HomeMy WebLinkAboutStormwater Management Plan for Underground Injection Control Devices 2019 City of Lake Oswego, Oregon
Stormwater Management Plan
For
Underground Injection Control Devices
In Support of Coverage Under DEQ's
1200-U WPCF General Permit for
Stormwater Injection
Prepared for the
Oregon Department of Environmental Quality
July 7, 2016
Revised 11/1/2019
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TABLE OF CONTENTS
1.0 Introduction 1
1.1 Regulatory Background 1
1.1.1 MS4 NPDES Permit Background 1
1.1.2 TMDL Background 2
1.1.3 Lake Oswego UIC Background 2
1.2 Document Organization and Management 3
2.0 Source Control Measures and BMPs 4
2.1 Structural BMPs 4
2.2 Operational (Non-Structural) BMPs 4
3.0 Spill Prevention and Spill Response Plans 5
3.1 Spill Prevention 6
3.2 Spill Response 6
4.0 Operations and Maintenance Procedures 7
4.1 Operations Procedures 7
4.2 Maintenance Procedures 8
5.0 Employee Education 8
6.0 Stormwater Sampling 8
6.1 Stormwater Sampling 8
6.2 Stormwater System Reporting 9
7.0 Other Proposed Actions 9
8.0 References 10
LIST OF TABLES
Table 1: Allowed Non-Stormwater Discharges to UlCs 5
LIST OF FIGURES
Figure 1: Lake Oswego UlCs, Geology, and Water Wells With Setbacks Defined In
OAR 340-044-0018(3) 12
Lake Oswego UIC SWMP
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Lake Oswego UIC SWMP a
1.0 INTRODUCTION
Management of Class V stormwater injection devices (referred to herein as UlCs) is a classic
situation where "groundwater governance" is required (van der Gun et al., 2016). "Groundwater
governance" addresses three realities:
1. The subsurface, including groundwater, is put to multiple current uses and may be put to
other or additional future uses. Balancing these uses requires knowledge of the relevant
geologic characteristics of the subsurface, as well as the benefits and costs—direct and
external—of these uses.
2. "It is difficult and expensive to explore the subsurface adequately" resulting in "large
uncertainties in the proposed properties and potential of the underground."
3. "[M]any processes that produce change in the subsurface are virtually irreversible on a
human time scale—or are reversible only at a very high cost."
This UIC Stormwater Management Plan (SWMP) is intended to provide a framework for
exercising "groundwater governance" with respect to stormwater management in Lake Oswego.
The plan is required by Oregon Department of Environmental Quality's (DEQ's) General Water
Pollution Control Facilities Permit for Class V Stormwater Underground Injection Control Systems,
permit number 1200-U, effective December 14, 2015 through November 30, 2025.This SWMP is
a requirement of permit Schedule D.5 for the City of Lake Oswego (City) because several dry wells
owned and operated by the City accept stormwater runoff from surfaces with high traffic
volumes (greater than 1,000 trips per day).
1.1 Regulatory Background
Stormwater within the City limits is managed under multiple regulatory schemes implemented
by the Oregon Department of Environmental Quality (DEQ):
• The City's municipal stormwater permit(specifically,the Municipal Separate Storm Sewer
System (MS4) permit;
• Total Maximum Daily Loads (TMDL);
• Underground Injection Control (UIC) facilities are used to infiltrate runoff into the
subsurface, re-establishing a more natural hydrologic cycle.
