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					NPDES MS4 PERMIT COMPLIANCE
       ANNUAL REPORT
    July 1, 2005 - June 30, 2006
                 &
  TUALATIN SUB-BASIN TMDL
       ANNUAL REPORT
    July 1, 2005 - June 30, 2006

         October 2006




     PREPARED FOR THE
  OREGON DEPARTMENT OF
  ENVIRONMENTAL QUALITY
            BY
            Clackamas County Service District No. 1
    Surface Water Management Agency of Clackamas County
 (including the City of Happy Valley and the City of Rivergrove)

   NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM (NPDES)
           MUNICIPAL SEPARATE STORM SEWER SYSTEM (MS4)
               STORMWATER MANAGEMENT PLAN



We, the undersigned, hereby submit this National Pollutant Discharge Elimination
System (NPDES) Municipal Stormwater System Annual Report in accordance
with NPDES Permit Number 101348. We certify under penalty of law that this
document and all attachments were prepared under our direction or supervision
in accordance with a system designed to assure that qualified personnel properly
gather and evaluate the information submitted. Based on our inquiry of the
person, or persons, who manage the system, or those persons directly
responsible for gathering the information, the information submitted is, to the best
of our knowledge and belief, true, accurate and complete. We are aware that
there are significant penalties for submitting false information, including the
possibility of fine and imprisonment for knowing violations.




___________________________               ___________________________

Michael S. Kuenzi, Director               Catherin L. Daw, City Manager
Water Environment Services                City of Happy Valley
                  PERMIT HOLDER INFORMATION



CO-PERMITTEE’S NAME:     Clackamas County Service District No. 1
                         (Includes the City of Happy Valley)
                         Surface Water Mgmt. Agency of Clack. Co.
                         (includes the City of Rivergrove)

ADDRESS:                 9101 SE Sunnybrook Blvd.
                         Clackamas, OR 97015

CONTACT PERSON:          Michael S. Kuenzi, Director
                         Water Environment Services
                         Clackamas County
                         (503) 353-4567

OTHER CO-PERMITTEES:     Clackamas County
                         City of Gladstone
                         City of Johnson City
                         City of Lake Oswego
                         City of Milwaukie
                         City of Oregon City
                         City of West Linn
                         City of Wilsonville
                         Oak Lodge Sanitary District
                               Table of Contents

1. INTRODUCTION
2. RIVERS AND CREEKS
3. STORM SEWER SYSTEMS
4. STATUS OF STORMWATER MGMT. PROGRAM IMPLEMENTATION
   4.1      Maintenance
   4.2      Planning Procedures for New Development and Significant
            Redevelopment
   4.3      Flood Management Projects and Water Quality
   4.4      Pollutants in Runoff from Closed Landfills
   4.5      Program to Reduce Pollutants in Discharges Associated with the
            Application of Pesticides, Herbicides, and Fertilizers
   4.6      Illicit Discharges and Spills
   4.7      Industrial Stormwater Program
   4.8      Construction Site Runoff: Structural and Non-Structural BMPs
   4.9      TMDLs
   4.10     303(d) Parameters
   4.11     Public Involvement
   4.12     Monitoring Program
   4.13     Non-Stormwater Discharges
5. FUNDING, STAFF, AND EQUIPMENT

6. LEGAL AUTHORITY

7. IDENTIFICATION OF WATER QUALITY IMPROVEMENTS OR
   DEGRADATION

8. PROPOSED CHANGES TO SWMP

APPENDICES
Appendix A Clackamas County MS4 Permit Areas
Appendix B Known CCSD#1 Structural Controls and Outfalls
Appendix C Monitoring Reports for CCSD#1 and SWMACC
Appendix D MS4 Co-Permittee Coordinated Monitoring Plan
Appendix E Annual Reports for CRBC, RCCRS and SOLV

Appendix F Expenditures and Budget for CCSD#1 & SWMACC

Appendix G Summary of Permits Stormwater & Erosion Control Plan Review for
           CCSD#1 & SWMACC
1.0 INTRODUCTION
Background
Clackamas County Service District No. 1 (CCSD#1), the Surface Water
Management Agency of Clackamas County (SWMACC), the City of Happy
Valley, and the City of Rivergrove are Phase 1 co-permittees on the same
Municipal Separate Storm Sewer System (MS4) permit. The other Phase 1 co-
permittees on this same MS4 permit are the Oak Lodge Sanitary District,
Clackamas County, and the following cities: Gladstone, Johnson City, Lake
Oswego, Milwaukie, Oregon City, West Linn, and Wilsonville. (Phase 1
communities are generally those with a population of 100,000 or more.
Clackamas County co-permittees are classified as Phase 1 communities
because they meet this threshold collectively, though not separately.) The
Clackamas County MS4 permit was issued by DEQ on December 15, 1995, was
renewed by DEQ on March 3, 2004, and was modified by DEQ on July 27, 2005.

A joint Stormwater Management Plan (SWMP) was developed in 1993 for
CCSD#1 and SWMACC, pursuant to the (then pending) issuance of initial MS4
permits to Phase 1 communities in Oregon. The 1993 SWMP was updated in
2000. Further revisions were proposed in 2006 as part of the revised SWMPs for
CCSD#1 (includes the City of Happy Valley) and for SWMACC (which includes
the City of Rivergrove.)


District Demographics – CCSD#1
Clackamas County Service District No. 1 is administered by Water Environment
Services (WES), a department of Clackamas County.

Clackamas County Service District No. 1 includes the following four geographic
subunits:
   • Fischer’s Forest Park - in the Redland area
   • Hoodland - in and near Welches, Wemme, and Rhododendron
   • Boring - in the hamlet of Boring
   • Portland metropolitan area - Only the Portland metro area subunit of
      CCSD#1 is regulated by the MS4 permit. The remaining subunits serve
      rural areas or very small urban areas that are not within the Portland
      metro area’s urban growth boundary (UGB). This subunit is known as
      CCSD#1-UGB. The developed area of the City of Happy Valley lies within
      CCSD#1-UGB, and the remainder of Happy Valley will be annexed to
      CCSD#1 as it is developed. With the exception of small portions of the
      Cities of Gladstone and Damascus, the balance of the area in this
      urbanized subunit is unincorporated.

Table 1 is a summary of current land use acreage and associated runoff
coefficients (taken from Section 2.4.7.1 of the Oregon Department of
Transportation Hydraulics Manual) in CCSD#1-UGB. The runoff coefficient


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               1
indicates the percentage of rainfall expected to leave a site as runoff during any
given storm event.


              Table 1
              Land Use           Area        Runoff Coefficient
                               (acres)
              Agriculture         24                0.50
              Commercial         760                0.70
              Industrial       1,654                0.80
              Undeveloped        337                0.20
              Open Space         339                0.25
              Other               44                0.35
              Residential      7,623                0.60
              Streets          2,320                0.90
              Total           13,101                  -


The table below compares the number of ESUs in July 2005 and 2006, for
residential and commercial/industrial land uses:

           ESUs                       July 2005 July 2006 Change
           Residential                 14,213    14,972    759
           Commercial/Industrial       29,112    29,112
           Total                       43,325    44,084

An equivalent service unit (ESU) is defined as 2500 square feet of impervious
surface, the assumed average for a single family home. The number of ESUs
listed for July 2005 and 2006 are based on CCSD#1 customer billing records.
Excluding roadways, the amount of impervious area in CCSD#1 increased by 44
acres (749 ESUs) during the last year. Based on aerial mapping, new roadways
(not reflected in customer billing records) are estimated to account for an
additional 50% increase in impervious area, or an additional 22 acres over the
last year. This rate of growth is expected to continue through the next reporting
year.

Appendix A shows the entire area of Clackamas County within the Portland UGB,
which includes all MS4 co-permittees. Appendix B shows structural controls and
outfalls in CCSD#1-UGB.

District Demographics - SWMACC
SWMACC is administered by Water Environment Services (WES), a department
of Clackamas County.

The City of Rivergrove lies within SWMACC. Some urbanized, unincorporated
lands are also within SWMACC. While SWMACC includes the City of Rivergrove


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             2
and all of the unincorporated lands in Clackamas County that drain to the
Tualatin River and Lake Oswego, only the urbanized portion of SWMACC within
the Portland metro area’s UGB is regulated by the MS4 permit.

Table 3 is a summary of current land use acreage and associated runoff
coefficients (taken from Section 2.4.7.1 of the Oregon Department of
Transportation Hydraulics Manual) in SWMACC-UGB. The runoff coefficient
indicates the percentage of rainfall expected to leave a site as runoff during any
given storm event.

              Table 3
              Land Use        Area (acres)    Runoff Coefficient
              Agriculture          2.8              0.50
              Commercial           3.6              0.70
              Industrial           0.0              0.80
              Undeveloped          0.0              0.20
              Open Space           0.0              0.25
              Other                0.0              0.35
              Residential        743.0              0.60
              Streets            120.0              0.90
              Total              869.4                -

Appendix A shows the entire area of Clackamas County within the Portland UGB,
which includes all MS4 co-permittees and shows all of SWMACC, most of which
is outside the UGB.

Program Goals and Objectives
The overall goals of the Stormwater Management Plan are to:
   • Reduce the discharge of pollutants from the MS4 to the maximum extent
      practicable (MEP)
   • Protect and/or enhance the natural function of the surface water bodies
      that are within CCSD#1-UGB and SWMACC.

The specific objectives of the Stormwater Management Plan are to:
   • Involve and educate the public regarding opportunities to improve surface
      water quality and aquatic habitat in riparian areas to minimize nonpoint
      source pollution
   • Protect or improve the quality of the water in District’s rivers, streams, and
      wetlands through the cost-effective use of non-structural methods (i.e.
      Best Management Practices). These practices shall initially be focused on
      preventing point and nonpoint source water pollution. If stormwater
      pollution cannot be prevented, it will be controlled at the source.
   • Integrate the need to manage stormwater for both water quality and
      drainage benefits by emphasizing the use of natural systems (i.e.
      infiltration of stormwater into soil) whenever possible



MS4 Permit Compliance Report for CCSD#1 & SWMACC                             3
   •   Coordinate among government agencies, residents, trade associations
       and other ratepayers and groups to reduce the level of pollutants that
       enter the MS4.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                          4
2.0 RIVERS AND CREEKS
Rivers and creeks that receive discharges from the District’s MS4-permitted
areas, include but aren’t limited to, the following:

CCSD#1
• Johnson Creek
• Kellogg Creek
     Mt. Scott Creek
            Cedar Creek
                    Mel Brook Creek
            Dean Creek
            Phillips Creek
• Clackamas River
     Cow Creek
     Carli Creek
     Sieben Creek
            Rose Creek
            Sunshine Creek
     Rock Creek
            Graham Creek
            Trillium Creek

SWMACC
Rivers and creeks that receive discharges from the District’s MS4-permitted
areas, include but aren’t limited to, the following:

   Tualatin River
      Pecan Creek
      Saum Creek
      Wilson Creek
      Carter Creek (a Fanno Creek tributary)
      Rock Creek “South”
      Tate Creek




MS4 Permit Compliance Report for CCSD#1 & SWMACC                          5
3.0 STORM SEWER SYSTEMS
The Two Types of Separate Storm Sewer Systems
Surface-discharging storm sewer systems: In conjunction with Clackamas
County’s Department of Transportation and Development (DTD), the District
owns or operates surface-discharging storm sewer systems in the MS4-permitted
area. Most parts of the MS4-permitted surface-discharging storm sewer system
are comprised of piped storm sewers, but some swales and open ditches are
also present. It is important to note here that many privately owned surface-
discharging storm sewer systems are present near the District’s MS4-permitted
systems. These privately-owned surface-discharging storm sewer systems are
not regulated by the District’s MS4 permit. As is required by the Schedule
B(2)(b)(vi) of the MS4 permit, maps providing updated information [as described
in 40 CFR §122.26(d)(1)(iii)(B)] on the location of all known components of the
MS4 have been submitted to DEQ as an element of the SWMP. All new drainage
systems and controls constructed through private development or public works
projects are continually documented on as-built drawings and GIS maps. Many
archived drawings of older systems have also been compiled and added to
county databases. Known surface-discharging facilities are shown in Appendix B.

Injection-type storm sewer systems: DTD and the District jointly manage about
150 injection-type storm sewer systems that are in or near CCSD#1. DTD and
the District jointly manage about 50 injection-type storm sewer systems near the
SWMACC District’s MS4-permitted area. Discharges from injection-type storm
sewer systems are not regulated by any MS4 permit, but they are regulated by
the federal Safe Drinking Water Act and Oregon’s OAR 340, Division 44. The
District and DTD jointly applied for an area-wide Water Pollution Control Facility
(WPCF) permit from DEQ for these devices on December 19, 2001. As of
January 2006, this WPCF permit had not been issued. Nearly all of these
stormwater injection devices are drywells. A separate stormwater management
plan guides the District’s and DTD’s stormwater management programs in the
geographic areas that drain to drywells.


Major Outfalls
Publicly owned storm sewers which discharge to surface waters can be divided
into two categories: major and minor. The Environmental Protection Agency
(EPA) defines a major outfall as one that is:
    • a single pipe 36” in diameter or greater, or
    • a single conveyance other than a circular pipe serving a drainage area of
       more than 50 acres, or
    • a single pipe 12” in diameter or greater if the outfall also receives any
       drainage from lands zoned for industrial activity, or
    • a single conveyance other than a circular pipe which receives drainage
       from more than two acres of land zoned for industrial activity.



MS4 Permit Compliance Report for CCSD#1 & SWMACC                            6
Minor outfalls are all other publicly owned storm sewer outfalls which discharge
to surface waters. Twenty-nine (29) major outfalls are located in CCSD#1-UGB.
In an effort to identify and, if appropriate, control illicit discharges, each major
outfall receives at least one dry-weather inspection per year. See section 4.6.4
for more information.

Conveyance System Components and Structural Controls
The District owns and/or maintains a large number of structures that provide a
stormwater treatment function. They include, but aren’t limited to, the following:
vegetated aboveground stormwater detention facilities, swales, sedimentation
manholes, and various types of underground proprietary pollution control
systems. Inventoried facilities include roughly 8000 catch basins and manholes,
255 miles of storm sewer pipes, 182 detention ponds, 750 detention pipes, and
31 treatment facilities (swales and underground devices). Maps with the location
of many of these devices were submitted to DEQ as an element of the revised
SWMP (see Appendix B). The District regularly evaluates opportunities to install
additional structural controls. See sections 4.1 and 4.2 for more information.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                              7
4.0 STATUS OF STORMWATER MGMT. PROGRAM
    IMPLEMENTATION
According to the MS4 permit’s schedule D(2)(c), the following elements are
required to be present within the District’s SWMP. These elements, which rely
upon the implementation of Best Management Practices (BMPs), reduce the
discharge of pollutants to the maximum extent practicable (MEP).


4.1   Maintenance [Schedule D(2)(c)(i)(1) and (3)];
This section is divided into three portions:
   a) Conveyance System Components, Structural Controls and additional
       maintenance activities
   b) Street Sweeping
   c) Other O & M for public streets

4.1.1 Conveyance System Components, Structural Controls and
        Additional Maintenance Activities
The conveyance system components that are maintained by the District and DTD
include culverts, storm sewer lines, ditches, and inlets that are located in the
right-of-way of publicly owned roads or in a storm drainage easement. The
conveyance system also includes a large number of structures that provide a
significant stormwater treatment function. They include, but aren’t limited to, the
following: vegetated aboveground stormwater detention facilities, sedimentation
manholes, and various types of underground proprietary pollution control
systems. The strategy for the overall system is to interdict debris and other
materials before they gain entrance into the pipes. The District’s maintenance
focus, therefore, revolves around catch basins, pollution control manholes and
other “debris capturing” structures. These facilities are regularly inspected and
maintained on an as-needed basis. Maintenance records are kept by the both
DTD and the District.

While a majority of the newer storm systems have been inventoried and given
identification numbers, a portion of our system is still in the process of being
identified. Part of the maintenance procedure is to identify those structures as
encountered. Multiple structures were identified and mapped during cleaning this
permit year.

Implementation schedule:
This portion of our stormwater maintenance program is in a state of transition as
the District accelerates its role in the overall stormwater program. DTD previously
played a primary role in the District’s maintenance efforts but will now be scaled
back to a support role only. The District is directly responsible for maintenance
agreement areas (all subdivisions constructed since 1998) and is phasing in the
CCSD #1 road rights-of-way at this time. The transition period resulted in a
temporary decrease in some of the maintenance categories. Further, the
maintenance progress was interrupted several times due to the Aquatech


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            8
Combination truck experiencing mechanical failures that resulted in almost two
months of downtime.

Measurable performance indicators:
   • miles of ditches maintained
   • number of components inspected and/or cleaned, and/or
   • mass or volume of material removed during cleaning

Conveyance System Components & Structural Controls
Stormline cleaning
SWMACC       570 linear feet of storm line cleaned, .65 ton of sediment removed

Culvert cleaning
SWMACC       13 culverts cleaned, 1.0 tons of sediment removed

Ditch cleaning
SWMACC 5,780 linear feet of ditch cleaned, 283 tons of sediment removed

Catch basin cleaning
CCSD#1       1832 catch basins were cleaned, over 350 tons of sediment
removed
SWMACC 31 catch basins cleaned, 3.45 tons of sediment removed

TV storm drain pipe
SWMACC 92 linear feet of storm line TV'd.

Drywells
CCSD#1       12 drywells cleaned, 3.6 tons of material removed
SWMACC       10 drywells cleaned, 6.1 tons of material removed

Manholes
CCSD#1       734 manholes cleaned, 123.35 tons of material removed
SWMACC       2 manholes cleaned, .20 tons of material removed

Control Structures
CCSD#1        16 Control Structures cleaned, 10.7 tons of material removed

Some of the areas that require maintenance are not safe to clean during normal
working hours or periods of high traffic flow. To address this crews performed
one “night” cleaning this winter that involved several high traffic areas. These
included Sunnyside Road and 122nd avenue.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                                  9
Total amount of material removed through Conveyance System Component
Cleaning:

   District         2003-2004         2004-2005          2005-2006
CCSD1             67.4              280.8              487.8
SWMACC            381.5             254.6              294.4
                  448.9 tons        535.4 tons         782.2 tons



Additional System Maintenance Activities

Maintenance Agreement Program
The majority of cleaning efforts for CCSD#1 centered on systems associated with
the Subdivisions in the Maintenance Agreement Program. These 240+
subdivisions are in a wide range of development stage and life cycle. Cleaning
of the systems in these areas intercepts the material before it van enter the
public system. Each development may have different factors that will affect the
level and frequency of maintenance. The goal is to maximize cleaning efforts by
targeting those developments that are in higher risk areas for sediment transfer
and in early stages of development completion.

Staff performed several major retrofit projects and major clean ups of detention
ponds. For example, at the 92nd Ave. pond staff modified the outlet, removed
approximately 30-50 yards of sediment, built two additional wetland/wet areas,
and planted around 500 native plants. The Addington Place Subdivision Pond
was addressed by repairing a major sinkhole in the wall of the pond. Brush was
also removed along with several yards of sediment near the outlet. The adjacent
trail was also repaired and chips spread along its length.

One major repair of a storm system within a Maintenance Agreement Subdivision
occurred this year. The homeowner called to report a six-foot deep sinkhole near
a manhole in her backyard. This manhole had a 6” storm line that had shifted and
was leaking. The problem was over 8’ deep but staff were able to dig up the
connection by hand and make repairs.

Detention Pipes/Tanks
No detention pipes were cleaned during this permit year however upwards of
thirty systems were inspected as part of the cleaning and inspection program.

Detention Ponds
In May, a temporary employee was hired to find, catalog and evaluate the
detention ponds and other open facilities in our District. Data collection included
gathering information regarding vegetative cover, invasive species locations and
concentrations as well as recommendations for maintenance needs. This project
is currently still underway.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            10
CCSD#1 has a contractual relationship with the Clackamas County Corrections
crew, which allows their utilization for pond maintenance. The current agreement
is for these crews to work on maintenance three (3) days a week. This
maintenance work on ponds includes trash removal, weeding/brushing and
planting of native plants. Throughout the year these crews performed
maintenance at 80 out of 125 ponds. Many of these ponds were visited multiple
times. Crews also planted over 3000 native plants during the winter months at
several ponds and at the Rose Creek property.

Along with routine weeding and brushing staff have sprayed for invasive species
at several of the ponds and in other open spaces. Staff continues to coordinate
with several homeowner associations and property management firms to
manage expectations, level of efforts and future projects. One of these is a
wetland enhancement project that is planned for completion in the summer of
2007. Originating as a complaint and emergency call out during the winter
months in the Happy Valley Heights Subdivision, this project is underway and a
DSL & Army Corps of Engineers Permit has been acquired. Additional
coordination is occurring with the City of Happy Valley.

Flood Control Facility
Staff repaired several access grates that were vandalized. Trash was removed
and additional locks and chains were installed. This facility was tested in
December 2006 and maintenance was performed on the access roadway three
(3) times during the permit year.

Phillips Creek Ponds
These ponds were maintained six (6) times during the year. Trash and other
debris were removed. Weeding and brushing activities were also performed as
well as a bit of spraying for invasive species.


4.1.2 Street Sweeping
Major arterial curbed streets are swept on a regular basis. The frequency varies
depending on a variety of factors (for example, traffic volumes).

Implementation schedule: Ongoing effort.

Measurable performance indicators:
   • number of miles that were swept, and/or
   • mass or volume of material removed during sweeping




MS4 Permit Compliance Report for CCSD#1 & SWMACC                          11
CCSD#1
Clackamas County Department of Transportation and Development (DTD)
crews are responsible for cleaning and maintaining stormwater systems within
County-maintained rights-of-way within the Districts’ boundaries and for street
sweeping.

Street sweeping removed approximately 1,705.5 cubic yards of material from
1639.59 miles of streets. This amount is for the entire County, which includes
areas within the Districts’ boundaries.

Happy Valley
City crews are responsible for street sweeping inside of the City limits.

Reporting the level of street sweeping for the City was proposed as part of the
revised SWMP in May 2006 and as such will be implemented in the 2006-2007
permit year.


4.1.3 Other Operation & Maintenance for Public Streets

Descriptions:
  • Road repair activities: These are conducted by DTD in a manner that
      minimizes or prevents erosion. When possible, this work is scheduled
      during the dry season.
  • Litter control: This involves 1) the removal of large dead animals from
      roadways, 2) preventing illegal solid waste dumping through signage and
      enforcement actions against offenders, 3) removal of illegal solid waste
      dumps, and 4) DTD’s “Adopt A Road” program, which enlists support for
      litter removal on specific road segments from individuals, families,
      community groups and businesses.
  • Ice removal work: This is performed by DTD on certain paved streets on
      an as-needed basis. The frequency varies depending on a range of
      factors, including personnel availability, air temperature, road surface
      temperature, humidity, and precipitation.
  • Road sanding: This enhances traction during ice/snow events. After the
      ice/snow event, when practical, the sand is removed from the roadway
      with mechanical sweeping machines.

Implementation schedule: Ongoing effort.

Measurable performance indicators:
   • number of miles of road enrolled in the “Adopt A Road” program
   • mass or volume of material removed by the “Adopt A Road” program
   • number of illegal solid waste dumps removed
   • mass or volume of material removed by the elimination of illegal solid
     waste dumping sites


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            12
NOTE: As these activities are conducted under the authority and budget of the
Clackamas County Department of Transportation and Development (DTD), the
measurable performance indicator specifics can be found in the Annual MS4
Report submitted by DTD.


4.1.4 Miscellaneous Maintenance Activities
      (Small Projects and Complaint Resolution)

Small projects – CCSD#1
  • Responding to a homeowner complaint of flooding and erosion in Happy
      Valley, District staff dug up and replaced a broken storm line that was
      severed by a contractor working for WES during a sanitary sewer lateral
      installation a year earlier at the location of SE 132nd and SE Meadow Park.
  • An investigation into erosion complaints from an outfall that was not
      installed correctly lead to the installation of a new outfall and the addition
      of 20 cubic yards of rip-rap to protect private property and the storm
      drainage easement located at the dead end of SE Lucille St., in Happy
      Valley.
  • Due to a homeowner complaint at the Holly Tree Mobile Home Park,
      located near the Johnson Creek Blvd. Home Depot Store, District staff
      negotiated with the property manager for repair of two “Lynch” type catch
      basins to prevent flooding of the roadway and pollution from entering the
      public storm system.
  • A customer complaint was received regarding surface water flow into their
      property from 3 neighbors who did not have their rain drains hooked up to
      the laterals that were provided to the storm system. District staff worked
      with the homeowners of Anderegg Park in getting this drainage issue
      resolved.
  • Due to flooding and safety concerns, DTD Road Department installed 8
      asphalt berms for WES to relieve the flooding problems on SE Crest
      Drive, SE Thiessen Rd, SE Vista Lane, SE Clackamas, SE Vista View
      Lane, SE Johnson Rd, SE Overland & SE Hill Rd.
  • Due to public safety concerns of flooding and erosion on SE Beech St.,
      District staff contracted with DTD Roads to repair and pave around a catch
      basin so that water would actually go into it.
  • Responding to a homeowner complaint, a new partition that was being
      constructed on SE 96th & SE Idleman was flooding the neighbor due to the
      problem of a storm drainage pipe to the detention pond. District staff met
      with the developer dug up & repaired all of the fittings thus containing all of
      his detained water on site.
  • Due to a community concern and complaint District staff met with the
      homeowners around SE 105th and SE Charlotte to discuss issues with
      problems of builders in the areas. Met with the builders who then installed
      storm drainage pipe and catch basins on SE 105th, which is a non-County
      maintained Road.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             13
   •   District staff met with the Homeowners Association at Altamont to help
       them install 2 catch basins and road pavement repair in their
       neighborhood on SE Cambray. Their road is a non-County maintained
       road.
   •   Installed a catch basin for the City of Happy Valley’s requested help on the
       corner of SE 132nd and SE Clatsop Rd.
   •   Met with City of Happy Valley staff to solve problem with poor drainage
       and flooding issues in an open space area. District staff hired the
       Community Corrections Crew to hand dig and remove brush to contain the
       water in the stream and to channel and convey it to where it is supposed
       to go.
   •   Worked with the developer for the Cardinal Terrace Sub-Division to look at
       and re-plan the bypassing of a dry well on SE Jennings Rd. The new
       drainage will connect to an existing outfall to Kellogg Creek.
   •   Responding to a flooding complaint near the corner of SE Thiessen Rd
       and SE Webster. The Field Operations Crew vactored and cleaned the
       plugged catch basin and T.V.’d the line.
   •   Responding to flooding at Hines Trucking Co. off of HWY 212, District staff
       advised the company how to avoid future flooding and by using the Field
       Operations Crew, cleaned 200 ft. of storm sewer line and T.V.’d 250 ft.
   •   The District staff dug a drainage swale between the new home
       development: Dew Point and a homeowner on SE Jennings Ave. A storm
       drainage easement was created and this was put in place to help the
       homeowner avoid future surface water runoff from this subdivision.
   •   Residents needed help from flooding and drainage from a “blown off”
       manhole lid on SE Spring Mountain Rd. Field Operations cleaned the pipe
       and stopped the overflowing from the manhole
   •   Due to downstream flooding and erosion from the Thiessen Heights
       subdivision, District staff contracted out a project to lay 450 L.F. of 12-inch
       storm drainage pipe and 8 rain drain laterals to pick up water in a drainage
       swale that was no longer working and conveying it to the detention pond
       where it was supposed to be flowing.
   •   Helped the City of Happy Valley with a catch basin outfall project on SE
       Monner Rd. The District contracted with the DTD Road Department to
       repair the outfall and lay 20 cubic yards of riprap down to protect the
       stream from erosion.
   •   Field Operations Crew repaired a storm sewer manhole lid near the corner
       of SE 142 and SE Territory Dr.
   •   District staff fixed and repaired a sink hole in a storm drainage easement
       by repairing the broken storm line that was connected to an underground
       detention tank located at SE 142nd and Sieben Creek Dr.
   •   Due to flooding issues at Wildlife Estates, District staff cleaned out all of
       the debris and vegetation that was blocking the conveyance at the inlet to
       the storm system
   •   DTD Roads completed a flooding and drainage project on SE Rainier Rd
       with the addition of gravel and shoulder smoothing for the District.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                              14
   •   DTD Roads installed 10 L.F. of 12-inch storm line and connected it to an
       existing catch basin and armored the road shoulder for the District near
       the corner of SE Thiessen and SE Hill Rd.
   •   District staff laid gravel on the shoulder of SE Oetkin Rd to convey water
       into the existing catch basin located there.
   •   District used the Community Corrections crew to hand dig 300 L.F. of ditch
       and lay 300 L.F. of 6-inch perforated pipe on Mr. Austria’s property located
       off of SE Valley View Terrace Rd, to prevent erosion of the hillside caused
       by the developer who had severed the storm sewer line.
   •   District staff crew filled in potholes on SE Elderberry and SE Hill Rd. with
       “cold patch” caused by blocked stormwater conveyance system on SE Hill
       Rd., working with DTD Engineering to finish the job and replace the catch
       basin and pipe.
   •   District staff completed re-ditching a drainage swale in Happy Valley off of
       SE Mt. Gate Drive and SE Blaze Rd. Three down stream homeowners
       were being impacted by this clogged swale.
   •   District staff opened up a clogged and buried outfall on SE 127th and SE
       Regency. SE Regency was flooding because the outfall was located under
       6 feet of fill. A new drainage swale was then added, armored, and erosion
       control measures put into place.
   •   District staff hand dug a short ditch on Cedar Creek to drain a small pool
       that a homeowner thought might contain the West Nile Virus mosquitoes
       at the location where SE Mather Rd. crosses over creek.

