR’S ASSESSMENT AND ADJUSTMENT FACTOR OF POTENTIAL ADVERSE IMPACTS

The evaluator will assess the potential adverse impacts posed to groundwater from the UIC, using professional judgment regarding the cumulative information available. This assessment is intended to account for factors not addressed in Section 1.. HIGH: UIC may pose a high threat to groundwater and could affect human health or groundwater use as

a drinking water resource. MEDIUM: UIC may pose a moderate threat to groundwater by impacting local subsurface soil and

groundwater near the UIC. Impacts are possible to human health or groundwater drinking water uses.

LOW: UIC is unlikely to pose a threat to groundwater, because stormwater quality impacts are limited

and are not likely to cause significant degradation of groundwater, soil, or surface water. NO IMPACT: UIC has had no impact or an insignificant impact on the environment, and is protective of

groundwater and human health. GENERAL SCORING GUIDELINES The following are the recommended guidelines for determining a course of action for a UIC—or group of UICs with similar characteristics-- based on the total score obtained from the scoresheet. These priority-assignment numbers are guidelines only, and the final decision on a site’s further-action priority should take all relevant criteria into account, including those documented in the scoresheet as well as the evaluator’s recommendation.

TOTAL SCORE RECOMMENDED ACTION 51 or above High Priority 32 - 50 Medium Priority 18 - 31 Low Priority Less than 18 UIC is Protective of Groundwater: No Further Action* (NFA) determination may

be appropriate if approved by DEQ

* No Further Action determination must be approved by the DEQ.

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Analyte Solubility (mg/L)

Log Kow (Octanol - Water Coefficient)

Kd (ml/g) Koc (L/kg) Koc Source Notes on Pollutant Mobility

Vapor Pressure

(Torr)

EPA Groundwater

Mobility Ranking1

Mobility of Pollutant in

Water

Total Antimony 1 170,000 0.73 45 NR NR NR 0.01 Medium

Total Barium 1 2,800 0.23 41 NR NR NR 0.01 Medium

Total Beryllium 1 84,000 -0.57 790 NR NR NR 0.01 Medium

Total Selenium 1 2.60E+06 0.24 5 NR NR NR 1.0 High

Total Thallium 1, 2 8600 0.23 71 NR Strongly adsorbed to some alkaline clays NR 0.01 Medium

Total (inorganic) Mercury 1 450 0.62 52 NR NR 0.002 0.01 Medium

Total Cyanide 1, 2 NR -0.69 9.9 1 to 70 Insoluble forms of CN adsorb to sediments 310 1.0 High

Alachlor 1, 2 240 3.5 440 2.2 NR 2.20E-05 0.01 Medium

Atrazine 1, 2 70 2.6 55 122 NR 2.80E-07 0.01 Medium

Bis(2-chloroisopropyl)ether 4, 5 1,700 2.48 NR 73 May leach if present in many soils 0.56 NR Medium

Bis(2-chloroethyl)ether 6 17,200 1.21 NR 10.9 NR 0.71 NR Medium

Carbofuran 1, 2 351 2.32 22.4 29.4 May leach if present in many soils 3.40E-06 NR Medium

Carbon Tetrachloride 1, 2 790 2.8 0.35 71 Moves readily through soil 120 1.0 High

Chlorobenzene 1, 4 470 2.8 0.44 NR Moderate adsorption in org. soils 12 1.0 High

o-Dichlorobenzene 1, 2 4000 2 0.085 280 to 320 May be moderately to tightly adsorbed in soil

13 1.0 High

p-Dichlorobenzene 1, 2 79 3.5 1.2 612 May be moderately to tightly adsorbed in soil

1 1.0 High

1,3-Dichlorobenzene 3 125 3.5 3.7 620 NR 2.2 NR Medium

1,2,4-Trichlorobenzene 1, 2 35 4 3.6 1000 to 5000 Moderate to high mobility in soil 0.43 1.0 High

Chlordane 1 0.056 5.5 240 NR NR 9.80E-06 0.01 Medium

Lindane 1 7.3 3.6 2.1 NR NR 0.00041 1.0 High

2,4-D 1, 2 4500 2.9 NR 19.6 to 109.1 Low to moderate mobility in soil 0.067 NR High

Dinoseb 2 52 3.15 NR 124 High mobility in soil 1 NR High

Picloram 2 430 0.3 NR 13 Moderate mobility in soil 6.20E-07 NR Medium

Dalapon 2 800,000 0.77 NR NR Very high mobility NR NR High

Diquat 2 700,000 -3.05 NR NR Very low mobility 1.30E-05 NR Low

Endothall 2 100,000 NR (biodegrades fast) NR <2 High mobility in soil very low NR Medium

Glyphosate 2 11,600 NR (biodegrades fast) NR 0.0000404 Reversible adsorption Negligible NR LowNotes:

2 USEPA (2006). Groundwater & Drinking Water Technical Factsheets. Available at: http://www.epa.gov/ogwdw/hfacts.html3 USEPA (2006). EPA Region IX Preliminary Remediation Goals (PRGs). Available at http://www.epa.gov/region09/waste/sfund/prg/.

1 USEPA (2004). Superfund Chemical Data Matrix Methodology (SCDM). Appendix A. 28 January 2004. Available at http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm.

Table 1 - Mobility RankingPriority Pollutants

December 2006 Page 1Table 1


Table 1 Notes: (Continued From Previous Page)4 Spectrum Laboratories, Inc. (2006). Chemical Fact Sheets. Available at http://www.speclab.com/compound/chemcas.htm5 Department of Health and Human Services. National Toxicology Program.6 Agency for Toxic Substances and Disease Registary (ASTDR). http://www.atsdr.cdc.gov/toxprofiles/tp127-c3.pdfSolubility = the maximum dissolved quantiy of a pollutant in pure water at a given temperature.

Low Kow values (<10) are considered hydrophlic and tend to have higher water solubility. High Kow values (>104) are very hydrophobic.

Vapor Pressure = pressure exerted by a vapor in equilibrium with the solid or liquid phase of the same substance.

NR = not reportedinfiltrated through subsurface soils). Pollutant fate and transport should be used to assess potential adverse impacts on groundwater quality.

Kd = soil/water distibution coefficient. The amount of a chemical adsorbed by a sediment or soil (i.e ., the solid phase) divided by the amount of test

chemical in the solution phase, which is in equilibrium with the solid phase, at a fixed solid/solution ratio.

Mobility of Pollutant = used in UIC Prioritization Procedure to conservatively (assumes no dilution and/or degration) estimate the mobility of pollutants in water. Rating does not account for chemical or physical degradation or attentuation of stormwater pollutants discharged to a UIC and

Koc = soil/water distibution coefficient. Koc is a measure of the tendency for organic chemicals to be adsorbed to the soil. The higher the Koc value for each compound, the lower the mobility and the higher the adsorption.

EPA Mobility Ranking = from EPA's SCDM (reference 1). Value used where available; based on solubility and the soil/water distribution coefficient to determine the relative groundwater mobility factor.

Log Kow = octanol/water partition coefficient is the ratio of a compounds concentration in the octanol phase to its concentration in the aqueous phase of a two-phase system.



AnalyteSolubility (mg/L) 1

Log Kow

(Octanol - Water Coefficient) 1

Kd (ml/g) 1Koc (in Soil)

(L/kg) 2Koc (in Soil) Source Notes 2

Vapor Pressure (Torr) 1

EPA Groundwater

Mobility Ranking 1

Mobility of Pollutant in Water

Benzene 1,800 2.1 0.12 98 High to very high mobility in soil 95 1.0 HighToluene 530 2.7 0.36 37 to 178 Very high to moderate mobility in soil 28 1.0 HighEthylbenzene 170 3.1 0.73 164 Moderate mobility in soil 96 1.0 HighXylenes 180 3.1 0.73 48 to 68 High to moderate mobility in soil 6.6 1.0 High

Pentachlorophenol 2,000 5.1 1.2 1250 to 1800 High tendency to adsorb to soil and sediment 0.000032 1.0 High

Bis(2-ethylhexyl) phthalate 0.34 5.1 2,300,000 10,000 to 100,000 Low mobility in soil 0.000000068 0.0001 LowBenzo(a)pyrene 0.0016 6 160,000 106.6 to 106.8 Very low mobility in soil 0.0000000055 0.0001 LowTotal Arsenic 120,000 0.68 29 NR Naturally occurs in soils NR 0.01 MediumTotal Cadmium 1,700 -0.07 75 NR Mobility higher than other metals NR 0.01 Medium

Total Chromium 600,000 0.23 19 NR Low mobility - high adsorbtion to soils/sediments NR 0.01 Medium

Total Copper 570 -0.57 430 NR Naturally occurs in clays NR 0.01 Medium

Total Lead 870 0.73 900 NR Low mobility in most soils, lowest at neutral pH and high organic matter. NR 0.01 Medium

Total Zinc 1,400 NR 62 NR NR NR 0.01 Medium

Nitrate-Nitrogen High in soil & water Low adsorbtion in soil NR NR High mobility in soil NR NR High

Notes:

2 USEPA (2006). Groundwater & Drinking Water Technical Factsheets. Available at: http://www.epa.gov/ogwdw/hfacts.htmlSolubility = the maximum dissolved quantiy of a pollutant in pure water at a given temperature.

Low Kow values (<10) are considered hydrophlic and tend to have higher water solubility. High Kow values (>104) are very hydrophobic.

Vapor Pressure = pressure exerted by a vapor in equilibrium with the solid or liquid phase of the same substance.

Mobility of Pollutant = used in UIC Prioritization Procedure to conservatively (assumes no dilution and/or degration) estimate the mobility of pollutants in water. Rating does not account for chemical or physical degradation or attentuation of stormwater pollutants discharged to a UIC and

Koc = soil/water distibution coefficient. Koc is a measure of the tendency for organic chemicals to be adsorbed to the soil. The higher the Koc value for each compound, the lower the mobility and the higher the adsorption.

Mobility Ranking = from EPA's SCDM (reference 1). Value used where available; based on solubility and the soil/water distribution coefficient to determine the relative groundwater mobility factor.

1 USEPA (2004). Superfund Chemical Data Matrix Methodology (SCDM). Appendix A. 28 January 2004. Available at http://www.epa.gov/superfund/sites/npl/hrsres/tools/scdm.htm.

Log Kow = octanol/water partition coefficient is the ratio of a compounds concentration in the octanol phase to its concentration in the aqueous phase of a two-phase system.

Kd = soil/water distibution coefficient. The amount of a chemical adsorbed by a sediment or soil (i.e., the solid phase) divided by the amount of test

chemical in the solution phase, which is in equilibrium with the solid phase, at a fixed solid/solution ratio.

Table 2 - Mobility RankingCommon Pollutants



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Page 1 of 2 UIC Prioritization Scoresheet


UIC Prioritization Scoresheet Site Name: Site Address: BES UIC ID Number: Site Evaluator: Date: Note: This scoresheet will be completed by Underground Injection Control Systems (UIC) Program or Coordinated Site Assessment (CSA) staff (or other trained City staff) acting as site evaluators following the attached UIC Program Prioritization Procedure Instructions. The scoresheet provides the UIC Program staff with UIC priorities, based on potential adverse impacts to groundwater (high, medium, low and not applicable categories) associated with City-owned UICs. The score-sheet should be completed using readily available information. The UIC Program Manager will assign the final UIC priority. No Confidence HIGH MEDIUM LOW Impact Value 1. UIC Prioritization Criteria a. Does not meet water quality limits 9 5 3 0*1 ___ b. Separation Distance 9 5 3 0* ___ c. Distance to Drinking Water Well 9 5 3 0* ___ d Land Use 7 4 3* ND2 ___ e. Traffic Volume 7 4 3* 0 ___

f. Pre-Treatment ND 4 2* ND ___ g. Mobility of Pollutant 5 3 1* 0 ___ h. Soil Permeability 5* 3 1 0 ___ i. Distance to Surface Water 3 2 1 0* ___ 2. Evaluator Assessment of UIC 10 5 1 0 Add the circled numbers to get the total UIC prioritization score. Total Score = _____(71 possible points) Assigned priority, based on numeric score = _____ (H, M, L)

HIGH PRIORITY: 51 or above MED PRIORITY: 32 - 50 LOW PRIORITY: 18 - 31 PROTECTIVE/NFA: Less than 18 (no further action determination may be appropriate if UIC is protective of

groundwater and if approval is provided by DEQ).

1 * indicates default value to be used, in the event information is not readily available for “initial” screening purposes. 2 ND indicates criterion has not been defined at the designated level.

December 2006


Page 2 of 2 UIC Prioritization Scoresheet

EVALUATOR DISCUSSION Describe the overall impression of the potential adverse impacts posed by the public UIC to groundwater or permit compliance. Include brief discussion of major factors such known or potential non-conformance conditions, pollutant concentrations, and human and environmental factors. Also discuss relevant factors or considerations not addressed in the UIC scoresheet. If applicable, explain why the total score does not reflect the adverse impacts the UIC may pose to groundwater, human health or the environment. FINAL PRIORITY ASSIGNMENT (based on numeric score and Evaluator’s Discussion) Check one of the following::

High Priority Medium Priority

Low Priority

Other____________________________

Further Evaluation Required

Protective/No Further Action Required

December 2006


December 2006

RODS

Text Box


UIC Management Program Evaluation and Response City of Portland

Appendix H Evaluation and Response Guideline Introduction

Appendix H

UIC Evaluation and Response Guidelines


December 2006 Page 1 of 6








Evaluation and Response Guideline Introduction PURPOSE This section describes the general UIC Evaluation and Response (UICER) guidelines that may be followed by the City to complete timely UIC compliance determinations, identify pollutant source(s), initiate response actions, and evaluate or demonstrate that groundwater quality meets the requirements for OAR 340-040. These guidelines may be used for individual UICs or groups of UICs identified as potentially not meeting Water Pollution Control Facilities (WPCF) permit requirements or to address data gaps identified during implementation of the System Management and System Monitoring program elements described in the UIC Management Plan (UICMP). In addition, the guidelines are intended to clarify the City’s interpretation of WPCF permit intent and language. The guidelines provide, but are not limited to:

• A description of general protocols and criteria that may be used, as necessary and appropriate, to determine compliance status.

• A general framework for performing investigations that may be needed to make a compliance determination, identify a pollutant source(s), initiate response actions, or demonstrate groundwater protection.

• A description of response action that may be implemented to mitigate or correct issues at identified UICs. In addition, selected guidelines may be used on a case-by-case basis to develop the criteria and conditions when “no further action” (NFA) may be an appropriate corrective action response for a non-compliant UIC condition (see WPCF permit Schedule D, Section 12(c)). APPLYING THE EVALUATION GUIDELINES These guidelines will be applied on an as-needed basis to address further evaluation needs and objectives. The need for further evaluation (i.e., identification of data gaps and/or further evaluation of existing information) and the initial objective of the evaluation will be identified through System Monitoring or Management activities (see UICMP), and/or application of the Compliance Determination Procedure. The guidelines presented in this section provide general direction for:

• Identifying and investigating potential stormwater pollutant sources; • Initiating response actions to address conditions that may not be compliant with WPCF permit conditions

(e.g., stormwater discharge quality exceeds the Maximum Allowable Discharge Limits (MADLs) established in the WPCF permit during either an individual stormwater event or over the course of a permit year (i.e., annual mean concentration)); and

• Implementing actions to ensure that groundwater is protected. These actions might include: risk assessment, pollutant fate and transport analyses, additional stormwater monitoring, groundwater monitoring, or other actions approved by DEQ.

The tasks and steps defined in the following guidelines are intended to be adapted, as necessary and appropriate, based on the specific issue and available factual information. Use of these guidelines will allow City staff to implement timely, decisive, consistently applied actions to address UIC compliance issues and to assure groundwater is protected.

Implementation of these guidelines, to the extent feasible and practicable, will be performed considering the priority (see UICMP Appendix G: Prioritization Procedure) of the individual UIC or group of UICs. The overall




goal is to address those UICs with the greatest likelihood of adversely impacting groundwater. However, implementation of these guidelines will also consider other factors, including the following:

• Permit requirements; • Geographic proximity of other UICs being evaluated; • Site or issue specific conditions; • Scope of evaluation (e.g., number of UICs to be evaluated); • Staff, equipment, and funding availability; • Other BES and Capital Improvement Program (CIP) priorities or ongoing or planned projects; • Relationship to watershed or other citywide projects (e.g., sewer, transportation); • Opportunities to streamline or more efficiently perform further evaluation activities (e.g., grouping

similar problems, geographic approach); and • Best professional judgment.

DEVELOPMENT OF EVALUATION AND RESPONSE GUIDELINES These guidelines were developed to provide a common-sense approach to planning and implementing the additional evaluation needs, and to ensure that the level of planning, investigation, and documentation is commensurate with the potential threat to groundwater quality, the intended use of the information, and the resources available (e.g., staff, funding, equipment). The guidelines address the management and scientific elements of the further evaluation process and facilitate logical development of the evaluation. They also encourage the efficient use of resources, transparency of intent and direction, sound of project conclusions, and proper documentation. The guidelines serve to:

• Focus data requirements and assist in optimizing design for data collection, • Document data requirements and procedures steps for data collection and evaluation; and • Provide overview of the potential sampling design and data collection process.