1.1.1 MS4 NPDES Permit Background
The DEQ regulates surface-discharging stormwater runoff from the City of Lake Oswego through
the (MS4) National Pollutant Discharge Elimination System (NPDES) Permit No. 101348, issued to
Clackamas County and its co-permittees. The permit is issued under the Clean Water Act and
requires the City to remove pollutants discharging to surface water bodies "to the maximum
extent practicable." The current MS4 permit requires permittees to adopt stormwater
management strategies that use "low impact development" (LID) approaches. The first tenet of
LID is that runoff is reduced, primarily through onsite stormwater facilities (structural best
management practices or BMPs). Where possible, stormwater should be infiltrated into the
ground. The City has recently adopted code language and amended the Comprehensive Plan to
require LID approaches for new development and redevelopment. In addition to development
Lake Oswego UIC SWMP 1
review activities, the City's Stormwater Management Plan addresses spill prevention and
response actions, internal training and external education and outreach, and other pollutant
source control measures for stormwater. In the substance of these activities and control
measures, there is no distinction made between stormwater directed to surface water and
stormwater directed to groundwater.
Along with actions to reduce pollutants, each co-permittee is required to prepare and submit to
DEQ an annual report on activities, accomplishments and implementation of their individual
SWMPs, monitoring results, and adaptive management actions. The reports cover the period of
July 1 to the following June 30th of each year.The annual report is due by November 15t following
the end of the permit year. Reports related to stormwater management and links to DEQ permit
and water quality documents are maintained on the City website at:
http://www.ci.oswego.or.us/publicworks/permits-plans-and-reports.
1.1.2 TMDL Background
Total Maximum Daily Loads are also a Clean Water Act requirement. The City has a duty to
implement measures to reach TMDLs as defined in Oregon state law (OAR 340.42). TMDLs are
developed for surface water bodies that do not meet water quality standards even when point
source permits in the NPDES program are in place. For the Tualatin River watershed, impairment
comes primarily from excess phosphorus, suspended sediment (affecting dissolved oxygen) and
temperature; in the Willamette, excess temperature is an issue. Both watersheds also have
TMDLs for mercury (which is often bound to sediment, like phosphorus) and bacteria, which has
both natural and anthropogenic sources. Infiltrating runoff back into the subsurface is the
preferred stormwater best management practice (BMP) to manage all of these pollutants.
Cations like mercury and phosphorus are bound in the soil. Bacteria also is retained in the soil.
Infiltrating stormwater indirectly reduces streambank erosion (an important source of
phosphorus) by reducing the frequency and magnitude of erosive runoff. Pollutant reduction
measures for phosphorus, suspended sediment, mercury and bacteria are managed through the
MS4 permit. Summer instream temperature conditions are improved when there is larger
volumes of cool groundwater discharge to surface streams, and when channels are not
excessively widened due to erosion, resulting in shallower water that more easily warms. In
addition, the City is required to promote riparian shading as a strategy to meet temperature
TMDLs.
1.1.3 Lake Oswego UIC Background
The City has historically used UICs to manage stormwater runoff in two general regions, the
Rosewood/Lake Grove neighborhoods on the western side of the City, and the Old Town/First
Addition neighborhoods on the east side of the City (Figure 1). Both of these areas have coarse
grained Missoula flood deposits at or near the surface, promoting effective and efficient
infiltration. On the western side of the City, the incorporated boundary is highly irregular, and
the City abuts areas of unincorporated Clackamas County where dry wells are also used for
stormwater management; in this area, a vertical separation distance of <3 feet between the
Lake Oswego UIC SWMP 2
lowest infiltration of the dry well and the seasonal high groundwater table was deemed to be
protective (see GSI 2011 for details).
The UIC program arises from the Federal Safe Drinking Water Act, rather than the Clean Water
Act, specifically to address risk to groundwater as a drinking water source. Because UlCs infiltrate
below a biotically active soil layer where pollutant sequestration or degradation can occur, there
is a greater risk that they can be a conduit for pollutants reaching groundwater than is presented
by other stormwater facilities.
The City registered 32 UlCs with DEQ in 2002 at the completion of an initial inventory.
Collectively, these were designated by DEQ as UIC number 10573. The City also applied for an
individual Water Pollution Control Facility (WPCF) permit in December, 2008. No action was
taken by DEQ on that permit application pending development of a general permit for entities
such as the City with fewer than 50 UICs. This permit became available in December, 2015,
prompting this application.The City is required to provide this UIC Stormwater Management Plan
as a permit condition because approximately half of the City's UICs drain surfaces that are subject
to more than 1,000 vehicle trips per day, putting them in the "high risk" category.