Small Projects – SWMACC
  • Continuing a preventive maintenance program on drywells, WES Field
      Operations raised 2 drywell lids to improve the ability to locate and
      maintain this system.
  • WES Field Operations sprayed herbicide on a storm drainage easement
      on SW Pilkington Rd to prevent the grasses and weeds from overtaking
      the drywell and Stormceptor located there.
  • Repaired 2 catch basins on SW Borland Road.
  • Repaired three ditch inlets and 2 catch basins on SW Stafford Rd.
  • WES Surface Water had DTD Road Department install one catch basin,
      45 L.F. of 12-inch storm sewer pipe and connect it to an existing dry well
      located on SW Kenny Ave.
  • Repaired 1 catch basin and 10 linear feet of 12" storm sewer on SW
      Johnson Road.
  • Replaced 30 feet of cross culvert on SW Mossy Brea
  • Staff worked on SW Shadow Wood Drive, fixing and repairing a sink hole,
      drain pipe, and laying gravel in the affected area.
  • A homeowner on SW Lake Forest Blvd had concerns with standing water
      on the shoulders. Staff met on site with the DTD Road Department and
      had them smooth the shoulders and add gravel to fill the low spots




MS4 Permit Compliance Report for CCSD#1 & SWMACC                            15
Complaint Resolution – CCSD#1
Due to numerous complaint investigations involving flooding, erosion, and public
safety concerns:
   • Met with the president of Portland Trucking on SE Jennifer to address
       issues of tracking mud onto the road. He installed a wheel wash area and
       invited District staff back to review it.
   • Worked with DTD Engineering to relive a surcharged cross culvert on SE
       124th in Clackamas, which was causing neighborhood flooding and water
       quality problems.
   • Contracted with the Community Corrections Crew to remove debris
       around the large cross culvert under SE 122nd, which flooded during a rain
       event due to plugged inlet side of the culvert.
   • Worked with the City of Happy Valley in relieving a large erosion problem
       caused from a subdivision on to private property located on SE Callahan
       Rd.
   • Worked with the City of Happy Valley on 43 different water quality issues
       ranging from ditching work, erosion complaints, drainage problems, vector
       control, problem solving to complaint resolution.
   • District staff “witched” 2 buried storm lines. Found them at SE 106th and
       SE Sunnyside and SE 127th and SE Regency.
   • Removed the silt sack in catch basin on SE Spencer Ct. due to the
       complaint of homeowner that the street was flooding and construction was
       completed in the partition.
   • Homeowner on SE Pinegrove Loop was concerned about sinkhole in the
       open space area behind her home. Her drainage was eroding the location
       of the underground detention and Surface water gave her suggestions
       how to fix the problem.
   • Homeowner on SE 153rd drive was concerned about possible flooding
       from a detention pond next to their lot. District staff worked on the pond to
       clear old debris and keep the outlet structure free from brush and
       clogging.
   • District staff met and helped a homeowner on SE Mary Ann Lane with
       solving their rain drain drainage problem.
   • Met with homeowner on SE Sunnycreek Lane and showed them how the
       drainage swale will protect them from flooding and asked the homeowner
       to remove debris as it builds up on the inlet grate to help keep the surface
       water in the swale.
   • Homeowner on SE 119th near Echo Valley had a cross connection from
       her kitchen sink to the catchbasin in the street. Her sink was flooding
       when the rain drains were full and she had a plumber come out and fix her
       cross connection.
   • District staff helped a property owner on site at SE Glendon Drive work
       with the neighboring developer solve a drainage and erosion issue coming
       off of that site.
   • District staff helped mediate a neighbor-to-neighbor drainage dispute on
       SE Sunnyview Court.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             16
   •   District staff helped homeowners with an Oregon Drainage Law dispute on
       SE Dagmar Rd. The property owners were very pleased with the response
       and will work on their issues.


Complaint Resolution - SWMACC
  • Helped homeowner resolve “neighbor to neighbor” issue on SW Boones
     Ferry Rd. by redirection of his rain drains.
  • Looked at a drainage complaint on SW Dogwood Lane, then helped the
     homeowner work with the City of Lake Oswego to get the sanitary line
     connected.
  • Resolved the rain drain termination for a homeowner on SW Knaus
  • Resolved a drainage issue on SW Terry Ct.
  • Replaced a stormwater manhole lid on SW Benfield Rd.
  • Resolved a drainage issue by opening a blocked ditch inlet on SW
     Pilkington Rd.
  • Helped resolve a neighbor to neighbor drainage issue on SW Charles Ct.
  • Instituted a plan to stop flooding on SW Kenny Ave.
  • Spoke with a homeowner on SW Mossy Brae who was interested in buffer
     issues and a stream restoration grant. She was referred to Hilda Stevens
     for any additional information to help provide her contact information for
     SOLV and Friends of Trees.
  • District staff worked with the residents of SW Firwood to help them solve
     their standing water problems by using the DTD Road Department to
     shape the road shoulder and fill in some of the low spots on the shoulder
     with gravel.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                        17
4.2    Planning Procedures for New Development and Significant
       Redevelopment [Schedule D(2)(c)(i)(2)]

The Districts use the following planning procedures for developing, implementing,
and enforcing controls to reduce the discharge of pollutants from storm sewers
collecting runoff from areas of significant development or redevelopment. These
controls include county-funded capital improvement projects to provide new
stormwater treatment facilities in previously developed areas and regulations
requiring such facilities with all new land development or redevelopment projects.
All new developments are also required to infiltrate runoff from frequent low-
intensity rain events in order to limit the increase in runoff volume from urban
development and provide groundwater recharge to maintain dry weather
instream base flows.

Implementation Schedule:
     • For retrofitting systems constructed prior to CCSD#1 adoption of
       stormwater treatment requirements in May 2000, CCSD#1 has identified
       seven (7) major outfalls to be retrofitted with stormwater treatment
       devices, with a portion of the funding for construction possibly eligible for
       EPA grant funding. Design of these stormwater quality improvements is
       complete, and construction is scheduled for the summer of 2007.
       CCSD#1 plans to conduct future feasibility studies to identify additional
       outfalls suitable for the installation of treatment facilities. Additional
       opportunities will be identified in coordination with roadway improvement
       projects to be planned by the Clackamas County Department of
       Transportation and Development (DTD). Detailed descriptions of these
       projects will be included in future annual reports.
     • For all new developments, implementation is ongoing.

Measurable Performance Indicators:
    • For developments occurring prior to CCSD#1 adoption of stormwater
       treatment requirements in May 2000, the indicator is the number of new
       treatment or infiltration facilities installed by CCSD#1 in previously
       developed areas. One such treatment facility was installed with the
       Amherst St. improvements, in conjunction with DTD. This facility serves
       approximately ½ acre of existing roadway that was repaved.
    • For developments occurring subsequent to CCSD#1 adoption of
       stormwater treatment requirements in May 2000, the number of
       treatment or infiltration facilities installed in accordance with these
       requirements. Between July 2005 and 2006, it is estimated that 25 such
       facilities have been installed, serving approximately 120 acres. (These
       estimates reflect the number of new subdivision applications processed
       and the increase in ESUs reported in Section 1. The number of new
       ESUs has been multiplied by an assumed average lot size of 7000 SF to



MS4 Permit Compliance Report for CCSD#1 & SWMACC                             18
       determine the area served by facilities constructed with each new
       subdivision.)




MS4 Permit Compliance Report for CCSD#1 & SWMACC                           19
4.3    Flood Management Projects and Water Quality
       [Schedule D(2)(c)(i)(4)]

The Districts have procedures to assess the impact of flood management
projects on water quality. In addition to the structural pollution controls discussed
in Section 4.2, District regulations also require protection of vegetated corridors
along stream banks to reduce temperatures, filter pollutants, and prevent
erosion. If streams or wetlands are believed to be present on a property
proposed for development, they must be delineated and a concurrence obtained
from the Oregon Department of State Lands (DSL). Proposed construction or
earthwork within the boundaries of a jurisdictional stream or wetland is referred to
DSL and US Army Corps of Engineers to determine if a joint fill-removal permit is
required.

CCSD#1
The District has also submitted a Flood Insurance Study (FIS) to the Federal
Emergency Management Agency (FEMA) delineating the previously unmapped
floodplain limits of the Rock and Richardson Creek watersheds, which have
recently been annexed to the Portland metropolitan Urban Growth Boundary.
Mapping these floodplains is a necessary first step to protecting their natural
functions when the watersheds are urbanized.

SWMACC
There are no known flood management projects in SWMACC’s MS4-permitted
area.


4.3.1 Sensitive Area Plan Review
Throughout 2005-2006, plans for development project sites were reviewed for
the presence of sensitive areas, including wetlands and stream corridors. Those
with sensitive areas on or within 200 feet of the site were reviewed for natural
resource buffers (in compliance with Metro Title 3). In some cases, developers
were unaware that wetland or riparian areas existed on their sites. Partially as a
result, staff worked to develop a buffer issue policy review paper for management
consideration and to coordinate plan review and permitting efforts with state and
federal agencies (Oregon Division of State Lands and US Army Corps of
Engineers). The buffer issue policy review paper was also submitted to
consultants currently working on the Stormwater Management Master Plan
Update Project. Additionally, with the Endangered Species Act listings present in
Clackamas County, Clackamas County Department of Transportation and
Development (DTD), continues to apply for federal grant funds for retrofitting or
placing new culverts in fish bearing creeks to allow fish passage, in coordination
with NOAA Fisheries or National Marine Fisheries Service (NMFS) and Oregon
Department of Fish and Wildlife (ODFW). DTD has entered into an



MS4 Permit Compliance Report for CCSD#1 & SWMACC                              20
Intergovernmental Agreement with ODFW for biological assistance and
permitting.

Nature in the Neighborhoods
Metro’s new Nature in the Neighborhoods program has been proposed to comply
with Statewide Goal 5 to protect significant fish and wildlife riparian and upland
habitats and will encourage local agencies to utilize low impact development
strategies and techniques beginning in 2009. WES is working with Metro and the
Clackamas River Basin Council and other partners during 2006 to participate in
grant projects related to low impact development with the development
community.

4.3.2 Buffer Violations and Enforcement
Twelve buffer and/or conservation easement violations were noted during the
permit year involving mainly private property owners or developers who were
removing vegetation or diverting streams with heavy equipment and working
within stream corridors and WES Sensitive Area buffer areas. All of these
violations continue to involve cooperation and education, coordination, mitigation,
and ongoing maintenance, monitoring, and reporting activities.

4.3.3 Surface Water Master Planning
Master Plans are to be updated to include water quality analysis and projects to
address water quality. This work is in progress and the status is as follows:

   •   Cow Creek Masterplan (December 1995)
   •   Sieben Creek Masterplan (December 1995)
   •   Kellogg/Mt. Scott Creeks Masterplan (October 1997)
   •   Johnson Creek Masterplan (October 1997)
   •   Rock and Richardson Creeks Masterplan (May 2001)
   •   Rock and Richardson Creeks Floodplain Study was begun in January
       2002 and was submitted to FEMA in February 2003. FEMA requested
       revisions to the hydrologic calculations in June 2004, which were
       submitted for approval along with floodplain maps and profiles in August
       2004. The revised hydrology has been approved, and the mapping
       submittal is presently being updated with new LIDAR data obtained
       through the Surface Water Management Program Masterplan. FEMA has
       issued draft DFIRMs for Rock and Richardson Creeks, but the public
       comment period and final adoption have not yet been completed.
   •    Upper Kellogg Creek Floodplain Study (March 2001) has been
       approved by FEMA.
   •   Water Quality Data Evaluation and Monitoring Plan (July 2000)
   •   Surface Water Management Program Masterplan This project is a
       complete review and evaluation of the WES’ Surface Water Management
       Program. It was tasked to analyze current practices, encompass updates
       of information from previous master plans, and potentially plan for the
       urbanizing area around Damascus. Selection of the consulting team and


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            21
       awarding of the contract occurred in the spring of 2004. The Masterplan
       was completed in April 2006 and is currently under review to identify and
       assess potential policy and program changes and impacts.
   •   Rock Creek Sanitary Interceptor Project WES staff conducted an
       inventory of Rock Creek from Highway 212 to Sunnyside Road during
       November 21-23, 2005 to assess in-stream and channel and habitat
       conditions.
   •   Stream Reach Evaluation Tool WES, in cooperation with Metro staff
       completed a stream reach evaluation tool to assess the urbanizational
       impacts of the Damascus Concept Plan on the Rock Creek sub watershed
       basin.

Stormwater Design Award Competition
WES has agreed to again serve as a sponsoring agency of Metro’s “10-years
later” review of the 12 winners of its 1996-1997 Stormwater Design Award
Competition. This effort evolves around a review panel reviewing the current
status of the winning sites as reported by the owner contacts. After a joint
sponsor-owner-review panel workshop a summary document would be prepared
on the lessons learned.

4.3.4 Instream Flood Management Projects
Only two instream flood management projects have been constructed in the
District: one on Phillips Creek and the other on lower Mt. Scott Creek. The
Phillips Creek Flood Control Facility was constructed by the Clackamas County
Development Agency in 1986, as part of the Clackamas Town Center
development. The District modified this facility in 2000, with hydraulic and
landscaping improvements designed to enhance its water quality functions. The
Mt. Scott Creek Flood Control Facility was constructed by the Clackamas County
Development Agency in 1996 after a flood event damaged industrial and
commercial businesses. The District is responsible for annual maintenance of
this facility. While the maintenance of this facility is routine and has been
performed without incident, several issues are of concern as they relate to the
operational structure. The remote nature of the area and the natural cover
results in attracting a transient element to this locale. Vandalism occurs where
walkway gratings are removed and dropped down the well. Additionally,
padlocks are routinely cut off of gates and electrical boxes. The District is
working with the Clackamas County Sheriff to tighten the security of this facility to
eliminate any chance that vandalism will interfere with the operational readiness
of this control structure and to reduce potentially negative environmental impacts
(e.g. litter and human waste) of the transient settlement.

The majority of District flood management systems are upland facilities designed
to detain runoff from developed areas. District regulations mitigate the impact of
urban development on natural stream hydrology. New developments must
provide detention for channel-forming (two-year recurrence interval) storm events




MS4 Permit Compliance Report for CCSD#1 & SWMACC                              22
in order to approximate pre-development runoff conditions and reduce impacts
on stream function and morphology.

Implementation schedule:
CCSD#1 is currently analyzing a design methodology for retrofitting existing
detention facilities in order to improve water quality performance. The District
anticipates completing such retrofits as pilot projects by the year 2007.
Subsequent monitoring of these modified facilities will provide a basis for
retrofitting additional systems in other watersheds throughout the District. In
addition, major redevelopment projects in the private sector will provide further
retrofit opportunities. One such example is the nearly 100-acre Clackamas Town
Center redevelopment that is currently in the plan review process. Detailed
descriptions of detention retrofit projects will be included in future annual reports.

Measurable performance indicators:
    • For assurance that flood management policies assess the impacts on
       the water quality of receiving water bodies for projects in the MS4-
       permitted area, the indicator will be the number of policies that are
       assessed and/or modified. Modification of current stormwater detention
       policies will occur pursuant to adoption and implementation of the
       Program Master Plan in 2007.
    • For assurance that existing structural flood control devices have been
       evaluated to determine if retrofitting the device to provide additional
       pollutant removal from stormwater is feasible, the indicator will be the
       number of devices that are assessed and/or retrofitted. During the last
       year, twenty-six (26) such facilities were assessed for retrofitting
       opportunities, and five (5) were selected to be retrofitted in 2007.


4.3.5 Natural Resource Management
Natural resource management provides benefits to water quality in a variety of
ways. Buffers can provide the following functions and values that contribute to
fish and wildlife habitat in urban streamside areas including but not limited to:

   •   Microclimate and shade;
   •   Stream flow moderation and water storage;
   •   Bank stabilization, sediment, and pollution control and filtration;
   •   Large wood recruitment and retention and channel dynamics;
   •   Organic material sources; and wildlife habitat patches, interior habitat,
       connectivity and proximity to water, and to other upland habitat areas.

Metro’s Nature in Neighborhoods Design for Habitat and Clean Water
Competition
WES has also agreed to sponsor Metro’s Nature in Neighborhoods Design for
Habitat and Clean Water Competition. This competition is designed to solicit
successful approaches to designing the built environment with nature in mind.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               23
Sites will be selected for design using innovative approaches. Competition
entrants will devise site plans and landscape designs for the sites, many of which
feature high quality habitats to be preserved or maintained. The goals are to
generate greater awareness and interest of best practices and innovative design
techniques for implementation, and build a collection of resources for the design
and development community to use.

Foster Creek Wetland Mitigation Bank Proposal
Staff attended meetings as a member of the Mitigation Bank Review Team. A
Mitigation Banking Instrument for the Foster Creek Wetland Mitigation Bank was
submitted by the Bank Sponsors for review to the U.S. Army Corps, DSL and
other MBRT members in May 2006. The corresponding Memorandum of
Agreement is expected to be finalized in 2007. The bank is located along Eaden
Road six miles east of Oregon City, and five miles southeast of Damascus. The
service area includes watersheds located within, and adjacent to the Fourth Field
Hydrologic Unit Code (HUC) Clackamas River Subbasin up to an elevation of
1200 feet mean sea level. The service area includes 186 square miles within the
fourth field HUC Clackamas River subbasin, and 141 square miles within
watersheds that drain directly to the Fourth Field HUC Middle and Lower
Willamette River subbasins.


Riparian and Wetland Restoration/Bank Stabilization

Stop Oregon Litter & Vandalism (SOLV)
Stop Oregon Litter & Vandalism (SOLV) work parties were held throughout
Clackamas County at the following sites: Addington Place Greenway, Canby
Community Park, Carter Creek, Clackamas High School, Colton Creek, Cow
Creek, Fields Creek, Goat Island, Holcomb Creek, Mt. Scott Creek (Bischel and
Calder properties), Oregon Trail, Phillips Creek, Sunrise Wetlands, and Wilson
Creek. 1,197 volunteers and 470 students contributed 698 hours in removing
50,960 pounds of green debris and planting more than 4,800 native plants.

City of Portland Bureau of Environmental Service’s (BES) Watershed
Revegetation Program
WES entered into an Intergovernmental Agreement with the City of Portland
Bureau of Environmental Service’s (BES) Watershed Revegetation Program to
perform native plantings and invasive plant removal and maintenance services at
the City of Happy Valley Park Wetland Mitigation site. This site was permitted
through the U.S. Army Corps of Engineers and the Department of State Lands as
a result of construction impacts associated with roadway improvements and two
regional stormwater detention facilities. More than 4,800 native plants were
installed throughout the 8.2 acre site. Maintenance of the site to control invasive
species will be continued on an annual basis through 2008.

Friends of Trees (FOT)



MS4 Permit Compliance Report for CCSD#1 & SWMACC                            24
WES entered into a four-year contract with Friends of Trees (FOT) for planting,
invasive plant removal, and maintenance services for the Spring Mountain
project. A dam was removed on Mt. Scott Creek during 2003 through federal
funding and this contract will ensure native plant survival and maintenance of
invasive plant species through 2008.

Friends of Trees worked on four other additional sites during the permit period
and the following volunteer hours related to maintenance including but not limited
to: cutting; shearing, and pulling non-native invasive species; native plantings;
and transect monitoring activities were documented and reported:

Echo Valley Wetlands – 4 site visits, 9 volunteers, and 9 hours.
Spring Mountain – 6 site visits, 940 native plants installed, 23 volunteers, and
120 hours.
Three Creeks – 6 site visits, 1,400 native plants installed, 43 volunteers, and 258
hours.
Trillium Creek – 3 site visits, 300 native plants installed, 8 volunteers, and 48
hours.
Hearthwood Wetland – 3 site visits, 400 native plants installed, 28 volunteers,
and 116 hours.

Tsunami Crew
WES is supporting the Tsunami group’s efforts to remove invasive species and
replant native species within the Three Creeks Natural Area. The Three Creeks
Natural Area is below the North Clackamas Aquatic Park. It consists of 80 acres
and includes an area where Phillips Creek, Deer Creek, and Mt. Scott Creek
come together. The area also consists of a regional park and flood control
facility. Over the past five years, this small group of dedicated volunteers has
removed tons of invasive species and planted more than 13,000 native plants.
The Tsunami crew spends 2-3 days per week in this area and has logged more
than 8,000 volunteer hours.

WES in partnership with eight other community partners applied for a Metro NIN
Community Challenge for Watersheds grant. The overall project goal is to
reduce and eventually eliminate the use of this critical habitat area by transients
by performing more frequent Sheriff’s patrols, thereby reducing the need and
expense of additional cleanups. Four objectives of the grant project include: 1)
conducting more frequent (monthly) patrol sweeps; 2) performing cleanups
(estimate of four) of illegal dump sites; 3) carrying out three volunteer planting
events to install 5,000 additional native plants; and 4) conducting community
outreach through a public awareness campaign. The community partners
include: Waste Management; Tsunami Crew; Friends of Trees; Friends of
Kellogg and Mt. Scott Creeks Watersheds; WES; and the following Clackamas
County Departments: Code Enforcement; Sheriff’s Office; Parks & Recreation
District; Community Corrections.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                             25
MS4 Permit Compliance Report for CCSD#1 & SWMACC   26
4.4    Pollutants in Runoff Fromm Closed Landfills
       [Schedule D(2)(c)(i)(5) and Schedule D(2)(c)(iii)]

CCSD#1
Two landfills appear to be located within the CCSD#1 MS4-permitted area. They
are:

McFarlane’s Bark Inc. (13345 SE Johnson Road)
This manufacturing facility may not actually be a landfill, but information on this
facility has been submitted to the DEQ on a regular basis to ensure that
CCSD#1’s landfill waste/stormwater monitoring-related requirements are met.
The facility receives yard debris and other green and woody materials, but it does
not accept other solid wastes. These materials are processed into compost and
soil-amending products that are then exported from the site. This facility
possesses a 1200Z Stormwater Discharge Permit. The facility’s 1200Z permit is
administered by DEQ, and the facility’s owners/operators are required under this
permit to monitor for pollutants in the facility’s runoff. In addition, it is WES’
understanding that this facility does not discharge stormwater or other flows into
the MS4; the facility’s stormwater flows directly to Mt. Scott Creek via storm
sewer systems that are privately owned. For these reasons, a) WES did not
monitor the facility during the reporting period, and b) there is no MS4 permit
“measurable performance indicator” for this facility.

Johnson Creek Landfill/Lavelle Landfill (7600 SE Johnson Creek Blvd.)
This landfill has been closed since 1973. Although it may be possible that runoff
or leachate from this property could be capable of entering the County-owned
storm sewer system segment that terminates at Outfall #7 (aka. the SE Johnson
Creek Blvd. Outfall), that determination has not been made with absolute
certainty. WES personnel perform dry-weather outfall inspections at Outfall #7
on an annual basis. The annual inspection for this reporting period was
conducted on August 18, 2005. During this inspection, WES personnel verified
that no fluid of any type was entering the storm sewer system from this property
at that time. Discharge from the landfill or the area near the landfill has never
been detected by WES during these annual inspections.

Implementation schedule: This work item has already been implemented.

Measurable performance indicators:
The measurable performance indicator for the Johnson Creek Landfill/Lavelle
Landfill is the number of outfall inspections that are performed which confirm that
flow (i.e. leachate or stormwater runoff) is not leaving the closed landfill. If flow is
ever confirmed to be leaving the landfill, a second measurable performance
indicator (measurement of the flow’s water quality), will then also apply.

SWMACC
There are no open or closed landfills in SWMACC’s MS4-permitted area.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                                 27
4.5    Program to Reduce Pollutants in Discharges Associated
       With the Application of Pesticides, Herbicides and
       Fertilizers [Schedule D(2)(c)(i)(6)]
The program to reduce pollutants to the MEP for discharges from the MS4 that
are associated with the application of pesticides, herbicides, and fertilizers is
divided into these five sections:
A. Public Education
B. Disposal of Unwanted Quantities and Containers
C. Road Maintenance
D. Landscape Maintenance
E. Scientific Research

A description of the work that was conducted during the 2005-2006 reporting
period within each of these five programmatic areas is provided below.