The guidelines were developed based on the EPA’s Data Quality Objectives (DQO) Process1. The DQO Process is recommended when data are to be used to make some type of decision (e.g., compliance or non-compliance with a standard) or estimation (e.g., ascertain the mean concentration level of a pollutant). The DQO Process consists of seven steps that are listed in Table 1. While these steps are presented in a sequential fashion in Table 1, they are actually iterative in nature. One or more of these steps may be revisited as more information is obtained. A generalized DQO Process was applied in developing the UICER guidelines in order to identify approaches to evaluating issues anticipated or identified during implementation of the UICMP. The UICER guidelines generally:

• Define the potential issue (e.g., problem statement). • Identify applicable permit or regulatory requirements. • Define the specific project objective(s). • Specify the UIC population for the application of the guideline. • Identify the approach(es) for evaluating the issue. • Establish decision criteria or next steps for the issue.

1 “Guidance on Systematic Planning Using the Data Quality Objectives Process” prepared by the EPA. EPA/240/B-06/001.

February 2006. EPA QA/G-4.




The UICER guidelines are intended to outline a general framework for evaluation and response decisionmaking. During application of the guidelines it is anticipated the DQO Process will be used to further develop the site-specific approach that will be used to address a specific issue, support further studies (e.g., groundwater protection demonstration, fate and transport modeling), or develop work plans for site-specific investigations (e.g., source investigations).

Table 1: Data Quality Objective Process DQO Step Activities

Step 1: Define the Problem

• Define the problem • Define regulatory requirements • Identify the planning team, budget, schedule • Identify decision maker

Step 2: Identify the Goal of the Study

• Describe the project goals and objectives • Identify the principal study question(s) • Develop decision statements

Step 3: Identify Information Inputs • Identify the types of data needed to answer questions • Identify potential data sources • Identify appropriate sampling and analyses methods

Step 4: Define the Boundaries of the Study

• Specify the target population • Identify the population characteristics of interest • Define the spatial (e.g., scale) and temporal limits • Define potential constraints of the study or to data collection

Step 5: Develop the Approach

• Define the parameter(s) of interest • Determine the quality of data needed • Generate “If…then…else” statements or specify the estimator for

estimation problems Step 6: Specify Performance of

Acceptance Criteria • Specify decision rules or acceptable limits on estimation uncertainty

Step 7: Develop Plan for Obtaining Data

• Describe how, when, and where the data will be obtained • Determine the quantity of data needed • Identify potential alternative sampling and analysis designs that may

be appropriate

EVALUATION AND RESPONSE GUIDELINE DESCRIPTIONS Eight (8) UICER guidelines were developed and are presented in this Appendix. A brief description of each guideline is provided below. Separation Distance. UICER Guideline No. 1 describes the specific steps City of Portland Bureau of Environmental Services (BES) may follow, as necessary and appropriate, to evaluate and/or verify the separation distance between the bottom perforation in a given UIC and the seasonally high groundwater level. This information will be used to determine whether an individual UIC or group of UICs are compliant with WPCF permit conditions. MADL Exceedance. UICER Guideline No. 2 describes the additional evaluation BES may use, as necessary and appropriate, to evaluate either individual sampling event or annual mean stormwater discharge concentration MADL exceedances. This evaluation is in addition to the WPCF permit required notification and reporting requirements (see Stormwater Discharge Monitoring Plan; City of Portland, 2006). This evaluation may be used to identify potential pollutant sources, support corrective actions or response actions, or to assure adequate data are available to calculate the annual mean pollutant concentration.




UIC Proximity to Drinking Water Wells. UICER Guideline No. 3 describes the steps used to evaluate the setback distances from a UIC to a groundwater well used for domestic or public water supply. Information generated in this evaluation will be paired with information from the annual Stormwater Discharge Monitoring reports to evaluate compliance with the WPCF permit for UICs near domestic or public water wells. Source Identification. UICER Guideline No. 4 describes the basic process that may be followed to characterize an individual City-owned UIC drainage basin, and provides tools to identify potential sources of pollutants detected in stormwater. Source-Specific Investigation Monitoring. UICER Guideline No. 5 describes the additional evaluation BES may perform, as necessary and appropriate, to identify and characterize potential pollutant source(s) or cause(s) of MADL exceedances, including individual storm event concentration(s) and/or annual mean concentration(s). This guideline may also be used to develop monitoring strategies to investigate and/or document pollutant contributions to stormwater discharges to City-owned UICs from naturally occurring soil concentrations, anthropogenic/urban background, and/or air deposition. Groundwater Protectiveness Demonstration. UICER Guideline No. 6 describes the steps BES may follow, as necessary and appropriate, to evaluate and/or demonstrate that stormwater discharged to an individual UIC or group of UICs is protective of groundwater as a drinking water resource. This information may be used to support compliance determinations, corrective actions, or response actions. The steps described in this procedure are intended to clearly define the types and quality of data needed to demonstrate groundwater protection and WPCF permit compliance. Groundwater protection can be demonstrated in several ways, including but not limited to:

• Fate and Transport Analyses (UICER Guideline No. 6a); • Additional Stormwater Monitoring (UICER Guideline No. 6b); • Concentration Limit Evaluation (UICER Guideline No. 6c); • Implementation of Structural BMPs (see BMP Monitoring Program described in the UICMP); and

Regional Assessment of Problem. UICER Guideline No. 7 describes steps BES may follow, as necessary and appropriate, to assess the need to look beyond or apply the results from an individual UIC to either other nearby UICs, or to UICs within the City’s UIC system (i.e., other UIC within the immediate vicinity of a non-compliant UIC that may have similar levels of pollutants and may require sampling, further evaluation, or corrective action). Guideline No. 7 may also assist the UIC Program in categorizing or grouping UICs for further evaluation or corrective action. For example, UICs that may have inadequate separation distance may be grouped based on geographic or hydrogeologic considerations. Response Actions. UICER Guideline No. 8 describes steps BES may follow, as necessary and appropriate, to assess, select, and implement response actions.




REPORTING ON GUIDELINE IMPLEMENTATION The results or findings generated through the implementation of the UICER guidelines will be documented by the City of Portland. Documentation may include electronic mail, letters, memoranda, spreadsheets, work sheets, or reports depending on the scope and complexity of the evaluation or response. Data, records, reports, etc. will be maintained in the UIC Program files and will be available for review upon request. Evaluation and Response results and/or findings will be summarized in the Annual UICMP Report submitted to DEQ in November of each year. The Annual UICMP Report will include the following information, as necessary and appropriate:

1. Summary of information accumulated during the annual reporting period including: a. Guidelines Implemented; b. Issues or UICs evaluated; c. Analysis of information accumulated during the annual reporting period; and d. Key findings or results.

2. Summary of planned evaluation or response activities for the upcoming permit year. EVALUATION AND RESPONSE GUIDELINE LIMITATIONS The guidelines provide a range of actions that may be implemented by employees of the City of Portland to determine UIC compliance, identify a pollutant source, initiate a response action, or demonstrate groundwater protection. The guidelines describe the thought process and general steps that the City may use to evaluate UICs in order to make timely, conclusive decisions regarding UIC compliance with WPCF permit requirements. These guidelines are intended to provide flexible, dynamic, and iterative approaches to evaluating UICs and will be applied and adapted on a site-specific basis, as determined necessary and appropriate by the City of Portland, based on factual information. The specific scope of actions implemented from the guidelines will vary, based on site-specific conditions, available information, and the complexity of the issue. The guidelines generally are designed to apply larger, more complex issues or sites with the highest likelihood for adversely impacting groundwater quality or exceeding permit limits. Only limited elements of the information or data described in the guidelines may be necessary or applicable for relatively simple or straightforward issues. The level of effort and application of the additional detailed elements, described in the guidelines, will increase as appropriate to evaluate complex multivariate issues. The information contained in the guidelines should be interpreted and used in a manner that is consistent with the Water Pollution Control Facilities Permit for Class V Stormwater Underground Injection Control Systems issued by DEQ on June 1, 2005 to the City of Portland. The guidelines are intended to clarify WPCF permit requirements; but they are not intended to modify the permit.







Page 1 of 8 UICER No. 1


UIC Evaluation and Response Guideline No. 1

Separation Distance PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response Guideline (UICER) provides the basic procedure that will be followed to determine if an individual City-owned Underground Injection Control (UIC) system (i.e., injection point; injection well) or group of UICs are constructed and operated in compliance1 with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). The purpose of this guideline is to support the Compliance Determination Procedure. APPLYING THE GUIDELINE This guideline describes the specific steps BES may follow, as necessary and appropriate, to evaluate and/or verify the separation distance between the bottom perforation in a given UIC and the seasonally high groundwater level. This information will be used to develop the weight-of-evidence necessary to determine whether an individual UIC or group of UICs are compliant with WPCF permit conditions using information of known and verifiable quality. As described in the Systemwide Assessment Report (City of Portland, 2006), the reported separation distances are estimates and contain inherent uncertainties and therefore should only be used for identifying and prioritizing the further evaluation of UICs in areas of high groundwater and not for determining permit compliance.

The steps described in this guideline are intended to clearly define the types and quality of data needed to determine UIC permit compliance. Non-compliant conditions will be defined based on known and verifiable information that is determined to have a high or medium confidence level, as described below:

Level of Confidence

Description

High Data and information that is based on: field verification of the characteristic(s) being evaluated; direct observations; written professional reports; or contained in files, field notes, etc. prepared by an appropriate professional.

Medium

Data and information obtained from a reliable professional that is based on: limited field verification; casual observations or indications; anecdotal information passed by word-of-mouth but not documented in written professional reports; files, field notes, etc. prepared by an unknown author with known original study objectives (limited data quality); and data interpreted or extrapolated, based on best professional judgment, from nearby sites or information.

Low

Data and information is based on: no field verification; no direct observations; third party anecdotal information; limited or no written documentation; files, field notes, etc. prepared by an unknown author with unknown original study objectives (unknown data quality); and other data or information that cannot be directly verified or confirmed.

1 Defined in Schedule F, Section 5(gg)(v), of DEQ Water Pollution Control Facilities (WPCF) permit No. 102830).

December 2006



PERMIT REQUIREMENTS Schedule F, Section 5(tt) of the WPCF permit reads:

“Separation Distance means the distance in the unsaturated zone, confinement barrier or engineered filtration medium between the bottom of the public UIC and groundwater, and prevents contaminants from reaching groundwater. Under no circumstance shall a separation distance between groundwater and the bottom of the public UIC be less than 5 feet, unless specifically authorized in writing by the Department, that protects groundwater to primary drinking water regulations under the federal Safe Drinking Water Act (SDWA), or complies with the groundwater protection requirements specified in Oregon Administrative Rules (OAR) 340-40, including Concentration Limit Variances (CLVs) established as a permit condition under OAR 340-040-0030, or may protect human health. For this permit, minimum separation distance between the bottom of a public UIC and groundwater and must meet the following conditions to physically remove fecal coliform and E. Coli bacteria established in Table F-1. “

SEPARATION DISTANCE ESTIMATES The separation distance is defined as the approximate distance between the bottom-most perforations in the UIC to the approximate seasonal high groundwater level. The separation distance is calculated using the following formula: Sd = GW - UICperf where, Sd = separation distance in feet; GW = estimated depth to seasonal high groundwater level in feet below ground surface (bgs); UICperf = estimated depth to bottom-most UIC perforation in feet bgs (note: the bottom most

perforation for standard sumps is defined as the bottom of the UIC minus 2 feet. Two feet are added to the separation distance to account for the standard depth of the sediment trap ring based on a standard City UIC sump design.)

The WPCF permit specifies that required separation distance be estimated relative to seasonal high groundwater levels. The City used Geographic Information System (GIS) analysis to estimate the vertical separation distance between the bottom of the UIC and groundwater at each UIC location using preliminary depth to groundwater and seasonal groundwater variation data from the United States Geological Survey (USGS; Snyder, 2006) and available total UIC completion depths from the City’s Hansen database. The process for estimating the initial depth to seasonal high groundwater is described in the Systemwide Assessment Report.

Estimation of the separation distance is intended to serve as an indicator for identifying and prioritizing UICs in areas of high groundwater and that may not be in compliance with the minimum separation distance required by WPCF permit Table F-1. Estimated separation distances for City-owned UICs are presented in the Systemwide

December 2006



Assessment Report and are based on modeled information and are considered preliminary. This guideline describes the general steps BES will follow to evaluate and/or verify separation distance for the purpose of determining compliance with permit conditions. A list of UICs that may not have the permit required separation distance(s) was prepared and included in the Systemwide Assessment Report (City of Portland, 2006). These UICs, and others identified during the City’s ongoing UIC Management Plan (UICMP; submitted to DEQ on December 1, 2006) System Management program element, will be further evaluated using this guideline, to the extent necessary, to allow the City to determine compliance status. FURTHER EVALUATION FRAMEWORK Steps 1 through 4, below, describe the general framework that may be followed to evaluate Separation Distance(s). The sequence presented below is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps (e.g., individual field visits identified in the discrete steps may be combined to reduce field staff time and to streamline the schedule). The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs.

Implementation of this guideline, to the extent feasible and practicable, will be performed considering the priority (see UICMP Appendix G: Prioritization Procedure) of the individual UIC or group of UICs. The overall goal is to address those UICs with the greatest likelihood of adversely impacting groundwater. However, as noted in Appendix H, implementation of this guideline will also consider other factors, including the following:



Step 1: Estimate Separation Depth The WPCF permit specifies a required separation distance relative to seasonal high groundwater level. Estimation of the separation distance is intended to serve as an indicator for identifying and prioritizing UICs in areas of high groundwater and that may not be in compliance with the minimum separation distance required by permit Table F-1.

A. Estimate Separation distance (using the equation presented in the previous section) using:

a. Total depth of UIC, as reported in the Hansen database

b. USGS estimate of the groundwater depth

c. USGS estimated seasonal high groundwater correction

B. If the estimated separation distance is > 10 feet, no further evaluation is needed.

December 2006



C. If the estimated separation distance is < 10 feet, go to Steps 2 through 4, as needed and appropriate. Steps 2 through 4 describe the steps BES will follow to evaluate and/or verify separation distance for the purpose of determining compliance with permit conditions.

Step 2: Compile and Review Available Data and Information For UICs that are estimated to have separation distances less than the distance required by Table F-1 of the WPCF permit (i.e., < 5 feet for UICs with a total depth of < 5 feet; < 10 feet for UICs with a total depth of > 5 feet), the following information may be compiled, reviewed, and used to modify the separation distance estimate or to perform a weight-of-evidence evaluation (see Step 4), as necessary and appropriate:

A. Obtain and review UIC construction information.

a. Review existing data and information for accurate UIC total depth measurements. The following information may be reviewed, as applicable and appropriate:

i. UIC As-built drawings, if available;

ii. BES Hansen Database; and

iii. Other BES records, if available, for total depth information, such as:

1. Flow test data: Historical information collected on some City-owned UICs during construction and installation;

2. UIC Operations and Maintenance Records; and

3. UIC Inspection Records.

b. Obtain and review site-specific UIC setting information, as needed and appropriate

i. UIC location information, such as:

1. Hansen Database;

2. Site visit, if necessary;

3. Location description (i.e., latitude and longitude, Township/Range/Section/Quarter Section/Quarter-Quarter Section);

ii. Local and regional topography (e.g., slope);

iii. Location of UIC relative to nearest surface water body (e.g., wetlands, ponds, creeks, streams, rivers); and

iv. Flood plain maps.

c. Recalculate separation distance using newly obtained data from Step 1(A), if appropriate.

i. If separation distance is > 5 feet for UICs with a total depth of < 5 feet and > 10 feet for UICs with a total depth of > 5 feet (see WPCF permit Table F-1), no additional evaluation is needed.

ii. If separation distance is < 5 feet for UICs with a total depth of < 5 feet and < 10 feet for UICs with a total depth of > 5 feet (see Permit Table F-1), go to Step 2(B).

B. Obtain and review local groundwater information.

Information regarding local or regional groundwater conditions can be obtained from a variety of sources. This information may be general in nature. Subsurface geology or hydrogeologic conditions can vary considerably over a short distance in the Portland area due to the alluvial nature of area sediments, so professional judgment will be used to determine the applicability and adequacy of available information. The following information may be used in these reviews as necessary and appropriate:

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a. Consult with City staff (e.g., BES, Bureau of Maintenance [BOM], Bureau of Development Services [BDS]), as necessary and appropriate, to assess localized groundwater conditions in the vicinity of the subject UIC(s).

b. Consult with other agencies, institutions, etc. (e.g., USGS, Oregon Water Resources Department [OWRD], Portland State University), as necessary and appropriate, to evaluate localized groundwater conditions in the vicinity of the subject UIC(s).

c. Obtain, review, and evaluate localized depth to groundwater data, if available, in the vicinity of the UIC(s) to estimate “site specific” conditions using information from nearby test pits, boring logs, groundwater monitoring wells, drinking water wells, etc. Preference will be given to information obtained from sites (e.g., logs, wells) within 100 to 1,000 feet of the subject UIC to the extent practicable. The following data may be reviewed, as necessary and appropriate:

i. Driller’s logs are available from the OWRD (http://apps2.wrd.state.or.us/apps/gw/well_log/Default.aspx) for public water wells, monitoring wells, and other holes.

ii. Monitoring well logs and groundwater data may be available in DEQ files for sites with environmental issues (e.g., Leaking Underground Storage Tanks, Cleanup, Solid Waste Landfills, Site Assessment, Water Quality permits).

iii. Groundwater elevations may be available from wells monitored by the City, USGS or OWRD (http://www.wrd.state.or.us/OWRD/GW/well_data.shtml).

iv. BES files (e.g., Combined Sewer Overflow tunnel project, etc.) may be available including boring logs, test pits, infiltration tests, etc.