1.2 Document Organization and Management
This Stormwater Management Plan focuses on the City's current actions specific to stormwater
discharged to UICs from runoff at City facilities and public road rights of way. It addresses
management requirements of DEQs 1200-U UIC general permit Schedules D.5 and B.2. Plan
sections are cross-referenced to specific sections(Schedules) of the permit to the extent possible.
The ACWA UIC Best Management Practices Manual (ACWA 2013) was consulted regarding plan
contents.
Management actions described by the City specific to UlCs are intended to integrate with the
City's existing obligations to minimize pollutant discharge to receiving waters (surface or
groundwater) under the City's MS4 permit, under TMDL implementation requirements, and
under current practice for managing UlCs based on the City's application for Rule Authorization
in 2002 and for an individual WPCF permit in December 2008. At that time, the City applied for a
permit on 32 UICs. Since then, 3 UICs have been closed (City UIC numbers 6, 19, and 241). As the
City's stormwater asset management program has become more robust since 2008, 9 UlCs were
recognized during the course of preparing the 1200-U application package and are getting
registered for the first time. A full system assessment, including data associated with these new
UlCs (City UIC numbers 33-41), is presented as Attachment B to the City's 1200-U permit
application. The attachment provides details on all of the currently active dry wells of which the
City is aware, including those on private property that accept runoff from the public right of way.
The City will update this Plan as needed based on operational feedback and information (see
Section 4.0), capital improvements, asset management activities, or direction from DEQ. Once
1 This dry well is located at the City's Public Works facility and was bypassed several years ago. It will be formally
decommissioned later this summer in conjunction with construction of a new facility.
Lake Oswego UIC SWMP 3
the 1200-U permit is received, the City will post the permit with this plan on the City's UIC web
page: http://www.ci.oswego.or.us/publicworks/underground-iniection-control.
2.0 SOURCE CONTROL MEASURES AND BMPs
The City has three types of UIC configurations managing water from the public right of way:
1. Dry wells consisting of 48-inch (appx.) open concrete pipe installed vertically into the
ground with at least one perforated ring of concrete pipe and sometimes a solid bottom
(City Standard Detail SD1-07).2
2. Bottomless catch basins, also consisting of 48-inch (appx.) open concrete pipe installed
vertically into the ground, with or without perforations but with a fully open bottom.
3. Infiltration trenches, rectangular in cross section with the base not more than 5 feet
below grade, rock filled, with a perforated distribution pipe at mid-depth and a surface
soil or gravel cover.
Nearly all of these UICs are within the public right of way, except those along Lakeview Blvd.west
of Pilkington Rd. that were installed on private land but accept road runoff. Stormwater is
conveyed to UlCs through 1 - 3 (rarely 4 or 5) inlet grates (typically no more than 2 feet x 3 feet
in area, sometimes with curb inlet section) and pipes.
2.1 Structural BMPs
Upstream pre-treatment between the inlet and the UIC, where present, consists of a sumped
catch basin (or manhole) or a pollution control catch basin (or manhole),the latter having a sump
and a snouted connection to the dry well to better retain floatable trash or hydrocarbons in the
manhole prior to discharge to the UIC (City Standard Details SD1-08A,-B and SD5-04).1 Standard
sump depth is at least 18 inches, and more recently 2 feet. In other cases,there is no substantial
pre-treatment. Pre-treatment type is indicated in Attachment A to the Permit Application. During
fiscal year 2016-2017, the City will work with DEQ to develop a retrofit schedule as described in
Section 7.0 of this document.
2.2 Operational (Non-Structural) BMPs
As part of the City's overall stormwater management obligations under the MS4 permit, both
street sweeping and catch basin cleaning occur regularly. Most arterials are swept at least
monthly with regenerative air sweepers which, based on ongoing studies by the City of Seattle,
are substantially more effective than prior sweepers at removing fine grained sediment and
related pollutants (Seattle 2016a, b). The two pollutants -- pentachlorophenol and lead -- that
are the focus of 1200-U permit monitoring requirements are both associated with sediment.