4.5.1 Public Education Program
WES administers a public education program which provides information that
motivates those who live and work in the MS4 area to reduce stormwater
pollution that is caused by the application of pesticides, herbicides, and fertilizers.
Common topics that are addressed by this program include:
    • Less harmful alternatives to the use of pesticides, herbicides, and
        fertilizers are provided. For example, use of ladybugs to eat insect pests
        is encouraged as an alternative to pesticide application.
    • Information is provided about the potential hazards to water quality, public
        health, and aquatic life associated with the misuse of pesticides,
        herbicides, and fertilizers.
    • Users are reminded that pesticide and herbicide products need to be used
        in a manner consistent with the product’s label.

The following is a partial summary of work that was conducted during the 2005-
2006 reporting period (A complete listing of Public Education Activities can be
found in Section 4.11.1.


Intergovernmental Coordination

Regional Coalition for Clean Rivers and Streams
  In response to shared needs to meet NPDES municipal stormwater permit
  requirements, WES joined with a number of other jurisdictions in 1994 to form
  the Regional Coalition for Clean Rivers and Streams to develop and
  implement a five-year coordinated pollution prevention awareness campaign.
  Members of the Regional Coalition of Clean Rivers and Streams (RCCRS)
  include the City of Portland, Clean Water Services, City of Gresham, and the


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               28
   Clean River Partners of Clackamas County (Milwaukie, Rivergrove,
   Gladstone, Happy Valley, Oak Lodge Sanitary District, Wilsonville, Lake
   Oswego, Oregon City and West Linn) to combine resources in developing an
   advertising campaign that addresses stormwater in the Metro area.

   This cooperative effort resulted in a $67,000 annual budget media campaign
   targeting more than one million residents of 26 cities in the tri-county area.
   The campaign uses a combination of media to reach a broad audience with a
   water quality/pollution prevention message. The message, media and
   effective number of residents reached by the campaign are outlined in the
   annual report attachment. This past year’s campaign utilized bus transit signs,
   bilingual (English/Spanish) newspaper print, print media ads, and social-
   marketing incentives. The website was updated and social-marketing
   incentives such as the All Natural Lawn Care kit were effective elements in
   the campaign. WES continues leadership in the Coalition media events with
   contributions of $4,000 per year. The campaign was also recognized with a
   Superior Award by the National Association of County Information Officers.
   See The RCCRS Annual Report, Appendix E and the website at:
   www.cleanriversandstreams.org.

Pollution Prevention Outreach (P2O) Team
   The Pollution Prevention Outreach (P2O) Team’s Eco-Logical Business
   Program’s Landscaper Certification provides incentives to firms in the
   landscaping business. Firms must use alternatives to pesticides or only use
   pesticides sparingly to receive this certification. WES is a P2O Team
   member.

Multi-Agency Meeting
  A meeting attended by representatives of WES, the South Fork Water Board,
  the Clackamas County Soil & Water Conservation District, the Sunrise Water
  Authority (SWA), and the Clackamas River Basin Council was held at SWA
  on January 30th, 2006. The sole purpose of this meeting was to discuss ways
  to improve and coordinate pesticide outreach and education efforts in the
  Clackamas River watershed.


Publications

WES Website

WES newsletters
  Articles in WES newsletters (StreamLines in CCSD#1-UGB). These
  newsletters are mailed to all customers along with billing statements.

U.S. Geological Survey publications




MS4 Permit Compliance Report for CCSD#1 & SWMACC                           29
   U.S. Geological Survey publications. WES funds have been contributed
   towards the generation and publication of several relevant reports, including
   Report 2003-4145, titled “Pesticides in the Lower Clackamas River Basin,
   Oregon, 2000-2001”, and Report 2004-5061, titled “Organochlorine
   Pesticides in the Johnson Creek Basin, Oregon, 1988-2002”.

Brochures
   Numerous brochures (disseminated at the WES booth at fairs, for example)


Citizen Calls

A citizen who called WES on 8/19/05 for advice on proper usage of herbicide in a
riparian area along Johnson Creek was provided with technical assistance (see
WESWorks case #3414).


Implementation Schedule:
This has already been implemented. Public education/involvement campaigns
addressing ways to reduce stormwater pollution caused by the application of
pesticides, herbicides, and fertilizers are underway and have been recently
conducted. For a description of campaigns planned for the future, contact the
WES Community Relations Specialist at 503-353-4567.

Measurable Performance Indicators:
The primary measurable performance indicators are the number of public
education/involvement campaigns that are underway, are planned for the near
future, or that have been recently conducted. Other measurable performance
indicators that may be used include, but aren’t limited to:
    • The number of citizens who attend workshops, who visit the WES booth at
        fairs, or who attend presentations (at the local school, for example) on
        ways to reduce stormwater pollution caused by the application of
        pesticides, herbicides, and fertilizers.
    • The number of brochures distributed that address ways to reduce
        stormwater pollution caused by the application of pesticides, herbicides,
        and fertilizers.


4.5.2 Disposal of Unwanted Quantities and Containers
When the co-permittees (The Cities of Rivergrove and Happy Valley, CCSD#1,
and SWMACC) receive inquiries from the public about the proper disposal
method for empty containers that once held pesticide/herbicide or for disposal of
unwanted quantities of these products, citizens are promptly forwarded to Metro
at 503-234-3000.

Implementation Schedule:


MS4 Permit Compliance Report for CCSD#1 & SWMACC                           30
This has already been implemented.

Measurable Performance Indicators:
The measurable performance indicator is the number of calls that Metro receives
from the co-permittees in any given time period. The number of these calls
wasn’t specifically tracked by the co-permittees during the reporting period
(7/1/05 to 6/30/06), but the co-permittees estimate that the number is about 15.
In addition, the co-permittees are not aware of any instances during the reporting
period where these items – empty containers and unwanted quantities – were
dumped in or near the MS4.


4.5.3 Road Maintenance
Herbicides are occasionally used by Clackamas County’s Road Department in
road maintenance operations in the MS4-permitted area. In fact, in many years,
the Road Department applies no herbicides for roadside vegetation control in the
co-permittees’ MS4 permitted service area. This is due to the facts that: a) most
County roads in the MS4-permitted area are paved, have curbs, and are served
by piped storm sewer systems, and b) any vegetation present in the road right-of-
way is usually part of a landscape maintained by the adjacent property’s owner.
In most of the instances that involve Road Department roadside vegetation
management activity within the co-permittees’ MS4-permitted area, mowing is
the preferred vegetation control system. When herbicides are used, these
products are always used in a manner consistent with the product’s label.

Implementation schedule:
This has already been implemented.

Measurable Performance Indicator:
The quantity of herbicide products used by the Road Department per zip code is
the measurable performance indicator for this section. This is the same data that
will be reported to Oregon's Department of Agriculture in the Pesticide Use
Reporting System (PURS). The PURS is still not operational at this time, so this
data is not available for this reporting period.

4.5.4 Landscape Maintenance
Herbicides, pesticides and fertilizers are used by public agencies in landscape
maintenance applications around publicly-owned buildings and facilities. When
herbicides and pesticides are used, these products are used in a manner that is
consistent with the product’s label. When fertilizer is used, it is used sparingly
and it is promptly swept up if it is accidentally spread onto paved areas.

Implementation Schedule:
See the measurable performance indicators portion of this section. A list will be
assembled and at least one meeting will be held prior to February 2009.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                            31
Measurable Performance Indicators:
The measurable performance indicators that apply to this section shall be
completed before the current permit expires in February 2009. They are:
   • To assemble a list of all City, SWMACC, CCSD#1, and County-owned
      buildings and facilities in the co-permittees’ (The Cities of Rivergrove and
      Happy Valley, CCSD#1, and SWMACC) MS4 permitted area, and
   • To meet with the proper facility and building maintenance personnel to
      inform them that herbicides, pesticides and fertilizers must be used with
      care in landscape maintenance applications. They will also be
      encouraged to: a) substitute the use of these products for other, less
      harmful ones, b) to use less herbicide, pesticide and fertilizer, if possible,
      when they are used, and c) to naturescape with native plants, which are
      likely to need less herbicides, pesticides and fertilizers, whenever
      possible.

Given that these measurable performance indicators were proposed by the co-
permittees to DEQ in a May 1, 2006 submittal, neither of these tasks were
completed during the July 1, 2005 to June 30, 2006 reporting period, but they will
be completed by the end of February 2009.

4.5.5 Scientific Research
Given the high analysis cost, the co-permittees have jointly funded research on a
periodic basis that determines if pesticides and herbicides are present in
stormwater and/or surface water bodies, and if present, the concentration of
certain pesticides and herbicides are quantified by this research.

In the case of plant fertilizer, WES conducts research on the presence of certain
common plant nutrients in stormwater and surface water bodies on a routine
basis. During the 2005-2006 reporting period: a) This data was collected from at
least 28 sites in the MS4 and from sites in and near the Districts on surface water
bodies, and b) the nutrients that were monitored are ammonia, nitrate,
orthophosphate and total phosphorus. This data is provided in the
surface/stormwater monitoring report in one of the MS4 report’s Appendices.

Implementation schedule:
This is already being implemented.

Measurable Performance Indicators:
For pesticides and herbicides, the measurable performance indicator for this
scientific research section is the number of studies that are funded and/or
supported by the co-permittees during the current permit term. There are two
studies:
    • The first study is currently being conducted by the U.S. Geological Survey
        (USGS) in the Clackamas River watershed. Water samples have already
        been collected and analyzed for the presence of 120 dissolved pesticides,
        herbicides, and select breakdown products, but the report has not been


MS4 Permit Compliance Report for CCSD#1 & SWMACC                              32
       written yet. Water samples were collected during storm events on May 9,
       2005 and September 30, 2005. This multi-year study has been supported
       by many local governmental partners, including CCSD#1. CCSD#1,
       which includes the City of Happy Valley, provided $19,600 to the USGS
       for this study. About half of this money ($10,000) was provided by
       CCSD#1’s FY 2005-2006 budget (the other $9,600 was provided by
       CCSD#1’s FY 2004-2005 budget). Funds have been contributed by
       CCSD#1 towards several other USGS studies in recent years. These
       include Report 2003-4145, titled “Pesticides in the Lower Clackamas River
       Basin, Oregon, 2000-2001”, and Report 2004-5061, titled “Organochlorine
       Pesticides in the Johnson Creek Basin, Oregon, 1988-2002”.
   •   The other study is one which is being conducted by DEQ in the
       Clackamas River watershed. Although no co-permittee funds were
       contributed towards water sample collection and analysis, WES personnel
       have assisted with other aspects of the study, including monitoring site
       selection and data interpretation. The report has not been written yet, for
       the most recent data collection dates were in April and May 2005. A
       meeting to discuss preliminary interpretation of some of the study’s data
       was held in WES’ office in Clackamas on October 17, 2005. The DEQ’s
       study complements the above-noted USGS pesticide/herbicide monitoring
       work, for: a) the DEQ’s laboratory methodology yields total recoverable
       amounts for pesticides and herbicides while the USGS’ laboratory yields
       data on the dissolved fraction that’s present, and b) the DEQ’s monitoring
       work occurred during some dry-weather periods while the USGS’
       monitoring dates were timed to correlate with significant storm events.

For plant fertilizer, the measurable performance indicators for this scientific
research section is the number of surface/stormwater samples that were
collected and analyzed for nutrients. Two hundred seventy-seven water samples
were collected and analyzed for total phosphate as phosphorus, orthophosphate
as phosphorus, nitrate + nitrite as nitrogen, and ammonia as nitrogen. Note that
several of these samples were composite samples (comprised of 3 or more grab
samples) that were collected during storm events.



4.6    Illicit Discharges and Spills [Schedule D(2)(c)(ii)]

4.6.1 Illicit Discharge Elimination Program (IDEP):
The District’s Illicit Discharge Elimination Program (IDEP) detects, addresses,
and if necessary, controls the discharge of certain wastewaters to the County’s
storm sewers within the MS4-permitted areas of CCSD#1. In general, illicit
discharges are improper, unauthorized “point sources” of wastewater which have
been discharged to surface water bodies or public storm sewer systems. Rain
and melted snow are “nonpoint sources” and cannot be illicit discharges, but
wastewater from washing a fleet of vehicles or from rinsing paintbrushes could


MS4 Permit Compliance Report for CCSD#1 & SWMACC                           33
be illicit discharges. Illicit discharges can enter public storm sewer systems in a
variety of ways, such as through a hard-piped connection, through a gardening
hose, or from a bucket of waste dumped directly into a storm sewer catch basin
in the street.

The Measurable Performance Indicators for all of Chapter 4.6 are:
   1. The number of dry-weather outfall inspections that were conducted.
   2. The number of illicit discharges that were controlled.
   3. The number of non-stormwater discharges that were addressed, and if
      necessary, controlled.
   4. For the onsite sewage disposal program, the number of permits issued,
      inspections performed, and enforcement actions taken.

For the 2005-2006 reporting period, Measurable Performance Indicator
information is provided in the relevant section of Chapter 4.6.


4.6.2 IDEP: Prevent Illicit Discharges into MS4 [Schedule D(2)(c)(ii)(1)]
As stated in the permit, this section provides a description of “A program,
including inspections, to implement and enforce an ordinance, orders or similar
means to prevent illicit discharges to the municipal separate storm sewer
system…”.

The Illicit Discharge Elimination Program improves water quality and protects the
aquatic environment by detecting, evaluating, and if necessary, controlling these
improper or illegal discharges to the District’s injection-type and surface-
discharging storm sewer systems. The Illicit Discharge Elimination Program:
   • Is the District’s primary tool for preventing, detecting, addressing, and if
        necessary, controlling illicit discharges.
   • Performs dry-weather inspections at major Clackamas County and
        District-owned storm sewer outfalls to identify and locate illicit discharges.
   • Receives, documents, and responds to reports (from citizens, for
        example) of illicit discharges which are, or have been, observed.

All wastewaters suspected of being an illicit discharge are investigated and
documented by District staff. Copies of documents pertaining to each
investigation are referred to DEQ’s Northwest Region for review, as DEQ
continues to reserve the right to assume a direct role in any case involving the
discharge of waste to public water bodies.

Twenty-four (24) specific types of discharges, including uncontaminated pumped
groundwater and discharges resulting from individual residential car washing, are
defined by DEQ as “non-stormwater discharges”. They’re allowed to be present
in the MS4 as long as certain basic control steps, if deemed appropriate by WES,
are taken by the discharger (please see the next section for more information on
non-stormwater discharges).



MS4 Permit Compliance Report for CCSD#1 & SWMACC                               34
When an illicit discharge is identified, control options may be required. Control
options that may be recommended by WES include, but aren’t limited to:
    • The removal of certain pollutants from the wastewater prior to discharge to
       the storm sewer system (i.e., cease usage of soap when washing)
    • Issuance of the proper discharge permit from the State of Oregon’s
       Department of Environmental Quality (DEQ). A discharge that has been
       authorized and controlled by a DEQ water quality permit is not an illicit
       discharge.
    • Application of the wastewater to dry land with no discharge to surface
       waters or storm sewers. This option is inappropriate for certain types of
       wastewaters, discharge rates, and soil types and may require the
       issuance of a WPCF permit from DEQ.
    • Wastewater reuse without any discharge
    • Hauling the wastewater off-site for proper disposal
    • With the necessary permits, discharge the wastewater to CCSD#1’s
       sanitary sewer system.

The illicit discharges to the MS4 during the 2005-2006 report period that WES is
aware of are in this section. The illicit discharges listed in this section did not
contain “reportable” quantities of certain dangerous or hazardous materials, and
as a result, the discharges were not required to be reported to the Oregon
Emergency Response System (OERS). The discharges to the MS4 that WES is
aware of that were reported to OERS during the 2005-2006 report period are
defined as “spills”, which are listed in section 4.6.5 of this report.
    • Sediment-laden Discharge to Kellogg Creek, 7/7/05. A significant
        quantity of sediment was discharged into Kellogg Creek by an unknown
        discharger in the watershed above SE Thiessen Avenue. Although most
        of this portion of the watershed is within CCSD#1, the City of Johnson City
        (about 43 acres) is also present in this area. Citizen reports were
        provided to WES several hours after the discharge ceased, so it could not
        be traced to the source. A Notice of Noncompliance (NON) was not
        issued because the responsible party's (RP) identity is unknown.
    • Concrete, 7/14/05. A WES employee noticed on July 14, 2005 that
        concrete and concrete-related wastes had been improperly discharged
        from the front yard of a home on SE One Rosa Drive in CCSD#1. A WES
        inspector conducted an inspection later that same day. He confirmed that
        these wastes were discharged onto the surface of the street, and that a
        small amount made it into a Clackamas County-owned catch basin. This
        storm sewer system outfalls to Mt. Scott Creek, but the inspector
        confirmed that wastes had not moved through the system to the creek yet.
        Stan Kielman of Portland, the person who discharged this material, was
        notified that all concrete and concrete-related wastes needed to be
        promptly removed from the street and catch basin. The cleaning work
        was completed by July 19, 2006. A NON was issued by WES on July 27,
        2005.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            35
   •   Paint Waste from House Painting, 7/27/05. A WES vacuum truck crew
       working on SE Orchid Avenue in CCSD#1 discovered that paint and/or
       painting-related washwater had recently been discharged into a County-
       owned catch basin in the street. The owners of the homes in the area
       were contacted by WES inspectors, but nobody claimed to be responsible
       for the discharge. A NON was not issued because the RP’s identity is
       unknown.
   •   Wastewater with Foul Odor, 8/16/05. While conducting monthly surface
       water sample collection work, a WES crew noticed a foul odor emanating
       up from the Riverside Park storm sewer outfall on the Clackamas River in
       CCSD#1 on August 16, 2005. WES representatives contacted Safeway’s
       Distribution Center (16800 SE Evelyn Street), which occupies nearly all of
       this basin’s area, and discussed the possible link(s) to other odor-related
       incidents in this storm sewer system in past years. Safeway
       representatives inspected their facility and found two sources that may
       have contributed to the odor problem. The source could have been
       related to bakery personnel watering down their roof because of the hot
       weather. A second possible source could have been related to a
       breached asphalt berm at their trailer wash and compost facility. Portland
       Road & Driveway came to the facility on the afternoon of August 16th to
       repair the berm. An environmental services firm was also at the site
       before noon on August 16th to flush and vacuum the facility’s storm sewer
       system, discharging the resulting wastewater to the sanitary sewer
       system. A WES crew visited the outfall at Riverside Park in the morning
       on August 18th to confirm that the odor was no longer present. A NON
       was not issued because the source of the odor was not identified with
       certainty.
   •   Washing Wastewater, 8/17/05. While conducting dry-weather storm
       sewer outfall inspections on August 17, 2005, a WES crew detected
       pollutants in water being discharged from the SE 106th Avenue storm
       system’s outfall to the Clackamas River in CCSD#1. An upstream
       investigation led to the Les Schwab Tire Store at 10602 SE Highway 212.
       They were discharging wastewater into the storm sewer system from their
       tire and wheel washing area. Washing-related wastewater management
       options, which were available to the company, were provided in a NON
       that was sent on September 2, 2005. On February 28, 2006, Clackamas
       County provided final plumbing, electrical and building permit approval for
       the conversion of this area into a covered washing station that discharges
       to CCSD#1’s sanitary sewer system. Wastewater from the washing area
       was discharged into one of the store’s toilets between the afternoon of
       August 17, 2005 and February 28, 2006.
   •   Washing Wastewater, 8/18/05. While conducting dry-weather storm
       sewer outfall inspections on August 18, 2005, a WES crew detected
       pollutants in water being discharged from the SE Capps Road outfall to
       Carli Creek in CCSD#1. An upstream investigation led to the identification
       of three illicit discharges in the outfall’s basin, one of which was from the


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             36
       Pacific Seafood facility at 16797 SE 130th Avenue. They’d been
       discharging washing-related wastewater earlier in the day, and though this
       wastewater was discharged into the facility’s private storm sewer system,
       this wastewater did not enter the County's storm sewer system on that
       date. Washing-related wastewater management options, which are
       available to the company, were provided in a letter that was sent to the
       company by WES on August 24th. A NON was not issued by WES, for
       washwater was not discharged to the MS4 on August 18th. A September
       6th reply letter stated that no washwater would be discharged to the MS4
       in the future.
   •   Washing Wastewater, 8/18/05. While conducting dry-weather storm
       sewer outfall inspections on August 18, 2005, a WES crew detected
       pollutants in water being discharged from the SE Capps Road outfall to
       Carli Creek in CCSD#1. An upstream investigation led to the identification
       of three illicit discharges in the outfall’s basin, one of which was from the
       Crystal Greens Landscaping facility at 12259 SE Capps Road. They’d
       been discharging washing-related wastewater earlier in the day, and this
       wastewater had flowed through the County's storm sewer system, entering
       Carli Creek on that date. Foul-smelling, decomposing vegetation,
       including lawn clippings, was in the facility’s private storm sewer system,
       the public system, and in the creek on August 18th. Washing-related
       wastewater management options, which are available to the company,
       were provided in a NON that was sent to the company by WES on August
       23rd. A September 12th reply letter stated that no washwater would be
       discharged to the MS4 from their facility in the future.
   •   Washing Wastewater, 8/18/05. While conducting dry-weather storm
       sewer outfall inspections on August 18, 2005, a WES crew detected
       pollutants in water being discharged from the SE Capps Road outfall to
       Carli Creek in CCSD#1. An upstream investigation led to the identification
       of three illicit discharges, one of which was from the Wymore Transfer Co.
       facility at 12651 SE Capps Road. They’d been discharging washing-
       related wastewater earlier in the day, and this wastewater had flowed
       through the County's storm sewer system, entering Carli Creek. The
       facility is equipped with an outdoor, uncovered washing station, which is
       piped directly into the SE Capps Road storm sewer system. Numerous
       washing-related wastewater management options, which are available to
       the company, including connection of the washing station to the District’s
       sanitary sewer system, were outlined in a NON that was sent to the
       company by WES on August 26th. The NON had asked for a written reply
       from the company. As of October 16, 2006, despite repeated verbal and
       emailed requests from WES, the company has not submitted a proper
       written response to the NON, so this case is open and unresolved.
   •   Hot Tub Draining, 8/25/05. An illicit discharge was prevented on August
       25, 2005 on SE Briarfield Court in CCSD#1 when a citizen who owns a hot
       tub called WES for guidance prior to draining it. WES recommended that
       the tub be drained into one of the home’s sinks through a hose – the sink


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             37
       is connected to the District’s sanitary sewer system – and the citizen said
       that the water would be disposed of in this manner. A NON was not
       issued because there was no discharge to the MS4.
   •   Concrete, 9/2/05. A citizen notified WES on September 2, 2005 that
       concrete and concrete-related wastes were being discharged into the
       storm sewer system from the front yard of a home on SE Pinegrove Loop
       in CCSD#1. A WES inspector conducted an inspection later that same
       day. He confirmed that these wastes were discharged onto the surface of
       the street and into a Clackamas County-owned storm sewer system which
       outfalls to Graham Creek, a tributary to Rock Creek, as a product of
       driveway work. Steve Boehme & Concrete of Aloha, Oregon, the
       company that discharged this material, was notified that all concrete and
       concrete-related wastes needed to be promptly removed from all impacted
       segments of the storm sewer system, and that all cleaning should be
       performed with a vacuum truck to ensure that no waste was released into
       Graham Creek during, or as a product of, the cleaning operations. A NON
       was issued by WES on September 12th. The cleaning work was
       completed on September 16th.
   •   Automotive Oil Spill, 9/7/05. Oil was spilled at the corner of SE Emery
       Lane and Bradford Road in CCSD#1 while a vehicle’s crankcase oil was
       being changed. A WES inspector promptly visited the site. Although
       there was no oil in the storm sewer system, a large, fresh oily spot was on
       the road adjacent to a County-owned catch basin. The person who
       caused the spill apologized, promised to prevent or promptly clean up
       future spills, and assisted the WES inspector with the deployment and
       removal of granular absorbent material. A NON was not issued, for oil
       was not discharged to the MS4.
   •   Gasoline Odor, 10/14/05. A trucking facility near Hwy 212’s intersection
       with SE 135th Avenue in CCSD#1 called WES to report that a gasoline
       odor had been present earlier in the day on October 14, 2005. A WES
       inspector promptly visited the site, even though the odor had already
       dissipated by the time the odor was reported to WES. The source of the
       odor could not be determined, although several possible sources were
       identified. The facility’s storm sewer system, which is privately owned,
       and the nearest creeks, Sieben and an un-named tributary, were checked
       and found to be free of gasoline at the time of the inspection.
   •   Sudsy Wastewater, 11/15/05. While conducting monthly surface water
       sample collection work, a WES crew noticed that thick mounds of suds
       were being discharged from the Riverside Park storm sewer outfall to the
       Clackamas River in CCSD#1 on November 15, 2005. A WES
       representative conducted a joint site visit with an employee of the
       Safeway’s Distribution Center (16800 SE Evelyn Street), which occupies
       nearly all of this outfall’s drainage area. During this inspection, a likely
       source was identified near the fueling island. A long-handled brush was
       sitting in a bucket of soapy water, and at least one truck cab had recently
       been washed. Soapy suds and wet pavement were all around the nearest


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            38
       catch basin. A NON was not issued, because the source of the soapy
       suds at the outfall was not conclusively identified, but the employee of the
       Safeway’s Distribution Center was reminded that soapy wastewater in any
       amount could not be discharged into their storm sewer system.
   •   Wastewater with Solvent Smell, 11/22/05. While conducting routine
       storm sewer system repair work, a WES crew noticed that wastewater
       with a solvent smell was moving through the storm sewer system on SE
       Goose Hollow Drive in the portion of the City of Damascus that is in
       CCSD#1 on November 22, 2005. This storm sewer system outfalls to an
       un-named tributary of Rock Creek. A WES representative conducted an
       upgradient inspection and determined that the wastewater was being
       discharged by an employee of Siri Farms of 16140 SE Highway 212
       during tractor washing work. A NON was issued on December 6th. The
       NON provided a range of washing alternatives. The farm’s written reply to
       the NON stated that they’d elected “…to conduct washing activities
       elsewhere.”
   •   Excavator and Driveway Washing, 1/20/06. The owner of the home at
       13666 SE 116th Court in CCSD#1 discharged highly turbid excavator and
       driveway washing wastewater into a catch basin in the street near the
       home on January 20, 2006. Significant earthmoving activity had been
       conducted on a portion of the home’s yard and a neighboring home’s yard
       earlier that day. A WES inspector, alerted by a neighbor’s phone call,
       arrived while the washing was underway, and he notified the homeowner
       that the driveway could continue to be washed later that same day, but
       based on a 1700A permit requirement, the driveway needed to be swept
       (or at minimum, scraped with a shovel) first to minimize water pollution. A
       letter with alternatives for future management of heavy equipment and
       driveway cleaning wastewater was sent to the homeowner on March 31st.
   •   Antifreeze Discharge, 2/1/06. DEQ called a WES inspector on February
       1, 2006 to report that DEQ had received an anonymous tip from a caller
       that Maynard's Auto Repair at 10355 SE Hwy 212 "had been intentionally
       discharging antifreeze into a ditch". This property is not served by an MS4
       that is owned by CCSD#1 or Clackamas County. Drainage at this
       property apparently discharges to ODOT's MS4 and directly to Cow
       Creek. Given that the alleged inappropriate discharge was not to their
       MS4, WES and Clackamas County had no jurisdiction in the matter, so the
       referral to WES by DEQ was not accepted. The DEQ was encouraged to
       visit the site or refer the case to ODOT, for ODOT has their own MS4
       permit.
   •   House Paint, 3/9/06. A WES storm sewer system cleaning crew
       discovered paint in the catch basin in the street in front of the house at
       8880 SE Emily Park Way in the Altamont neighborhood of CCSD#1. Paint
       on the catch basin's grate was dry at that time. The owners of this home
       said that they'd had their home's exterior painted during the summer of
       2005 by a company named Bright's Custom Painting of Spokane,
       Washington. They also said that, to the best of their knowledge, painting


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            39
       cleanup-related wastewater was not discharged into their home's sinks,
       toilets, or onto the surface of their yard by this company. A representative
       from Bright's Custom Painting said that his company probably would not
       have discharged paint, or wastewater that contained even trace amounts
       of paint, to the storm sewer system. WES did not issue a NON, for there
       was insufficient evidence to support one.
   •   Tile Installation Wastewater, 3/9/06. On March 9, 2006, a citizen called
       WES to report that a Karpate Tile and Stone employee was repeatedly
       dumping buckets of wastewater into a catch basin in the street near the
       home at 14131 SE Rolling Meadows Court in the portion of the City of
       Happy Valley that is within CCSD#1. This catch basin is part of a storm
       sewer system that outfalls to wetlands that are tributary to Mt. Scott Creek.
       A WES inspector visited the property on March 15th and spoke with one of
       the home’s owners. She stated that Karpate Tile and Stone had been
       hired by her family to do tile installation work in her home. She also stated
       that she believed that at least one Karpate Tile and Stone employee had
       dumped several buckets of wastewater into the catch basin that is closest
       to her home. According to the homeowner, this wastewater – generated
       during a tile installation process – contained a significant quantity of grout.
       The homeowner said she didn't realize that this wastewater was not
       allowed to be discharged into the street's catch basins. The WES
       inspector was able to speak by phone on March 22nd with a Karpate Tile
       and Stone employee. During this conversation, he was notified that a
       NON would be sent in the near future. The NON was issued on April 3rd
       and was sent via certified mail, but it was returned to sender as
       “unclaimed”. On April 20th, this NON and a cover letter were again sent
       via certified mail. On May 30th, these items also came back as
       “unclaimed”. A July 11th voicemail message was left for the Karpate Tile
       and Stone employee, but he did not reply. On September 21st, WES
       contacted the company by phone and WES was asked to send the NON
       again, this time via non-certified US Mail. The cover letter and NON were
       sent out via non-certified US Mail on September 22nd. This case is still
       open, for the company has not yet submitted a satisfactory written
       response to the NON.
   •   Paint or Drywall Mud, 3/14/06. On March 14, 2006, a WES employee
       noticed that white wastewater was entering a creek from one of the ODOT
       storm sewer pipes that drain SE 82nd Avenue (Hwy 213) in CCSD#1. This
       creek, associated with wetlands, is a tributary to Phillips Creek. The WES
       employee located the catch basin where the material was dumped. The
       catch basin was in the Video Only parking lot at 8200 SE 82nd Ave. The
       material appeared to be paint or drywall mud. Employees of Video Only
       and another nearby business stated that they did not dump the material.
       Given that the responsible party could not be identified, ODOT paid a
       cleanup company to remove the waste from their storm sewer system. A
       NON could not be issued because the responsible party could not be
       identified and the impacted MS4 is owned by ODOT.