C. Obtain and review local and regional geology and hydrogeology reports, as needed and appropriate, including but not limited to:

a. USGS;

b. OWRD;

c. Oregon Department of Geology and Mineral Resources;

d. University research, theses, dissertations; and

e. Natural Resources Conservation Service (NRCS).

D. Assess uncertainty in seasonal high groundwater estimate, as needed and appropriate.

a. Assess the variation (e.g., slope, gradient) of groundwater depths in the USGS depth to groundwater map in the vicinity of subject UIC(s).

b. Assess the proximity of nearest data points used in generation of USGS groundwater map.

c. Assess the general confidence in the estimated depth to groundwater in the area of the subject UIC (i.e., does estimated groundwater depth make sense when viewed in context with other local information?) by looking at distance to nearest control point, mean baseline groundwater levels, and uncertainty associated in the depth to groundwater maps.

d. Assess the general confidence in the seasonal high groundwater correction factor.

i. Assess the proximity of nearest data points used in the USGS estimate of the seasonal high correction factor.

ii. Assess the general confidence in the USGS estimated seasonal high correction factor in the area of the subject UIC (i.e., does estimated seasonal high correction factor make sense when viewed in context with other local information?)

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http://apps2.wrd.state.or.us/apps/gw/well_log/Default.aspx



Step 3: UIC Field Verification For UICs that have estimated separation distances that are less than those specified by Table F-1 of the WPCF permit, one or more of the following tasks may be performed, if necessary and appropriate, to determine if the minimum separation distance is met. The tasks listed under this step may be performed concurrently or sequentially, depending on UIC specific information and timing of other steps. To the extent practicable, the City will attempt to limit the number of field visits to optimize the evaluation schedule and to reduce evaluation costs.

A. Verify UIC location and accessibility

a. Perform site visit to verify UIC location against the available record.

b. Verify accessibility of sedimentation manhole and UIC sump.

c. Determine if survey (horizontal or vertical) is needed to locate UIC.

d. Survey if appropriate.

B. Verify total depth of UIC sump (note: coordinate with Step C below if practicable).

a. Measure total depth of UIC sump.

b. Assess, to the extent feasible, if total depth measurement represents:

i. Top of sediment (if present); or

ii. Bottom of UIC.

c. Check for presence of water in the UIC (see Step 3(C)).

d. Determine if UIC should be cleaned to improve accuracy of UIC depth measurement.

i. If depth of UIC is unknown or likely contains a significant amount of sediment, issue a work order to have BOM clean the UIC system.

ii. Once the UIC cleaning is performed, repeat Step 3(B).

C. Determine if groundwater is likely to be present within UIC perforations.

a. If the estimated separation distance is > 3 feet, go to Step 4.

b. If the estimated separation distance is < 3 feet:

i. Inspect subject UIC during period of high groundwater (e.g., February – May), to determine if groundwater is present within the UIC.

ii. Measure the depth to water (if present) from land surface. Water level measurement should not be taken during or immediately after a storm event. To the extent practicable, measurements should be made following at least 2 days with no precipitation to allow collected stormwater to infiltrate to minimize the potential of obtaining false readings.

iii. Measure the total depth of UIC (see Step 3(B)).

iv. Calculate the height of the water column in the UIC by subtracting the measured depth to water from the measured total depth of the UIC.

c. If water is observed within the UIC, assess to the extent practicable, if the observed water is groundwater, stagnate water trapped within the base of the UIC (i.e., bottom 2 to 3 feet of UIC), or slowing infiltrating stormwater discharge.

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D. Recalculate separation distance using new data obtained from Step 3.

a. If water (believed to be groundwater) is observed in the UIC and the water level is estimated to be within the UIC perforations (i.e., > 2 feet of standing water within the UIC sump), go to Compliance Determination.

b. If groundwater is not observed during representative seasonal high groundwater period, go to Step 4. Step 4: Separation Distance Weight-of-Evidence Evaluation For UICs that have estimated separation distances that are less than those specified by Table F-1 of the WPCF permit and it is estimated that the seasonal high groundwater level is below the total depth of the UIC (e.g., estimated separation distances between > 0 and < 10 feet), a weight-of-evidence evaluation will be performed, if needed and appropriate, to determine if the UIC is compliant with the permit or if further evaluation is needed. The weight-of-evidence evaluation may include the following steps to use as necessary and appropriate, to determine if it is reasonably likely that the required separation distances presented in Table F-1 of the permit are met.

A. Develop Hydrogeologic Conceptual Site Model.

Develop a simplified Hydrogeologic Conceptual Site Model (HCSM) of the subject UIC(s). The HCSM should present a conceptual understanding of the hydrogeological and hydrological system in the vicinity of the subject UIC. It should consider the following data and information previously collected in Steps 2 through 3, as appropriate:

a. Available data and information (Step 2) on the subject UIC(s) including:

i. UIC Total Depth;

ii. UIC Location;

iii. Local and Region Topography;

iv. Proximity to surface water bodies; and

v. Local and regional surface water and groundwater information.

b. Field verified UIC completion depth (see Step 3); and

c. Field verified presence of groundwater in UIC during seasonal period of high groundwater (see Step 3).

d. The HCSM should include information on the following, as needed and appropriate:

i. Summary of site geology and hydrogeology, which may include:

1. Available boring logs, test pit logs, public water well logs, etc.;

2. Nature and extent of local geologic units;

3. Geologic or hydrogeologic cross sections; and

4. Available water level measurements.

ii. Conceptual description of localized surface water hydrology (e.g., description of local storm water flow and management);

iii. Factors that influence stormwater infiltration; groundwater recharge and discharge (e.g., soil types, geologic, surface water bodies), such as:

1. Soil types or geologic units;

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2. Location of UICs;

3. Groundwater flow direction (vertical and horizontal); and

4. Physical characteristics of water-bearing zones (i.e., aquifers).

iv. Data and information that has been field verified, directly observed, or is documented in professional written reports, files, field notes, etc., and prepared by an appropriate professional(s).

v. Data and information from a reliable professional(s), based on little to no field verification (i.e., anecdotal information), on casual observations or indications, and/or information passed by word-of-mouth but not documented in written profession reports, files, or notes.

vi. Maps that illustrate the following:

1. UIC system layout (location of UIC(s), proximity to surface water bodies);

2. Topography;

3. USGS estimated depth to groundwater;

4. Measured Depth to groundwater; or

5. Depth of UICs.

B. Estimate reasonably likely depth to groundwater.

a. Based on consideration of the HCSM, the level of confidence of the information (see description below) and the data used in the HCSM, and best professional judgment, estimate whether the separation distance is reasonably likely to meet the permit required distances.

i. If the estimated separation distance, based on the weight-of-evidence evaluation, is reasonably likely to be > 10 feet, the UIC will be assumed to be compliant. Document compliance status using the Compliance Determination Procedure.

ii. If the estimated separation distance, based on the weight-of-evidence evaluation, is reasonably likely to be < 10 feet, the UIC will be assumed to be non-compliant and will be identified for Corrective Action in accordance with the Corrective Action Plan (CAP; City of Portland, 2006).

b. If data of known and verifiable quality, are available to determine compliance status, the City may at its discretion either perform further evaluation actions as described in Section 5 of the UICMP. Additional actions may include:

i. Performing a limited field investigation(s) to observe site-specific conditions such as measuring the depth of groundwater in nearby wells (if any), advancing soil borings, or installing piezometers using the further evaluation guidelines presented in the UICMP.

ii. Demonstrating groundwater is protected using the Groundwater Protectiveness Demonstration guideline (UICER No. 6).

iii. Requesting written DEQ approval of a permit modification (see Policy & Regulations BMP), based on a demonstration that a decrease in separation distance is protective of groundwater quality (see Groundwater Protectiveness Demonstration guideline (UICER No. 6, ).

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Page 1 of 6 UICER Guideline No. 2



MADL Exceedances PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response (UICER) guideline provides the basic process that will be followed in the event that stormwater discharge concentrations exceed the maximum allowable discharge limits (MADLs) specified in Table 1 of the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830) during an individual storm event or the annual mean concentration. Stormwater sampling and analyses requirements are defined in the final Stormwater Discharge Monitoring Plan (submitted to DEQ on August 31, 2006). APPLYING THE GUIDELINE In addition to the required notification and reporting requirements described below, BES may undertake further evaluation and/or response actions, as necessary and appropriate, to evaluate and address MADL exceedances. Further evaluation may be used to identify potential pollutant sources, assure adequate data are available to calculate the annual mean pollutant concentration(s), demonstrate groundwater is protected, and support corrective actions or response actions. The steps described in this guideline are intended to define the types and quality of data that may be needed to demonstrate permit compliance and groundwater protection. This information will be used in determining whether an individual UIC or group of UICs is compliant with permit conditions using information of known and verifiable quality. The steps described in this guideline are intended to clearly define the types and quality of data needed to determine UIC permit compliance. Non-compliant conditions will be defined based on known and verifiable information that is determined to have a high or medium confidence level, as described below:

Level of Confidence

Description


Medium


Low


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PERMIT REQUIREMENTS Individual Storm Events. Schedule C, Section 9 of the WPCF permit requires that for an individual storm event

in which a MADL concentration is exceeded, the City must notify DEQ of the exceedance within seven days after review, but not exceeding 30 days after receipt of the laboratory data. The written notification must include, at a minimum, the following: a. The pollutant of concern; b. The public UIC at which the exceedance occurred; and c. The potential source(s), if known.

Annual Mean Concentration. The WPCF permit requires: Schedule B, Section 7(a)(vii) -

“A discussion of compliance response actions taken to correct a MADL annual mean exceedance.” Schedule C, Section 10. Compliance Response Action for Annual Mean MADL Exceedance -

“a. If, at the end of a wet season monitoring period, an annual mean concentration for any MADL in Table 1 is exceeded, the Permittee must: i. Implement a compliance response action to correct the exceedance within the first wet season

following the exceedance; ii. Notify the Department in writing within 7 days of determining exceedance of the annual mean

MADL. The written notice must include the public UIC location, the pollutant, and the annual mean concentration; and

iii. Discuss the following in the annual monitoring report of Schedule B.7 for the wet season in which the exceedance occurred: (1) The location of the public UIC(s) where the pollutant occurred; (2) The pollutant(s) of concern and the concentrations for the wet season monitored, including

the annual mean MADL concentration; and (3) The compliance response action proposed, being taken, or taken by the Permittee to correct

the exceedance. b. If the annual mean concentration of any MADL in Table 1 is exceeded for two consecutive wet

seasons, the Permittee must either decommission the public UIC or initiate a corrective action in accordance with Schedule C.12.g. to bring the annual mean MADL concentration into compliance with Permit conditions.”

In addition, DEQ states1 that “An exceedance of the annual mean concentration triggers a compliance response action. The Department does not consider the exceedance of the annual mean concentration as a permit violation. However, any failure to take a compliance response or corrective action is a permit violation... . “

1 “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit number:

102830, prepared by DEQ, dated June 1, 2005. Section 4.3.3.

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NOTIFICATION AND REPORTING Notification and reporting requirements of individual stormwater event and annual mean MADL exceedances are described in the Quality Assurance Project Plan (QAPP; City of Portland, 2006). The QAPP describes the contents and schedule of the MADL exceedance report(s) and the annual Stormwater Discharge Monitoring report. In addition, annual monitoring reports must include (Permit Schedule B, Section 7) identification and discussion of any exceedance of an individual storm event MADL or annual mean MADL concentration, including:

(1) Any potential cause of the exceedance, to the extent practicable and if known; and (2) Actions taken during the wet season to reduce the concentration of the pollutant of concern.

FURTHER EVALUATION FRAMEWORK Steps 1 through 3, below, describe the general framework that may be followed to evaluate the MADL exceedance(s). The sequence presented is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps (e.g., individual field visits identified in the discrete steps may be combined to reduce field staff time and to streamline the schedule). The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs.

Implementation of this guideline, to the extent feasible and practicable, will be performed considering the priority (see UICMP Appendix G: Prioritization Procedure) of the individual UIC or group of UICs. The overall goal is to address those UICs with the greatest likelihood of adversely impacting groundwater. However, as noted in Appendix H, implementation of this guideline will also consider other factors, including the following:



Step 1: Review Available Analytical Data

A. Compile analytical data for pollutant(s) exceeding its MADL including: a. Current permit year pollutant concentrations for individual sampling events; b. Annual mean pollutant concentrations, if available; c. Annual mean pollutant concentration calculations, if available; d. Previous permit year(s) pollutant concentrations for individual events, if appropriate; and e. Previous permit year(s) annual mean pollutant concentrations for MADL exceedances, if available.

B. Define range of pollutant concentration(s) for pollutant of interest using results of previous stormwater sampling events.

C. Assess if pollutant concentration is an outlier.

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a. If pollutant concentration is within the known or expected range, continue to Step 2. b. If concentration is outside the known or reasonably expected range for the pollutant:

i. Plot data (e.g., box plot, probability plot). ii. Assess if concentration appears to be an outlier.

1. If data does not appear to be an outlier, proceed to Steps 2 and 3 as appropriate. 2. If data appears to be an outlier:

• Consider collecting an additional stormwater discharge sample(s) (see UICER Guideline No.6b) from the subject UIC for use in calculating the annual mean concentration, if the potential outlier concentration is excluded. The permit states that the annual mean concentration should be based on at least five separate stormwater discharge events during the wet season, unless sample collection is beyond the reasonable control of the City (see WPCF Permit Schedule B(3)).

• Consider excluding outlier from calculation of annual mean (See Section 8.2.5.4 of the QAPP for discussion of outliers).

D. If the annual mean concentration exceeds the MADL for the second consecutive wet season, go to Compliance Determination or request DEQ approval to:

a. Perform a Groundwater Protectiveness Demonstration (UICER Guideline No. 6).

b. Include the UIC in a Regional Assessment (see UICER Guideline No. 7).

Step 2: Assess Potential Source or Cause of MADL Exceedance(s) A. Evaluate potential source(s) or cause(s) of the pollutant of interest, as necessary and appropriate, as

described in Source Identification (UICER Guideline No. 4).

B. Assess pollutant mobility characteristics (see UIC Prioritization Procedure Tables 1 and 2). This may include: a. Solubility; b. Chemical portioning coefficients; c. Theoretical fate and transport; and d. Breakdown or degradation byproducts.

C. Review information collected regarding the subject UIC system (location, depth to groundwater, drainage catchment characteristics, hydrogeology, traffic volume and type, etc.) (see UICER Guideline Nos. 1 and 4).

D. Based on information identified in Steps 2A through 2C, determine need for additional evaluation and/or response actions. For example: a. Identify potential basin characteristics that may help identify pollutant sources or track pollutant

migration within the UIC drainage area for field inspection (see UICER Guideline No. 4) or source investigation (see UICER Guideline No. 5).

b. If potential pollutant source(s)/cause(s) is identified, go to Step 3.

E. Assess the need to look beyond the individual UIC with a MADL exceedance to identify if other UICs within the vicinity (i.e. “regional”) or with similar characteristics should be further evaluated (See UICER Guideline No. 7).

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Step 3: Identify and Implement Potentially Applicable Response Actions or Further Evaluation Activities

A. Assess magnitude of MADL concentration exceedance (i.e., storm event concentrations divided by applicable MADL).

a. If magnitude2 is < 2 times the MADL, continue stormwater discharge monitoring in accordance with the SDMP (City of Portland, 2006) and continue to other steps or other guidelines as necessary and appropriate.

b. If magnitude is > 2 times the MADL, consider implementation of potentially applicable response actions, go to the Response Action Guideline (UICER No. 8).

2 Factor of 2 selected based on the ½ the dilution factor used for lead in DEQ’s “Fact Sheet and Class V Underground

Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit number: 102830, by DEQ, dated June 1, 2005.

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Proximity to Drinking Water Wells PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response Guideline (UICER) provides the basic process that will be followed to determine if an individual public Underground Injection Control (UIC) system (i.e., injection point; injection well) or group of UICs are constructed and operated in compliance1 with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). Specifically, this procedure evaluates the setback from a UIC to a groundwater well used for domestic or public water supply. Information generated in this evaluation will be paired with information from the UIC Stormwater Discharge Monitoring Plan (City of Portland, 2006) to evaluate compliance with water quality requirements established in the permit for UICs near domestic or public water wells. APPLYING THE GUIDELINE This guideline describes the steps BES may follow, as necessary and appropriate, to evaluate and/or verify the UIC setback distance or 2-year time of travel for UICs with measured or estimated concentrations greater that the maximum allowable discharge limits (MADLs) defined in Table 1 of the permit. This information will be used in determining whether an individual UIC or group of UICs are compliant with permit conditions using information of known and verifiable quality. As described in the Systemwide Assessment Report (City of Portland, 2006), the reported setback distances or 2-year time of travel definitions are estimates and contain inherent uncertainties and therefore should only be used for identifying and prioritizing the further evaluation of UICs and not for determining permit compliance. The steps described in this guideline are intended to clearly define the types and quality of data needed to determine UIC permit compliance. Non-compliant conditions will be defined based on known, and verifiable information that is determined to have a high or medium confidence level, as described below:

Level of Confidence

Description


Medium


Low


1 Defined in Schedule F, Section 5(gg)(v), of DEQ Water Pollution Control Facilities (WPCF) permit No. 102830).

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PERMIT REQUIREMENTS The WPCF permit requires that UICs that are located less than 500 feet from a domestic well, or are within a two-year time of travel of a public water well, or are located less than 500 feet from a public water well without a delineated time of travel, must meet the water quality requirements specified in Table 1 of the permit. The following paragraphs provide specific WPCF permit language regarding UICs and water wells:

Schedule C, Section 12 (Corrective Actions) of the permit reads:

“. . .A corrective action must be implemented under the following conditions. . .

iii. For public UICs within domestic, irrigation or public water well setbacks as defined in Schedule F.5.gg, the Permittee must demonstrate through monitoring data that the quality of stormwater discharged into the public UIC meets the annual mean Maximum Allowance Discharge Levels (MADLs) specified in Table 1. . .”