Therefore, street sweeping is expected to have a beneficial impact on reducing the discharge of
these and other stormwater pollutants to the UlCs.
Catch basin cleaning is an integral part of UIC maintenance and is described in Section 4.2.
2 See http://www.ci.oswego.or.us/standard-details
Lake Oswego UIC SWMP 4
3.0 SPILL PREVENTION AND SPILL RESPONSE PLANS
The 1200-U permit allows the City to discharge stormwater and selected non-stormwater fluids
into the subsurface under Schedule A.1 (Table 1). All other discharges to the subsurface through
UICs are regarded as spills, are considered an "endangerment of health or the environment," and
are prohibited [Schedule A.5].
Table 1: Allowed Non-Stormwater Discharges to UICs [Schedule A.1]
a. Water line flushing(excluding super-chlorinated discharges);
b. Landscape irrigation:
c. Uncontaminated groundwater infiltration;
d. Uncontaminated pumped groundwater;
e. Discharges from potable water sources;
f. Water from potable groundwater monitoring wells:
g. Draining and flushing of municipal potable water storage reservoirs:
h. Foundation drains;
i. Air conditioning condensate:
j. Springs:
k. Water from crawl space pumps that has not been contaminated with oils or other chemicals:
1. Footing drains:
tn. Lawn watering;
n. Individual residential car washing:
o. Charity car washing.provided that chemicals, soaps.detergents. steam or heated water are not used, and
washing is restricted to the outside of the vehicle (no engines,transmissions or undercarriages);
p. Other vehicle washing,in addition to paragraphs n and o above,provided that chemicals,soaps,
detergents. steam or heated water are not used,and washing is restricted to the outside of the vehicle(no
engines. transmissions or undercarriages);
q. De-chlorinated swimming pool and fountain discharges:
r. Street wash water,provided that street wash water is applied using best management practices that
minimize debris and sediment entering the UIC. Washing any spill of any substance(including any oil or
hazardous material as defined in Oregon Revised Statute 466.605)into any UIC is prohibited;
s. Routine external building wash-down and pavement wash waters provided that chemicals, soaps,
detergents. steam or heated water are not used;
t. Discharges or flows from emergency fine-fighting activities provided you take precautions,to the extent
practicable.to protect UICs dieing emergency fine-fighting activities, and clean the UIC system after the
fire-fighting event if fluids from the fire fighting activities reach the UIC system.Wash down of spills of
oil or hazardous materials into any UIC is prohibited:
u. Start-up flushing of groundwater wells; and
v. Other similar temporary discharges of uncontaminated water.
Spills of oil or hazardous substances that reach "UICs are subject to the emergency response
requirements of ORS 466 and OAR 340-142" according to Schedule A.4. Following the spill, the
City is obligated to clean the UIC system and take any other corrective actions (with DEQs prior
approval) "as soon as practicable" to "eliminate any endangerment of health or the
environment" (Section A.5).
Lake Oswego UIC SWMP 5
3.1 Spill Prevention
Spills within the City (i.e., accidental releases) started to be tracked as part of the City's MS4
program requirements of the permit issued in March, 2012. The vast majority of spills reported
to the City (10—20 per year) are small volume (generally much less than 30 gallons) and related
to vehicular crashes, vehicular maintenance activities, or "illicit discharges." The City's MS4
permit addresses "illicit discharges" that are intentional rather than accidental, but result in the
discharge of inappropriate materials to the City's stormwater or surface water system. Illicit
discharges to storm drain inlets have included cooking oil, wastewater including septage from
recreational vehicles, spilled paint, wash water from pressure washing, drainage from
spas/pools/hot tubs, and cement wash water or sawcut waste. Except for cement-related spills,
these have all been "one-offs" and were dealt with using a warning letter.