MS4 Permit Compliance Report for CCSD#1 & SWMACC                              40
   •   Resolution to Long-Term Washwater Discharge Issue. The annual
       report for 2004-2004 contained a description of an incident that occurred
       on November 2, 2003 at the Organically Grown Co-op facility at 16107 SE
       98th Avenue in CCSD#1. Custom Pressure Washing, Inc. (PO Box
       752/Lake Oswego, OR 97034-0075) had discharged soapy truck
       washing-related wastewater into the storm sewer system, which outfalls to
       Cow Creek, without a 1700A permit. The company had failed to submit a
       proper response to WES for several years after November 2, 2003, even
       though certified letters were sent via U.S. Mail to, and claimed by, the
       company on November 10, 2003, January 14, 2004, and April 7, 2005.
       WES sent letters to the company, because WES does not have
       jurisdiction to issue a NON, given that the impacted storm sewer system is
       privately owned and is not connected to the MS4. Custom Pressure
       Washing, Inc. finally submitted a satisfactory response to WES on July 19,
       2006.

Measurable Performance Indicator:
  • The total number of illicit discharges that were controlled. Twenty (20)
     illicit discharges were identified and/or controlled during the reporting
     period.


4.6.3 IDEP: Non-Stormwater Discharges in MS4 [Schedule D(2)(c)(ii)(1)]
The MS4 permit also states that “…this program description must address all
types of illicit discharges, however the following category of non-stormwater
discharges or flows must be addressed where such discharges are identified by
the municipality as sources of pollutants to waters of the United States: water line
flushing, landscape irrigation, diverted stream flows rising ground waters,
uncontaminated ground water infiltration, uncontaminated pumped ground water,
discharges from potable water sources, start up flushing of groundwater wells,
aquifer storage and recovery (ASR) wells, potable groundwater monitoring wells,
draining and flushing of municipal potable water storage reservoirs, foundation
drains, air conditioning condensation, irrigation water, springs, water from crawl
space pumps, footing drains, lawn watering, individual residential car washing,
flows from riparian habitats and wetlands, dechlorinated swimming pool
discharges, street wash waters, discharges of treated water from investigation,
removal and remedial actions selected or approved by the Department pursuant
to Oregon Revised Statute (ORS) Chapter 465, the state’s environmental
cleanup law; and discharges or flows from emergency fire fighting activities
where discharges or flows from fire fighting are identified as not significant
sources of pollutants to the waters of the state.” All of these 24 non-stormwater
discharges are allowed by the District to be discharged into the MS4 in CCSD#1-
UGB, although this permission is frequently conditional. The control measures
employed by the District – as well as the rationale for their selection – for each of
those above-noted non-stormwater discharges is being included in section 4.13.
This is required by the permit’s Schedule B(2)(b)(iii). Section 4.13 is titled “Non-


MS4 Permit Compliance Report for CCSD#1 & SWMACC                              41
Stormwater Discharges”. The following is a list of nonstormwater discharges that
WES is aware of which occurred during the reporting period:
   • Potable Water, 10/21/05. A citizen called on 10/21/05 to report that
     potable water has continually flowed, 24 hours per day, for four years from
     a neighboring residential property on SE Kronan Drive in CCSD#1. WES
     confirmed that a very small amount of water flows into the street from the
     property’s yard after first having passed through the home’s water meter.
     It then flows across the pavement to a County-owned catch basin.
     Sunrise Water Authority (SWA), the potable water provider in the
     neighborhood, had previously confirmed that the water being discharged
     is potable water, but SWA doesn't have a rule which prevents customers
     from intentionally wasting small volumes of water. The WES inspector
     determined the discharge likely posed no threat of harm to the
     environment, for the storm outfall is about 432 feet from the nearest
     jurisdictional water body (Cow Creek), and little, if any, chlorine would be
     present if any of the potable water actually made it to Cow Creek (during a
     storm event, for example). During dry weather, the potable water would
     quickly be absorbed into the soil between the creek and the outfall. The
     leak was not ordered to be halted by WES. The citizen was encouraged
     by WES to ask his neighbor to fix the leak. SWA representatives have
     repeatedly attempted to contact the homeowner with the leak, but the
     homeowner has refused to respond to them.
   • Uncontaminated Pumped Groundwater, November 2005. Armadillo
     Underground, Inc. requested permission to discharge uncontaminated
     pumped groundwater from a construction site at the SE corner of Hwy
     212/224 and SE 135th Avenue on October 17, 2005. WES issued a
     written authorization to discharge with conditions later that same day. The
     groundwater was discharged into the middle of the open, vegetated field
     on the SE corner of Hwy 212/224 and SE 135th Avenue. This lot is owned
     by Clackamas County’s Dept. of Transportation and Development.
     Permission to discharge was granted by this Dept. Pretreatment was
     provided by a "dirt bag", which is a large bag made of filter fabric. On
     rainy days or during other occasions when discharges exceeded the field's
     ability to infiltrate, evaporate, and/or transpire the whole volume, excess
     flows may have entered the MS4. Many conditions for this approval were
     adhered to, including those that pertained to the discharge’s turbidity on
     days there was a discharge to MS4. The discharge began on November
     3rd and occurred periodically over the next few weeks.
   • Uncontaminated Pumped Groundwater, March 2006. The Sunrise
     Water Authority (SWA) received permission from WES to discharge
     pumped, unchlorinated groundwater from a water supply well to a
     Clackamas County-owned storm sewer system in CCSD#1 during six
     dates in March 2006. The discharge, at a rate of 800 gallons/minute (1.78
     cubic feet/second), was to a catch basin in SE Territory Drive in
     Clackamas. This storm sewer system discharges to Rose Creek, a
     Sieben Creek tributary. This discharge was part of a test that the well was


MS4 Permit Compliance Report for CCSD#1 & SWMACC                          42
       being subjected to. Samples of groundwater were collected prior to the
       discharge, then sent to a laboratory. This data indicated that the
       groundwater met all receiving stream standards. Many conditions for this
       approval were adhered to by SWA, including but not limited to, those that
       pertained to: a) the prevention of ice formation on the road, b) reducing
       the hydrant discharge rate during significant rain events, and c) water
       quality monitoring during the discharge to ensure that the water met all
       receiving stream standards.
   •   Washing Wastewater, 4/14/06. In response to a complaint that WES
       received, a WES inspector visited Quality Sandblasting’s facility at 12805
       SE Carpenter Drive in CCSD#1 on April 14, 2006. The manager
       explained that items to be sandblasted are first dipped into a tank of paint
       stripper, then into a rinse tank where much of the paint and stripper is
       removed. After these steps, the piece is taken outside where any
       remaining paint and stripper is removed with a pressure washer. This
       process takes place over a grated and screened catch basin. This catch
       basin drains through a Stormceptor, a below-ground stormwater treatment
       device. Flows from the Stormceptor then enter the MS4. This MS4’s
       outfall is on Carli Creek near the West end of SE Capps Road. The WES
       inspector determined that most of the paint chips are removed by the
       catch basin’s screen and the Stormceptor. The facility manager said that
       pressure washing is performed, on average, during one day per week.
       This washing is authorized under the 1700A NPDES permit’s deminimis
       conditions (schedule A’s section 3), given that washing additives are not
       used and the number of items washed per week is less than eight (8).
   •   Dechlorinated Drinking Water, June 13-15, 2006. The Sunrise Water
       Authority (SWA) received permission from WES to drain 2 million gallons
       of dechlorinated water from a water tank into a Clackamas County-owned
       storm sewer system in the portion of the City of Happy Valley that is within
       CCSD#1 from June 13, 2006 to June 15, 2006. The discharge, at a rate
       of 500 gallons/minute (1.11 cubic feet/second), was from the tank at
       10797 SE Idelman Road. The storm sewer system outfalls to an un-
       named Phillips Creek tributary. Lab data showed that the water met all
       receiving stream standards. Conditions for this approval were adhered to
       by SWA, including one which recommended the reduction of the
       discharge rate during significant rain events.

Measurable Performance Indicator:
  • The number of non-stormwater discharges that were addressed, and if
     necessary, controlled. For the 2005-2006 reporting period, the number is
     five (5).


4.6.4 IDEP: Field Screening [Schedule D(2)(c)(ii)(2) and (3)]
The MS4 permit requires a description of “Procedures to conduct on-going field
screening activities during the life of the permit, including areas or locations that


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               43
 will be evaluated by such field screens” and a description of “Procedures to be
 followed to investigate portions of the separate storm sewer system that, based
 on the results of the field screen, or other appropriate information, indicate a
 reasonable potential of containing illicit discharges or other sources of non-
 stormwater…Such a description must include the location of storm sewers that
 have been identified for such evaluation.”

 This section is divided into three portions:
 a. Dry-weather outfall inspections
 b. Prohibition on cross-connections in new/re-development
 c. Regulation of onsite sewage disposal systems

 a. Dry-weather outfall inspections
 The purpose of dry-weather outfall inspections is to detect an illicit discharge at
 the outfall or confirm that they are not present. If one is detected, District staff
 track it upstream through the storm sewer system to the source, and then
 address, or if necessary, control the discharge. Illicit discharges are detected
 during dry-weather inspections through the use of hand-held water quality
 measuring equipment and through visual inspections by the inspector. When a
 visual inspection or a pollutant level measured at an outfall indicates that an illicit
 discharge may be present, an upstream investigation through the storm sewer
 system is performed. When the discharge’s source is located, District staff
 cooperate with the property owner and/or business owner to evaluate, and if
 necessary, control the discharge.

 Storm sewer outfalls in the MS4-permitted area that are owned by Clackamas
 County DTD and/or the District are divided into two categories: major and minor
 outfalls. According to the MS4 permit and EPA, a major outfall is an outfall
 which:
    • is a large pipe (>36” inside diameter), or
    • is a conveyance other than circular pipe that serves a drainage area of
         more than 50 acres, or
    • is a single pipe (>12” inside diameter) if it also receives any drainage from
         lands zoned for industrial activity, or
    • is a single conveyance other than a circular pipe which receives drainage
         from more than two acres of land zoned for industrial activity.

 The balance of the County and District-owned surface-discharging storm sewer
 outfalls are classified as minor. There are no major outfalls in SWMACC. Table
 1 contains basic information about all twenty-nine (29) known major outfalls in
 CCSD#1’s MS4-permitted area.

          Table 1. Major Storm Sewer Outfalls in the MS4-Permitted Area
 OF          Outfall Name         Receiving Stream 1° Land Use    Diameter       Material
#1 Riverside Park                 Clackamas River Industrial   36"              Concrete
#2 SE 106th Avenue                Clackamas River Industrial   60"              Concrete



 MS4 Permit Compliance Report for CCSD#1 & SWMACC                                44
#3    SE 120th & Carpenter          Carli Creek       Industrial    54"              Concrete
#4    SE Capps Road                 Carli Creek       Industrial    42"              Concrete
#5    SE Evelyn Street              Cow Creek         Industrial    30"              Concrete
#6    SE Wichita Avenue             Johnson Creek     Industrial    24"              Concrete
#7    SE Johnson Creek Blvd.        Johnson Creek     Industrial    12"              Concrete
#8    SE Bell Avenue                Johnson Creek     Industrial    12"              Concrete
#9    SE Mather Road                Dean Creek        Industrial    24"              Concrete
#10   SE Fuller Road                Phillips Creek    Residential   48"              Plastic
#11   SE Lawnfield Road             Dean Creek        Industrial    36"              Steel
#12   SE Pheasant Court             Mt. Scott Creek   Industrial    36"              Steel
#13   SE Linwood Avenue             Johnson Creek     Residential   54"              Concrete
#14   SE 102nd Avenue               Cow Creek         Industrial    24"              Concrete
#15   SE Violet Avenue              Cow Creek         Industrial    12"              Concrete
#16   SE Industrial Way             Dean Creek        Industrial    36"              Concrete
#17   ODOT District 2B              Dean Creek        Industrial    30"              Concrete
#18   SE Jennifer-Railroad          Cow Creek         Industrial    42”              Concrete
#19   SE Webster Rd.                Kellogg Creek     Residential   30” x 48” oval   Steel
#20   Withycombe View               Dean Creek        Industrial    12”              Concrete
#21   Bell Station                  Johnson Creek     Residential   36”              Concrete
#22   SE Southgate St. @ 82nd Ave   Phillips Creek    Commercial    36”              Concrete
#23   Sieben Creek                  Sieben Creek      Residential   48”              Steel
#24   SE Last Rd.                   Cow Creek         Industrial    12”              Concrete
#25   SE Sunnyside Rd.              Phillips Creek    Commercial    Dual 72” box     Concrete
#26   SE Tolbert St.                Dean Creek        Industrial    27”              Concrete
#27   Happy Valley Park             Mt. Scott Creek   Residential   36”              Plastic
#28   Sunnyside Village             Rose Creek        Residential   42”              Plastic
#29   Sunnyside @ Sunnybrook        Mt. Scott Creek   Residential   23.6” + 35.4”    Concrete

 These outfalls are inspected by WES for the presence of illicit discharges at least
 once per year:
    • All known major outfalls, and
    • The six (6) known minor outfalls in the urbanized, MS4-permitted portion
       of SWMACC.

 The inspections are performed during the Willamette Valley’s seasonal drought
 (summer and early fall) and are not performed if measurable rain has fallen
 within the previous 24 hours. These guidelines have been set to aid in the
 detection of illicit discharges by avoiding rainfall and by minimizing the presence
 of groundwater which commonly seeps into storm sewer systems, for these
 relatively clean waters will dilute any illicit discharges that may be within the
 storm sewer system. This makes it difficult or impossible to detect an illicit
 discharge. A DEQ-approved inspection form is completed during each site visit.

 Measurable Performance Indicators:



 MS4 Permit Compliance Report for CCSD#1 & SWMACC                                     45
   •   The number of dry-weather outfall inspections that were conducted.
       During the 2005-2006 reporting period, one dry-weather outfall inspection
       was performed at each of the 29 major outfalls in CCSD#1 and at each of
       the six (6) known minor outfalls in the urbanized, MS4-permitted portion of
       SWMACC.
   •   The number of illicit discharges that were controlled during this type of
       work. During the 2005-2006 reporting period, three (3) illicit discharges
       that were controlled (see section 4.6.2 for specific information about these
       incidents).

b. Prohibition on cross-connections in new/re-development
The co-permittees (The Cities of Rivergrove and Happy Valley, CCSD#1, and
SWMACC) prohibit cross-connections in new/re-developments through the
development and building permit review and issuance process. This system,
which features plan review in the office and inspections by certified plumbing
inspectors, ensures that fixtures which need to be plumbed into CCSD#1’s
sanitary sewer system or a private septic system are actually plumbed into those
systems, preventing hundreds of illicit discharges per year.

c. Regulation of onsite sewage disposal systems
A potential type of illicit discharge that can be present in the MS4 is wastewater
from septic systems that have been incorrectly installed and those that are
failing. In addition to managing CCSD#1 and SWMACC, Water Environment
Services (WES) also administers the Onsite Sewage Treatment and Disposal
(Onsite) Program in Clackamas County as an Agent of DEQ through a
Memorandum of Understanding. WES regulates residential and commercial
systems with a residential strength waste of up to 2,500 gallons per day. The
Onsite program reduces septic system failures, repairs failing systems, and
permits new septic systems.

WES is notified in a variety of ways when septic systems are failing. Owners or
renters contact WES to identify options and potential problems. Adjacent
property owners contact WES with reports of suspected systems that are based
on problems with odors, discharge onto their properties, water bodies or roadside
ditches. Other County departments or local agencies may also refer a suspected
system to WES for investigation.

Failing systems are both a health hazard and a potential environmental threat
and are a high priority for WES to address. One goal of the onsite program is to
investigate the suspected problem or complaint the same day as receiving the
notice of a potential problem. The complaint becomes a high priority in three
days and urgent in a week. If a site visit has not been performed within one
week, the activity has a higher priority than all of the other activities performed by
the Onsite program’s staff.

For failing systems, steps for needed correction are identified by WES and a


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               46
process for implementation is set forth. Initial efforts by WES encourage
voluntary compliance. WES has an agreement with Clackamas County’s
Community Environment Division to bring violators into compliance if other efforts
are unsuccessful. In the event this is unsuccessful, the County has the ability to
levy both fines and fees for code violations. A citation of $500 and additional civil
penalties of up to $3,500 per violation can be issued for a high priority violation.
Time frames for repair are established with the property owners and the length of
time allotted to repair is determined based on the severity of the problem.
Discharges to the ground surface and into waterways are not allowed and are
given as short a time as feasible for construction of repairs or alternatives.
Alternatives vary from limiting the usage of the septic system (timing of laundry,
for example), to installing a temporary holding tank, or vacating the premises until
the problem is resolved.

Measurable Performance Indicators:
The following figures are countywide, of which only a small portion is inside the
MS4 permitted areas of SWMACC and CCSD#1. For the 2005-2006 reporting
period:
   • The number of septic system permits issued was 787
   • The number of inspections performed was 861
   • The number of enforcement actions taken was 88



4.6.5 IDEP: Spills into the MS4 [Schedule D(2)(c)(ii)(4)]
The MS4 permit requires “…A description of procedures to prevent, contain, and
respond to spills that may discharge into the municipal separate storm sewer.“

WES’ Spill Response Program prevents, contains, and responds to spills of
dangerous, hazardous and other materials in the MS4-permitted areas of
CCSD#1 and SWMACC. The Spill Response Program ensures that the actual or
possible release of dangerous/hazardous materials to the MS4 is properly
addressed. Except for minor incidents, personnel always coordinate closely with
other agencies and departments, including Clackamas County Fire District No. 1
(and for certain incidents involving hazardous materials, the Gresham HazMat
Team), Tualatin Valley Fire & Rescue, DEQ, Oregon State Police, Clackamas
County’s Road Department, and Oregon’s Department of Transportation.

A draft Standard Operating Procedure (SOP) was created in 1999 for addressing
and responding to spills of dangerous and/or hazardous materials. This SOP
was revised and finalized in 2004. The 2004 SOP provides guidance to
employees who administer the Spill Response Program. Specific guidance is
provided by the SOP in the following areas:
   • Determining if the incident needs to be reported to Oregon Emergency
       Response System (OERS - see the next paragraph in this section)




MS4 Permit Compliance Report for CCSD#1 & SWMACC                             47
   •   Determining if a site visit needs to be performed by WES personnel. If a
       site visit is not to be performed, guidance on providing a proper referral of
       the incident to another government agency is provided
   •   How to conduct a safe and effective site inspection as a first responder to
       an incident
   •   How to safely prioritize activities at the site of a release.
   •   Protecting the environment through deployment of certain spill response
       tools, such as granular absorbents, absorbent booms, and pads.
   •   Documenting the release incident
   •   Incident follow-up activities

Certain incidents involving the release of pollutants in the State of Oregon must
be promptly reported to OERS at 800-452-0311. Incidents that must be reported
to OERS, as contained in OAR 340-108-0010(1), involve the release of materials
in amounts greater than or equal to the following:
    • If spilled into waters of the state, or escape into waters of the state is
       likely, any quantity of oil (or other petroleum-based fuel or lubricant) that
       would produce a visible oily slick, oily solids, or coat aquatic life, habitat or
       property with oil, but excluding normal discharges from properly operating
       marine engines
    • If spilled on the surface of the land, any quantity of oil over one barrel (42
       gallons)
    • An amount equal to or greater than the quantity listed in 40 CFR Part 302-
       Table 302.4. This is a list of hazardous substances and their reportable
       quantities. See the 2004 SOP for this large and detailed document.
    • One (1) pound of pesticide residue as defined by 340-101-0033(5)(a)
    • Virtually any quantity of nerve agents (such as Sarin, VX, etc.)
    • Any quantity of radioactive material, or radioactive waste

WES responded to and/or documented the following spill incidents in CCSD#1
during the 7/1/05 to 6/30/06 reporting period:
   1. OERS 2005-1478. Sewage Released from Truck, 7/1/05. Sewage was
       released from a truck at the junction of Hwy 212/224 and I-205. The
       volume released was about 50 gallons. Some sewage entered ODOT's
       surface-discharging storm sewer system, but it only flowed a short
       distance downstream, and no sewage entered waters of the state. A
       cleanup contractor removed all of the sewage that had entered ODOT's
       MS4. The responsible party's identity is unknown. A Notice of
       Noncompliance (NON) was not issued by WES, for there was no
       discharge to the County’s storm sewer system and because the
       Responsible Party's (RP) identity is unknown.
   2. Not reported to OERS. Motor Oil, 11/7/05. On November 7, 2005, a
       WES storm sewer system cleaning crew discovered a catch basin that
       had an unusual amount of oil in it. The catch basin is in the street in front
       of the home at 13760 SE Ellen Drive in CCSD#1. A WES inspector
       confirmed that there was no detectable oil in a downgradient catch basin,


MS4 Permit Compliance Report for CCSD#1 & SWMACC                                 48
      manhole, and aboveground, vegetated stormwater detention pond on that
      date, so the release was not reported to OERS. The inspector then
      applied granular absorbent material to the surface of the street near the
      catch basin, and put two absorbent pads in the catch basin. These items
      were removed at WES’ expense after the oil was absorbed, then the catch
      basin was cleaned. All neighbors in the area were contacted by WES, but
      none claimed to be responsible for the oily waste. These neighbors were
      asked to take reasonable measures to prevent spills in the future, and if
      they do occur, to quickly clean all impacted areas and prevent the entry of
      the material into storm sewers. A NON was not issued, for the RP's
      identity is unknown.
   3. OERS 2005-2978. Diesel Spill from a Truck Owned by Gordon
      Trucking, 12/21/05. WES received a telephone call from a representative
      of the Safeway Distribution Center (16800 SE Evelyn St. in Clackamas) on
      December 21, 2005, who said that Safeway had become aware of a
      significant diesel spill. The diesel was released from a truck owned by
      Gordon Trucking at the Distribution Center. Diesel entered Safeway’s
      private storm sewer system, then moved downstream through the
      County’s storm sewer system and into the Clackamas River at Riverside
      Park. Gordon Trucking took full responsibility for the release and Safeway
      and Gordon Trucking personnel deployed absorbent materials around the
      Safeway distribution center and at the outfall. ThermoFluids arrived later
      in the day to replace absorbent pads and booms and to vacuum the
      impacted sections of storm sewer system and River. The total volume of
      diesel that was released was estimated to be between two and three
      gallons. Significant rains on that day then moved this fuel away from the
      spill location. A NON was issued to Gordon Trucking (15628 SE 102nd
      Avenue/Clackamas) by WES on January 9, 2006.
   4. OERS 2005-3087. Petroleum on Roadways, 12/29/05. The City of
      Milwaukie documented a petroleum sheen on the surface of SE Johnson
      Creek Blvd in Milwaukie and in CCSD#1, on I-205, and on other nearby
      roadways. The City traced the source of the sheen to a dump truck that
      was traveling to and from a construction site in the City of Portland at SE
      39th and Henderson. Roadways were wet at the time; the sheen on the
      impacted roadways was about 18” wide. Given that the material could’ve
      posed a traction hazard for vehicles, ODOT spread sand on the petroleum
      at the Johnson Creek Blvd/I-205 interchange. None of the material that
      was released West of I-205 in CCSD#1 was recovered, for City of
      Milwaukie staff did not believe that this small quantity of petroleum on
      Johnson Creek Blvd. was readily recoverable with granular absorbent
      material or any other means. A NON was not issued by WES, for it is
      WES’ understanding that the City of Portland intended to initiate an
      enforcement action for the release.
   5. OERS 2006-0027. Diesel Spill from a Central Refrigerated Service,
      Inc. Truck, 1/2/06. WES received a telephone call and email message
      from a representative of the Safeway Distribution Center (16800 SE