Schedule D, Section 13 (Corrective Actions) of the permit reads:

“. . . e. The Permittee may exclude any public UIC authorized by this permit from the non-compliant conditions for domestic well or public water system well setbacks, if the Permittee demonstrates any of the following conditions are met, and the Department concurs in writing with the exclusion. The Permittee must demonstrate:

i. The stormwater is pre-treated prior to discharge to the public UIC to meet limits established in Table 1; and/or

ii. Irrigation wells cannot be used as a drinking water supply source through enforceable ordinance, plumbing code or other legal process. . .”

Schedule F, Section 5(gg) of the permit reads:

“. . . Non-compliant means a public UIC meets any of the following conditions:

i. It is within 500 feet of a domestic or irrigation well and does not meet the water quality limits established in the permit;

ii. It is within 500 feet of a public water well serving a public water system and does not have a Department of Human Services groundwater time-of-travel (TOT) delineation and the water quality of the discharge does not meet the water quality limits established in the permit;

iii. It is within the 2-year TOT delineated by the Department of Human Services (DHS) for a public water well or wells serving a public water system and the water quality of the discharge does not meet the water quality limits established in the permit;

iv. Any public UIC that does not meet the water quality discharge limits established in the permit at the end-of-pipe discharge point into the public UIC; …”

Schedule F, Section 5 of the permit defines the following permit terms:

“Domestic well means a water supply well used to serve no more than three residences for the purpose of supplying water for drinking, culinary, or household uses. Domestic wells include irrigation wells because irrigation wells can be used as drinking water supply wells without well modification or notification to the Oregon Water Resources Department, unless the Permittee has adopted an enforceable regulatory mechanism that prevents the use of irrigation wells for domestic or public drinking water supply purposes.”

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“Irrigation well (See Domestic Well).”

“Public water system well or public water well means a water supply well serving a public water system.”

“Public water system means a system for the provision of piped water for human consumption, if such system has more than 3 service connections or supplies water to a public or commercial establishment which operates for a total of at least 60 days per year, and which is used by 10 or more individuals per day. Public water system also means a system for the provision to the public of water through constructed conveyances other than pipes to at least 15 service connections or regularly serves at least 25 people per day for at least 60 days per year. A public water system is a ‘community water system’, a ‘transient non-community water system’, a ‘non-transient non-community water system’ or a ‘state regulated water system.’ “

DOMESTIC WELL SETBACK AND/OR TIME OF TRAVEL ESTIMATES Estimation of the well setback is intended to serve as an indicator for identifying and prioritizing UICs with setbacks less than 500 feet or within the 2-year time of travel. Estimated setbacks and 2-year time of travel for City-owned UICs are presented in the Systemwide Assessment Report and are based on modeled information and are considered preliminary. This procedure describes the general steps BES will follow to evaluate and/or verify UIC proximity to drinking water wells for the purpose of determining compliance with permit conditions. A list of UICs that may not have the 500-foot setback distance, or are within an estimated 2-year time of travel was prepared and included in the Systemwide Assessment Report. These UICs and others identified during the City’s ongoing System Inventory and Assessment will be further evaluated to the extent necessary to allow the City to determine compliance status. FURTHER EVALUATION FRAMEWORK Steps 1 through 4, below, describe the general framework that may be followed to evaluate the UIC proximity to drinking water wells. The sequence presented below is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps (e.g., individual field visits identified in the discrete steps may be combined to reduce field staff time and to streamline the schedule). The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs.

Implementation of this guideline, to the extent feasible and practicable, will be performed considering the priority (see UICMP Appendix G: Prioritization Procedure) of the individual UIC or group of UICs. The overall goal is to address those UICs with the greatest likelihood of adversely impacting groundwater first. However, as noted in Appendix H, implementation of this guideline will also consider other factors, including:



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Step 1: Evaluation of 500-foot UIC Setback from Domestic Water (including Irrigation and Public) Wells

For UICs that have estimated setback distances less than 500 feet from domestic water wells, the following steps will be performed, as necessary and appropriate, to confirm the estimated distance between the UIC and the domestic well:

A. Review applicable UIC and domestic well information.

a. Review Hansen Database and other BES records for UIC location information.

b. Determine if UIC has pretreatment.

c. Review available well location information (i.e., street address; township, section, range; or latitude and longitude).

d. Assess the accuracy of the water well location information.

e. Review available aerial photographs using the BES ArcGIS system: i. Attempt to more accurately locate subject UIC and drinking water well (e.g., standpipe, pump

shed, water tank) on appropriate aerial photograph(s). ii. Attempt to more accurately locate subject UIC and drinking water well on appropriately scaled

local maps.

B. Field verification of setback distance, well use, status (e.g., active, inactive, abandoned) and well condition.

a. Perform site visit to verify UIC location and to map location of groundwater well.

b. Meet with the current owner/occupant of property with groundwater well, if accessible.

c. Complete an inventory checklist with the owner or occupant (whoever can provide the most accurate information).

d. Request owner or occupant allow documention of the well location. i. Sketch location of water well on appropriate map or aerial photograph.

ii. Locate water well by measuring distance from at least two fixed locations visible on an aerial photograph or local map (e.g., corner of house, well shed, fence corner, telephone pole) or using a portable global positioning system (GPS) unit.

iii. Photograph the groundwater well to document well condition, nearby household land uses (e.g., shed, pesticide storage, family garden, etc.) and relationship of well to nearby landmarks (e.g., house, trees).

iv. If well owner or property occupant is not home, leave an introduction letter, aerial photo, and well questionnaire form with a self-addressed envelope for locations where no one could be contacted at the site.

e. Determine whether a survey is needed to more accurately locate the UIC and domestic well.

f. Survey UIC location if needed.

C. Recalculate well setback distance from the UIC using new data obtained from Step 1.

a. If reevaluated setback distance is >500 feet, go to the Compliance Determination Procedure.

b. If reevaluated setback distance is <500 feet and well is an irrigation well, go to Step 3.

c. If reevaluated setback distance is <500 feet, go to Step 4.

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Step 2: Evaluation of UICs within 2-Year Time of Travel For UICs identified as being within the 2-year time of travel from a public water well(s) the following steps will be performed, as necessary and appropriate, to verify the location and time of travel estimate the following:

A. Verify UIC and water well locations (See Step 1(A) and 1(B)).

B. Verify and/or update information used to perform spatial query to identify UICs that intersect the two-year time of travel polygons are correct.

C. Rerun ARC-GIS spatial query if information has changed to determine whether or not the subject UIC is within 2-year time of travel:

a. If UIC remains within 2-year time of travel, go to Step 4.

b. If UIC is determined to be outside 2-year time of travel, go to the Compliance Determination Procedure.

Step 3: Evaluation of UICs within 500 feet of an Irrigation Well For UICs that have estimated setback distances (less than 500) feet from known irrigation wells, the following step will be performed, as necessary and appropriate:

A. Complete applicable portions of Step 1A and 1B.

B. Determine if local enforceable ordinance, plumbing code, or other legal process have been implemented to prevent irrigation wells from being used as a drinking water supply.

a. If an enforceable restriction(s) is in place, provide documentation of the restriction to DEQ and request approval in writing from DEQ to apply the exclusion in Schedule D, Section 13(e)(ii) to the subject UIC or UICs.

b. If enforceable restrictions are not in place, go to the Compliance Determination Procedure. Step 4: Evaluation of Stormwater Quality Discharged to UICs located within 500 feet of a

Drinking Water Well or within a 2-year Time of Travel For UICs that are determined to be located within 500 feet of a drinking water well (e.g., domestic, irrigation, public) and/or within the estimated 2-year time of travel, the following steps may be performed, as necessary and appropriate to determine if stormwater discharged to the subject UIC meets the water quality requirements specified in Table 1 of the permit:

A. Determine whether or not subject UIC pre-treats stormwater prior to discharge to the subject City-owned UIC.

a. Review Hansen Database, as-built drawings, and results of field verification inspections (See Step 1).

b. If UIC has pre-treatment, provide documentation of the known or anticipated treatment effectiveness and request approval in writing from DEQ to apply the exclusion in Schedule D, Section 13(e)(ii) to the subject UIC or UICs. Information/documentation may be available from the following sources: i. BMP Monitoring Program (see UIC Management Plan);

ii. Annual Stormwater Discharge Monitoring Program (See UICER Guideline No. 6b); or iii. Groundwater Protectiveness Demonstration Guideline (See UICER Guideline No. 6).

c. If the UIC does not have pre-treatment, go to Step 4(B).

B. Assess quality of stormwater being discharged into subject UIC(s).

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a. Determine if subject UIC is part of required Stormwater Discharge Monitoring Program (UICMP Section 4). i. If UIC has been sampled use available results to determine if the water quality requirements

specified in the permit are met. ii. Use available results for Compliance Determination Procedure.

b. If UIC has not been sampled, estimate the likelihood that stormwater quality discharged into the subject UIC will meet the water quality requirements specified in the permit. One of the following methods may be used at the City’s discretion,

to estimate potential stormwater discharge concentrations using one or more of the following or their equivalent.

1. Results from representative UICs sampled as part of the Stormwater Discharge Monitoring Program (UICMP Section 4) or using potential correlations (e.g., trend analyses) between traffic category, traffic type, land use, etc.

2. Results of supplement stormwater discharge monitoring in UICs located within 500 feet of domestic wells, public wells, or within a 2-year time of travel (UICMP Section 4 and UICER Guideline No. 6b), if available, and potential correlations between traffic category, traffic type, land use, etc.

c. Compare stormwater quality information from Step 4(B) to determine if stormwater pollutant concentrations are likely to exceed the MADLs defined in Table 1 of the permit.

i. If it is determined that the annual mean stormwater concentrations are not likely to exceed MADLs, based on the best available data and a weight-of-evidence evaluation, the UIC(s) will be considered compliant. If the UIC(s) is determined to be in compliance with the permit, the compliance will be documented in accordance with the Compliance Determination Procedure.

ii. If it is determined that the annual mean stormwater concentration(s) are likely to exceed their respective MADLs, based on the best available data and a weight-of-evidence evaluation, one of the following actions may be performed as described in Section 5 of the UICMP. Additional actions may include the following:

1. Perform additional stormwater sampling as described in the Additional Stormwater Monitoring Guideline (UICER Guideline No. 6b)).

2. Perform a Groundwater Protectiveness Demonstration (UICER No. 6) which may include Fate and Transport Analyses (UICER Guideline No. 6a);

3. Performa aA Regional Assessment of Problem (UICER Guideline No. 7);

4. Change or create city code, policies, or administrative rules to: • Provide public water to domestic well users; • Restrict installation of new domestic wells; and • Prevent or restrict conversion of irrigation wells to drinking water wells.

5. Install or upgrade UIC pre-treatment to protect groundwater.

6. City may designate the UIC(s) as non-compliant and identify it for Corrective Action in accordance with the Corrective Action Plan (City of Portland, 2006).

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Source Identification PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response (UICER) guideline provides the basic process that will be followed to identify potential sources of stormwater pollutants within an individual City-owned Underground Injection Control (UIC) system (i.e., injection point; injection well) catchments or group of UICs. Specifically, this guideline provides tools for further evaluating characteristics of a given UIC catchment and identifying potential sources of pollutants in stormwater. This guideline relies on the review of readily available information contained in the City of Portland’s ArcGIS system or through public databases. APPLYING THE GUIDELINE This guideline may be followed in the event a pollutant is detected during implementation of the Stormwater Monitoring Program (see Stormwater Discharge Monitoring Plan (SDMP), August 2006) at a concentration near or exceeding its respective maximum allowable discharge limit (MADL), in response to a citizen compliant, or as follow-up to the ongoing System Management activities (see UIC Management Plan (UICMP), Section 3.0). The results of this evaluation may be used to identify the need for UIC or source specific investigations, and to design specific source sampling plans (see Source Specific Investigation UICER Guideline No. 5). In addition, the information from implementation of this guideline may be used to improve UIC operation and management to assure groundwater protection. For example, the information may assist the City in focusing, refining, or improving the following: UIC operation and maintenance procedures (see Operations and Maintenance Plan); UIC pollution control activities best management practice (BMP); or other BMPs included in the System Management Program (i.e., Education and Training). PERMIT REQUIREMENTS The WPCF permit requires the City to identify and discuss the potential source(s) or cause(s) of any MADL exceedance including individual storm events concentration(s) and/or any annual mean concentration(s) [Schedule B, Section 7(a)(v)]. FURTHER EVALUATION FRAMEWORK This guideline describes the steps that BES may follow, as necessary and appropriate, to evaluate and/or identify stormwater pollutant sources that may be discharged to an individual UIC or group of UICs. The sequence presented below is intended to be flexible and dynamic to address site-specific circumstances. This describes the thought process and general steps that the City may use to identify a pollutant source. The specific scope of actions implemented using this guideline will vary, based on site-specific conditions, available information, and the complexity of the issue. This guideline is designed to apply larger, more complex issues or sites with the highest likelihood for adversely impacting groundwater quality. Only limited elements of the information or data described in the guidelines may be necessary or applicable for relatively simple or straightforward issues.

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Some steps may be performed concurrently or in a different order to optimize staff resources and to eliminate potential overlap between steps. The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs. Step 1: BES Record Review - UIC Catchment Information Collect and review the following types of information, as needed and appropriate, regarding the subject UIC catchment(s):

A. Size and composition of UIC drainage catchment (e.g., square feet, acres):

a. Estimate percentage of impervious surfaces (e.g., rights-of-way, rooftops, discharge from private properties including parking lots, roadways, or other paved surfaces.

b. Identify potential pollutant types and sources for impervious surfaces within the drainage catchment (see Steps 2 through 4).

B. General surface topography within catchment (i.e., slope or grade);

C. Key features of UIC catchment:

a. Location and number of catch basins or inlets; b. Location of stormwater conveyance lines (e.g., pipe diameter, connections); c. Location of sedimentation manhole, if present; d. Location of UIC; e. Construction details of UIC, as available (e.g., total depth, perforated zone); f. Presence, if any, of structural control measures (e.g., constructed features to control storm water flow

such as berms, retention/detention ponds, vegetative swales, sediment traps, ditches, oil-water separators, etc.) associated with the UIC system; and

g. Location of above ground utilities in the catchment (e.g., utility poles, transformers, substations).

D. UIC maintenance records.

Step 2: Public Database Review Collect and review information from public atabases, as needed and appropriate, regarding the subject UIC catchment(s):

A. Predominant land use(s) within UIC drainage catchment;

B. Estimated traffic volume and type for public roadways within the UIC catchment;

C. Potential commercial / industrial sources within UIC drainage catchment, using the following types of information sources or data bases as necessary and appropriate:

a. BES Geographic Information System (GIS) aerial photographs; b. BES GIS tax lot records; c. DEQ permitted underground storage tank (UST) database:

http://www.deq.state.or.us/wmc/tank/ustfaclist.htm; d. DEQ Leaking UST Database: http://www.deq.state.or.us/wmc/tank/LustPublicLookup.asp; e. DEQ Facility Profiler (database warehouse): http://deq12.deq.state.or.us/fp20/StartPage.aspx; f. DEQ Environmental Cleanup Site Information (ECSI) database:

http://www.deq.state.or.us/wmc/ECSI/ecsiquery.asp?listtype=ecsilist.asp&listtitle=Environmental+Cleanup+Site%20Information+Database;

g. State of Oregon Water Resources Department Well Log database: http://www.wrd.state.or.us/;

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h. Oregon State Fire Marshall (OSFM) Incident Search: http://www.sfm.state.or.us/CR2K_IncDB/Incident_Search.htmlSFR.

Step 3: Preliminary Identification of Potential Pollutant Source(s) Using the information collected in Steps 1 and 2 from public files and databases to identify potential pollutant sources within the UIC drainage catchment. The purpose of this Step is to assist in planning and implementing a field reconnaissance of the drainage catchment in Step 4. The preliminary identification of potential pollutant sources should include consideration of the following types of information, as needed and appropriate:

A. Facilities or features (e.g., commercial, industrial, manufacturing, utility) that may contribute pollutants to stormwater runoff.

B. Potential activities on properties within the UIC catchment that may contribute stormwater and/or pollutants to the UIC (e.g., fueling, painting, etc).

C. Applicable regulatory permits and/or previous actions (e.g., pre-treatment permit, permits, spills, inspections, enforcement actions).

D. DEQ program files (e.g., air, water, storm water, underground storage tank, cleanup, underground injection control point) if appropriate and applicable; obtain, if needed and available, the following site-specific documents:

a. Stormwater Pollution Control Plan(s); b. Stormwater BMPs; c. Spill Prevention and Pollution Control Plan(s); and d. Applicable environmental investigations.

E. Potential sources of pollutants from site materials inventory, if available (e.g., fuels, solvents, detergents, plastic pellets, metallic products, hazardous substances, transformers, fertilizers, pesticides, ash, slag, sludge, etc.). The State Fire Marshal’s Community Right-to-Know hazardous substance database can be used, along with facility inventory records.