Because the City operates UICs that drain public rights of way, appropriate roadway signage to
maintain conditions suitable to minimize vehicular accidents and education of residents
regarding "illicit discharge" are the most effective spill prevention measures that the City can
implement. Vehicular crashes may result in spills of automotive fluids, most typically gasoline or
anti-freeze. Traffic issues are monitored and crash data analyzed by Engineering staff, and
addressed as the issue arises. Education of residents regarding appropriate and inappropriate
behavior around the storm drainage system is a requirement of the City's MS4 permit and the
City will incorporate UIC and groundwater messaging into its MS4 educational outreach. Outlets
used by the City for public education include social media (Facebook, Twitter, Instagram),
newsletters, regional groups (TV PSAs at KPTV, Regional Coalition for Clean Rivers and Streams,
and the Clean Rivers Coalition, the City'.
3.2 Spill Response
The City's spill response procedures, required as part of its NPDES MS4 permit, have been
updated to reflect the UIC permit requirements. Spills are reported by the public through calls
to the Watershed Hotline (503.675.3982), 911, or Public Works. The Fire Department is the
primary responder for motor vehicle accidents.
The City departments utilize each other's strengths to create the best response team for a spill
or illicit discharge. The first responding department determines if the spill can be safely
contained and notifies other departments, as necessary, to assist in the incident. If a spill
contains hazardous materials, the Fire Department will notify the regional hazardous material
response team. The Oregon Emergency Response System (OERS) will be notified when
appropriate to the size and type of spill.
If a spill is small but likely to impact the stormwater system, staff are trained to deploy absorbent
socks to contain the spill and use either absorbent pads (in wet weather) or granular absorbent
(in dry weather). If a spill is large, staff are trained to deploy drain covers to protect catchbasins
and UICs, use absorbent socks to contain the spill, and cleanup the remaining spill using either
absorbent pads or granular absorbent. The City may hire an environmental services company to
finish cleanup to DEQ standards depending on the severity of the incident. At a minimum, the
Lake Oswego UIC SWMP 6
affected UIC(s) and stormwater system will be cleaned and proper disposal will be completed for
waste generated during the incident.
The City will report the number of spills affecting a UIC, the responding department(s), and a
summary of the actions completed for incidents in the annual UIC report.
4.0 OPERATIONS AND MAINTENANCE PROCEDURES
The City's stormwater management code (Lake Oswego Code [LOC] Chapter 38 Sections 25 and
26) and ownership of real property including transportation rights of way provides legal authority
to operate, maintain, and enforce provisions of the 1200-U permit as required in Section D.1.
Revenues from the City's surface water utility (LOC 38.24) provide the financial means needed to
perform this work. Adaptive management [Schedule D.3] is a cornerstone of the City's
operational approach to stormwater. As such,the City's MS4 adaptive management strategy will
be used
4.1 Operations Procedures
The permit requires the City to undertake several specific operational duties not described
elsewhere in this UIC SWMP:
1. Schedule B.1: Maintain an inventory of UICs and related site information (in table and
map form) as described in the permit.
2. Schedule C.3: Update the inventory in the event of UIC decommissioning, notify DEQ and
provide and obtain approval for a Decommissioning Plan, and pay the required fees.
3. Schedule C.4: Add newly constructed or discovered UICs to the inventory and
management approach as required, and notify/register them with DEQ (including fee
payment) within 30 days of construction or discovery.
4. Schedule A.3: In the event of monitored pollutant concentrations higher than action levels
indicated in Section 6, the City is required to identify the pollutant source, affected UICs
(including those with similar site characteristics that might be similarly affected),
determine whether corrective actions are warranted (i.e., pollutant source control,
changes to operational BMPs, retrofitting the UIC to add upstream structural BMPs, or
decommissioning the UIC), obtain approval for corrective actions from DEQ, and
undertake those actions.