MS4 Permit Compliance Report for CCSD#1 & SWMACC                          49
      Evelyn St. in Clackamas) on January 2, 2006, who said that Safeway had
      become aware of a significant diesel spill on that day. The diesel was
      released from a truck owned by Central Refrigerated Service, Inc. at the
      Distribution Center and on several nearby roads. A significant amount of
      rain fell on this day. Diesel entered Safeway’s private storm sewer
      system, then moved downstream through the County’s storm sewer
      system and into the Clackamas River at Riverside Park. Diesel also
      appears to have entered Cow Creek, a Clackamas River tributary, from
      SE Last Road and Evelyn Street. Safeway personnel quickly deployed
      absorbent materials around the Safeway distribution center and at the
      outfall. ThermoFluids arrived later in the day to replace absorbent pads
      and booms, to pressure-wash diesel from pavement, and to vacuum
      diesel from the impacted sections of public and private storm sewer
      system and the River. The total volume of diesel that was released is not
      known. A NON was issued to Central Refrigerated Service, Inc. (Salt
      Lake City, Utah) by WES on January 9, 2006.
   6. OERS 2006-0092. Motor Oil Spill from Rented Truck, 1/6/06. WES
      received a telephone call from a representative of the Safeway Distribution
      Center (16800 SE Evelyn St. in Clackamas) on January 6, 2006, who said
      that Safeway had become aware of a small spill of motor oil on that day.
      The motor oil was released at the Distribution Center from a truck owned
      by Penske Truck Rentals. The truck had been leased by a company
      called Naturally Fresh (Atlanta, Georgia). All motor oil was quickly
      contained with granular absorbent materials by Safeway personnel.
      ThermoFluids arrived later in the day to pressure-wash and vacuum oil
      from pavement. The total volume of motor oil that was released was no
      more than eight (8) quarts and may have been as few as one or two
      quarts. A NON was not issued by WES, for oil was not discharged to
      County or CCSD#1-owned storm sewers.
   7. OERS 2006-0264. Hydraulic Fluid from Recycling Center, 1/17/06. A
      WES water sample collection crew detected a petroleum sheen on Cow
      Creek, a significant Clackamas River tributary, on January 17, 2006. A
      portion of this sheen was traced to the waste paper compacting machine
      at K.B. Recycling, Inc.’s facility at 9602 SE Clackamas Road in
      Clackamas. Hydraulic fluid had leaked from the waste paper compactor,
      then was washed by rainfall into K.B. Recycling, Inc.’s storm sewer
      system, a wetland, a ditch that drains the wetland, and into Cow Creek.
      WES and K.B. Recycling staff deployed a boom and numerous pads –
      provided free of charge by WES – on the uncovered, paved area near and
      beneath the compacter and on a man-made swale which receives
      drainage from the compacter’s area. The company then purchased
      booms and pads that were used to capture more hydraulic fluid on and
      after January 17th. The company swept the area around and beneath the
      waste paper compacter’s area on January 17th, for loose paper that had
      fallen onto an uncovered, paved area around the compacter had soaked
      up some hydraulic fluid. A NON was not issued by WES, for hydraulic



MS4 Permit Compliance Report for CCSD#1 & SWMACC                          50
       fluid was not discharged into a storm sewer system that is owned by
       Clackamas County or CCSD#1.
   8. OERS 2006-0545. Paint from Vehicle, 2/13/06. On February 13, 2006,
       a vehicle of some type (unknown make, model, owner, etc.) dropped
       several containers of paint onto SE Clackamas Road in CCSD#1. This
       release occurred in the early morning darkness during rainy weather and
       most of the roughly eight (8) gallons of paint that were spilled flowed
       through a county-owned storm sewer system and into Kellogg Creek.
       Crews from WES and Clackamas County’s Road Dept. responded to the
       scene, and some paint was removed with a vactor-type truck’s high-
       pressure hose & vacuum and with a street sweeping truck. A NON was
       not issued by WES, for the RP is unknown.
   9. Not Reported to OERS. Gasoline, 2/24/06. A citizen witnessed the
       response to a gasoline spill in the parking lot of the Fred Meyer store at
       16301 SE 82nd Drive in CCSD#1 on the evening of Friday, February 24,
       2006. A WES inspector called the store on March 1st and talked with a
       store employee to get more information, and he said that it was his
       understanding that no gasoline made it into the store's storm sewer
       system. Sorbents and drain blocking mats were used. The gasoline was
       released from a van that had been driven to the store by a store customer.
       The amount of gasoline that was released is unknown, but it must have
       been less than 42 gallons, the reporting threshold. A NON was not issued
       – and a letter was not sent – by WES, for the release appears to have
       been accidental and the RP’s identity is not known.
   10. Not Reported to OERS. Motor Oil, 3/8/06. A WES inspector responded
       to a report of a motor oil leak on March 8, 2006. The automobile was
       parked in the street in front of the home at 9452 SE Chatfield Court in
       CCSD#1’s Altamont neighborhood, and it was raining heavily at the time.
       Motor oil was washing off from the space where the car was. The
       stormwater then entered the County’s storm sewer system. The release
       was not reported to OERS, for the amount of stormwater contamination
       was similar to that found in many convenience store parking lots. The car
       was owned by the homeowner’s housekeeper. The homeowner was
       asked in a March 31st letter to please notify the housekeeper that
       reasonable measures (proper use of granular absorbents, or park the car
       in a garage, are examples) did need to be taken to prevent or minimize
       stormwater contamination if the leak was not going to be fixed. On April
       3rd, the homeowner indicated that the car was going to be sold or donated
       to charity in the near future.
   11. OERS 2006-0784. Diesel Fuel from Highway Collision, 3/17/06. On
       March 17, 2006, a six vehicle collision occurred during heavy rainfall on
       and near the I-205 bridge over the Tualatin River in SWMACC. This
       collision did not occur in SWMACC’s MS4-permitted area. About 25
       gallons of diesel fuel were released from one of two trucks that were
       involved in the collision. ODOT and DEQ responded to the scene.
       According to DEQ’s responder, a small amount of fuel entered the



MS4 Permit Compliance Report for CCSD#1 & SWMACC                          51
       Tualatin River. WES inspectors were not notified of this release and did
       not participate in the cleanup. A NON was not issued by WES, for the
       release was accidental and diesel was not discharged into a storm sewer
       system owned by Clackamas County or SWMACC.
   12. Not Reported to OERS. Oil on Kellogg Creek, May 2006. Residents of
       the home at 7529 SE Lillian Avenue in CCSD#1 contacted WES on May
       23, 2006 to say that there had recently been oil on the surface of Kellogg
       Creek in their back yard. Although they didn’t know which day they’d seen
       the oil, it had been before heavy rains started to fall on May 21st. Oil was
       not present on Kellogg Creek’s waters on May 23rd, or on any date after
       that, so the release was not reported to OERS. For future releases, the
       residents were urged to contact WES as soon as they become aware of it.
       A NON was not issued by WES, for the RP’s identity is unknown.
   13. OERS 2006-1556. Fire Suppression Flows from Manufacturing
       Facility, 6/25/06. A fire occurred at Design Craft Door's shop at 7813 SE
       Luther in the early morning on Sunday, June 25, 2006, and some fire
       suppression flows left the site. The structure(s) that burned were about
       115 feet north of a portion of CCSD#1 (in Multnomah County and in the
       City of Portland), but at least some of the wastewater flowed through
       CCSD#1 on the way to Johnson Creek. Information on the chemicals and
       other wastes that may have been in the wastewater are not available.
       Clackamas County Fire District #1 and City of Portland Fire Bureau both
       responded to the scene. WES staff did not participate in the cleanup. A
       NON was not issued by WES, for: a) the fire appears to have been caused
       by arson, which is a criminal act, and b) the source of the wastewater was
       not within CCSD#1.

Measurable Performance Indicator:
  • The total number of spills that were controlled and/or addressed by WES
     or by one or more of WES’ partners. Thirteen (13) illicit discharges were
     identified and/or controlled during the reporting period.

The following older incident, originally included in the 2004-2005 annual report, is
still unresolved:
     • OERS 2004-1457. Paint Waste from House Painting, 7/12/04. A citizen
        called WES on July 12, 2004 to report that paint and/or paint cleanup-
        related wastewater was being discharged into the public storm sewer
        system from the house at 10662 SE Happy Valley Drive in the portion of
        the City of Happy Valley that is within CCSD#1. The two WES inspectors
        who promptly conducted a site visit confirmed that College Works Painting
        of Santa Ana, California was actively discharging a significant volume of
        paint and paint cleanup-related wastewater into the public storm sewer
        system from this home. When the inspectors arrived, they observed that
        paint and paint cleanup-related wastewater was being intentionally
        discharged into the street and the public storm sewer system by two of
        College Works Painting’s employees. Earlier that day, waste paint and


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             52
       paint cleanup-related wastewater had entered the home’s backyard
       drainage lines, allowing a mixture of paint and water to drain onto the
       surface of the street from the curb’s drain line. About a gallon of paint
       (plus large amounts of water) were discharged. At the time the inspectors
       arrived, the College Works Painting employees were using a garden hose
       – flowing at the maximum rate – to intentionally push paint and paint
       cleanup-related wastewater down the street and into the public storm
       sewer system. By the time the inspectors arrived at the site, the College
       Works Painting’s employees had: a) made no attempt to notify the City of
       Happy Valley, Clackamas County, the State of Oregon or Clackamas
       County Fire Dist. No. 1 of this release of paint, and b) had not tried to
       remove any of the paint and paint cleanup-related wastewater from the
       street or public storm sewer system. Thermo Fluids, an environmental
       services firm, was hired by College Works Painting to remove the paint
       and paint-containing wastewaters from the home’s storm sewer lines, the
       street’s surface, and the public storm sewer system. NONs were issued
       by WES on November 5, 2004 and April 7, 2005, both of which requested
       that a written response be submitted to WES. Email messages were
       exchanged in September 2005; WES requested a written response at that
       time as well. Numerous phone conversations, the most recent of which
       was on October 10, 2005, have also occurred where WES requested a
       written reply. WES’ file for this case is still open, for College Works
       Painting has not submitted a written response to WES with regards to the
       July 12, 2004 release. It is also important to note here that College Works
       Painting was also responsible for a significant release of paint and paint-
       containing wastewater to public storm sewers from the home at 12261 SE
       Easthampton Street in Clackamas on June 27, 2001. These two
       properties (12261 SE Easthampton Street and 10662 SE Happy Valley
       Drive) are both within WES’ Clackamas County Service District No. 1. A
       NON was also issued by WES for that June 27, 2001 release.


4.6.6 IDEP: Public Reporting [Schedule D(2)(c)(ii)(5)]
The District implements a program to promote, publicize, and facilitate public
reporting of the presence of illicit discharges and other types of improper disposal
of materials into the MS4. After WES receives a report, staff investigate and, if
appropriate, apply control measures.

Illicit Discharges and Spills: Through the periodic publication of articles in the
Districts’ newsletters, Streamlines and Mainstream, ratepayers are encouraged
to promptly report illicit discharges and spills. This newsletter is mailed to every
ratepayer in each District along with each billing statement. In a recent article,
ratepayers were:
• provided with guidance on determining what an illicit discharge is;
• directed to keep at a safe distance and in an upwind direction from the
     discharge or spill;


MS4 Permit Compliance Report for CCSD#1 & SWMACC                              53
•   call 911 for certain high-priority incidents

After citizens become aware of an illicit discharge or spill, they’re encouraged to
promptly contact WES in person, by phone, or by email.

Other types of improper disposal of materials: Information on this is
transmitted to the public through the District’s newsletters, Streamlines and
Mainstream. On a periodic basis, articles on various relevant topics (for
examples, proper pet waste disposal and proper yard debris management) are
published.

A new Public Reporting item which became available for the first time during the
2005-2006 reporting period is a “problem reporting form” on WES’ website.
Spills and illicit discharges can now be reported to WES at:
http://www.co.clackamas.or.us/wes/forms/report_problem.htm

Please see section 4.11 for a full report on the Public Reporting section’s
achievements during the 2005-2006 reporting period.


4.6.7 IDEP: Management of Used Oil & Toxic Materials [Schedule
D(2)(c)(ii)(6)]
The MS4 permit requires “A description of educational activities, public
information activities, and other appropriate activities to facilitate the proper
management and disposal of used oil and toxic materials.”

Through the periodic publication of articles in the Districts’ newsletters,
ratepayers are encouraged to:
• properly dispose of used oil, unused quantities of toxic materials, and toxic
    wastes, and
• use products that are not toxic or less toxic. This eliminates the generation of
    toxic waste or reduces the toxicity of the waste that is generated.

In these newsletter articles and in the direct conversations with the ratepayers
that contact WES for guidance, citizens are encouraged to contact Metro for
guidance on the proper disposal of used oil and toxic materials. Metro provides
its services throughout the Portland metropolitan area, including all portions of
the Districts. When customers contact WES about disposal of these items,
they’re usually referred to Metro’s hotline (503-234-3000) or encouraged to visit
the nearest household hazardous waste facility located at Metro’s South Transfer
Station in Oregon City. Metro implements a program that:
• Operates two household hazardous waste facilities. One of these is adjacent
    to the Metro South Transfer Station in Oregon City. Used oil and many types
    of toxic materials can be deposited here, and;
• Operates Metro’s hotline (503-234-3000). Callers are provided with
    information about the various facilities that used oil and many toxic materials


MS4 Permit Compliance Report for CCSD#1 & SWMACC                                54
    can be taken to, for the household hazardous waste facility is not able to
    accept all types of toxic materials from all types of District ratepayers, and;
•   In conjunction with Clackamas County’s Community Environment Division,
    Metro mandates that curbside recycling services be available to all curbside
    solid waste customers in the Districts. Used oil can be recycled at the
    curbside by any curbside solid waste customer in the District.

On unusual occasions when certain customers contact the District about the
proper disposal methods for certain specific toxic disposal guidance (i.e. large
quantity of material from an industrial customer), they’re not referred to Metro,
but are referred to DEQ’s Hazardous Waste group.

During the 2005-2006 reporting period, callers were directed to Metro for
guidance on the proper disposal of used oil and toxic materials. Please see
chapter 4.11 (titled “public involvement) for a full report on the public information
activities that are relevant to this section which were conducted during the 2005-
2006 reporting period.


4.6.8 IDEP: Seepage from Municipal Sanitary Sewers [Schedule
D(2)(c)(ii)(7)]
The MS4 permit requires “A description of controls to limit infiltration of seepage
from municipal sanitary sewers to municipal separate storm sewer systems
where necessary.”

The only public sanitary sewer lines in SWMACC’s MS4-permitted area are
owned by the City of Lake Oswego, an MS4 permit co-permittee. Controls to
detect seepage from these lines into the County’s/SWMACC’s MS4 is addressed
through annual, dry-weather storm sewer outfall inspections (see chapter 4.6.4)
and through promptly responding to reports from citizens of unusual colors, odors
and solids.

CCSD#1 prevents exfiltration of flows from its municipal sanitary sewers in the
following ways:
• Through ownership of a relatively new sanitary sewer system. Most of the
    infrastructure in CCSD#1-UGB’s sanitary sewer system has been constructed
    since 1974 and its condition is generally sound and free of cracks and leaks.
• Through the presence of a rigorous maintenance program involving routine
    cleaning and inspection of lines to ensure that there are very few leaks. Lines
    are inspected with a television camera on a periodic basis. Tree roots, which
    could cause leakage, are removed whenever identified.

CCSD#1 is able to identify and control the exfiltration of flows from municipal
sanitary sewers when it occurs by:
• Performing dry-weather inspections at all major outfalls on an annual basis to
   detect non-stormwater flows, and;


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               55
•    Receiving and promptly responding to reports from citizens of unusual colors,
     odors and solids, and;
•    By performing monthly instream monitoring. At this time, this monitoring is
     performed at all major creeks and at three (3) storm outfalls in the MS4-
     permitted areas of CCSD#1-UGB. This monthly monitoring can detect
     exfiltration of flows from municipal sanitary sewers to the MS4 in two ways: a)
     olfactory cues can allow a person who is collecting surface water samples to
     detect the presence of sewage, and b) E. coli is one of the parameters that
     the water samples are analyzed for. High levels of E. coli over a significant
     time period could prompt a special, follow-up visit to the area by District staff
     to attempt to locate the source(s) of the bacteria.



4.7     Industrial Stormwater Program and
        Commercial/Residential Stormwater Program [Schedule
        D(2)(c)(iii)]

The MS4 permit requires ”A description of a program to monitor and control
pollutants in stormwater discharges to municipal systems from municipal landfills,
hazardous waste treatment, disposal and recovery facilities, industrial facilities
that are subject to section 313 of title III of the Superfund Amendments and
Reauthorization Act of 1986 (SARA), and industrial facilities that the municipal
permit applicant determines are contributing a substantial pollutant loading to the
municipal storm sewer system.” Chapter 4.7 is divided into these five sections:

A.   Municipal landfills
B.   Hazardous waste treatment, disposal and recovery facilities
C.   Industrial facilities that are subject to section 313 of SARA title III
D.   Other industrial facilities
E.   Commercial/residential stormwater program

Each of these above-noted sections is addressed separately below. The MS4
permit also states that “The program must:
• Identify priorities and procedures for inspections and establishing and
   implementing control measures for such discharges, and;
• Describe a monitoring program for stormwater discharges associated with the
   industrial facilities identified in Schedule D(2)(c)(iii), to be implemented during
   the term of the permit, including, at a minimum, the submission of quantitative
   data on the pollutant parameters included in the Department’s NPDES 1200-
   Z industrial general stormwater permit.”

Within each of the first four of the following five sections of 4.7, both of these
additional programmatic areas – inspections & control measures and monitoring
program for stormwater discharges – are addressed separately.



MS4 Permit Compliance Report for CCSD#1 & SWMACC                               56
The first four sections of chapter 4.7 only pertain to the portion of CCSD#1 that’s
within the Urban Growth Boundary, for there are no industrial lands in
SWMACC’s MS4-permitted area. The fifth section, titled “commercial/residential
stormwater program” applies to all commercially and residentially zoned lands in
CCSD#1-UGB and SWMACC. Twenty-one (21) industrial facilities in CCSD#1-
UGB are currently in possession of a DEQ 1200Z NPDES Stormwater Discharge
Permit (see table 2). CCSD#1 will continue to maintain a long-standing policy of
referring facilities to DEQ if they lack a 1200Z, but are required to have one.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                            57
Table 2
            Company Name                         Address                Area          DEQ File #
Bovic Industries dba Container Bins   13109 SE 132nd Avenue         Clackamas        103872
Consolidated Metco, Inc.              10448 SE Highway 212          Clackamas        106964
R. S. Davis Recycling, Inc.           10105 SE Mather Road          Clackamas        109850
Fred Meyer Inc.                       11500 SE Highway 212          Clackamas        106748
Distribution Inc. dba FTL             16795 SE Evelyn Street        Clackamas        107617
Gordon Trucking, Inc.                 15628 SE 102nd Avenue         Clackamas        107688
McFarlane’s Bark, Inc.                13345 SE Johnson Road         Milwaukie        110259
Miles Fiberglass & Composites, Inc.   8855 SE Otty Rd               Portland         106844
SNF, Inc. dba Gem Top                 8811 SE Herbert Court         Clackamas        110962
Oregon Iron Works, Inc.               9700 SE Lawnfield Road        Clackamas        107395
Precision Castparts Corp.             13340 SE 84th Avenue          Clackamas        71920
Precision Castparts Corp.             6667 SE Johnson Creek Blvd.   Portland         110151
Precision Castparts Corp.             13350 SE Johnson Road         Milwaukie        109805
Precision Castparts Corp.             6465 SE Crosswhite Way        Portland         106157
Safety-Kleen Systems, Inc.            16540 SE 130th Avenue         Clackamas        102806
Safeway Stores, Inc.                  16800 SE Evelyn Street        Clackamas        102441
SAPA Anodizing, Inc.                  9124 SE 64th Avenue           Portland         107010
Temco Metal Products                  10240 SE Mather Road          Clackamas        113713
Unified Western Grocers, Inc.         6433 SE Lake Road             Milwaukie        111951
Warn Industries, Inc.                 13270 SE Pheasant Court       Milwaukie        107180
Wymore Transfer Co.                   12651 SE Capps Road           Clackamas        110888




4.7.1 Municipal Landfills

Description
There are only two (2) facilities in the District’s MS4-permitted area that appear to
qualify as municipal landfills:
• One is a closed landfill in CCSD#1-UGB. Schedule D(2)(c)(iii)’s requirements
   for that closed landfill are satisfied by the program that is described under
   section 4.4, which is titled “Pollutants in Runoff From Closed Landfills.”
• The other qualifying facility appears to be McFarlane’s Bark, Inc. in CCSD#1-
   UGB. The District does not – and the District believes that it is not required to
   – maintain a program that is mandated by schedule D(2)(c)(iii) of the MS4
   permit for McFarlane’s Bark, Inc.’s facility because: a) the facility does not
   discharge stormwater into the District’s MS4, and; b) the facility is currently in
   possession of 1200Z NPDES permit that was issued – and is administered –
   by the DEQ.

Inspections and Control Measures:
Not applicable. See the Description portion of this section.

Monitoring Program for Stormwater Discharges:
Not applicable. See the Description portion of this section.

Measurable performance indicators:


MS4 Permit Compliance Report for CCSD#1 & SWMACC                                58
Not applicable. See the Description portion of this section.


4.7.2 Hazardous Waste Treatment, Disposal, and Recovery Facilities

CCSD#1:
The District is aware of only one facility in the District which meets the definition
of a Hazardous Waste Treatment, Disposal and Recovery (TDR) Facility. This
facility is Safety Kleen Systems’ operation at 16540 SE 130th Avenue.

Inspections and Control Measures:
The District did not perform any inspections of this facility given that the facility is
in possession of a 1200Z NPDES Stormwater Discharge permit. This is due to
the facts that: 1) the District does not act as DEQ’s agent for the administration of
the 1200Z permit, and 2) DEQ does not provide the District with any information
on the administration of the 1200Z permit (i.e. does not share copies of reports
submitted by 1200Z permit holders, does not share stormwater quality data). In
the future, exceptions to this inspection policy will be made if:
    • the District is invited to visit this facility by Safety Kleen Systems
    • the District is invited to visit the facility by DEQ
    • the District receives a complaint or referral about the facility that pertains
       to an actual or potential discharge of significantly polluted stormwater to
       the MS4. An inspection would also be conducted in the event of a spill or
       illicit discharge that enters – or threatens to enter – the MS4.

Monitoring Program for Stormwater Discharges:
Given that this permit has extensive stormwater quality monitoring requirements,
the District will not monitor the facility’s stormwater quality unless one of the three
above-noted exceptions (see inspections and control measures) occurs.

Measurable performance indicators:
The measurable performance indicator is the presence or absence of a valid
1200Z permit for the Safety Kleen Systems’ facility at 16540 SE 130th Avenue in
Clackamas. This permit was in effect during the reporting period.


4.7.3 Industrial Facilities Subject to Section 313 of SARA Title III

Description:
Facilities that are subject to the requirements in Section 313 of SARA Title III are
those required to report to U.S. EPA (via the State Fire Marshal) air, water and
land discharges of certain toxic chemicals used in industrial process. The need
to report is triggered by exceeding specified threshold usage levels for certain
toxic chemicals. The data in these reports are added to the EPA’s Toxic Release
Inventory (TRI) database. The TRI reporters have thresholds for reporting to the
EPA that are much higher than those required by the State Fire Marshal under


MS4 Permit Compliance Report for CCSD#1 & SWMACC                                59
Oregon’s Community Right-to-Know law. The relevant MS4 permit requirement
[Schedule D(2)(c)(iii)] for this portion of the SWMP pertains only to the TRI
reports to the EPA, not those reports required by the State Fire Marshal under
Oregon’s Community Right-to-Know law. To the best of the District’s knowledge,
the following facilities are subject to the reporting requirements of Section 313 of
SARA Title III:
   1. Miles Fiberglass & Plastics            8855 SE Otty Road
   2. Warn Industries, Inc.                  13270 SE Pheasant Court
   3. Warn Industries, Inc.                  12900 SE Capps Road
   4. Safety Kleen Systems                   16540 SE 130th Avenue
   5. PCC Structurals Inc.                   13340 SE 84th Avenue
   6. PCC Structurals Inc.                   13350 SE Johnson Road
   7. Unified Western Grocers                6433 SE Lake Road

These seven (7) facilities were located during a detailed search of an EPA
webpage titled Toxics Release Inventory (TRI) Program on November 28, 2005.
The address of this page is: http://www.epa.gov/tri/tridata/state_data_files.htm.
Reports from these facilities were present in the EPA database for 2002, the
most recent year for which data is available. Reports from facilities from previous
years were not used to compile this list.

Inspections and Control Measures:
In general, the District will not perform any inspections at a facility if the facility is
in possession of a 1200Z NPDES Stormwater Discharge permit. This is
because: 1) the District does not act as DEQ’s agent for the administration of the
1200Z permit, and 2) the DEQ does not provide the District with any information
on the administration of the 1200Z permit (i.e. does not share copies of reports
submitted by 1200Z permit holders, does not share stormwater quality data). In
the future, exceptions to this inspection policy will be made if:
    • the District is invited to visit the facility by the industry
    • the District is invited to visit the facility by DEQ
    • the District receives a complaint or referral about the facility that pertains
       to an actual or potential discharge of significantly polluted stormwater to
       the MS4. An inspection would also be conducted in the event of a spill or
       illicit discharge that enters – or threatens to enter – the MS4.

Of the above-noted seven facilities, the following six (6) facilities are currently
authorized to discharge stormwater under a 1200Z permit:
    • Miles Fiberglass & Plastics         8855 SE Otty Road
    • Warn Industries, Inc.               13270 SE Pheasant Court
    • Safety Kleen Systems                16540 SE 130th Ave
    • PCC Structurals Inc.                13340 SE 84th Ave
    • PCC Structurals Inc.                13350 SE Johnson Road
    • Unified Western Grocers             6433 SE Lake Road




MS4 Permit Compliance Report for CCSD#1 & SWMACC                                   60
The facility that does not have a 1200Z permit is the Warn Industries, Inc.’s
facility at 12900 SE Capps Road in Clackamas. It is connected to the MS4 in the
District. In the May 1, 2006 IER to DEQ, District personnel pledged to seek
permission from Warn Industries to conduct an inspection of the facility during
the term of the MS4 permit (7/27/05 to 2/28/09). During this inspection, District
personnel will attempt to determine if this facility is required to obtain a 1200Z
permit. If this facility is required by the Department to obtain a 1200Z permit, and
if one is obtained, the relationship between the District and the facility would be
similar to the above-noted six (6) facilities that already are in possession of a
1200Z permit. If the District and DEQ determine that this facility is not required to
obtain a 1200Z permit, District personnel will ask Warn Industries, Inc. to
voluntarily collect a representative sample of stormwater during one storm in the
first rainy season following the inspection of their facility. This stormwater would
then be analyzed for the 1200Z permit’s pollutant parameters.