F. City of Portland program files (e.g., storm water, plumbing records, etc.) if appropriate and applicable.

Information regarding potential pollutant sources (e.g., potential source, pollutant(s) associated with potential source, estimated volume, storage method, period used) may be tabulated as needed, and the location of each potential source may be shown on a site plan, if appropriate. Step 4: Field Reconnaissance A field reconnaissance may be performed to verify or confirm the information collected in Steps 1 and 2 or to collect additional information regarding the subject UIC. The following types of data may be collected or activities performed during the field visit, as determined by the City to be needed and appropriate:

A. Verify information collected in Step 1.

B. Evaluate stormwater drainage.

a. Evaluate drainage patterns (i.e., identify, if possible, what is actually draining to the UIC). b. Evaluate drainage system.

i. Catch basins/inlets; ii. Pretreatment (e.g., oil/water separators); and iii. UIC construction (e.g., depth).

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http://www.sfm.state.or.us/CR2K_IncDB/Incident_Search.htmlSFR



C. Inspect property line of identified potential pollutant source(s) within UIC catchment.

a. Identify location and type(s) of potential pollutant sources. i. Manufacturing or other industrial processes; ii. Equipment or vehicle maintenance; iii. Vehicle fueling; iv. Vehicle washing; v. Outdoor uncovered storage (materials, equipment, products, etc.); vi. Painting; vii. Dust or particulate generating activities; viii. Trash or recycling rolloffs or dumpsters; and ix. Utility poles.

b. Perform preliminary visual assessment of potential stormwater drainage from facility to City UIC catchment.

c. Identify presence, to the extent practicable, of stormwater controls, on-site UICs, etc. D. Provide facility outreach.

a. Provide facility with information regarding stormwater and groundwater quality protection (see Education and Training BMP).

b. Provide facility with information regarding stormwater management (see Pollution Prevention BMP and Operations and Maintenance Plan).

Step 5: Identify Other Potential Pollutant Sources

A. Research potential sources of pollutant(s). Other potential pollutant sources may be identified and considered to the extent feasible and practicable.

a. Review BES Chemical Profiles and search literature. i. Potential sources for pentachlorophenol and di(ethylhexyl)phthalate (DEHP) are described

in the chemical profiles presented in the Annual Stormwater Discharge Monitoring Report (City of Portland, July 2006);

ii. Professional Journals and Publications; and iii. Internet (e.g., world wide web) searches.

B. Identify sources of low level pollutants considered to be ubiquitous in urban areas. The source(s) of these pollutants may be associated with:

a. Natural soil background concentrations (e.g., metals); b. Air Deposition (e.g., metals, PAHs, DEHP); and c. Anthropogenic or urban background.

Step 6: Next Steps Based on an evaluation of the results of Steps 1 through 5, the City may, as needed and appropriate:

A. Perform environmental testing to evaluate the contribution of non-point pollutant sources to support response or corrective actions, source control activities, potential permit modifications, no further action determinations, or groundwater protectiveness demonstrations (see Source Specific Investigation Monitoring (UICER Guideline No.5).

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B. Refer an identified pollutant source (e.g., facility, utility, business) to DEQ for further evaluation and investigation under the appropriate DEQ regulatory authority (e.g., Water Quality, UIC, Environmental Cleanup, Solid Waste, Hazardous Waste, UST).

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Source Specific Investigation Monitoring PURPOSE This City of Portland Bureau of Environmental Services (BES) Underground Injection Control (UIC) Evaluation and Response (UICER) guideline provides the basic process that will be followed to investigate potential stormwater pollutant sources or to demonstrate that response actions are effective. Specifically, this guideline provides a tool for evaluating potential pollutant sources and demonstrating that stormwater discharge limits to UICs are protective of the highest beneficial uses of groundwater (i.e., drinking water) as required by the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). APPLYING THE GUIDELINE This guideline may be used to develop source-specific investigation plans, as determined by BES to be needed and appropriate, to obtain data of sufficient quality and quantity to identify pollutant sources and:

• Confirm contribution of pollutants to City-owned UICs from an identified source (see UICER Guideline No. 4).

• Assess the need for or the effectiveness of response actions (see UICER Guideline No. 8) or corrective actions (see Corrective Action Plan (CAP); City of Portland 2006).

• Document the contribution of pollutants from: - Air deposition; - Anthropogenic or urban background; and - Ubiquitous sources.

• Improve the management of UICs to assure groundwater protection, etc., by identifying and implementing changes to the best management practices (BMPs) identified in the UIC Management Plan (UICMP; Section 3.0) or the UIC Operation and Maintenance Plan (UICMP Appendix B).

UICER Guideline No. 6b addresses additional stormwater monitoring that may be needed to facilitate interpretation (e.g., assess data gaps, data trends, annual mean concentrations) of stormwater data collected in accordance with the Stormwater Discharge Monitoring Plan (SDMP; City of Portland, 2006) or to support permit or UICMP modifications. PERMIT REQUIREMENTS The WPCF permit requires the City identify and discuss the potential source(s) or cause(s) of any MADL exceedance including individual storm events concentration(s) and/or any annual mean concentration(s) [Schedule B, Section 7(a)(v)].

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FURTHER EVALUATION FRAMEWORK This guideline describes the steps BES may follow, as necessary and appropriate, to develop a source specific sampling plan to investigate a potential pollutant source(s) that may be discharging to an individual UIC or group of UICs, or to evaluate the effectiveness of a response action. The intent of this document is to lay out a logical, flexible stepwise approach to evaluating stormwater quality associated with specific sources, locations, or issues. The specific scope of actions implemented using this guideline will vary, based on site-specific conditions, available information, and the complexity of the issue. This guideline is designed to apply larger, more complex issues or sites with the highest likelihood for adversely impacting groundwater quality. Only limited elements of the information or data described in the guidelines may be necessary or applicable for relatively simple or straightforward issues. The sequence presented below is intended to be flexible and dynamic to address source-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps. The actual steps performed and sequencing of the steps will be determined based on source-specific facts regarding each UIC or group of UICs. Implementation of this guideline, to the extent feasible and practicable, will be performed considering the priority (see UIC Prioritization Procedure) of the individual UIC or group of UICs.

Step 1: Records Review Review applicable information and data generated from implementation of the following guidelines, as needed and appropriate:

A. Stormwater Discharge Monitoring (Stormwater Discharge Monitoring Plan; City of Portland, 2006));

B. MADL Exceedance(s) (UICER Guideline No. 2);

C. Source Identification (UICER Guideline No. 4);

D. Groundwater Protectiveness Demonstration (UICER Guideline No. 6); and

E. Response Actions (UICER Guideline No. 8). Step 2: Develop Objectives

A. Define the goal(s) and/or objective(s) for the source-specific investigation. Objectives may include, as needed and appropriate:

a. Confirm source contribution of pollutants to City-owned UIC.

i. Identify specific pollutants associated with the pollutant source.

ii. Identify pollutant migration pathway from source to UIC.

b. Assess magnitude of pollutant concentration(s).

c. Identify need for response action (see UICER Guideline No. 8) including potential referral of individual facilities to DEQ for source control.

d. Demonstrate effectiveness of response action(s).

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Step 3: Develop Source Specific Investigation Monitoring Plan A. Initiate the Data Quality Objectives (DQO) Process1 that EPA recommends for environmental

investigations when data are to be used to make some type of decision (e.g., compliance or non-compliance with a standard) or estimation (e.g., ascertain the mean concentration level of a contaminant). The DQO process is summarized in Section 5 and Appendix H of the UICMP.

B. Develop the scope of a source-specific investigation plan (i.e., sampling and analyses plan) using the DQO process as general guidance. The degree to which the DQO process is used will depend on the source specific issue and the complexity of the issue.

C. Prepare a brief Source Investigation Monitoring Workplan describing the proposed investigation. The investigation should be performed to the extent practicable with the SDMP or the BMP Monitoring Program (UICMP Appendix E) and meet the requirement of the permit (e.g., method reporting limits, notification of concentrations exceeding MADLs).

Step 4: Implement Plan Implement the Source Investigation Monitoring Plan. Document any deviations from the plan.

Step 5: Evaluate Results Compile and evaluate the results of the source-specific investigation. The results may be used, as needed and appropriate to:

A. Determine the need for additional monitoring to meet the objectives of the investigation or to address data gaps identified by the investigation.

B. Initiate response actions (see UICER Guideline No. 8) or corrective actions (see CAP).

C. Refer an identified pollutant source (e.g., facilities, source) to DEQ for further evaluation and investigation under the appropriate DEQ regulatory authority (e.g., Water Quality, UIC, Environmental Cleanup; Solid Waste; Hazardous Waste; Underground Storage Tank).

D. Improve the management of UICs to assure groundwater protection, etc., by identifying and implementing changes to the BMPs identified in the UICMP or the UIC Operation and Maintenance Plan.

E. Evaluate or demonstrate permit compliance.

F. Support permit or UICMP modifications.

G. Document the contribution of pollutants from air deposition, anthropogenic (i.e., urban) background, or ubiquitous sources.

1 “Guidance on Systematic Planning Using the Data Quality Objectives Process” prepared by the US Environmental

Protection Agency. EPA/240/B-06/001. February 2006. EPA QA/G-4.

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Groundwater Protectiveness Demonstration PURPOSE This City of Portland Bureau of Environmental Services (BES) Underground Injection Control (UIC) Evaluation and Response (UICER) guideline provides the basic process that will be followed to evaluate whether an individual public UIC system (i.e., injection point; injection well) or group of UICs are constructed and operated in compliance with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). Specifically, this guideline provides tools for evaluating if stormwater discharge limits to UICs are protective of the highest beneficial uses of groundwater (e.g., drinking water). APPLYING THE GUIDELINE The WPCF permit and the DEQ “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” (DEQ, June 2005) identify several types of activities that may be used to support additional evaluation of specific conditions and/or demonstrate groundwater protection. These activities include groundwater monitoring, “risk assessment”, structural retrofitting of UICs, UIC decommissioning, or other actions as directed or approved by DEQ. The overall intent of the groundwater protectiveness demonstration (i.e., “risk assessment”) is to evaluate and/or demonstrate that stormwater discharges into City-owned UICs complies with Oregon Administrative Rules 340-040, does not adversely affect the beneficial uses of groundwater, and are protective of public health and the environment.

The term “risk assessment” as used in the permit, and as referenced in the UIC Management Plan (UICMP) and this guideline, is broadly defined, may be multifaceted, and involve one or more of the following activities:

• Pollutant fate and transport analyses; • Additional stormwater discharge monitoring to identify pollutant sources or facilitate data interpretation; • Evaluation/modification of permit concentration limits or groundwater compliance limits to assure

protection of human health and the environment.

The groundwater protectiveness demonstration may be used to support the WPCF permit or UICMP modifications. Modifications to the permit are allowed through OAR 340-045-0055. Revisions to the permit or UICMP would be submitted to DEQ for review and approval. In the event a permit modification is requested or UICMP revision submitted, the City would present the basis for the proposed change. The basis would include scientifically valid data and appropriate analyses to demonstrate that the proposed change (e.g., an increase in the maximum allowable discharge limit (MADL) concentration; development of a MADL for a pollutant not currently identified in the permit; decrease in separation distance) does not adversely affect groundwater quality for its beneficial uses as defined in OAR 340-040-0020 and is protective of public health and the environment. The permit requirements that address the assessment of potential risk to groundwater are specifically addressed in the following guidelines:

• Fate and Transport Analyses (UICER Guideline No. 6a); • Additional Stormwater Monitoring (UICER Guideline No. 6b); and • Concentration Limit Evaluation (UICER Guideline No. 6c).

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PERMIT REQUIREMENTS The WPCF permit requires the City of Portland to protect groundwater quality while operating its public UICs (Schedule B, Section 8.) The permit states that groundwater will be protected from pollution that could impair existing or potential beneficial uses for which the natural water quality of the groundwater is adequate.

DEQ states1 that the overarching goal of the UIC WPCF permit is to protect the highest beneficial use of groundwater, while allowing underground injection of permitted fluids. By preserving the naturally high quality of groundwater, the public’s health, safety and welfare, and the environment are protected during subsurface injection activities. The permit conditions are specifically designed to protect groundwater through managing and monitoring stormwater quality before it is discharged into the subsurface. The permit is intended to:

• Protect groundwater quality while continuing to manage stormwater disposal through UICs. • Support watershed health by maintaining aquifer recharge in urbanized areas. • Demonstrate through a statistically valid discharge monitoring program and reporting requirements that

groundwater quality is maintained while meeting the goals of stormwater management and watershed health.

• Establish rigorous compliance and corrective action protocols, including time constraints, in the event that stormwater discharge quality exceeds the groundwater protection levels established in the permit.

FURTHER EVALUATION FRAMEWORK The guidelines presented below are intended to evaluate and/or demonstrate that stormwater discharged to an individual UIC or group of UICs is protective of groundwater quality. The guidelines are flexible and dynamic in order to address site-specific circumstances. This section describes the actions BES may implement, as necessary and appropriate, to support compliance determinations associated with MADL exceedances, potentially inadequate separation distance, or other permit conditions, corrective actions, or response actions. The guidelines are intended to identify the general process and define the types and quality of data needed to demonstrate groundwater protection and permit compliance. Groundwater protection may be evaluated and/or demonstrated using one or more of the following activities:

1. Fate and transport analyses; 2. Stormwater discharge monitoring; 3. Demonstrating stormwater discharge limits or groundwater compliance limits are protective of human

health and the environment; 4. Implementation of structural stormwater controls to reduce the volume of stormwater discharged to the

UIC (e.g., porous pavement, swales) or reduce pollutant concentrations (e.g., retrofitting the UIC with a filtration system designed to remove the pollutant). Evaluation and/or implementation of structural controls are addressed in the following three documents:

• Corrective Action Plan (City of Portland, 2006); • Structural Controls BMP (see UICMP); and • BMP Monitoring Program (see UICMP).

The intent of this document is to layout a logical, flexible stepwise approach to demonstrate that groundwater quality is protected as a drinking water resource (i.e., not adversely impacted by stormwater discharges to UICs). The following paragraphs provide a brief description of the primary strategies that may be used to demonstrate groundwater protection. Guidelines Nos. 6a through 6c provide addition detail.

1 “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit number: 102830,

by DEQ, dated June 1, 2005.

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Fate and Transport Analyses (UICER Guideline 6a) BES may evaluate the fate and transport of a given stormwater pollutant, if determined to be necessary and appropriate, to:

• Provide technical data to demonstrate groundwater is protected and support site-specific decisions or modifications to the permit or UIC Management Plan (UICMP), as necessary and appropriate, to:

o Decrease required separation distance between the UIC and seasonal high groundwater. o Increase maximum allowable discharge limits (MADL) for pollutants specified in the permit. o Develop MADLs for pollutants not currently included in the permit.

• Evaluate whether a stormwater pollutant entering an individual UIC or group of UICs may impact groundwater at concentrations above those considered protective of human health and the environment.

• Evaluate whether a potential groundwater well user(s) (e.g., domestic, irrigation, public supply) may be exposed to stormwater pollutants at concentrations above those considered protective of human health and the environment.

• Demonstrate groundwater is protected and if appropriate that no further action is warranted.

Additional Stormwater Monitoring (UICER Guideline 6b) In addition to the stormwater monitoring conducted under the Stormwater Discharge Monitoring Plan (SDMP; City of Portland, 2006), additional data may be collected to facilitate interpretation (e.g., assess data gaps, data trends, annual mean concentrations) or address data gaps. Additional stormwater monitoring may be performed at the discretion of BES as described in UICER Guideline 6b. This data may be used to:

• Demonstrate whether or not stormwater discharges at an individual UIC or group of UICs meet the water quality limits defined in the permit;

• Characterize concentrations of a pollutant(s) in stormwater entering a UIC; or

• Demonstrate that the UIC discharges are not impacting groundwater at concentrations of concern.

Concentration Limit Evaluation (UICER Guideline 6c)

This guideline can be used to evaluate a single UIC or multiple UICs within a specified area that exceed a MADL or groundwater compliance limit for a specific pollutant. BES may perform a Concentration Limit Evaluation, if determined necessary and appropriate, to:

• Provide technical data to demonstrate groundwater is protected and support site-specific decisions or modifications to the permit or UIC Management Plan (UICMP), as necessary and appropriate, to:

o Increase maximum allowable discharge limits (MADL) for pollutants specified in the permit. o Develop MADLs for pollutants not currently included in the permit.

• Evaluate whether a stormwater pollutant entering an individual UIC or group of UICs may impact groundwater at concentrations above levels considered protective of groundwater quality for current or future beneficial uses including drinking water (see OAR 340-044).

• Evaluate whether a potential groundwater well user(s) (e.g., domestic, irrigation, public supply) may be exposed to stormwater pollutants at concentrations exceeding the groundwater quality protection requirements specified in OAR 340-040.

• Demonstrate that either a corrective action or response action meets the groundwater quality protection requirements specified in OAR 340-040.