5. Schedule A.7: Address within one year of receiving the permit how to manage UIC #40
(asset ID E17B-143D) that is located within a 500 foot horizontal setback for a drinking
water well (CLAC 66141) through a groundwater protectiveness identification, retrofits,
or decommissioning.
6. Schedule F.1.c: "take all reasonable steps to minimize or correct any adverse impacts on
[human health and] the environment resulting from noncompliance with this permit" if
needed.
Lake Oswego UIC SWMP 7
4.2 Maintenance Procedures
The City is obligated by the 1200-U permit to maintain the stormwater infrastructure of and
associated with a UIC. Under Schedule F.2.a, the City must properly operate and maintain the
UlCs and connected infrastructure through performance of routine maintenance, provision of
funding to support the operations and maintenance activities including staff training, and
required monitoring with the process controls outlined in Section 6.
The City's maintenance activities consist primarily of inspection and cleaning using the City's
vactor equipment in the same manner as is done under the MS4 program. Sumped catch basins
are cleaned annually. Materials removed from UlCs and related infrastructure are managed for
disposal with other debris removed from the MS4 system [Schedule F.2.b]. The proposed
frequency of inspection for UIC and related stormwater infrastructure is annually except for high
risk UICs in the first permit year, where semi-annual inspections will be performed. Cleaning of
UlCs and associated stormwater infrastructure will occur when warranted (e.g., capacity of UIC
sump or catch basin sump is less than 50 percent) based on inspection results.
5.0 EMPLOYEE EDUCATION
The City is required to provide stormwater training to its employees as part of its MS4 permit and
will summarize the training (webinars, seminars, conferences, etc.) in its annual UIC report. The
City will provide spill response training to staff annually and report on the number of attending
staff in its annual report.
6.0 STORMWATER SAMPLING
6.1 Stormwater Sampling
Stormwater monitoring is required by the permit if any covered UlCs drain high traffic areas,
among other risk factors. Most of the City's UlCs are in residential neighborhoods. Half of the
City's UICs are in the high-traffic category. The number of UlCs required to be sampled is 5
percent of the total, which for the City is two (2). The City is designating UIC numbers 22 and 40
for sampling:
1. UIC number 22 is located on Jean Road, immediately east of a neighborhood commercial
district with multi-family and single family residential uses in the catchment. Vehicle
traffic at this location is estimated at 7,000 trips per day(TPD) based on traffic counts and
estimation based on methods used by DEQ. One storm drain inlet feeds this dry well.
2. UIC number 4 is located at 16088 Boones Ferry Rd and is a high-risk UIC (more than 1,000
vehicle trips/day). It drains a large commercial parking lot with a car wash and auto repair
shop
The City is required to collect samples during two storm events in the first permit year, and
annually thereafter. Staff will collect samples during storm events of 0.1 inches or greater. The
Lake Oswego UIC SWMP 8
City will provide information in the annual report on the 24-hr antecedent precipitation, the rain
event precipitation, and field parameters such as water temperature, dissolved oxygen,
conductivity, and pH.
Stormwater samples will be collected as individual grabs at the two UICs. One field replicate
sample will be collected during each event. All samples will be analyzed for the following
constituents using 40 CFR 141 (Safe Drinking Water Act)-compliant methods:
• Pentachlorophenol,with a target reporting limit of< 1 µg/Lfrom the analytical laboratory
• Total lead, with a target reporting limit of< 15 µg/L from the analytical laboratory
The analytical laboratory selected for use by the City will be accredited for pentachlorophenol
and lead in non-potable water by the NELAC Institute. Oregon's ORLAP accreditation program,
administered by the Oregon Public Health Division, is one of the NELAC Institute member bodies;
ORLAP recognizes all NELAC fields of accreditation.
Other sampling and monitoring protocols (e.g., documentation, record keeping, and sample
collection, preservation, and handling) will follow those described in the City's Comprehensive
Sampling and Analysis Plan for its MS4.