Monitoring Program for Stormwater Discharges:
As was stated above, if the District and DEQ determine that the Warn Industries,
Inc. facility at 12900 SE Capps Road in Clackamas is not required to obtain a
1200Z permit, District personnel will ask Warn Industries, Inc. to voluntarily
collect a representative sample of stormwater during one storm from their facility;
this stormwater would then be analyzed for the 1200Z permit’s pollutant
parameters. In addition, CCSD#1 will ask the facility to share the data and will
include the data in the relevant MS4 permit annual report to DEQ. If the data
shows that one or more of the 1200Z permit’s pollutant parameters was
exceeded, then District personnel will ask the facility to conduct source tracking
work in an effort to identify the source of the pollution, and if necessary, District
personnel will ask the facility to implement control measures to improve the
quality of the facility’s stormwater discharges. If the facility implements control
measures but the initial attempt to improve stormwater quality does not produce
the required improvement, District personnel will continue to provide guidance
and technical assistance until the facility’s stormwater quality improves to the
required level. This inspection of Warn Industries’ facility did not occur during the
2005-2006 MS4 permit reporting period.

Measurable performance indicators:
The performance of an inspection of the Warn Industries facility at 12900 SE
Capps Road is the primary measurable performance indicator. This inspection of
Warn Industries’ facility did not occur during the 2005-2006 MS4 permit reporting
period. If it is determined in the future that a 1200Z permit is not required to be
obtained by this facility, then successful completion of a storm monitoring event
will be an additional measurable performance indicator. A third measurable
performance indicator will be for the District to notify Warn Industries that
stormwater quality improvement is needed if a 1200Z permit is not required to be
obtained by this facility, if a storm monitoring event is successfully completed,
and if the laboratory data from that storm’s water samples shows that
improvement in the site’s stormwater quality is needed.



MS4 Permit Compliance Report for CCSD#1 & SWMACC                              61
4.7.4 Other Industrial Facilities

Description:
This section’s facilities are addressed directly by the District and are those that:
   • Are not required to obtain a 1200Z permit, and that contribute a
       substantial load of pollutants to the MS4. This generally is determined by
       the District to have occurred if the facility’s stormwater runoff exceeds (or
       is likely to exceed) the DEQ’s surface water quality standards in OAR
       340’s Division 41, or
   • Have 1200Z permits that invite WES to their site to render technical
       assistance. Other industrial facilities also include those facilities with
       1200Z permits that are visited by WES in response to water quality
       complaints that are received.

Inspections and Control Measures:
Facilities will primarily be inspected on a complaint-driven basis, but it is possible
that some inspections will be conducted by the District during source tracking
activity if the District’s storm event monitoring work or monthly monitoring work
shows that excessive levels of one or more pollutants are present. All facilities
that are the subject of a complaint will be inspected in a timely manner by District
staff. The implementation of control measures for stormwater discharges from
these facilities will be deemed necessary by the District if the presence of excess
levels of stormwater pollution can be confirmed by the District. For instances
where the presence of excess levels of pollution in stormwater has been
confirmed by the District, and in the event that the discharger’s initial attempts to
improve stormwater quality do not produce the required improvement, then
District personnel will continue to provide guidance and technical assistance until
the facility’s stormwater quality improves.

Monitoring program for stormwater discharges:
The presence of excess levels of pollution in stormwater can generally be
confirmed by two general methods: visual and analytical. Analytical
methodologies include hand-held meters, test strips (i.e. pH) and those
performed by a water laboratory. The District will use visual or analytical
methods at the District’s discretion.

Inspections conducted during reporting period:
   1. FTL site at 16795 SE Evelyn in Clackamas, 12/22/05. A WES technical
      assistance inspector was invited to the site by Distribution Inc., dba FTL,
      to discuss their site's stormwater management system and their spill
      prevention and response system. During this visit, much of the focus was
      on their 1200Z permit. FTL had until March 2006 to revise their 1200Z's
      Stormwater Management Plan (SWMP). It had been raining heavily on
      12/22/05, and the site's stormwater discharge to the MS4 was turbid. The


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      turbid nature of the runoff appeared to be wholly due to the fact that a
      large part of the yard's unpaved surface had a large percentage of fine
      solids. The WES technical assistance inspector asked FTL to consider re-
      working the surface of much of the facility’s parking lot to yield a clean
      gravel surface. The site’s truck fueling system was also addressed during
      the visit. Diesel fuel is stored in an above-ground tank that is surrounded
      by a concrete spill-containing berm. The berm was leaking on 12/22/05,
      and FTL representatives agreed to repair the berm and stop the leak. The
      WES technical assistance inspector and the FTL representatives also
      walked down to the County's MS4 outfall which serves the site. The
      outfall, which discharges to Cow Creek, would be a good place to install
      absorbent booms and pads in the event of a petroleum spill.
   2. The K.B. Recycling, Inc. facility at 9602 SE Clackamas Road in
      Clackamas, 1/17/06. While conducting a routine, monthly water sample
      collection visit to Cow Creek at SE Last Road in the morning on January
      17, 2006, a WES crew noted that a prominent sheen was present on Cow
      Creek. It was raining heavily at the time. Later that morning, a portion of
      the sheen was traced to the waste paper compacter’s area at the K.B.
      Recycling, Inc. facility at 9602 SE Clackamas Road. The incident (#2006-
      0264) was reported to the OERS on January 17th. The potential need for
      a 1200Z permit at this facility was discussed between WES and the
      company on January 17th. In an April 12, 2006 letter to the company,
      WES stated that it appears that the facility’s primary SIC code may be
      5093. This code, titled “scrap and waste materials”, is a regulated code
      that would obligate the company to apply for a 1200Z permit. To confirm
      whether this facility needs a 1200Z permit or not, WES asked the
      company in the April 12th letter and in two phone conversations in August
      2006 to please provide the facility’s SIC code(s). As of September 11,
      2006, WES had not received SIC code information for this facility from the
      company.
   3. Johnson Cement Products facility at 6500 SE Johnson Creek Blvd.
      12/22/05. In response to a complaint that had been received, a WES
      inspector visited the Johnson Cement Products facility at 6500 SE
      Johnson Creek Blvd. in CCSD#1 December 22, 2005. Several years ago,
      this facility had been in possession of a 1200Z permit for a time, then this
      permit was terminated due to the fact that some drywells are on the
      property. On December 22nd, a rainy day, the WES inspector confirmed
      that oily stormwater was flowing from the facility and into Clackamas
      County’s MS4. The storm sewer system outfalls to Johnson Creek. On
      December 22nd, an employee of the company said that the runoff was
      leaving the site because a privately owned drywell wasn’t injecting quickly
      enough. On December 23rd, the WES inspector told the facility’s manager
      that one of the following needs to occur: a) the drywell needs to be
      repaired, or; b) a new drywell needs to be legally constructed, or; c) apply
      for a 1200Z permit because stormwater is being discharge to Johnson
      Creek. The WES inspector spoke with the property’s owner on April 18,



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      2006 and learned that he plans to clean and/or refurbish the drywell so
      that runoff no longer enters the SE Johnson Creek Blvd. storm sewer
      system, avoiding the need for a 1200Z. He was also told that, as an
      owner of one or more drywells, he's obligated to get them registered by
      DEQ if they're not registered yet. The WES inspector spoke with the
      facility’s manager on September 21, 2006 and learned that the drywell is
      expected to be cleaned and refurbished during the week of September
      24th. At that time, the facility’s manager was also told that, because his
      facility is an owner of one or more drywells, he's obligated to get them
      registered by DEQ if they're not registered yet.

Measurable performance indicators:
     • The number of inspections performed. Three (3) inspections were
        performed.
     • The number of letters or enforcement actions. No letters or enforcement
        actions in this permit period.
If storm monitoring event monitoring work is conducted on the site’s runoff, and if
the laboratory data from that storm’s water samples shows improvement in the
site’s stormwater quality is needed, a third measurable performance indicator is
for the District to notify the industry that additional stormwater quality
improvement is needed. This monitoring did not occur during the reporting
period.


4.7.5 Commercial/Residential Stormwater Program

Description
The commercial/residential stormwater program applies to all commercially and
residentially zoned lands in CCSD#1-UGB and SWMACC, including rural areas
not regulated by the MS4 permit. Facilities and properties addressed by this
program are those that:
    • May be (or are) contributing a substantial load of pollutants to the MS4, to
       other County or District-owned storm sewers, to neighboring properties, or
       to surface water bodies, or
    • Invite WES to their site to render technical assistance, or
    • Are visited, with property owner/tenant’s permission, by WES in response
       to one or more water quality complaints that had been received, or
    • Are visited by WES at DEQ’s request.

Inspections and Control Measures:
Facilities and properties will primarily be inspected on a complaint-driven basis,
but some inspections will be conducted by staff in SWMACC and CCSD#1 during
source tracking activity if storm event-related or other monitoring work shows that
excessive levels of one or more pollutants are present. All facilities and
properties that are the subject of a complaint will be inspected in a timely manner
by staff. The implementation of control measures for stormwater discharges from


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these facilities and properties will be deemed necessary by WES if the presence
of excess levels of stormwater pollution can be confirmed. For instances where
the presence of excess levels of pollution in stormwater has been confirmed, and
in the event that the discharger’s initial attempts to improve stormwater quality do
not produce the necessary improvement, then WES will continue to provide
guidance and technical assistance until stormwater quality improves.

Properties addressed by WES during reporting period:
   1. Water in Pond in Rural Area, 5/15/06. A citizen contacted WES on
      5/15/06 to state that a pond near her home is covered with red material.
      The pond she referred to is actually a reservoir – a dam in the unnamed
      Wilson Creek tributary's channel creates the standing water. She stated
      that her dog often swims in the pond and that in Spring 2005, the dog's fur
      smelled "like it was rotting" after the dog climbed out of the water. She
      also mentioned that there is a property in the watershed, upgradient from
      the pond, that boards horses. She wondered if manure-laden water or
      some other polluted wastestream may be related to the red material. The
      land with the pond is at 20121 South Sweetbriar Road. This land is not
      within the portion of SWMACC that’s regulated by SWMACC’s MS4
      permit. A WES inspector contacted the property owner, who said that the
      red material which floats on his pond is a plant named Azolla caroliniana
      (common names include fairy moss and carolina mosquito fern). He also
      said that wood shavings/chips occasionally wash into his pond and that he
      believed that this may be bedding for the horses that the complaintant
      spoke about. He said that he believed that it is reasonably likely that other
      horse-related waste, such as manure, is being discharged into the Wilson
      Creek tributary and then into his pond. He also said that he believed that
      one of the horse's owners, had recently died and he didn't want to place
      any additional burden on his widow at that time. He said that he'll call
      WES when he’s ready to initiate an upstream water pollution investigation.
   2. Discharge of Ponded Rainwater, 6/13/06. A citizen who lives on SE
      Braemark Court contacted WES on June 13, 2006 to report that Cedar
      Creek’s waters at SE Braemark Court were very turbid on that day. A
      WES inspector tracked the turbid water about 2,850 feet upstream to a
      road construction site. Goodfellow Brothers discharged the turbid water
      from an existing stormwater treatment and detention pond at SE 126th
      Avenue and Sunnyside Road while attempting to improve and enlarge the
      pond. This pond work is an element of the Sunnyside Road construction
      project, which is being funded by Clackamas County. The turbid
      discharge was caused by two primary factors: “in water work” and rain.
      Much of the sediment that caused the instream turbidity was discharged
      from the pond on June 13th with a pump. The pump was used to move
      sediment-laden water away from one of the pond's "cells" to re-create a
      dry workspace for the workers who were expanding the pond. Much or
      possibly all of the water that was pumped had entered the dry workspace
      when afternoon rains fell in the area on June 12th. Water entered the



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      entire pond in significant amounts, for the existing pond’s inlet, a storm
      sewer line, was still present and fully functional. This existing storm sewer
      line was contributing a steady amount of clean water into the pond on
      June 13th, a dry day. This clean water quickly became turbid as it flowed
      through the bottom of the pond as construction work – "in water work" –
      was being done in the pond. Goodfellow Brothers implemented a short-
      term solution, creating a shallow ditch with a trackhoe so that silt-free
      water could flow across the pond’s bottom from the inlet pipe to the outlet,
      while the WES inspector was on the site on June 13th. This project’s
      stormwater discharges were regulated by Clackamas County’s Dept. of
      Transportation (DTD) and Development’s 1200CA erosion control permit,
      so long-term solutions to the turbidity issue were implemented by DTD.




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4.8   Construction Site Runoff: Structural and Non-Structural
      BMPs [Schedule D(2)(c)(iv)]

4.8.1 Procedures for Site Planning

CCSD#1 Service Area Development Review

The District reviews all development plans for new construction or redevelopment
projects in the District’s service area through the building permit process. All
reviews are done in accordance with the Surface Water Management Rules and
Regulations for CCSD#1. These regulations require submittal of an erosion
prevention and sediment control plan containing methods and/or interim facilities
to be constructed or used concurrently with land development. Plan submittals
are required to provide details of erosion control measures, schedules for
construction, and a maintenance schedule for erosion control activities.

The Erosion Prevention and Sediment Control Planning and Design Manual
(created in 2000, and currently being updated) is offered as a resource to the
development community for preparation of plans for erosion prevention and
sediment control.

The one-acre threshold of the Department of Environmental Quality’s (DEQ)
NPDES 1200-C permits has been incorporated into this process. WES is an
agent of the DEQ for 1200-C permits for the following areas:
• Inside of the CCSD1 and SWMACC service districts (Including the City of
   Rivergrove);
• Inside the unincorporated areas of the County;
• Inside (through agreement) the Oak Lodge Sanitary District and the City of
   Gladstone.


City of Happy Valley Service Area Development Review

As of October 1, 2005, authority was transferred from Clackamas County Water
Environment Services (WES) to the City of Happy Valley to review all
development plans for erosion prevention and sediment control for new
construction or redevelopment projects in the City’s service area, through the
land use and building permit processes. The pertinent regulations are in
Sections 8 and 15 of the Happy Valley Municipal Code. These regulations
require submittal of an erosion prevention and sediment control plan, which
contains methods and/or interim facilities to be constructed or used concurrently
with land development. Plan submittals are required to provide details of
erosion control measures, schedules for construction, and a maintenance
schedule for erosion control activities.



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Also on October 1, 2005, WES relinquished NPDES 1200-C permits
implementation to DEQ for the area inside the City of Happy Valley. The City of
Happy Valley is currently seeking Agent status from DEQ for these permits.
Currently DEQ is responsible for plan review and approval of all NPDES 1200-C
permits within the City limits. DEQ is also responsible for enforcement of DEQ
regulations during site development construction.

The City of Happy Valley provides additional plan review and construction
inspection of erosion control measures for private and public development within
the City limits as authorized under Municipal Code Sections 8 and 15. The City
of Happy Valley has adopted Clackamas County WES regulations and standards
for erosion and sediment control. The Erosion Prevention and Sediment Control
Planning and Design Manual (created in 2005, and currently being updated) is
offered as a resource to the development community for preparation of plans for
erosion prevention and sediment control.


4.8.2 Requirements for Structural and Non-Structural Best Management
      Practices

CCSD#1 Service Area

Structural and non-structural BMPs are required by the District’s erosion control
regulations. Erosion control plans require specific descriptions of erosion control
measures, and implementation of control measures for any erosion identified
prior to and concurrent with construction activities. Maintenance of all erosion
control measures pursuant to an approved plan is the applicant’s responsibility.

Current Efforts to Improve Erosion Prevention and Sediment Control:
• Working with the Oregon Department of Agriculture and the Clackamas
  County Soil and Water Conservation District to coordinate on erosion and
  water quality issues generated by agricultural/rural sites.
• Working with multiple agencies on an update to the Erosion Control Planning
  and Design Manual. Target is to have the updated manual available in
  Summer 2007.
• Working with the DEQ to:
  o Continue to identify refine methods of processing the 1200-C permits.
      This includes informational handouts for applicants, a checklist for permit
      reviewers and identification of electronic resources that can help in permit
      application review.
  o Provide input and feedback on the implementation of the 1200-C permit
      (adopted January 2006) and the associated application (adopted June
      2006).
  o Coordinate with interested cities to create a standard template for the
      1200-C Memorandum of Agreement between DEQ and its Local Agents.
      The goal is to strive for consistency among the Local Agent's


MS4 Permit Compliance Report for CCSD#1 & SWMACC                            68
       implementation of the 1200-C program and increase compliance with
       erosion prevention and sediment control requirements. This new
       template is scheduled for adoption following the issuance of the new
       1200-C permit.


City of Happy Valley Service Area

Structural and non-structural BMPs are required by the City’s erosion control
regulations. Erosion control plans require specific descriptions of erosion control
measures, and implementation of control measures for any erosion identified
prior to and concurrent with construction activities. Maintenance of all erosion
control measures pursuant to an approved plan is the applicant’s responsibility.


4.8.3 Procedures for Identifying Priorities for Inspecting Sites and
      Enforcement Actions

CCSD#1 & SWMACC Service Area

The District inspects all construction project sites for implementation of erosion
control BMPs within the District’s service area. Additionally, Water Environment
Services is an Agent of DEQ in the issuance and administration of NPDES
1200C permits for developments disturbing areas one acre or larger throughout
unincorporated Clackamas County and, by agreement, within the Oak Lodge
Sanitary District and the cities of Gladstone and Rivergrove. District staff
inspects construction sites a minimum of twice during construction to verify
proper implementation of required BMPs. Additional inspections are performed
as necessary.

Priorities for inspection are based on site-specific characteristics (i.e., watershed,
grade, percent of soil cover to be removed, construction practices, season, and
proximity to sensitive areas.)

The District monitors compliance with the erosion control regulations and has the
authority to issue deficiency notices, charge re-inspection fees, issue fines and
stop land-disturbing development work at the site until provisions of the
regulations are met.

Measurable performance indicators:
• Annual number of permitted, active construction projects
• Annual number of erosion control inspections
• Annual number of enforcement actions




MS4 Permit Compliance Report for CCSD#1 & SWMACC                               69
Permit & Inspection Summary (July 1, 2005 - June 30, 2006)
Erosion Permits         415+
Inspections             3230+
Enforcement Actions     Reporting the number of enforcement actions (i.e.,
                        reinspection fees, Stop Work Orders, etc) was
                        proposed as part of the revised SWMP in May 2006
                        and as will be implemented in the 2006-2007 permit
                        year.


Gladstone
Since March 2001, CCSD#1 has performed erosion control permit issuance and
enforcement within the Gladstone city limits through an Intergovernmental
Agreement.

Permit Summary (July 1, 2005 - June 30, 2006)
Grading           2
Commercial        4
Multi family      0
Single Family     5
Miscellaneous     0
TOTAL:           11

Permit & Inspection Summary (July 1, 2005 - June 30, 2006)
Erosion Permits         11
Inspections             120+
Enforcement Actions     Reporting the number of enforcement actions (i.e.,
                        reinspection fees, Stop Work Orders, etc) was
                        proposed as part of the revised SWMP in May 2006
                        and as will be implemented in the 2006-2007 permit
                        year.

City of Happy Valley Service Area

The City inspects all construction project sites for implementation of erosion
control BMPs within the City’s service area. The DEQ issues and administers
NPDES 1200C permits for developments disturbing areas one acre or larger
inside the city limits. City staff inspects construction sites a minimum of twice
during construction to verify proper implementation of required BMPs. Additional
inspections are performed as necessary.

Priorities for inspection are based on site-specific characteristics (i.e., watershed,
grade, percent of soil cover to be removed, construction practices, season, and
proximity to sensitive areas.)




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The City monitors compliance with the erosion control regulations and has the
authority to issue deficiency notices, charge re-inspection fees, issue fines and
stop land-disturbing development work at the site until provisions of the
regulations are met.

Records of activities in each respective service area are maintained on file at the
District or at Happy Valley City Hall. Erosion control plans are filed as well as
inspection reports that describe non-compliance/enforcement actions.

Permit & Inspection Summary (July 1, 2005 - June 30, 2006)
Erosion Permits         12
Inspections             50
Enforcement Actions     5 (Reporting the number of enforcement actions [i.e.,
                        reinspection fees, Stop Work Orders, etc] was
                        proposed as part of the revised SWMP in May 2006
                        and as will be implemented in the 2006-2007 permit
                        year.)



4.8.4 Educational and Training Measures for Construction Site Operators

CCSD#1 Service Area

The Erosion Prevention and Sediment Control Planning and Design Manual
(December 2000) was developed in coordination with the City of West Linn and
Clean Water Services. It is available for contractors, citizens, or others involved
with construction activities within the permit area. The handbook is in the
process of being updated in cooperation with other jurisdictions in the Portland
metro area, with Summer 2007 as the target date for completion.

The District provides information to contractors during the permit review process,
including pre-construction review meetings. District staff meets with developers
and contractors to discuss requirements and to visit sites to review specific
requirements.

In response to the development community’s request for more education on
erosion prevention and sediment control, WES continues to partner with the
Home Builders Association of Metropolitan Portland, Clackamas Community
College, and the Cities of Happy Valley, Milwaukie and Oregon City on an
Erosion Control Certification program. Four hours of training in erosion control
every two years provides individuals the opportunity to be certified and eligible for
a discount on erosion control permits. This program went into effect November
1999.




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In 2001, the District partnered with regional jurisdictions, the Oregon Association
of General Contractors, the Homebuilders Association of Metropolitan Portland
and vendors of erosion control products to create and promote the Annual
Regional Erosion Prevention Awards Program. Developed to provide recognition
for contractors and developers with outstanding achievements in exceeding local
erosion control requirements, the program provides recipients with media
recognition, peer recognition and prizes donated by vendors of erosion
prevention and sediment control products and services. The Annual Regional
Erosion Prevention Awards Program provides the development community with
incentives to seek education regarding erosion prevention BMPs, improve BMP
selection and installation, and to better monitor and maintain the BMPs used in
their projects. Additional benefits of the program are to provide education for
jurisdiction’s inspection staff, help standardize erosion prevention requirements
and reduce noncompliance with erosion control requirements. As of 2006,
participants include over 25 jurisdictions in 5 counties in Oregon and southern
Washington. The awards were given for the Fifth Annual event on June 2, 2006
and received media coverage in the Oregonian, the Daily Journal of Commerce
and the NW Builder magazine.

Additional efforts:
  • WES created a brochure titled Managing Paint Waste Wisely…What
       Every Painter Should Know (August, 2002). See Section 11, Public
       Awareness and Education, for more information.
  • A brochure on proper disposal methods for concrete related wastes was
       developed in collaboration with the Clackamas County Co-permittees in
       June 2001, continues to be distributed by staff. See Section 11, Public
       Awareness and Education, for more information.
  • Erosion control packets are mailed to each new development or
       redevelopment applicant.


City of Happy Valley Service Area

The Erosion Prevention and Sediment Control Planning and Design Manual
(December 2000), developed by Water Environment Services, the City of West
Linn and Clean Water Services, is available for contractors, citizens, or others
involved with construction activities within the permit area.

The City provides information to contractors during the permit review process,
including pre-construction review meetings. City staff meets with developers and
contractors to discuss requirements and to visit sites to review specific
requirements.

The City has partnered in a voluntary certification program for erosion control
through Clackamas Community College. The certification process and
procedure are coordinated with other jurisdictions in Clackamas County.


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In 2005, the City joined with regional jurisdictions, the Oregon Association of
General Contractors, the Homebuilders Association of Metropolitan Portland and
vendors of erosion control products to promote the Annual Regional Erosion
Prevention Awards Program.




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4.9   TMDLs [Schedule D(2)(d)]
CCSD#1
The Willamette River Total Maximum Daily Load (TMDL) was submitted by DEQ
to the Environmental Protection Agency (EPA) on September 21, 2006 and the
EPA issued their approval of the document on September 29, 2006. TMDLs
were approved for:
• Two banned insecticides, DDT and dieldrin, in the Johnson Creek watershed.
• Water temperature
• Mercury
• Bacteria (E. coli)

SWMACC
In 2001, the EPA approved the Tualatin Subbasin TMDL. TMDLs were approved
for:
• Water temperature
• Dissolved Oxygen
• pH and chlorophyll A (total phosphorus)
• Bacteria (E. coli)


4.10 303(d) Parameters [Schedule D(2)(e)]
The July 27, 2005 MS4 permit which was issued to SWMACC, The Cities of
Rivergrove and Happy Valley, CCSD#1, and Clackamas County (hereafter
referred to as “the co-permittees”) required that an Interim Evaluation Report
(IER) be submitted to the DEQ by May 1, 2006. One component of the IER
pertains to 303(d)-listed stream and river segments in the co-permittees’ service
areas. As this information about 303(d)-listed waterbodies is not required to be
submitted to DEQ on an annual basis, please refer to section 4.10 of either of the
SWMPs, or section 4.10 of either of the IERs, for 303(d)-list-related information.


4.11 Public Involvement [Schedule D(2)(f)]

Introduction
A variety of communications strategies are implemented each year to increase
citizen awareness of programs and services provided by the District, strengthen
the department’s identity within the community, and expand information-sharing
efforts.

Throughout the year, WES created awareness in both the public and the
business sectors about the impact of stormwater pollution on the health of the
region’s rivers, creeks and wetlands. Awareness messages and involvement
activities were designed to educate area residents, students, and businesses



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about their personal link to water quality. The goal through these social
marketing activities and events was to build public awareness, foster
understanding, and change daily behavior or business practices to help improve
stormwater quality, which will ultimately affect the health of our rivers, creeks and
wetlands.

The communication strategies and public outreach activities implemented during
the past permit period have led WES to be recognized by various associations
around the nation. The Streamlines Newsletter received a Best of Class Award
by the National Association of County Information Officers (NACIO). WES also
received two other recognitions by NACIO for their educational campaigns:
Superior Award for the Is your lawn chemical free? Maybe it should be and a
Meritorious Award for the Freeze the Grease, Save the Drain. The Freeze the
Grease campaign also received an Award of Excellence by the City-County
Communications and Marketing Association (3CMA). The Clean Water: Lessons
for a New Generation video received an Award of Distinction by the
Videographer Awards.

Through citizen and stakeholder involvement, business workshops and public
education programs, WES has successfully engaged the public and other
jurisdictions in decision-making. WES continues to seek out opportunities to
maintain an ongoing dialogue with customers, the public, other utilities,
businesses, and students in the region.


4.11.1 District Public Awareness Activities

Publications
The District continues to modify existing publications and added several new
publications this year on natural gardening, groundwater protection, and surface
water to its “Request for Publications” page on the Water Environment
Services Community Outreach website, community events, and to its information
kiosk in the administration office.


50 WAYS TO LOVE YOUR RIVER
A brochure created by the Environmental Council with tips to help protect
Oregon’s Rivers for recreation, healthy wildlife, and drinkable water. More than
30 brochures were distributed during the 2005-2006 permit period.

AND YOUR POINT IS?
This illustrated booklet published by the Association of State Interstate Water
Pollution Control Administrators and America’s Clean Water Foundation is
distributed at all community events and public outreach activities. And Your Point
Is? is a colored comic style booklet designed for 1-3 graders and explains
nonpoint source pollution.