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Page 1 of 8 UICER Guideline No. 6a


UIC Evaluation and Response Guideline No. 6a

Fate and Transport Analysis

PURPOSE This City of Portland Bureau of Environmental Services (BES) Underground Injection Control (UIC) Evaluation and Response (UICER) guideline provides the basic process that will be followed to analyze the fate and transport of a stormwater pollutant discharging to an individual public UIC system (i.e., injection point; injection well) or group of UICs that are constructed and operated in compliance with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). This procedure provides tools for evaluating the potential adverse impacts to groundwater quality associated with the discharge of pollutants in stormwater to public UICs. This guideline may also be used to demonstrate that discharges to UICs do not adversely impact beneficial uses of groundwater and that DEQ-approved discharge limits are protective of public health and the environment as required by Oregon Administrative Rules (OAR) 340-040. APPLYING THE GUIDELINE This guideline may be used by BES to evaluate the fate and transport of a pollutant(s) in stormwater discharged to an individual UIC or group of UICs, if determined to be necessary and appropriate, in order to:

• Provide technical data to support site-specific decisions or modifications to the permit or UIC Management Plan (UICMP), as necessary and appropriate, to:

o Decrease required separation distance between the UIC and seasonal high groundwater. o Increase maximum allowable discharge limits (MADL) for pollutants specified in the permit. o Develop MADLs for pollutants not currently included in the permit.

• Evaluate whether a stormwater pollutant entering an individual UIC or group of UICs may impact groundwater at concentrations above those considered protective of human health and the environment.

• Evaluate whether a potential groundwater well user(s) (e.g., domestic, irrigation, public supply) may be exposed to stormwater pollutants at concentrations above those considered protective of human health and the environment.

• Demonstrate groundwater is protected and if appropriate that no further action is warranted. .

This guideline is may be used to support the application UICER Guideline No. 6c addressing evaluation, development, or modification of allowable stormwater pollutant concentration limits (i.e., MADLs or groundwater compliance limits defined in the permit.

FURTHER EVALUATION FRAMEWORK Steps 1 through 4, below, describe the general framework that may be followed to evaluate the fate and transport of stormwater pollutants discharged to City-owned UICs. This information will be used specifically to determine whether discharge limits of pollutants to an individual UIC or group of UICs are protective of groundwater quality as defined in OAR 340-040. The sequence presented below is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps (e.g., reduce staff time and to streamline the schedule). The actual steps

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performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs.

The steps described below are intended to clearly define the types and quality of data needed to evaluate potential groundwater impacts and/or demonstrate that the discharge of stormwater into the subsurface though City-owned UICs meets OAR 340-040 for groundwater protection.

This guide presents a stepped or phased fate and transport methodology that uses the appropriate level of analysis for meeting the objective of the specific application. If fate and transport analysis does not demonstrate groundwater is adequately protected, this guideline directs the user to alternate guidelines, BMPs, or corrective action that may be implemented by the City as needed and appropriate.

Prior to initiating this guideline, the specific data quality objectives (DQO) should be identified following the general process described in Appendix H of the UICMP. Step 1: Perform a Simple Dilution Effects Calculation DEQ’s June 1, 2005 Fact Sheet1 (see Fact Sheet Section 4.3.5.3) provides a simple dilution calculation to estimate the theoretical groundwater concentration due to the discharge of pollutants in stormwater directly into groundwater (i.e., UIC is constructed in groundwater). Based on DEQ’s calculation, the following equation was derived:

GWest = Csw / AV Where GWest = Estimated Groundwater Concentration (milligrams per litter (mg/L))

due to aquifer dilution Csw = Stormwater Pollutant Concentration (mg/L) discharged to UIC AV = Unit Aquifer Volume (L)

DEQ estimated a value of about 4.5 liters for the unit aquifer volume. A theoretical groundwater concentration at the UIC location can be estimated using the above formula and unit aquifer volume. This calculation is conservative in that it assumes the following:

• Pollutant is directly discharged into groundwater; • Pollutant has a constant discharge at a constant, set concentration; and • Equation does not account for natural attenuation (e.g., dilution, sorption, degradation) that would be

expected in the soil column between the bottom of the UIC and the seasonal high groundwater (i.e., separation distance) or within the aquifer.

The permit requires that the soil column be a minimum of 10 feet for UICs greater than 5 feet in depth and a minimum of 5 feet for UICs with a total depth of less than 5 feet. As noted in DEQ’s Fact Sheet (see Fact Sheet Section 4.3.5.2), unsaturated near-surface soil and deeper sediments are an “…integral part of stormwater treatment before the discharged fluids reaches groundwater.”

1 “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit

number: 102830, by DEQ, dated June 1, 2005.

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The following steps should be performed, as necessary and appropriate, using site-specific information: Step 1a: Calculate the estimated groundwater concentration, using the equation above, for each pollutant

exceeding its respective MADL (or other applicable standards established in OAR 340-040). The calculation should be performed using available stormwater discharge monitoring data (e.g., annual mean and individual stormwater discharge concentrations) for the subject UIC(s).

If the estimated groundwater concentration(s) is less than 2 times the MADL, no adverse impact to groundwater is assumed, proceed to Step 1c. If the annual mean concentration results in an estimated groundwater concentration greater than or equal to the MADL, or other approved regulatory level, proceed to Step 1b.

Step 1b: If the estimated groundwater concentration calculated using the annual mean stormwater concentration is

less than or equal to the MADL concentration proceed to one or more of the following, as needed and appropriate: • Fate and Transport Analysis – Step 2; • Additional Stormwater Monitoring (UICER No. 6b); • Concentration Limit Evaluation (UICER No. 6c); • Response Actions (UICER No. 8); or • Corrective Actions (Corrective Action Plan; City of Portland, 2006).

Step 1c: The results of the dilution effect analysis should be documented and submitted to DEQ for approval if the

results indicate no further action is warranted. The documentation should include, as appropriate, a discussion of the uncertainties associated with the estimated groundwater concentration and consideration of whether additional stormwater discharge monitoring is needed to verify that the pollutant concentration remains below a level of concern.

Step 2: Perform Fate and Transport Analysis Using a One-Dimensional Contaminant Transport

Calculation For UICs where the results of Step 1 indicate that a pollutant may exceed appropriate regulatory levels in groundwater (e.g., MADLs or other standards established in OAR 340-040), a more complex evaluation of fate and transport may be performed. Fate and transport analyses can be very complex. Prior to moving forward with expensive, complex fate and transport modeling, a simple one-dimensional calculation for contaminant transport in groundwater is recommended. The purpose of this step is to assess whether or not the estimated groundwater concentration will exceed the applicable MADL concentration within 2 years at a distance of 100 feet downgradient from the subject UIC. This approach is conservative since it does not account for site-specific conditions (e.g., separation distance). Key assumptions in estimating the groundwater concentration include:

• The pollutant is directly discharged into groundwater. • The pollutant is discharged to the UIC at a constant concentration. • Natural attenuation (e.g., dilution, sorption, degradation) does not occur, as would be expected in the soil

column between the bottom of the UIC and the seasonal high groundwater (i.e., separation distance) or within the aquifer.

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• The water-bearing zone into which the UIC stormwater discharges, is assumed to have isotropic and homogeneous physical and chemical characteristics.

Solute transport is governed by two equations. First, groundwater velocity is estimated using Darcy’s equation, which predicts groundwater flow in one dimension (x):

Vx = (K/ne)i Where Vx = downgradient velocity in ft/day

K = hydraulic conductivity in ft/day ne = effective porosity i = groundwater gradient (ft/ft)

Second, a simplified solute (i.e., pollutant) transport equation is used to estimate the concentration in groundwater. The equation, which governs the transport of a solute, is:

C/C0 = 0.5 [erfc{(L-Vxt)/(2(Lt)½}] Where C= concentration of constituent at time t (mg/L)

C0 = concentration of constituent at time to (mg/L) L =distance from well (ft) Vx = downgradient velocity in ft/day t = time (days) erfc = complimentary error function

These equations only take into account advection (i.e., movement with groundwater) and dispersion (i.e., hydrodynamic dispersion, mixing, spreading). These equations are believed to be appropriate for a simple estimation, because the effects of dispersion are much greater than those of diffusion (i.e., concentration gradient). It should be noted, that there are other processes occurring in the subsurface that affect the fate and transport of pollutants and other variables controlling the input of pollutants into the system. Consideration of these processes or variables requires the use of more complex contaminant transport models (See Step 3).

Step 2a: Calculate the estimated groundwater concentration, using the two-step equation above, for each pollutant exceeding its respective MADL (or other applicable standards established in OAR 340-040). Calculation should be performed using available hydrogeologic data and stormwater discharge monitoring data (e.g., annual mean and individual stormwater discharge concentrations) for the subject UIC(s).

If the estimated groundwater concentration(s) is less than the MADL (or other applicable standard established in OAR 340-040) at a distance of 100 feet from the subject UIC after 2 years of discharge, no adverse impact to the groundwater is assumed. Proceed to Step 2b.

If the estimated groundwater concentration(s) indicates that groundwater quality exceeds the MADL (or other applicable standard established in OAR 340-040) after 2 years of constant discharge and at a distance of 100 feet from the UIC, then proceed to one or more of the following, as needed and appropriate:

• Additional Fate and Transport Analysis – Step 3; • Additional Stormwater Monitoring (UICER No. 6b); • Concentration Limit Evaluation (UICER No. 6c); • Response Actions (UICER No. 8);

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• Corrective Actions (CAP); and • Permit or UICMP modifications.

Step 2b: If the results of Step 2a, indicate no further action is warranted, the findings will be submitted to DEQ for

review and approval. If the results indicate additional evaluation (i.e., Steps 3 or 4) is necessary, DEQ will be notified and a discussion of the next steps initiated. The results of the one-dimensional contaminant transport analysis will be documented. The documentation should include, as appropriate, a discussion of the uncertainties associated with the estimated groundwater concentration and consideration of whether additional stormwater discharge monitoring is needed to verify that the pollutant concentration remains below a level of concern.

Step 3: Additional Fate and Transport Processes (Modeled) For UICs where the results of Step 2 indicate that groundwater quality may have been adversely impacted by stormwater discharges into UICs at levels exceeding applicable MADLs (or other standards established in OAR 340-040), a more complex evaluation of fate and transport may be performed, as necessary and appropriate, that may include:

• Consideration of chemical and physical processes within the vadose zone (i.e., unsaturated soil between the bottom of the UIC and seasonal high groundwater) using equilibrium partitioning. Equilibrium partitioning describes the distribution of pollutant mass between solid and fluid portions of the medium (e.g., soil, air, water) as a result of sorption, solubility, and chemical reactions; and

• Biodegradation of constituents by indigenous microorganisms along the migration pathway. There are many tools that can be used to assist in the fate and transport analysis from very simple analytical tools to complex numerical models. Prior to performing a complex numerical model the following tasks should be performed:

• Develop a conceptual site model (CSM) that includes, but is not limited to, simple descriptions of the following:

o Stormwater pollutant concentrations (e.g., individual event, mean, range); o Stormwater discharge (flow); o UIC System (e.g., separation distance, catchment basin); o Hydrogeology;

Geologic units; Hydrogeologic units & characteristics; and Groundwater flow direction.

o Pollutant physical and chemical properties; and o Identification of potential receptors (e.g., domestic or public water wells, surface water features).

• Data quality analysis objectives (see Appendix H of the UICMP). Development of the CSM and modeling objectives will aid in identifying data gaps and assist in determining the level of effort that should be applied. Several commercial (e.g., SOLUTE, and VADSAT) or U.S. EPA models (e.g., BIOSCREEN, BIOCHLOR) are available for contaminant transport modeling. These readily available models are typically easy to use and may be used to evaluate the potential fate and transport of stormwater pollutants discharged to City-owned UICs. These models may be used to determine if the discharge concentrations are protective of groundwater or at what distance downgradient from the UIC the protective concentration (e.g., MADL, Maximum Contaminant Level (MCL) for municipal drinking water, or groundwater compliance level) is reached under steady-state groundwater flow conditions.

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Model input parameters can be defined using site-specific data or literature values typical of the pollutant and geologic media (often conservative default parameters are used for risk screening or as a simplified tool). Default parameters can be selected in such a manner to render the solution conservative. Typical input data needed for groundwater transport modeling includes:

• Target groundwater concentrations; • Source concentration; • Aquifer hydraulic properties; • Hydraulic gradient; • Aquifer geometry; • Recharge; • Soil physical parameters; • Source geometry (or concentration); • Dispersivity; • Receptor distance; • Chemical properties; and • Time (since release or if ongoing since release began).

Step 3a: The purpose of this step is to assess, using readily available fate and transport models, whether or not the

estimated groundwater concentration in the vicinity of the subject UIC will exceed the applicable MADL concentration (or other standards established in OAR 340-040), within 2 years at a distance of 100 feet downgradient of the subject UIC. This modeling effort may include conservative assumptions regarding potential natural attenuation, equilibrium partitioning, or biodegradation as appropriate. If the estimated groundwater concentration(s) is less than the MADL (or other applicable standard established in OAR 340-040) at a distance of 100 feet from the subject UIC after 2 years of constant discharge, no adverse impact to the groundwater is assumed. Proceed to Step 3c or reevaluate using more realistic assumptions (e.g., variable discharge concentration, variable discharge frequency). If the estimated groundwater concentration(s) indicates that groundwater quality exceeds the MADL (or other applicable standard established in OAR 340-040) after 2 years of constant stormwater discharge at a distance of 100 feet from the UIC, DEQ will be notified and a discussion of the next steps initiated. One or more of the following actions may be implemented, as needed and appropriate:

• Additional Fate and Transport Analysis – see Step 4; • Additional Stormwater Monitoring (UICER No. 6b); • Concentration Limit Evaluation (UICER No. 6c); • Corrective Actions (CAP); • Groundwater monitoring2, as determined necessary by the City of Portland, to verify whether or not

the fate and transport analysis correctly predict pollutant behavior in the subsurface and to provide data to support recommendations for permit or UICMP modifications; or

• Permit or UICMP modifications.

2 Groundwater monitoring is specifically not required under the permit as long as stormwater discharges meet the MADLs established in

the permit. In the event, groundwater monitoring is initiated the City will develop a Groundwater Monitoring Plan for DEQ review and approval as required by the permit.

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Step 3b: If the results of Step 3a, indicate no further action is warranted, the findings will be submitted to DEQ for review and approval. The results of the refined contaminant fate and transport analysis will be documented. The documentation should include, as appropriate, a discussion of the uncertainties associated with the estimated groundwater concentration and consideration of whether additional stormwater discharge monitoring is needed to verify that the pollutant concentration remains below a level of concern.

Step 4: Three-Dimensional Fate and Transport Modeling In the event Step 3 indicates that stormwater pollutants discharged to City-owned UICs adversely impact groundwater quality, more advanced complex tools can be used to more accurately evaluate pollutant fate and transport in the subsurface. These models may include 3-dimensional groundwater fate and transport models, vadose zone models, or coupled groundwater and vadose zone models. At this time, it is not anticipated that these complex models will be necessary. A decision to proceed with complex fate and transport modeling will be based on an updated CSM and the objectives of the modeling. If the modeling results are anticipated to be used for permit modification(s) or groundwater protectiveness demonstration, then BES will provide DEQ with a work plan describing the modeling objectives, modeling approach, selected input parameters, sensitivity analysis, and evaluation of the modeling results.

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Page 1 of 4 UICER Guideline No. 6b


UIC Evaluation and Response Guideline No. 6b

Additional Stormwater Monitoring PURPOSE This City of Portland Bureau of Environmental Services (BES) Underground Injection Control (UIC) Evaluation and Response (UICER) guideline provides the basic process that will be followed to determine if additional stormwater monitoring should be performed and, if so, how the additional data will be interpreted to ensure that an individual City-owned UIC system (i.e., injection point; injection well) or group of UICs are operated in compliance with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). The main objective of this guideline is to outline conditions where additional stormwater monitoring data may be needed to facilitate data interpretation, address stormwater data gaps, or demonstrate groundwater protection. This guideline presents the approach that may be used in conducting, interpreting, and documenting the additional monitoring. UICER Guideline No. 5 addresses additional stormwater monitoring that may be needed to identify pollutant sources and confirm the contribution of pollutants to City-owned UICs from an identified source. APPLYING THE GUIDELINE This guideline may be used by the City to develop the data quality objectives (DQOs), scope, and sampling and analyses plan for additional stormwater monitoring, if determined to be necessary and appropriate, in order to:

• Enhance the required Stormwater Discharge Monitoring Plan (SDMP; City of Portland, 2006) to address data gaps or to enhance data interpretation (e.g., trend or correlation analysis).

• Evaluate or verify the effectiveness of a response action, corrective action, or best management practice (BMP).

• Demonstrate whether or not stormwater discharges at an individual UIC or group of UICs meet the maximum allowable discharge limits (MADLs) defined in the permit or other applicable standards established in OAR 340-040.

• Support BES recommendations to modify the permit or the UIC Management Plan (UICMP; City of Portland, 2006) (e.g., modify the discharge limits, point of compliance, list of common pollutants).

The City is currently monitoring the quality of stormwater discharged to a representative group of UICs as described in the SDMP. However, as data is generated from the stormwater monitoring program, UIC decommissioning activities, BMP monitoring, and from system inventory and assessment activities, it is anticipated that data gaps will be identified. The following hypothetical situations are examples that may be encountered over the course of the permit, where the City may determine that additional stormwater monitoring is needed to ensure permit compliance and groundwater protection:

• A MADL has been exceeded, and a demonstration has been made through fate and transport analysis that the exceedance does not constitute a threat to groundwater. Additional stormwater monitoring may be needed to ensure that pollutant concentrations do not increase above levels protective of groundwater.

• Stormwater compliance monitoring data indicate an upward trend in pollutant concentration(s) at an individual UIC or group of UICs within a specified area. Additional stormwater data may be needed to ensure pollutant concentrations are protective of groundwater or to determine if the UIC is compliant with the permit.