6.2 Stormwater System Reporting
The permit requires reporting of multiple items to DEQ by November 1st following the end of the
permit year (July 1st to the following June 30th):
1. Changes in key personnel (City Manager, Stormwater Quality Coordinator) Schedule D.2
2. Adaptive management actions, including assessment of improvements to groundwater
quality and a review of newly available technologies and practices, as appropriate.
3. Planned changes to the physical (structural) characteristics of any of the UICs [Schedule
F.4.a
4. Stormwater sampling results [Schedule B.2.c and D.1.c]
5. Resolution of, or proposed solutions to, issues resulting in potential non-compliance or
violations [Schedule F.4.b, F.4.c]
6. Progress on corrective actions that require multiple permit reporting cycles to complete
[Schedule A.5.b].
Schedule F.3 documents the requirements for record retention (minimum of 10 years [Schedule
F.3.d]) and the nature and type of records to be retained [Schedule F.3.a, F.3.b]. These same
records are to be available to DEQ for inspection upon request [Schedule F.3.c].
7.0 OTHER PROPOSED ACTIONS
The City proposes to complete the following:
1. Annually clean, as needed, all infrastructure discharging to UICs.
Lake Oswego UIC SWMP 9
2. Perform a condition assessment for the City's UICs consisting of:
a. Precise location and description of inlet geometry, along with catchment areas,
pollutant-generating features within the catchment (e.g., wooden utility poles), and
activities (e.g., ;
b. Update the City's description of its UlCs including the structural connections between
inlets and the UIC, and details of the pretreatment structures including sump depths
and UIC inlet configurations.
c. Update the condition assessment in FY2223.
3. Add "Rain Water Only—Drains to Groundwater" markers at each unmarked inlet to a UIC
where some form of paving suitable for marking is adjacent to the inlet.
4. Develop a schedule for decommissioning UlCs or retrofitting UICs with approved
structural pre-treatment measures [Schedule A.6].
5. Revise the City's UIC Stormwater Management Plan as needed.
8.0 REFERENCES
ACWA. 2003. Underground Injection Wells for Stormwater Best Management Practices Manual.
Prepared by URS Corporation, Portland, Oregon for the Association of Clean Water
Agencies, Portland, Oregon. January.
City of Seattle. 2016a. Arterial street sweeping expansion.
http://www.seattle.gov/util/EnvironmentConservation/Proiects/SewageOverflowPreve
ntion/IntegratedPlan/StreetSweeping/index.htm.
City of Seattle. 2016b. MS4 Annual Report Phase I; Response to Question 72 re. Stormwater
Monitoring or Stormwater-Related Studies.
http://www.seattle.gov/util/cs/groups/public/@spu/@drainsew/documents/webconte
nth 050317.pdf.
GSI Water Solutions. 2011. Pollutant fate and transport model results in support of Clackamas
County WES' UIC WPCF Permit—groundwater protectiveness demonstration and
proposed EDLs. Technical Memorandum. Prepared by GSI Water Solutions, Inc.,
Portland, Oregon for Clackamas County Water Environment Services, Oregon City,
Oregon. September 17.
Van der Gun, Jac, Alice Aureli, and Andrea Merla. 2016. Enhancing groundwater governance by
making the linkage with multiple uses of the subsurface space and other subsurface
resources. Water Vol. 8 No 222. May 25, 2016.
Lake Oswego UIC SWMP 10
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Lake Oswego Dry Wells Water Wells NAD_ig83_HARN_StatePlane_Oregon_North_FIPS_36oi_Feet_Intl p� E OS,
����� ■ Projection:Lambert_Conformal_Conic, j
p Data from RLIS,DOGAMI,Oregon Water Resources Dept., U
i r 2,5oo 5,000 Moo io,000 a n d We I I Buffers Oregon Dept.Env Quality&City of Lake Oswego;
Feet Anne MacDonald,CEG;6)29/3.6 oRec o?/
Figure 1. Lake Oswego UlCs, Geology, and Water Wells With Setbacks Defined In OAR 340-044-0018(3)
Lake Oswego UIC SWMP 1200-U Permit 12