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BE AN ECOLOGICAL BUSINESS: HOW YOUR BUSINESS CAN HELP PREVENT POLLUTION.
A brochure created by the Ecobiz Pollution Prevention Outreach Team designed
to encourage landscape service businesses to implement environmentally
responsible landscaping practices. More than 25 brochures were distributed
during the 2005-2006 permit period.

BIOSOLIDS: A BENEFICIAL PRODUCT OF WASTEWATER
A brochure designed to educate farmers and the surrounding community about
the benefits of biosolid application as a by-product generated from wastewater
treatment. These brochures are distributed anytime a new site is approved or as
requested by the public. More than 500 brochures were distributed during the
2005-2006 permit period.

CLACKAMAS COUNTY SOIL & WATER CONSERVATION DISTRICT (CCSWCD)
The CCCSWC brochure offers the landowner the information they need to
change their behavior and take voluntary action to reduce their impacts to non-
point source water pollution. More than 50 brochures were distributed during the
2005-2006 permit period.

CLACKAMAS COUNTY WATER EDUCATION TEAM BROCHURE
This brochure describes the various programs or resources addressing
watersheds, drinking water, salmon, restoration, and stewardship involvement
within the Clackamas County community. More than 100 brochures were
distributed during the 2005-2006 permit period.

DO THE SMART THING
This illustrated brochure is a fun and informative booklet distributed to Agency
customers. The booklet provides descriptive information on how citizens can
make a difference in saving streams and ponds in the area. Tips on “doing the
smart thing” include gardening tips, weed and pest control management,
handling household hazardous waste properly, maintaining and cleaning cars,
and taking care of septic systems. This brochure will be revamped during the
2006-07 permit period. More than 20 brochures were distributed during the 2005-
2006 permit period.

EASEMENT INFORMATION FOR HOMEOWNERS AND BUILDERS
This brochure was developed by WES staff to build awareness about easements
and their purpose, and importance to both water quality and stormwater
conveyance. Sanitary sewer, stormwater and conservation easements were
discussed, with a focus on easements containing open drainage ways and water
quality swales. It is distributed with building permit application information and is
available at County customer service counters. More than 150 brochures were
distributed during the 2005-2006 permit period.




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ECOBIZ
The Automotive Services Program brochure is one part of the Eco-Logical
Business Program. The Automotive Services Program recognizes vehicle service
and repair businesses and shops that reach the highest standards in minimizing
their environmental impact. The goal of the program is to prevent and minimize
pollution generated by small businesses in the Tri-County area. This is the first
multi-media (air, water, solid waste) automotive services certification program in
the nation. The brochure explains the program and provides contact information
for Ecobiz certified automotive services. More than 75 brochures were
distributed during the 2005-2006 permit period.

FAT FREE SEWERS
This brochure describes the impacts of sewer overflows and backups as a result
of fats, oils and grease entering sewer pipes. The brochure contains tips on what
individuals and restaurant owners can do to prevent raw sewage overflowing into
parks, yards, streets and storm sewers. More than 125 brochures were
distributed during the 2005-2006 permit period.

GROUNDWATER PROTECTION & YOUR SEPTIC SYSTEM
The brochure explains what groundwater is and the value of keeping septic
systems properly maintained to reduce the threat to groundwater. More than 300
brochures were distributed during the 2005-2006 permit period.

GROW SMART, GROW SAFE
This new consumer guide to lawn and garden products was created by Metro.
The guide helps citizens make decisions about pesticides and fertilizers. Part of
the decision-making process is determining whether pesticides are needed. The
guide explains a number of steps that citizens can take to reduce or eliminate the
need for pesticides. More than 100 guides were distributed during the 2005-
2006 permit period.

INDUSTRIAL PRETREATMENT: PROTECTION OF WASTEWATER COLLECTION AND
TREATMENT SYSTEMS
This new brochure created by WES source control and water quality laboratory
services staff was designed to explain the objectives and responsibilities of the
national pretreatment program. The brochure explains how the industrial
pretreatment program protects waters from industrial pollutants that pass through
publicly owned treatment works (POTWs). More than 50 brochures were
distributed during the 2005-2006 permit period.

JAPANESE KNOTWEED
This illustrated brochure is a popular brochure that provides information on the
benefits of stopping the growth of this invasive plant and the techniques to
control it from spreading. More than 25 brochures were distributed during the
2005-2006 permit period.


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KELLOGG CREEK & MT. SCOTT CREEK
Developed by the Urban Streams Council, this brochure takes readers on a
journey of Kellogg and Mt. Scott Creeks, its wetlands, wildlife, and ways to
protect its water quality. More than 120 brochures were distributed during the
2005-2006 permit period.

MANAGING CONCRETE AND MORTAR TO PROTECT WATER QUALITY
This brochure was mailed to contractors and concrete businesses in Clackamas
County. WES and several cities developed and provided the brochure to help the
development community understand the consequences to the environment of
improperly disposing of concrete and cement-related wastes developed a joint
jurisdictional brochure. Tips on “What You Can Do” are provided in the flyer.
More than 120 brochures were distributed during the 2005-2006 permit period.

MANAGING PAINT WASTE
WES and the NPDES co-permittee partners customized and distributed
“Managing Paint Waste”, a brochure originally created by the Pollution
Prevention Outreach Program. The brochure discusses why improperly
disposed of paint waste can harm water quality, clean up “do’s and don’ts”, and
recycling options. More than 220 brochures were distributed during the 2005-
2006 permit period.

GARDENING WITH NATIVE PLANTS
This illustrated brochure is one of the most popular brochures distributed at
county and local events. WES worked with the City of Portland’s Bureau of
Environmental Services to use their native plant information and artwork to re-
print the City’s brochure. Its informative listings for those wishing to purchase
and use native plants in their gardening efforts are extremely effective. WES
distributed more than 2700 of these brochures or excerpts from it, through
mailings, exhibit booths, and during public presentations.

NATURAL GARDENING SHOPPER’S GUIDE
This alternative to pesticides guide provides consumers with choices about
garden-related products and the way to store and handle products. Created by
Metro, this guide is updated annually with a list of locations to buy natural and
organic products. WES distributed more than 100 of these brochures through
mailings, exhibit booths, and during public presentations.

PROTECTING OUR WATERSHED (ENGLISH/SPANISH)
This colorful brochure provides information on how everyone can take care of his
or her watershed. The brochure promotes the idea that people working together
can keep the watersheds healthy and productive. Developed by the Oregon
Association of Clean Water Agencies (ACWA), the booklet has been widely
distributed at community events and presentations. More than 125 brochures
were distributed during the 2005-2006 permit period.



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QUESTIONS & ANSWERS ON SEPTIC TANKS
This brochure was created for homeowners in Clackamas County to help them
understand the importance of keeping septic systems maintained and the
negative impact to groundwater and the rivers and streams if a failing septic
system is left in a failed state. More than 350 brochures were distributed during
the 2005-2006 permit period.

SIMPLE STEPS TO A HEALTHY LAWN AND GARDEN
This Metro brochure provides citizens with six simple steps to a healthy lawn and
garden without using chemicals. More than 75 brochures were distributed during
the 2005-2006 permit period through mailing, exhibit booths, and during public
presentations.

FROM SINK TO STREAM
This wastewater treatment brochure promotes awareness on how the
wastewater treatment facilities operate and how they protect water quality.
Information included in the brochure educates the reader on both wastewater
and surface water and provided tips on how to protect the County’s water
resources. More than 175 brochures were distributed during the 2005-2006
permit period.

SO…NOW YOU OWN A SEPTIC SYSTEM
Brochure designed by the National Small Flows Clearinghouse explaining how a
system operates, what to put in and what to keep out. More than 300 brochures
were distributed during the 2005-2006 permit period.

SOIL SAVVY
This illustrated pamphlet is a pocket guide to erosion and sedimentation control
and is widely used at construction sites and is also distributed to citizens to
provide them with ideas about how they can prevent soil loss on their property.
More than 325 brochures were distributed during the 2005-2006 permit period.

STREAM AND WETLAND ENHANCEMENT GUIDE
This illustrated brochure is one of the most concise and informative sources for
those wishing to enhance stream corridors and wetlands. WES distributed more
than 300 of these brochures or excerpts from it, through mailings, exhibit booth
distribution, and during public presentations.

STREAM-FRIENDLY HOME AND YARD CARE
This brochure was designed to provide general tips about roof treatments,
pressure washing, and composting. The brochure discusses the typical
problems and provides solutions for prevention and treatment. More than 375
brochures were distributed during the 2005-2006 permit period.




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TAKING CARE OF STREAMS IN WESTERN WASHINGTON, WESTERN OREGON, AND
COASTAL ALASKA
A total of four guides targeting specific audiences were developed through a
partnership between the Oregon State University, University of Idaho,
Washington State University in cooperation with the University of Alaska. The
guide targets audiences that could impact the riparian areas including
landowners, developers, recreationists, and homeowners. The guide explains
the importance of riparian areas, and opportunities for those target audiences to
help maintain or improve the health of streams and riparian areas. This is the
second year to distribute this brochure. To date WES has distributed more than
200 guides.

THE CARE AND FEEDING OF YOUR SEPTIC SYSTEM
A brochure designed by the National Small Flows Clearinghouse designed to
educate septic system owners about the operation of their system, when to have
the septic tank pumped, reducing the flow of wastewater, and general septic
system health tips. More than 275 brochures were distributed during the 2005-
2006 permit period.

TRAP THE GREASE IN THE KITCHEN (ENGLISH/SPANISH)
This brochure was designed by the Oregon Association of Clean Water Agencies
(ACWA) public education committee. The brochure aims to educate restaurant
business owners and operators of the importance to prevent grease from building
up and blocking sewer lines. The brochure includes tips for food workers to
tackle grease and stopping sewer overflows into streets and storm drains.
Distribution of this brochure began during the 2005-2006 permit period. More
than 150 bilingual brochures were disseminated at local community functions.

HOW WASTEWATER TREATMENT WORKS
This illustrated information and activities book published by Channing Bete
Company is designed for children in 4th – 6th grade. The booklet teaches kids the
importance of wastewater treatment with an emphasis on protecting public health
and water quality. More than 800 booklets were distributed at public events and
through teacher workshops during the 2005-2006 permit period.

WEF CAREER PATHS: EACH ONE OF US CAN MAKE A DIFFERENCE
This poster encourages high school students to choose a water environment
career. It provides an introduction to the various professions necessary to
operate drinking water facilities or wastewater treatment plants. WES distributed
more than 80 posters at public events and career fairs.

WES WATERFACTS
An introduction to WES’ mission statement, general information, and the services
provided as the surface water and/or wastewater treatment collection agency for
CCSD#1 and SWMACC. More than 700 brochures were distributed at public



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events and through the resource brochure rack in the WES administration office
during the 2005-2006 permit period.


WHAT GOES IN THE GROUND, GOES IN THE WATER
This brochure was created by ACWA to educate citizens on groundwater and
how daily activities can impact the water quality. More than 25 brochures were
distributed at public events and through the resource brochure rack in the WES
administration office during the 2005-2006 permit period.

What Have You Done For Your Watersheds Lately? 20 Actions You Can
Take To Protect Your Watersheds
WES, Clackamas County Parks, OSU Extension Service and the Soil and Water
Conservation District partnered to create this brochure, implementing a Complete
Communities recommendation. Home and yard, farm, landscaping and
streamside care tips for rural and urban streamside property owners are
included, as well as resources for additional information. More than 125
brochures were distributed during the 2005-2006 permit period.


Newsletters
Streamlines and Mainstream newsletters contain information about SWM
program activities and public awareness and education information. These are
distributed to approximately 18,500 CCSD#1 and 3,000 SWMACC residential
and business customers, typically as inserts with their surface water service
billing statements. Streamlines and Mainstream are also posted on the WES
website. Citizen News is the Clackamas County newspaper mailed quarterly to
over 159,000 citizens within the county by the Department of Public and
Government Relations. Happy Valley City Hall news is published bi-monthly for
its residents. The Healthy Living Guide Partnership Project produces four
quarterly issues per year with a total distribution of 40,000 listing recreation and
education offerings in North Clackamas County. Trash Talk is a solid waste and
recycling newspaper mailed twice a year to over 159,000 citizens in the county
by Community Environment, a division of the Department of Transportation and
Development.

Streamlines – Clackamas County Service District No. 1 (North Clackamas
Urban Area, including the City of Happy Valley). The 2005-06 editions of
Streamlines continue to implement community-based social marketing activities
to encourage citizens to adapt or change their behavior for the benefit of the
watershed. As part of these educational promotions, a public education phone
line was set-up to track participants and communication tools. In 2006,
Streamlines received the Best of Class award for external newsletters from the
National Association of County Information Officers.




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•   The 2006 – Volume 2, Issue 2 of Streamlines featured the Hearthwood
    Wetland Preserve restoration project, a cooperation between the Wetlands
    Conservancy and WES. The calendar of events listed upcoming meetings by
    the North Clackamas Surface Water Management Citizens Advisory
    Committee and the Citizen Advisory Council for wastewater treatment and the
    Clackamas County fair schedule. In response to the need to educate
    residents on the impacts of the West Nile Virus and stormwater facilities, the
    Fight the Bite campaign was used as the community-based social marketing
    promotion. Residents requesting the kit received a brochure with frequently
    asked question regarding West Nile Virus and stormwater facilities and steps
    that homeowners could take to reduce mosquito breeding. More than 225
    citizens responded as a result of the free coupon included with the newsletter.

•   The 2006 – Volume 2, Issue 1 of Streamlines highlighted upcoming meetings
    by the Surface Water Management Citizens Advisory Committee (SWM CAC)
    and the Citizen Advisory Council for wastewater treatment in CCSD1. This
    issue also provided a recruitment article for the SWM CAC and provided
    another progress report on the surface water management master plan. An
    article was included on the importance of protecting natural resources areas
    with undisturbed buffer zones and contact information for questions. The
    community-based social marketing campaign was on proper car washing.
    The slogan “Only rain down the storm drain” was used encouraging residents
    to minimize car washing at home and utilizing car wash facilities that recycle
    water. The car wash kit included a coupon for a free car wash, chamois, car
    wash sponge, and bilingual bookmark on car care tips. More than 460 car
    wash kits were mailed as a result of this campaign.

•   The 2005 – Volume 1, Issue 3 of Streamlines included information on the
    Clearwater Project, the surface water management master plan, upcoming
    meeting dates for the Surface Water Management Citizens Advisory
    Committee, and an article on watershed restoration taking place at the North
    Clackamas Park through WES’ watershed stewardship assistance program.
    The grant was awarded to the North Clackamas School District Parenting,
    Academics, Career and Employment (PACE) program. “Freeze the Grease,
    Save the Drain!” was the community-based social marketing campaign
    highlighted in this newsletter. The campaign educated citizens on the
    importance of pouring oil and grease in cans instead of sink drains; hence,
    preventing sewer back-ups that could be costly, expensive, and harmful to the
    environment. More than 275 kits and 475 foil-lined bags were mailed to
    citizens as requested through the educational phone line.

Mainstream – Surface Water Management Agency of Clackamas County (Lower
Tualatin River Basin, including the City of Rivergrove). The 2006 editions of
Mainstream are now including community-based social marketing incentives and
citizen responses are also being tracked using the public education phone line.




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•   The 2006 – Volume 2, Issue 1 of Mainstream provided citizens with an
    overview of the surface water management program and the benefits to
    protecting rivers, streams and wetlands in that service area. The newsletter
    also featured an article on watershed restoration taking place at the North
    Clackamas Park through WES’ watershed stewardship assistance program.
    The grant was awarded to the North Clackamas School District Parenting,
    Academics, Career and Employment (PACE) program. The newsletter listed
    upcoming meetings by the Lower Tualatin Surface Water Management
    Citizens Advisory Committee and a recruitment piece encouraging
    participation on that standing committee. Freeze the Grease, Save the Drain!
    was the community-based social marketing campaign highlighted in this
    newsletter. The campaign educated citizens on the importance of pouring oil
    and grease in cans instead of sink drains; hence, preventing sewer back-ups
    that could be costly, expensive, and harmful to the environment. More than
    275 kits and 475 foil-lined bags were mailed to citizens as requested through
    the educational phone line.

•   The 2005 – Volume 1, Issue 1 of Mainstream included information on the
    surface water management program and how fees are used to supporting
    watershed-based activities in the District. Upcoming events such as the
    Tualatin Riverkeepers paddle trip and the Clackamas County fair were also
    advertised. The Regional Coalition for Clean Rivers and Streams campaign
    focused on reducing fertilizer/chemical use at home. Citizens were provided
    with a coupon to request an all natural lawn-care kit containing coupons for
    native plants and environmentally sound gardening products, gardening
    gloves, and more. More than 475 citizens responded as a result of the free
    coupon included with the newsletter.

Citizen News – Clackamas County newspaper delivered quarterly to over
159,000 households. WES continued to incorporate environment related stories
in Clackamas County’s newspaper during the 2005-2006 permit period.

•   The Summer 2006 story titled Beautiful Wetlands Also Essential to Our
    Ecosystem highlighted the Hearthwood Preserve Wetland restoration project,
    a partnership between The Wetlands Conservancy and WES. The
    Clackamas County Soil & Water Conservation District contributed the article,
    Attack of the Himalayan Blackberry, educating the public on the top 10 weeds
    in Clackamas County.

•   The Spring 2006 included two stories produced by WES. The first story was
    titled Protecting Natural Resources: Citizen Panel Helps County Restart
    Sewer Planning Process introduced the Citizen Advisory Council for Service
    District No. 1 and the wastewater treatment options project. The other article
    titled Buffer Zones: Protecting Sensitive Creeks and Streams gave an
    introduction to sensitive natural areas that may require permits by land or




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    homeowner’s. Tips regarding who to contact and websites to visit for more
    information was provided with the article.

•   The Winter 2006 promoted the Lower Tualatin and North Clackamas Surface
    Water Management Citizens Advisory Committees and the vacancies
    available in each committee.

•   The Fall 2005 featured the 2005 State of the County Report: Thinking
    Globally, Acting Locally. The story report mentioned that WES staff along
    with nonprofit organizations logged many hours removing invasive plants and
    replanting with native plants and shrubs. It also highlighted some of WES’
    web enhancements including the ability to pay sewer/stormwater bills online.
    In addition to the State of the County report, the newspaper provided a story
    on Teacher Dan Huld and his class’ Watershed Stewardship Assistance
    Program Grant. The article tilted Teens Get Down and Dirty for Watershed
    Restoration explained the project area and highlighted the accomplishments
    by this dedicated group of students. Finally, the newsletter provided a
    schedule of the spring naturescaping workshops available in the area.

Happy Valley City Hall News - A bi-monthly newsletter published for Happy
Valley residents and those doing business in the community. In response to
Park Vandalism at the restoration area of Happy Valley Park, WES contributed
an article titled Native Plants are Enhancing Happy Valley Park. The story
explained the planting being done at the more than 25-acre natural area and
what residents could do to help protect that area. A public service
announcement (PSA) was also created in conjunction with the article ran all
summer in Clackamas County’s Government Channel.

Healthy Living Guide - The Healthy Living Guide Partnership Project produces
four issues per year with a total distribution of 40,000 per quarter listing
recreation and education offerings in North Clackamas County. WES purchased
the inside back-page of the guide to promote its River Heroes Education
Programs. The ad highlighted four key education programs including the
storytelling assemblies, Storm Drain Stenciling program, plant tours, and
stewardship grants and scholarships.

Trash Talk - A solid waste and recycling newspaper mailed twice a year to over
159,000 citizens in the county by Community Environment, a division of the
Department of Transportation and Development. The Fall 2005 edition promoted
the fall naturescaping workshops held in CCSD#1. More than 60 citizens
attended the fall workshops.

Copies of these newsletters are available at WES.

Downstream News - An in-house employee newsletter carries articles on
surface water management projects and information on topics such as:



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watershed restoration opportunities, update on the surface water management
master plan, reports on the Endangered Species Act, water quality tips, and
results of citizen participation at public outreach events.

Bill Inserts
Bill inserts or the appropriate service district newsletter is mailed with the
customer’s account statement. Recent bill inserts have included promotions
such as the all-natural lawn care kit from the Regional Coalition for Clean Rivers
and Streams.

District Customer Packets
Informative packets are sent to new customers or picked up at events. The
District packet contains information on water quality and conservation tips, best
management practices, as well as an insert reply card for those interested in
tours, public speaking engagements and presentations.

Water Environment Services Website
WES revamped its website to improve content, design, navigation and overall
management. The new website was unveiled in April 2006
(www.co.clackamas.or.us/wes) and includes several new features such as the
Report a Problem/Service Request forms, Online ePay, and Start/Stop
Sewer/Stormwater services. Annual reports, manuals, rules, permit
requirements, special projects, and educational resources regarding surface
water management are all available on the website. As a result of the 2006
customer satisfaction and values survey and the need for more public
involvement at advisory committee meetings, the North Clackamas Surface
Water Management Committee pilot tested and implemented an audio streaming
of their meetings to include a link to documents and presentations provided
during those sessions. In addition, educational events and public service
announcements that have been created to educate the public on stormwater
issues are also now streamed online
http://clackamas.granicus.com/ViewPublisher.php?view_id=3. These new
features have received strong public support. Since implementation (April 2006),
the following surface water meetings or educational videos are now online with
total number of virtual visits.

Meeting/Video                                               Virtual Visits
Clean water festival for kids                               132
North Clackamas SWM CAC June Meeting                        90
North Clackamas SWM CAC April Meeting                       77
Clackamas watershed sign project celebration                49
Lessons for a new generation                                40
Happy Valley Park public service announcement               40
Walking steelhead story for kids                            25
Wetland restoration – steps to success                      25
Celebrating water, land and people                          25


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Tree planting at Oregon Trail elementary                   24
Echo Valley wetland restoration                            20
Natural lawn care kit public service announcement          19
Three Creeks restoration project area                      15
Mt Scott Creek restoration project area                    14


WES Endangered Species Act Web Pages
WES continued to enhance its watershed and Endangered Species Act (ESA)
web pages. The site features the impacts and regulations surrounding the ESA
listings and also features water quality information as well as general watershed
resources and partners in the region. WES’ home page also features information
on surface water management, rules and regulations, administrative procedures,
technical specifications, erosion control manuals and information for citizens.

News Releases and Media Coverage
The District continues to coordinate and enhance news sharing with the media,
and increase citizen awareness and understanding of program issues. More
than 30 press releases were disseminated via the media and interested parties
list serves. These resulted in published articles in newspapers and television
news stories such as the Oregonian, Clackamas Review, Estacada News,
Oregon City News, West Linn Tidings, and local television stations. Topics
published by the media included those about the Regional Coalition for Clean
Rivers and Streams campaign on natural gardening and yard car, Clearwater
Project, the Surface Water Management Master Plan, on-going MS4 permit
litigation, recruitment ads to serve on the surface water management advisory
and budget committees as well as upcoming meetings, the stormwater
management plan and interim evaluation report public process, Watershed
Summit at the Clackamas Community College, revamped website, West Nile
Virus and stormwater detention facilities, volunteer opportunities for watershed
restoration projects.

In addition, WES continues to purchase ads in various newspapers to highlight
its stormwater public education and outreach programs. The River Heroes
Education Programs ad ran in the Clackamas Review newspaper Fall and Spring
Home editions. The Only Rain Down the Storm Drain ad ran in the Clackamas
Review newspaper Summer Fun & Recreation Guide, and the Homebuilders
Association’s The Neighborhood event magazine. Furthermore, WES continues
to sponsor ads in the North Clackamas Chamber of Commerce magazine and
area map publications.

4.11.2 Events and Volunteer Activities
The District sponsors and/or participates in events throughout the year that
engage volunteers in activities and learning opportunities that help protect water
quality, improve stream corridors and enhance wildlife habitat. Some of the major
events are summarized below:


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WES sponsored several elementary school programs during the 2005-2006
school year, which were developed and presented by the Clackamas Community
College’s John Inskeep Environmental Learning Center and professional
storyteller, Will Hornyak. In addition, WES continues to support community-wide
adult and youth programs.

Children’s Clean Water Festival
The Clean Water Festival is designed for 4th and 5th grade students to learn
about water and how it relates to our world. Water experts from Oregon and
Washington work with the 4th and 5th graders to explore water science and
watershed ecology through a variety of workshops and hands-on activities. The
Festival is an annual event with the goal to teach children that they are capable
of having real, long-lasting, positive impacts on water resources, and to equip
them with the information they need to do that in a fun and engaging way. WES
sets-up a hands-on exhibit with the environmental wheel as the main activity.
Children were quizzed on various surface water management topics and
provided with prizes. More than 1,200 children attended the one-day event in
April 2006. WES staff also serves in the planning committee for this event and
hosted a classroom workshop led by the Environmental Learning Center of
Clackamas Community College.

Clackamas County Employee Week
WES sponsors the County’s Employee Week celebration by donating over 150
surface water related educational prizes for various activities including the golf
tournament and other events held at Bullwinkle’s.

Clackamas County Fair
WES staffed a week-long booth at the 2005 Clackamas County fair and received
visitors from a wide area in Clackamas County as well as the metro area. WES
had a variety of displays on topics such as non-point source pollution, chemical-
free lawn care, fat-free sewers, and basic wastewater treatment and stormwater
management education. The primary focus of the booth was to motivate the fair
goers to change their behaviors as they go about their daily activities. WES
handed out promotional items with clean water messages, such as pens, fish
necklaces, salmon key chains, and mosquito repellent kits, and gardening
gloves. Visitors located their homes and schools on a map displaying County
watersheds. Activities included gyotaku fish printmaking, a quiz board and quiz
wheel to test both adults’ and children’s’ knowledge about watersheds, wetlands
and streams, and protection and conservation of our natural resources. It is
estimated that more than 4,000 residents visited the WES booth at the fair.

Clackamas County State of the County Address
WES staffed a booth at this September 2005 event, which is attended by elected
and staff officials of cities in Clackamas County as well as key citizen leaders.




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Agency information on surface water management projects, events and public
awareness was showcased.

Clackamas County Water Education Team (CCWET)
CCWET was formed in 2002 as a way to coordinate public education and
awareness activities in the County, as well as leverage limited funds. CCWET’s
goals are to increase awareness of water-related issues, engage citizens and
sustain behavioral changes. In addition to WES, members include area water
providers, a watershed council, local cities, OSU Extension Service and the Soil
and Water Conservation District. Partners continue to distribute a citizens’
resource brochure at local community events and mails a Teachers’ Resource
Guide every September to all teachers through the Clackamas Education Service
District. CCWET also held a teacher’s workshop which was attended by more
than 30 science teachers in the area.
WES staffed a stormwater booth station at WET day on May 31, 2006.

Friends Involved in Dog Outreach (FIDO) Day
WES was a major sponsor for the second annual FIDO Day held at the
Clackamas Community College. The Scoop on the Poop was the theme for
WES’ booth at this fair, educating citizens on the importance of picking up after
their pets for clean rivers and healthy communities. WES distributed more than
100 doggie bags with water quality messages.