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• Anomalous pollutant concentrations are detected in a UIC. Focused stormwater monitoring may assist the City in identifying and controlling pollutant sources.

• The City may elect to conduct additional UIC sampling at its discretion to address other data needs or requirements.

Stormwater sampling, in addition to the annual monitoring required as part of the UIC WPCF permit (see SDMP), may also occur as a part of:

• MADL Exceedances (UICER Guideline No. 2); • Source Specific Investigation (UICER Guideline No. 5); • Fate and Transport Analysis (UICER Guideline No. 6a); • Concentration Limit Evaluation (UICER Guideline No. 6c); • Response Action monitoring (UICER Guideline No. 7); • Corrective action effectiveness or verification monitoring (Corrective Action Plan (CAP); City of

Portland, 2006); or • BMP Monitoring Program (UICMP Section 4).

FURTHER EVALUATION FRAMEWORK This section describes the steps BES may follow, as necessary and appropriate, to evaluate whether additional stormwater monitoring should be performed, how stormwater monitoring should be conducted, and how the results might be used. The additional data may be used to determine whether stormwater discharge(s) to an individual UIC or group of UICs are protective of groundwater quality as defined in Oregon Administrative Rules (OAR) 340-040. The sequence presented below is intended to be flexible and dynamic to address issue-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps. The actual steps performed and sequencing of the steps will be determined based on issue-specific facts regarding each UIC or group of UICs. The steps described below are intended to clearly define the types and quality of data that may be needed to identify data trends, address data gaps, evaluate potential groundwater impacts and/or demonstrate that the discharge of stormwater into the subsurface though City-owned UICs meets OAR 340-040 for groundwater protection as a drinking water resource. Step 1: Determine If Additional Stormwater Monitoring is Necessary The need for additional monitoring will be determined on a issue-specific, fact specific basis. In general, the decision will be based on the results of the following steps:

A. Define the data gap (e.g., unknown source, unknown pollutant trend, UIC MADL compliance).

B. Identify the primary need for addressing the data gap (e.g., permit requirement, supplemental information).

C. Develop issue-specific DQOs for the additional monitoring following the general process described in UICMP.

D. Determine the type, quality, and quantity of data needed to meet the DQO(s).

E. Estimate the level of effort (e.g., staff time, laboratory costs, evaluation costs) for additional monitoring.

F. Assess if the need for data justifies the level of effort.

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G. If the estimated level of effort is justified by the need for the data (e.g., regulatory compliance, source identification) or if the data is required by DEQ, go to Step 2.

H. If the data is not required or if the costs of the additional monitoring are not justified by the planned data uses, go to one or more of the applicable UICER Guidelines, or return to the UICMP System Monitoring or System Management program elements.

EPA’s DQO Process1 may be used in planning so that UIC monitoring and resulting decisions are well documented, logical, and defensible. The DQO process allows for selecting the most resource-effective monitoring and assists in determining how much sampling is required to meet the specified objectives. For instance, additional monitoring to verify an anomalous detection will be less than to determine a concentration trend. DQOs should provide clear direction on the following: when to stop additional monitoring; what decisions may be made based on the additional monitoring data; and what additional data or steps may be needed. Step 2: Develop an Abbreviated Work Plan for the Additional Monitoring If it is determined in Step 1 that additional stormwater monitoring is appropriate or necessary, a brief work plan should be prepared for City field staff and the analytical laboratory(s) that includes the following information to the extent necessary and appropriate:

A. The specific objective(s) of the additional monitoring;

B. Number and location of sampling locations;

C. The planned frequency (e.g., events per year) and conditions (e.g., storm size and duration) under which the samples will be collected;

D. List of pollutants that will be analyzed;

E. Analytical methods and method reporting limits for the monitoring;

F. Sampling procedures/protocols (e.g., sampling methods, sample handling, holding times, preservation);

G. Data quality assurance/quality control needed for the specific investigation;

H. Data evaluation methods; and

I. Data reporting.

To the extent feasible and practical, additional stormwater monitoring will be performed in accordance with the final SDMP. Step 3: Implement Stormwater Monitoring Stormwater data will be collected according to the procedures specified in the work plan, and evaluated according to methods prescribed in the SDMP, as appropriate. The DQO process will facilitate making decisions based on the stormwater monitoring data. Step 4: Identify Next Steps Based on the objectives of the additional stormwater monitoring results, a decision will be made to determine if continued or additional monitoring is needed, using the general process described in Step 1. In addition, one or more of the following actions may be implemented, as needed and appropriate:

1 The DQO process involves the following steps: state the problem, identify the decision, identify inputs to resolve the

decision, define boundaries, develop a decision rule to integrate the outputs from the previous steps into a single statement that describes the basis for choosing among alternative choices, specify limits on decision errors, and optimize the design. See Appendix H of the UICMP for additional information.

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• Fate and Transport Analysis (UICER Guideline No. 6a);

• Concentration Limit Evaluation (UICER Guideline No. 6c);

• Response Actions (UICER Guideline No. 7);

• Corrective Actions (CAP);

• Permit or UICMP modifications; or

• Refer identified pollutant sources to DEQ for further evaluation or source control action.

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Page 1 of 6 UICER Guideline No. 6c


UIC Evaluation and Response Guideline No. 6c

Concentration Limit Evaluation

PURPOSE This City of Portland Bureau of Environmental Services (BES) Underground Injection Control (UIC) Evaluation and Response (UICER) guideline provides the basic process that may be followed to evaluate, develop, or modify the maximum allowable discharge limits (MADLs) for stormwater discharges to a City-owned or group of UICs, constructed and operated in compliance with the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830). MADLs are defined as being protective of human health and the environment. This guidance may also be used to evaluate, develop, or modify the groundwater compliance limits set in Table 1 of the WPCF permit; or to develop a “concentration limit variance (CLV).” A CLV is defined as the maximum acceptable concentration of a pollutant allowed in groundwater at a DEQ specified compliance point1 by Oregon Administrative Rules (OAR) 340-40. The permit allows the City to evaluate or demonstrate whether groundwater quality is protected (as defined by OAR 340-40 through corrective action, “risk assessment”, or other groundwater protection demonstration. The term “risk assessment” as used in the permit, and as referenced in the UIC Management Plan (UICMP; City of Portland 2006) and this guideline, is broadly defined, multifaceted, and may involve one or more of the following activities:

• Pollutant fate and transport analyses; • Additional stormwater discharge monitoring to identify pollutant sources or facilitate data interpretation;

and • Evaluation/modification of permit concentration limits or groundwater compliance limits to assure

protection of human health and the environment. The specific purpose of this guideline is to describe the general steps the City may follow to evaluate allowable stormwater discharge concentration limits defined in the permit. This evaluation may be used to develop or modify concentration limits, if necessary and appropriate, and to evaluate and/or demonstrate whether stormwater discharges to City-owned UICs meet the groundwater quality protection requirements for public health and the environment specified in OAR 340-040. APPLYING THIS GUIDELINE This guideline provides a general overview of the process that may be used to assess or demonstrate whether stormwater discharges to UICs adversely impact the beneficial uses of groundwater or if they are protective of human health and the environment. Application of this guideline is anticipated to evaluate stormwater discharge concentration limits in the event that stormwater discharges to one or more City-owned UICs exceeds the MADLs defined in Table 1 of the permit. This concentration limit evaluation may then be used to determine if an alternative stormwater limit would be protective of groundwater and meet the requirements of OAR-340-040. Such an evaluation may also be performed if it is determined that a pollutant is ubiquitous in the environment and not feasibly, practicably, or cost effectively controlled (see OAR 340-0040 and –0050).

1 A compliance point is defined in OAR 340-040-0010 as “…the point or points where groundwater quality parameters must be at or

below the permit-specific concentration limit or the concentration limit variance.”

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This guideline can be used to evaluate a single UIC or multiple UICs within a specified area that exceed a MADL for specific pollutant. BES may perform a Concentration Limit Evaluation, if determined necessary and appropriate, to:

• Provide technical data to demonstrate groundwater protection and support site-specific decisions or modifications to the permit or UIC Management Plan (UICMP), including:

o Increase maximum allowable discharge limits (MADL) for pollutants specified in the permit. o Develop stormwater MADLs for pollutants not currently included in the permit. o Modify groundwater compliance limits set in Table 1 of the WPCF permit (i.e., CLVs). o Develop a groundwater CLV(s) for pollutants not currently included in the permit, or in OAR

340-040.

• Evaluate whether a stormwater pollutant entering an individual UIC or group of UICs may impact groundwater at concentrations above levels considered protective of groundwater quality for current or future beneficial uses including drinking water (see OAR 340-040).

• Evaluate whether a potential groundwater well user(s) (e.g., domestic, irrigation, public supply) may be exposed to stormwater pollutants at concentrations exceeding the groundwater quality protection requirements specified in OAR 340-040.

• Demonstrate that either a corrective action or response action meets the groundwater quality protection requirements specified in OAR 340-040.

This guideline may be used to support the application of UICER Guideline No. 6a, which addresses the subsurface fate and transport of stormwater pollutants discharged to a UIC. The Concentration Limit Evaluation is not expected to be performed prior to implementing other applicable evaluation guidelines and response actions (see Section 5 of the UICMP). PERMIT REQUIREMENTS Evaluation/modification of the permit concentration limits or groundwater compliance limits are included in OAR 340-040-0030 that addresses Concentration Limit Variances. This section of the rule states “…The EQC or Director, as specified in subsection (4)(b) of this rule, may grant on a case-by-case determination a concentration limit variance for a pollutant provided no substantial present or potential hazard to human health or the environment is posed at that level. The party requesting the concentration limit variance shall provide all data required for consideration of the variance, and shall identify where gaps exist in the data for the required analysis. In establishing concentration limit variances, the EQC or Director shall consider the effects on groundwater quality, interconnected surface water quality, and associated effects on beneficial uses….” Specifically, OAR 340-040-0030(4)(c) identifies the factors that should be considered when evaluating concentration limits. These factors are summarized below and include, but are not limited to:

• Physical and chemical characteristics of the pollutant; • Pollutant fate and transport; • Hydrogeologic characteristics at the facility and the surrounding area; • The proximity and withdrawal rates of nearby groundwater users; • The current and future uses of groundwater in the area; • Potential for health risks caused by exposure to the pollutant and its degradation products; • Persistence and permanence of potential adverse effects of the contaminant and its degradation products; • Proximity and interconnections with surface water in the area;

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• Potential effect of the pollutant and its degradation products on ecosystems of the area; and • Comparative feasibility and cost of obtaining the permit-specific concentration limit and the concentration

limit variance. Groundwater compliance concentrations in Table 1 the WPCF permit are typically set at “background” levels and generally, represent CLVs. With the exception of lead (Pb), the CLVs are the federal MCLs for municipal drinking water. The groundwater compliance limits set in the permit may be modified following the process defined in OAR 340-040-0030(4). CLV modifications are subject to public review and comment and DEQ approval. Protective groundwater and stormwater concentration limits may be evaluated, estimated, or developed using standard equations and assumptions included in applicable U.S. Environmental Protection Agency (EPA) or DEQ guidance2 documents. Stormwater discharge limits can be estimated from protective groundwater concentrations using fate and transport analyses and back calculating concentrations using standard risk assessment equations. FURTHER EVALUATION FRAMEWORK This section describes the specific steps the City may follow, as necessary and appropriate, to evaluate permit concentration limits (e.g., MADLs and groundwater compliance limits) and to evaluate whether they are protective of human health, the environment, and groundwater quality as defined in OAR 340-040. The steps are intended to clearly define the types and quality of data needed to complete this evaluation. Steps 1 and 2 below describe the general framework that may be followed to evaluate regulatory concentration limits or stormwater or groundwater. The sequence presented is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps. The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs. This guideline presents a stepped or phased approach that uses the appropriate level of analysis for meeting the objective of a specific application. If the Concentration Limit Evaluation does not demonstrate groundwater is adequately protected, this guideline directs the user to other evaluation guidelines or to corrective action, as needed and appropriate.

Step 1: Problem Formulation The first step in performing a Concentration Limit Evaluation is to define the problem that will be addressed (e.g., MADL development, MADL modification, groundwater CLV development), or to more specifically define the appropriate type of investigation and/or analysis to be performed for a given UIC or UIC issue. During problem formulation, available information will be compiled to perform the following steps:

2 Guidance for Conduct of Deterministic Human Health Risk Assessments. Waste Management and Cleanup Division, Oregon

Department of Environmental Quality. December 1998.

Guidance for Ecological Risk Assessment. Waste Management and Cleanup Division, Oregon Department of Environmental Quality. March 2000.

Risk Assessment Guidance for Superfund - Volume 1 Human Health Evaluation Manual (Part A). US Environmental Protection Agency. Office of Solid Waste and Emergency Response. EPA/540/1-89/002. December 1989.

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Step 1a - Identify Data Quality Objectives.

Prior to initiating the Concentration Limit Evaluation, it is recommended that specific data quality objectives (DQO) be identified following the general process described in Appendix H of the UICMP. The Concentration Limit Evaluation should be performed in general accordance with applicable DEQ and EPA guidance1 addressing developing objectives, conceptual site models (CSM), and defining potential pollutant migration pathways. The DQO process will ensure that all data collected or used in support of the Concentration Limit Evaluation are of known and documented quality and have been collected at locations and in media that are pertinent to the evaluation.

Step 1b - Develop a Conceptual Site Model.

A CSM of the subject UIC(s) should be developed to describe the following, as necessary and appropriate:

A. Physical setting (e.g., soil, geology, hydrogeology, separation distance, topography, hydrology; climate);

B. Stormwater pollutant concentrations (individual event, mean, range) (see UICER Guideline No. 2);

C. Pollutant chemical and physical properties (see Prioritization Procedure, Tables 1 and 2);

D. Pollutant sources (see UICER Guidelines No. 4 and 5);

E. Fate and transport analyses (see UICER Guideline No. 6a);

F. Pollutant exposure pathways; and

G. Potential receptors (e.g., human, ecological).

Step 1c - Define Present and Future Uses of Groundwater

OAR 340-044 states ”…injection of wastes to the subsurface shall be limited and controlled in a manner that protects existing groundwater quality for current or potential beneficial uses including use as an underground source of drinking water.” However, in accordance with OAR 340-030 the current and future uses of groundwater will be defined, as necessary and appropriate. The groundwater beneficial use determination will be made following the applicable procedures described in DEQ’s Guidance for Beneficial Use Determinations at Environmental Cleanup Sites (DEQ, 1998a).

Step 1d - Identify Pollutant(s) of Interest

Typically, pollutant concentrations are screened against known protective standards to identify the pollutants to be evaluated. However, for evaluation of concentration limits associated with UICs, the pollutant(s) of potential concern will primarily be defined, based on observed exceedance(s) of applicable MADLs. In addition, pollutants may be identified through fate and transport analyses, additional stormwater monitoring, or source monitoring.

Step 2: Evaluation During the Concentration Limit Evaluation, available information and the results of Step 1 will be used, as necessary and applicable to perform the following steps:

Step 2a - Evaluate Potential Pollutant Exposure Pathways

In this step, the potential pathways, defined in the CSM, will be evaluated to determine if a potentially complete pathway exists to human or ecological receptors. Oregon risk assessment guidance allows development of site-specific risk scenarios. Such site-specific scenarios allow consideration of unique site

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conditions, thus providing a more reasonable and representative estimate of potential adverse impacts to groundwater.

Step 2b - Develop Protective Stormwater and Groundwater Concentration Limits In this step, the concentrations of pollutants in stormwater at the point of discharge will be developed that meet OAR 340-040 requirements to protect groundwater quality or groundwater compliance concentration limits will be developed in accordance with OAR 340-040. Protective concentrations of stormwater pollutants discharged to the subsurface may be estimated for selected complete and applicable pathways. These estimates would consider various chemical and physical processes controlling the migration of pollutants between the point of discharge (i.e., end of pipe) and the groundwater surface3. These estimates may address a range of environmental conditions and parameters to assess the potential uncertainty and sensitivity of the evaluation. The range of estimated protective stormwater concentrations may be used to:

• Develop, modify, and/or confirm stormwater concentration limits (i.e., MADLS) at the point of discharge that meet OAR 340-040;

• Develop, modify, and/or confirm groundwater compliance limits (i.e., CLVs) protective of groundwater users; and

• Develop recommendations for groundwater compliance point distances, based on the CLV evaluation.

• Develop technical data to demonstrate groundwater protection and support recommendations for site-specific decisions or permit modifications.

This step may also be used to reevaluate stormwater or groundwater concentrations limits using new or revised toxicity information for the pollutant of interest, or to evaluate new or revised exposure parameters for the pathway of interest. This information may also be used to qualitatively or quantitatively describe the uncertainty associated with the concentration limit(s).

Step 3 - Next Steps

The results of Step 2 will include technical data and recommendations regarding the need for revision of either the concentration limits set in permit for stormwater or groundwater, such as:

• If the estimated concentration limit (stormwater or groundwater) is greater than the permit limit, the City may propose a permit modification (i.e., concentration limit variance) or continue routine operation, maintenance, and monitoring, as applicable and appropriate, in accordance with the UICMP.

• If the estimated concentration limit is less than the permit limit, then one or more of the following actions may be implemented, as needed and appropriate: o Fate and Transport Analyses (UICER Guideline No. 6c); o Corrective action (see Corrective Action Plan; City of Portland, 2006); o Implementation of response actions to reduced pollutant concentrations entering the UIC (UICER

Guideline No. 8); o Prevent the use of groundwater or restrict to non-potable uses;

3 Pollutant fate and transport analyses (see UICER Guideline 6a) may be applied to estimate current or future pollutant concentrations.

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o Groundwater monitoring4, as determined necessary by the City of Portland, to provide data to support recommendations for permit or UICMP modifications; and

o Permit modifications as determined by the City or DEQ.


4 Groundwater monitoring is specifically not required under the permit as long as stormwater discharges meet the MADLs established in

the permit. In the event, groundwater monitoring is initiated the City will develop a Groundwater Monitoring Plan for DEQ review and approval as required by the permit.

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Regional Assessment of Problem PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response (UICER) guideline provides the basic process that will be followed to evaluate whether issues (e.g., potential non-compliance, pollutant types) affecting an individual City-owned Underground Injection Control (UIC) system (i.e., injection point; injection well) may affect other UICs in the vicinity or with similar UIC characteristics (e.g., potential pollutant sources, traffic categories, land use). Specifically, this guideline provides tools for identifying and assessing issues that apply to a group of UICs or to UIC within a geographic area. The primary object is to evaluate or demonstrate whether stormwater discharges to UICs are protective of the highest beneficial uses of groundwater (i.e., drinking water) per OAR 340-040. APPLYING THE GUIDELINE This guideline anticipates evaluation of the following types of issues that may apply to a group of UICs or to UICs within a geographic area. Potential issues include, but are not limited to the following:

• Separation distance; • Maximum allowable discharge limit (MADL) exceedances; • Identified pollutant sources; • Proximity to drinking water wells; and • Ubiquitous pollutants.

This guide may be used to improve the management of UICs to assure groundwater protection, etc., by identifying and implementing changes to the best management practices (BMPs) identified in the UIC Management Plan (UICMP; Section 3.0) or the UIC Operation and Maintenance Plan (UICMP Appendix B). This guideline can be used to develop or evaluate MADLs or groundwater concentration limit variances (CLVs) for ubiquitous pollutants on a regional basis, in conjunction with UICER Guideline No. 6c – Concentration Limit, Evaluation, to provide the technical data to support regional decisions or modifications to the permit or UIC Management Plan (UICMP), as necessary and appropriate. A regional assessment is not anticipated to be performed prior to implementing other evaluation guidelines or response actions (see Section 5 of the UIC Management Plan (UICMP); City of Portland, 2006). PERMIT REQUIREMENTS The permit recognizes and anticipates there may be situations where common problems or issues apply to a number or group of UICs or to UICs within a geographic area. Issues or problems that are large or complex in scope are considered to be “regional.” Corrective actions implemented to address these issues are termed “regional” corrective actions. A regional corrective action is warranted when implementation or completion of the regional corrective action solution cannot be accomplished within three full Capital Improvement Program (CIP) cycles. Regional corrective actions may be addressed by a permit modification under OAR-340-04500055

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or DEQ may issue an Order for a regional corrective action (Schedule C, Section 12(h) and (i)). For a permit modification, the following information must be provided “… for the non-compliant public UICs: i. A description, including map, of the boundary area for the proposed regional corrective action; ii. A discussion of the reason for the regional corrective action; iii. Identification of the public UICs that require a regional corrective action, including:

(1) The number of public UICs requiring corrective action; (2) The Permittee’s public UIC identification number; and (3) The Department’s public UIC identification number for each public UIC.

iv. A feasibility analysis including available technologies for corrective action, cost effectiveness, determination of highest and best practicable methods that protect the resource, public health and the environment;

v. The selected technology or technologies, as appropriate; and vi. An implementation and completion schedule.” In addition, the Oregon Department of Environmental Quality (DEQ1) expects the City to assess exceedances of the MADLs specified in Table 1 of the permit in a broader context. Specifically, DEQ identified a need to look beyond the specific UIC with a MADL exceedance to assess if other UICs “. . .within the vicinity may have similar levels of pollutants and may require sampling.” The permit allows the City to request an increase of the MADL for each pollutant listed in Table 1 of the permit or to develop groundwater CLVs. Any request to increase a permit established MADL must address the following:

• Any increase in the permit established MADL must be based on sound science; and • The proposed increase does not endanger the existing natural groundwater quality, which currently meets

human-health based protectiveness criteria. Under OAR 340-045-0055, any increase in a concentration limit represents a major permit modification because the increase may represent a lower protective level. As required by OAR 340-045-0055, DEQ will review modification requests and hold a public comment period. Upon closure of public comment period, and depending on comments received, DEQ may approve, deny or amend the request, or request additional information based on public testimony. FURTHER EVALUATION FRAMEWORK This section describes the steps BES may follow, as necessary and appropriate, to identify and assess issues that may affect a group of UICs or UICs within a geographic area. This information may be used to support compliance determinations, response actions, or corrective actions. The intent of this guideline is to layout a logical, flexible stepwise approach to ensure groundwater quality protection requirements specified in OAR 340-040 are met.

The sequence presented below is intended to be flexible and dynamic to address site- or issue-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps. The actual steps performed and sequencing of the steps will be determined based on site-specific or issue-specific facts regarding each UIC or group of UICs.

1 “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit

number: 102830, by DEQ, dated June 1, 2005.

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Step 1: Identify Potential Regional Issue Identify the problem or potential non-compliance issue (e.g., MADL exceedance) that has been identified during the System Management (e.g., System Inventory and Assessment Best Management Practice (BMP)) or the System Monitoring program element that may apply to a number of UICs or to UICs within a geographic area (i.e., a one-to-many relationship). This may include, but is not limited to, the following:

• Separation distance; • MADL exceedances; • Identified pollutant sources; • Proximity to drinking water wells; or • Ubiquitous pollutants.

Step 2: Conceptual Site Model Development In order to determine if a problem or non-compliance issue affects a number of UICs, a site-specific understanding of the cause of the problem or issue will likely be needed. By developing an understanding of the “cause and effect” relationship, a conceptual site model (CSM) can be developed to describe the characteristics of the UIC system (e.g., treatment, no treatment), UIC drainage catchment (e.g., land use, traffic category), possible pollutant sources, or environmental setting (e.g., hydrogeology, proximity of pollutant sources) that may be used to predict or identify other UICs that may be affected. Develop a simplified CSM of the subject UIC(s), based on consideration of the following data and information, as necessary and appropriate:

A. Available data and information on the subject UIC catchment(s) including:

a. UIC total depth;

b. UIC location;

c. Local and regional topography (e.g., slope);

d. Proximity to surface water bodies; and

e. Local and regional groundwater information.

B. The CSM should present a conceptual understanding of the UIC system in the vicinity of the subject UIC, as necessary and appropriate. The CSM may include the following:

a. Summary of site geology and hydrogeology (e.g. depth to groundwater, groundwater flow direction);

b. Anticipated surface water hydrology (e.g., description of local stormwater flow and management);

c. Factors that influence stormwater infiltration, groundwater recharge and discharge (e.g., soil types, geologic, surface water bodies); and

d. Identified or suspected stormwater pollutant source(s).

Step 3: Define the Problem and Develop Data Quality Objectives A. Initiate the Data Quality Objectives (DQO) Process2 that EPA recommends for environmental

investigations when data are to be used to make some type of decision (e.g., compliance or non-compliance with a standard) or estimation (e.g., ascertain the mean concentration level of a contaminant). The DQO process is summarized in UICMP Appendix H.

2 “Guidance on Systematic Planning Using the Data Quality Objectives Process” prepared by the US Environmental

Protection Agency. EPA/240/B-06/001. February 2006. EPA QA/G-4.

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B. Identify potential approaches or a plan for investigating the “regional” issue using the DQO process as general guidance. The degree to which the DQO process is used will depend on the nature and complexity of the issue.

C. Develop a brief plan describing the proposed investigation to assess the nature and extent of the potential “regional” problem or issues. The investigation should be performed to the extent practicable with the SDMP, BMP Monitoring Program, other UICER guidelines, and meet the requirement of the permit (e.g., method reporting limits, notification of concentrations exceeding MADLs).

D. Meet with DEQ to discuss and get input on planned regional approach and/or investigation. Meetings or “check ins” will be held with DEQ on an as needed basis depending on the scope and complexity of the issue.

Step 4: Implement Plan Implement the plan developed in Step 3 to evaluate the nature and extent of the problem or issue identified in Step 1. The plan may include the following, as necessary and appropriate: UIC inspections, research of UIC catchments, modeling, sampling and analyses, etc. Step 5: Evaluate Results Compile and evaluate the results of the regional assessment investigation. The results may be used, as needed and appropriate, to:

A. Determine the need for additional monitoring to meet the objectives of the investigation or to address data gaps identified by the investigation.

B. Determine the next steps in addressing the regional issue. These may include

a. Summarize findings of regional study for DEQ in an appropriate format. Applicable results will be reported to DEQ in the appropriate annual report, technical memorandum, letters, or reports, as determined necessary and appropriate. Data, records, or reports generated as a result of this work will be maintained in the UIC Program files and will be available for review upon request.

b. Prepare recommendations for path forward. These may include:

i. Initiate response actions (see UICER Guideline No. 8) or corrective actions (Corrective Action Plan; City of Portland, 2006).

ii. Improve the management of UICs to assure groundwater protection, etc., by identifying and implementing changes to the BMPs identified in the UICMP or the UIC Operation and Maintenance Plan.

iii. Evaluate or demonstrate permit compliance.

iv. Support permit or UICMP modifications.

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Page 1 of 4 UICER Guideline No.8



Response Actions PURPOSE This City of Portland Bureau of Environmental Services (BES) UIC Evaluation and Response (UICER) guideline provides the basic process that will be followed in the event that a UIC is identified as potentially not meeting permit requirements, but sufficient information is not available for the UIC to be determined to be non-compliant. For example, if stormwater discharge concentrations exceed either the maximum allowable discharge limits (MADLs) specified in Table 1 of the Oregon Department of Environmental Quality (DEQ) issued Water Pollution Control Facility (WPCF) permit (No. 102830) during an individual storm event, or the annual mean concentration, response actions may be appropriate Response actions are intended to reduce stormwater discharge concentrations at the surface in order to meet permit MADLs. Meeting MADLs at the “end of pipe” demonstrates compliance with state and federal requirements for the protection of “underground sources of drinking water” and “waters of the state.” Response actions for the purpose of this guideline are intended to be implemented in a timely manner and are considered interim in nature, until a final Compliance Determination has been made. The process in this guideline is similar to the process identified in the Corrective Action Plan (City of Portland, July 2006) for known non-compliant UICs. APPLYING THE GUIDELINE This guideline describes the steps BES may follow to evaluate and/or implement response actions, evaluate and address data gaps, or address concerns associated with groups (e.g., issue or location specific) of UICs. The steps described in this guideline for response actions are intended to reduce stormwater discharge concentrations or modify UIC operations and maintenance in order to assure permit compliance. PERMIT REQUIREMENTS The WPCF permit requires:

Schedule B. Section 7(a)(vii) - “A discussion of compliance response actions taken to correct a MADL annual mean exceedance.”

Schedule C, Section 8. Priority Pollutant Screen Detection Response. “b. After sampling at least 5 storm events at the public UIC(s) at which a PPS pollutant(s) detection

occurred, the Permittee must include in the annual monitoring report for the wet season being monitored the following: . . .

iii. Based on the annual mean MADL concentration, discuss actions being taken in accordance with Table 4.

c. In accordance with Table 4, the Permittee must initiate a compliance response action when a PPS pollutant annual mean MADL concentration is exceeded. The compliance response action shall be in accordance with Schedule C.10, below.”

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Schedule C. Section 10. Compliance Response Action for Annual Mean MADL Exceedance.

“a. If, at the end of a wet season monitoring period, an annual mean concentration for any MADL in Table 1 is exceeded, the Permittee must:

i. Implement a compliance response action to correct the exceedance within the first wet season following the exceedance; . . .

iii. Discuss following in the annual monitoring report of Schedule B.7 for the wet season in which the exceedance occurred: . . . (3) The compliance response action proposed, being taken, or taken by the Permittee to

correct the exceedance.” In addition, DEQ states1 that “…exceedance of the annual mean concentration triggers a compliance response action. The Department does not consider the exceedance of the annual mean concentration as a permit violation. However, any failure to take a compliance response or corrective action is a permit violation... . “ FURTHER EVALUATION FRAMEWORK Steps 1 through 4 below describe the general framework that may be followed to evaluate and implement response actions. The sequence presented below is intended to be flexible and dynamic to address site-specific circumstances. Some steps may be performed concurrently to optimize staff resources and to eliminate potential overlap between steps (e.g., discrete steps may be combined or eliminated to reduce staff time and to streamline the schedule). The actual steps performed and sequencing of the steps will be determined based on site-specific facts regarding each UIC or group of UICs. Step 1: Assess Potential Response Actions

A. Review the information that identified the potential need for a response action. Information sources may include but are not limited to:

a. Annual stormwater discharge monitoring results (see annual Stormwater Discharge Monitoring Report, submitted by July 15 of each permit year);

b. MADL Exceedances (see UICER Guideline No. 3);

c. Source Identification (see UICER Guideline No. 4); and

d. Source Specific Investigation Monitoring (see UICER Guideline No. 5).

B. Identify and review results of previous evaluation or response actions, if any, implemented for the subject UIC(s) or UIC(s) with similar characteristics (e.g., traffic category, land use, size).

1 “Fact Sheet and Class V Underground Injection Control (UIC) WPCF Permit Evaluation” prepared by DEQ for permit number:

102830, prepared by DEQ, dated June 1, 2005. Section 4.3.3.

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C. Assess effectiveness, if applicable, of previous response actions implemented to reduce pollutant concentrations at the subject UIC (i.e., comply with the MADLs) or UICs with similar characteristics.

Step 2: Identify Potential Response Actions A. Define the goal and/or objective for the response action (i.e., address the specific potentially non-

compliant condition) in order to:

a. Assess the effectiveness of response action alternatives.

b. Identify potential performance measures or key performance indicators to evaluate or demonstrate the effectiveness of the response action.

B. Identify potential response action(s) and/or further evaluation(s) that may be appropriate where a potential pollutant source(s) is identified. Implementation of one or more of the following response or evaluation actions may be considered, as needed and appropriate, to reduce pollutant concentrations or achieve permit compliance:

a. UIC System Cleaning (see Operations and Maintenance Plan (O& M Plan); UICMP Appendix B)- Request the Bureau of Maintenance clean the UIC system (inlets, stormwater lines, sedimentation manhole, sump).

b. Street Sweeping (see O & M Plan) - Request the Bureau of Maintenance sweep the public streets in the UIC catchment.

c. Source Identification (see UICER Guideline No. 4).

d. Source Control – Request BES Source Control Program initiate site inspections and/or education and training at potential pollutant source facilities.

e. Public Outreach – Request BES public relations staff develop educational materials (e.g., fact sheets, flyers, door hangers), and hold open houses or public meetings to educate and promote clean stormwater and groundwater.

f. Source Specific Investigation Monitoring (see UICER Guideline No. 5) – Initiate source-specific investigation to evaluate and document potential source(s) and provide information to assess potential response actions, corrective actions, enforcement action, and/or source control measures that may be appropriate.

g. Refer pollutant source (e.g., facilities, site) to DEQ for further evaluation and investigation under the appropriate DEQ regulatory authority (e.g., Water Quality, UIC, Environmental Cleanup, Solid Waste, Hazardous Waste, Underground Storage Tank).

h. Groundwater Protectiveness Demonstration (see UICER Guideline No. 6).

i. Permit Modification(s) (See Policy and Regulations BMP).

C. Identify potential response action(s) and/or further evaluation(s) that may be appropriate where a potential pollutant source(s) has not been identified. Consider implementation of one or more of the following as needed and appropriate:

a. Source Identification (see UICER Guideline No. 4);

b. Source Specific Investigation Monitoring (see UICER Guideline No. 5);

c. Groundwater Protectiveness Demonstration (see UICER Guideline No. 6); and

d. Permit Modification(s) (See Policy and Regulations BMP).

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Step 3: Select Response Action A. Select an appropriate response action, if necessary and appropriate, based on consideration of the

following factors:

a. The anticipated effectiveness of the response action to achieve the goals and objectives identified in Step 2A.

i. Meets WPCF permit compliance requirements;

ii. Complies with any other local, state, and federal regulations and standards; and

iii. Advances BES watershed goals and objectives.

b. Priority of UIC (see Prioritization Procedure);

c. Scope and complexity of action or evaluation;

d. Cost effectiveness;

e. Implementability;

f. BES and CIP priorities;

g. Relationship to watershed or other citywide projects (e.g., sewer, transportation);

h. Opportunities to streamline or more efficiently perform corrective actions by grouping similar problems or similar design or funding issues together; and

i. Design or implementation data gaps. Step 4: Implement Response Action

A. Evaluate the need and practicality of monitoring the effectiveness of the selection actions(s). Response action goals and objectives may be used to identify appropriate performance measures or indicators to demonstrate the effectiveness of individual actions. To the extent practicable, BES will use data gathered from the Stormwater Discharge Monitoring Plan (SDMP; City of Portland, 2006) and the BMP Monitoring Program (see UICMP) as one element of the compliance demonstration. If site-specific data are needed, the data will be collected and analyzed to the extent required, consistent with the BMP Monitoring Program and the SDMP.

B. Implement the selected evaluation and/or response actions.

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Appendix I

Corrective Action Plan

Corrective Action Program Element

Document submitted to DEQ on 7/15/06, under separate cover.


Appendix J

Glossary

Placeholder