FSA Tradeshow
WES and Clean Water Services partnered with the Food Service of America
(FSA) quality control team to host a booth at their annual tradeshow. WES and
Clean Water Services provided educational materials on the importance of
preventing grease and oil from entering sewer lines which could lead to sewer
back-ups, polluting the streets and storm drains.

Job and Career Fair
The purpose of the job fair is to highlight job opportunities at the County and
explain how youth can prepare themselves to become competitive for the
working world. WES handed out the WEF career paths poster and spoke with
students about the Stockholm Junior Water Prize. More than 200 WES bags
with surface water tips, WEF career posters, and other information materials
were distributed during the career fair.

Master Gardeners Spring Garden Show
A two-day event held in May at the Clackamas County fairgrounds. WES
partnered with the Soil and Water Conservation District for distribution of
materials. More than 1,000 native plant posters, 300 Stream & Wetland
Enhancement Guides, and 300 Stream-Friendly Home & Yard Care brochures
were disseminated during the event.

Oregon City 7th Street fair



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WES supported Oregon City Public Works by providing a display and surface
water management materials for their 7th Street project celebration. Oregon City
used the Regional Coalition’s message Is your lawn chemical free? Maybe it
should be., had citizens complete the survey card, and provided them with
gardening kneeling pads with a take-home message on lawn care. It was
estimated that over 100 visitors stopped by the booth.

Portland Home & Garden Show
WES partnered with the Bureau of Environmental Services, City of Gresham,
Metro and Clean Water Services in this 5-day long event. The objective was to
promote native planting, encourage use of organic products, and provide
information on resources available in the Portland Metro area. The Regional
Coalition for Clean Rivers and Stream campaign, Is your lawn chemical free?
Maybe it should be., was a variety of giveaways including gardening gloves,
native seed packets, and educational materials. The booth also included the fat-
free sewer campaign Freeze the Grease, Save the Drain! informing citizens
about best practices for proper disposal of fats, oils, and grease and their
impacts on the environment. More than 800 participants visited the booth.

Sunnyside Village RecMobile Kid’s Day
WES partnered with the North Clackamas Parks & Recreation District as the
educator for two Kid’s Day events. More than 80 kids participated in fish
printmaking and the Environmental Wheel activities. Kids received coloring
book, fish painting boxes, and other educational tools as take-home prizes.

Tualatin River Discovery Day
WES was a major sponsor of this annual event that attracted more than 250
people for a canoe trip on the Tualatin River. All participants are afforded an
opportunity to visit the Environmental Community Fair to learn about the ways
that they can improve the quality of the waters in their watersheds.
Approximately 125 canoes were launched during the June 2006 event. The
Tualatin Basin Public Awareness Committee staffed an informational booth. In
addition, WES personnel drove a shuttle van for the canoe trips and answered
questions pertaining to WES’ role with restoration and water quality issues
associated with the Tualatin River. The event produced media coverage on the
Tualatin River and water quality issues in the watershed.

Wellness Fair
The WES booth highlighted the Regional Coalitions for Clean Rivers and
Streams campaign theme Is your lawn chemical free? Maybe it should be.
Coupons for native plants were distributed, and a calorie calculator chart
determining calories burned per gardening/landscaping activity (i.e., weeding,
push lawn mower, planting trees, etc was available to review. More than 300
county employees attended the fair.

Westside Home Show



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The Tualatin Basin Public Awareness Committee had a booth at this weekend
event in February 2006 with the objective to promote native planting, encourage
use of organic products, and provide information on resources available in the
Tualatin Basin area. The Regional Coalition for Clean Rivers and Streams
campaign, Is your lawn chemical free? Maybe it should be., was used as the
main message encouraging people to minimize the use of lawn care chemicals.
More than 250 citizens visited the booth.


4.11.3 Adult & Youth Programs
The District continues to enhance its elementary school programs, which were
developed and are presented by the Clackamas Community College’s John
Inskeep Environmental Learning Center and professional storyteller, Will
Hornyak. In addition, the District supports community-wide adult and youth
programs, including naturescaping workshops, watershed assistance programs,
and high school scholarships.

Environmental Learning Center
The programs are: Clean Water-Healthy Fish: Basic Water Quality Monitoring;
Go With the Flow; and I Am Salmon… Salmon Am I. During 2005-2006, 24
presentations were delivered to schools within the WES service districts,
reaching more than 600 students. WES will continue to sponsor these
successful programs in 2006-07.

GYOTAKU FISH PAINTING
A printmaking adventure in which students make fish prints using realistic fish
replicas. The activity stimulates discussion about different fish species and fish
anatomy. Tips on ways to keep our fish healthy are provided. The activity is
recommended for grades K-3. Teachers can check out the kit for a 2-week
period. More than 1,500 children participated in this activity through school
classrooms or during community events.

NATURESCAPING FOR CLEAN RIVERS
WES sponsored four 4-hour Naturescaping for Clean Rivers workshops that
taught more than 120 attendees how to naturescape their yard. Naturescaping
features native plants, natural landscapes, and water-friendly gardening
practices. The result is less water use, fewer, if any, chemicals and less
maintenance. The Naturescaping Basics workshop includes a short outdoor field
trip to a nearby home or community project to see naturescaping in action.

THE RIVER RANGERS PROGRAM
The “River Rangers” education program continues to be promoted at community
events and in most of the schools in Clackamas County Service District No.1 and
Surface Water Management Agency of Clackamas County. This past year, the
program was presented to more than 500 third and fourth graders.



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Storm Drain Stenciling
WES provides this program to help reduce the improper disposal of pollutants
from entering area streams. The program alerts individuals of the connection
between streets and nearby waterways. Drains are marked on an as-needed
basis.
The following drain markings are available:
• Round marker (4” diameter), slogan - “Clean Water Only, Drains to Johnson
   Creek”
• Round marker (4” diameter), slogan - “Clean Water Only, Drains to
   Groundwater”. These are for use at catch basins that drain to drywells.
• Stencil (for use with paint) that says “Dump No Waste, Drains to Stream”
• Stencil (for use w/paint) that says “Dump No Waste, Protect Your
   Groundwater”. These are for use at catch basins that drain to drywells.
Catch basin stenciling equipment is available for use by others upon request.

WASTEWATER TREATMENT PLANT TOURS
WES welcomes groups and schools to their wastewater treatment facilities every
year to learn about how the wastewater is cleaned and treated. More than 100
students and adults visited one of WES’ wastewater treatment facilities during
the 2005-2006 permit period.

WATER POLLUTION: IT BEGINS WITH YOU (ENVIROSCAPE MODEL)
An interactive model used to demonstrate how water pollution occurs and how
students can prevent water pollution. Recommended for grades 1-4, teachers
check out the water pollution model unit for a 2-week period. More than 600
students participated in this activity during the first annual Water Education Time
day hosted by the Clackamas River Basin Council and Sunrise Water Authority,
and other events held at local schools.

WATERSHED STEWARDSHIP ASSISTANCE PROGRAM
During the 2005-2006 permit period, WES revamped its Watershed Stewardship
Assistance Program. A new brochure was created and overall program funding
was raised. A total of four organizations received funding for restoration,
education, community involvement, or monitoring projects. The Wetlands
Conservancy was awarded a grant to recruit volunteers and purchase native
plants and other supplies for their wetland restoration project at the Hearthwood
Wetland Preserve. The North Clackamas School District received two grants.
The first was awarded to Teacher Dan Huld and the PACE program for on-going
blackberry removal and native planting at the North Clackamas Park, and funding
was provided to pay for travel expenses for two 5th grade classes to attend the
Children’s Clean Water Festival. The final grant was awarded to the Tsunami
Crew, a group of dedicated citizen volunteers to purchase equipment for
knotweed eradication in the Three Creeks and other natural areas.
WES operates and maintains a Tool Trailer that allows citizens group’s access to
the tools and materials necessary to conduct a successful planting event.



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WILL HORNYAK, STORYTELLER: RIVER HEROES
Will Hornyak was contracted in the fall of 2003 to perform at elementary schools
within WES’ service districts. The assembly programs are educationally
challenging, informative, lively and entertaining. The stories have relevant
curriculum connections to English, drama, public speaking, writing, the
environment, and Native American studies. The goal of this program is to
encourage children to stand up, speak out, and make a pitch for clean rivers and
streams. More than eight (8) assemblies and 2,000 students listened to River
Heroes during the 2005-2006 permit period.


4.11.4 Additional Public Education Activities
• Information packets on the surface water program are mailed out as
   requested.
• WES provided educational materials to Community Environment for their
   Custodian workshop, which was attended by more than 25 school custodians
   in the service area. Materials included the native plant poster, proper paint
   disposal brochure, and fat-free sewers.
• WES staff participated in the Women in Trades fair providing opportunities to
   discuss jobs in environmental sciences field.
• WES staff attended SOLV’s Women in Science Day and educated junior and
   high school on the various careers that could lead to working in a water field.
• Clackamas River Watershed signs: Clackamas River watershed signs are
   currently displayed at seventeen (17) points in Clackamas County Service
   District No. 1 where County roads cross the river’s main stem and the river’s
   most significant tributaries. The logo includes the phrase “Your Clackamas
   River Watershed” and features images of a salmon, flowing water, a tree and
   mountains.
• Kellogg-Mt. Scott Creek Watershed signs are currently displayed at 22 points
   in the portion of the watershed within WES’ service area.
• Johnson Creek Watershed signs are currently displayed at 4 points within
   WES’ service area.
• Two types of signs “Protect Your Watershed” and “Protect Your Wetland”,
   were created during the 2001-2002 reporting period. The signs (18” X 24”)
   were installed at seven locations by the Road Dept. during that time. These
   signs are placed at additional locations as needed to encourage the public to
   respect and protect water bodies and their riparian areas.
• WES Staff and Roads Sign Shop developed Knotweed educational signs for
   the Phillips Creek at Causey Ave. Knotweed Eradication and Restoration
   project.
• Two hundred plastic, round markers (4" diameter) which say “Clean Water
   Only – Drains to Johnson Creek”. This message is intended to motivate
   the Johnson Creek-area community's residents, employers, and workers to
   do what they can to protect the creek’s water quality. In Fall 2006 WES plans
   to place the markers, using an adhesive, on paved surfaces at catch basins
   that drain into Clackamas County-owned/maintained catch basins in the


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    portion of the Johnson Creek watershed that is within CCSD#1. The marker
    placement location will be on the top of the curb near the drain, if a curb is
    present. WES expects that some of these catch basin markers will be
    deployed by community organizations, including Boy Scout Troops and
    certain local schools.
•   Catch basin stenciling equipment is available upon request. Provided 2
    stencils and 3 cans of white stenciling paint to Clackamas Middle School. The
    results were 25 stenciled catch basins.
•   Mailed out 2 packets of information to 2 residences on “Nutria Damage on
    Oregon Rivers and Streams.”
•   Mailed out 3 packets to 3 residents who had questions on the “Oregon
    Drainage Law”.

Presentations and Course Development
• An overview presentation on surface water management was given to more
   than 15 individuals at SOLV’s Green Team during the summer of 2005.
• In August 2006, WES staff gave a presentation to more than 20 SOLV Goat
   Island volunteers at the site on the importance of invasive plant removal and
   replanting with native plants for the riparian area and water quality.
• WES and Clean Water Services staff delivered a presentation on Community-
   Based Social Marketing and Surface Water Management Public Education at
   the West Coast and East Coast City-County Communications and Marketing
   Association (3CMA) conferences held in February and April of 2006.
• More than twelve (12) employees, citizens, and local partners attended a
   watershed web-seminar sponsored by WES during the fall of 2005.
• Staff conducted a crisis response and media training on potential spill
   response and wastewater related spills at the Clackamas County Short
   School in March 2006.
• Participated in the 14th Annual Student Watershed Summit as a judge for
   local high school environmental studies. The event was held in May 2006 at
   the University of Portland.
• WES staff hosted two web seminars: Building Community Relationships -
   Maintaining and Gaining Public consent (May 2005) and Developing the Mind
   of a Strategist (January 2006).
• Presentation on Stormwater Management at the annual Roads and
   Maintenance Short School in Central Oregon Oct. 2005
• The Environmental Policy Specialist presented the following presentations to
   the North Clackamas Stormwater Management Citizen Advisory Committee,
   Lower Tualatin Stormwater Management Citizen Advisory Committee, and
   the Clackamas River Basin Council: Rock Creek Interceptor Project;
   December 30, 2005 High Flow Event; Stream Buffers, and Three Creeks
   Projects: Community Restoration Project; Biostabilization Project; and the
   Nature in Neighborhoods Wall of Fame Project.
• Stormwater & maintenance presentations at two homeowner’s association
   meetings



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4.11.5 Public Participation

North Clackamas Surface Water Management Citizens’ Advisory Committee
(NCSWMCAC)
The North Clackamas Surface Water Management Citizens’ Advisory Committee
(NCSWMCAC) meets on a bi-monthly basis. The twelve NCSWMCAC members
advise Water Environment Services on surface water and stormwater
management standards, regulations, and policies for CCSD#1. As a result of the
2006 customer satisfaction and values survey and the need for more public
involvement at advisory committee meetings, the NCSWMCAC pilot tested and
implemented an audio streaming of their meetings to include a link to documents
and presentations provided during those sessions. Press releases are created
announcing upcoming meetings and the agenda is published online. The meeting
minutes, presentations, and supporting documents are all available online at
http://clackamas.granicus.com/ViewPublisher.php?view_id=3. These new
features have received strong public support. Since implementation in April 2006
the number of virtual attendees continues to increase. More than 77 viewers
visited the NCSWMCAC streaming audio for the April meeting and 90 for the
June meeting.

Tualatin Citizens’ Advisory Committee (LTCAC)
The Lower Tualatin Citizens’ Advisory Committee (LTCAC) met quarterly to
discuss projects and provide input on projects they would like to see
implemented in the Surface Water Management Agency of Clackamas County
service area.

CCSD#1 Budget Committee
CCSD#1’s Budget Committee met in May 2006 to discuss projects and budget
issues for the District.

SWMACC Budget Committee
SWMACC’s Budget Committee met in May 2006 to discuss projects and level of
effort in the District.

Clackamas River Basin Council
The Clackamas River Basin Council meets monthly. CCSD#1 supports the
Basin Council with funding, staff time and resources, and with a voting
representative for the Special Districts stakeholder group. Staff spent significant
time involved with the Project Implementation Team in development of a project
criteria and ranking scheme to assist in prioritization projects within the CRBC’s
Watershed Action Plan. Staff also participated in a number of strategic planning
sessions. WES staff also participated in the Clackamas River Cleanup on
September 11, 2005. CRBC’s annual report is included as Appendix E.




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The CRBC reported the following public involvement and educational events that
WES supported within WES’s service area during the permit reporting period:

   •   July 16 Citizen’s Water Quality Snapshot Event – 200 streamside
       residents along Rock and Richardson Creeks were invited to participate in
       a water quality sampling event. 200 streamside residents received water
       quality report information on ways to protect water quality and salmon
       habitat. The event received coverage in the Damascus Observer. 12
       Clackamas High School students participated in the Citizen’s Water
       Quality Monitoring event.

   •   Watershed Ecology Class – Clackamas High School – The CRBC
       supported a week long watershed ecology summer field class for 15
       Clackamas High School Students. Students studied riparian habitat,
       salmonids, macroinvertebrates, and water quality.

   •   September 11 Down the River Clean Up – This annual CRBC event
       involved 190 people in a clean up of 13 miles of the lower Clackamas
       River. Volunteers removed over 2.5 tons of trash from the river. This
       event raises community awareness of salmon and water quality.

   •   October 8 Salmon Festival – The CRBC brought their Culvert Fish Toss
       Game to the Regional Salmon Festival. This interactive display highlights
       the value of the Clackamas Watershed for salmonids. Attendance at the
       Salmon Festival was estimated at over 7,000.

   •   February 6-7 WET Teachers Workshop – The CRBC co-organized and
       facilitated a 2-day teacher’s workshop on watershed science. Twenty
       Clackamas County teachers attended, three of which were from the WES
       service district.

   •   March 9 Golf Course Quality Lawns for Homeowner’s Class – The
       CRBC facilitated outreach and publicity for the class by identifying and
       targeting subdivisions within the WES service district. Targeted
       landowner’s received class mailing information. The class focused on
       techniques to reduce water and lawn care product use. 37 residents
       attended this class, which was held at Damascus City Hall.

The Wetlands Conservancy
The Wetlands Conservancy (TWC) partnered with WES staff on several projects
within the Kellogg Creek Watershed. A summary of their activities follows:

   •   Removed 20,000 sq. ft. of Himalayan blackberry at Hearthwood wetland.
       The blackberry was removed and the area revegetated with native trees
       and shrubs.



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   •   Removed 7,000 sq.-ft. area of reed canarygrass monoculture at
       Hearthwood wetland by solarization (cover with plastic sheeting). The
       area was revegetated with a combination of native shrubs, trees, and
       emergent wetland plant species.

   •   Injected approximately 500 sq.-ft. of Japanese knotweed in the riparian
       zone of Kellogg Creek.

   •   Planted more than 1,180 native plants (trees, shrubs, emergent plugs).

Total of 40 volunteers and more than 150 volunteer hours.

Johnson Creek Watershed Council
The Johnson Creek Watershed Council (JCWC) meets monthly. CCSD#1 fills
one of the jurisdictional positions on the Council Board and supports the Council
with funding, staff time and resources. Additional meetings take place monthly
for a variety of subcommittees. Johnson Creek Watershed efforts include:
    • Developed and distributed Within Your Reach newsletter
    • Participated as pilot watershed in Healthy Waters Institute
    • Held Open House September 2005
    • Presented 2006 Watershed Wide Event at 10 sites
    • Participated in several work parties at high priority restoration sites:
       Bundy, East Moreland Golf Course/Crystal Springs, Errol Heights, Hogan
       Cedars, and Kelley Creek among others
    • Worked with several watershed schools on restoration activities
    • Actively worked on Goal 5 / Nature in Neighborhoods, Metro Bond
       measure acquisition priorities, urban growth boundary, land use and
       natural resource conservation planning in Springwater area and in
       Pleasant Valley
    • Distributed monthly E-Bulleting to serve as action alert on critical issues
       affecting Johnson Creek Watershed
    • Initiated State of the Watershed Action Report continued involvement in
       IJC and other monitoring groups and activities
    • Hosted Annual Meeting / State of the Watershed in May 2006
    • Continued to partner with Milwaukie on Riverfront Plan and Klein Point
    • Initiated Japanese Knotweed reconnaissance and eradication campaign

Portland State University Student Watershed Research Project
The Student Watershed Research Project (SWRP) is a self-funded program of
Portland State University’s Environmental Sciences and Resources. WES
provides financial assistance so that high school students in their community can
have the opportunity to engage in the scientific study of our watersheds. The
SWRP program is a long-term riparian and aquatic monitoring program that
couples watershed education with collection of high quality data. Over the last
14 years, SWRP has trained 190 teachers and involved over 10,000 students in
the long-term monitoring of local watersheds. The SWRP model enables non-


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scientists to collect high quality useful data which agencies may not have the
resources to collect on their own. SWRP provides technical assistance,
resources and training.

Sandy River Watershed Council
Staff serves as a member of the Sandy River Watershed Council (SRWC) and
has been
involved with the Sandy River Basin Partners (SRBP) group in development of
an Ecosystem Diagnostic and Treatment (EDT) model and watershed
assessment project. Staff will be involved in assisting the SRBP in developing
and facilitating the implementation of a Habitat Conservation Plan (HCP) for the
basin. Staff assisted the SRWC with a native plant sale at the Salmon Festival
on October 7-9, 2005.

Stop Oregon Litter & Vandalism (SOLV)
WES participated with Clean Water Services, City of Portland, and other parties
to sponsor staff for SOLV to assist with volunteer projects for stream restoration
work: TeamUp. WES staff works with SOLV to assist property owners with their
projects. See attachment C for SOLV’s annual report. WES and SOLV agreed
to a contract agreement to conduct the Phillips Creek Japanese Knotweed
Removal Project. Himalayan Blackberry was cut and removed and Knotweed
stems were injected with a chemical treatment by a SOLV contractor during
spring 2006. A volunteer planting event is scheduled for October 2007, and two
additional events are planned for winter of 2007. See Appendix E for SOLV’s
annual report.

Stormwater Management Plans & Interim Evaluation Report Public
Involvement
WES updated its Stormwater Management Plans and Interim Evaluation Report
(IER) as part of its National Pollutant Discharge Elimination System (NPDES)
Municipal Separate Storm Sewer System (MS4) permit. A 30-day comment
period was developed in order to allow the public an opportunity to review and
provide recommendations on the Stormwater Management Plans and Interim
Evaluation Report (IER) before submitting the final documents to the Oregon
Department of Environmental Quality (DEQ). In an effort to increase the level of
public participation, the Plans and IER public comment period adopted the
International Association for Public Participation spectrum during this process. A
variety of techniques were implemented to increase citizen awareness of the
surface water management program and expand information-sharing efforts. In
all, four comments were received from citizens and businesses and a summary
of the Districts’ responses was included in the report, along with full-detail report
of the outreach activities that took place during the 30-day public comment
period.

Surface Water Program Guiding Principles




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In May 2006, WES completed the Surface Water Management Program Master
Plan (Plan). The purpose of this Plan was to take a concise look back over the 13
year history of CCSD#1 and, more importantly, to provide a longer view into the
future of surface water management within the District. The Plan assessed
existing program policies and their results and, where necessary, proposed new
directions.
WES will now develop a strategic plan and create “guiding principles” for the
Surface Water Management Program. The recently completed plan provides
helpful information on possible new directions for WES in surface water
management. While the choices are numerous, WES needs to hear directly from
its constituent groups on what they believe WES’ role should be in the future,
establish priorities, and determine how surface water program fees should be
spent.
The SWM Program Guiding Principles project will provide WES management
with a set of measurable, outcome-based guiding principles, based on the values
and perspectives of its key stakeholders. These principles will then serve as a
framework for future programs implemented by the SWM Program. This project
is estimated to begin in mid-August 2006 and a project site has been established
at http://www.co.clackamas.or.us/wes/plans/swmplan.htm

Tualatin Riverkeepers
Staff worked with the Tualatin Riverkeepers (TRK) by investigating “trouble
ticket” complaints in SWMACC that were called in as possible water quality
violations. Investigated two items.

Tualatin River Watershed Council
Staff serves as an alternate member of the Tualatin River Watershed Council.
Staff made the following presentations to this committee:
   • Goal 5 Presentation at the annual meeting – August 11, 2005;
   • Sensitive Area Buffers – November 10, 2005; and
       December 30, 2005 High Flow Event – February 2, 2006.


4.11.6 Intergovernmental Coordination

City of Happy Valley
WES presented an update on the Stormwater Management Program Master
Plan update and the December 30, 2005 High Flow Event in the Rock Creek
subwatershed to the City of Happy Valley City Council/Planning Commission on
March 21. WES staff also worked in partnership to produce a newsletter alert
and a public service announcement on the vandalism that is ongoing at the
Happy Valley Park Wetland Mitigation area.

Clackamas County Hazardous Mitigation Committee



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WES participates in countywide planning to address emergency management
issues. This includes mapping of topography, floodplains, existing stormwater
systems, and determining priorities for updating and creating FEMA maps.

Clackamas County Soil & Water Conservation District (CCSWCD)
The CCSWCD receives funding from WES to conduct water quality related
workshops to address urban and rural natural resource concerns such as
erosion, sedimentation, mud, manure, nutrients, pesticides, weeds, etc. for areas
outside CCSD#1 and SWMACC. In addition, CCSWCD provides technical
assistance to County residents via phone calls, emails, written material and site
visits to address natural resource and water quality concerns. The following
programs were delivered to promote natural resource conservation (number of
attendees):
   •   Three School booths (75) and Christmas Tree erosion workshop (8) at
       Clackamas Community College (CCC)
   •   Agricultural Innovation Summit (32) at Oregon Convention Center
   •   Celebrating Water Event (100) at CCC
   •   Sustainability Fair (175) at CCC
   •   Two Oregon City Farmers Market (20 & 95) – focus has been on weed
       control and water quality protection
   •   Two Horse Management Workshops and two site tours (120)
   •   Gardeners Galore (15) at CCC
   •   Foster Creek mitigation bank review team (6)
   •   Greater Oregon City watershed council (12)
   •   Clackamas County Water Education Team meetings
   •   Envirothon (13) at Oregon Gardens – statewide natural resource
       education and competition
   •   Two Golf course quality lawns (27 and 18)
   •   Two Weed Control workshops (27 and 18)
   •   Agricultural water quality at Willamette school (25)
   •   Conservation video series running on county cable access including Golf
       Course Quality Lawns, Pasture Management, and Rain Water Harvesting.
       It is estimated that 35,000 view the Government Channel on a monthly
       basis.
   •   Oregon Watershed Enhancement Board meeting tour hosting.
       Highlighted locally implemented water quality protection best management
       practices including off-channel livestock watering facility, livestock
       exclusion fence of riparian area, and native plantings.


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   •   Marketing inserts in WES sewer bills (9000) offering technical assistance
       to citizens.
   •   Meeting notices in the Oregonian
   •   Individual site visits (14) – site visits focus on retaining and protecting soil
       in addition to protecting the quality of surface waters.

Low Impact Development
Ongoing coordination with Clackamas County’s Planning Division to allow
development with methods that reduce curbs and impervious areas. WES works
closely with the Building, Engineering, and Planning Divisions of the County’s
Department of Transportation and Development to explore possible changes to
development standards that would reduce surface water impacts.

Clackamas County Road and Engineering Department
Surface Water coordinates with the Clackamas County Road and Engineering
Department by attending their bi-monthly team meetings. These meetings
provide an opportunity to coordinate on projects, to identify areas of cooperation
and to avoid duplication of effort.

Clackamas County WES and Happy Valley Drainage Coordination
Maintenance staff meets with the City of Happy Valley to discuss and visit
problem drainage areas and help the City to resolve problems on their own or
with the assistance of WES

Clackamas River Watershed Management Group
Staff attended several Clackamas River Watershed Management Group
meetings during the 2005-2006 reporting period. Other group members include
the five public water districts that divert, treat and sell the Clackamas River’s
waters, Portland General Electric, the Bureau of Land Management, The U.S.
Geological Survey (USGS), and the U.S. Forest Service. Projects which are
currently being jointly funded by the Water Providers include, but aren’t limited to,
the maintenance of continuous flow and water quality monitoring gages at
several locations (including the South Fork Water Board’s water intake), the
implementation of a second pesticide study (USGS is lead agency), a significant
watershed modeling effort with Portland State University.

Clackamas Subbasin Local Advisory Committee (LAC)
Staff served on the LAC to review and update the Clackamas Subbasin
Agriculture Water Quality Management Plan. The LAC finished its work in
February 2005 and submitted the following: Clackamas Biennial Review report to
the Board of Agriculture, the Clackamas Agriculture Water Quality Management
Area Plan, and the Education Program to the Department of Agriculture. The
LAC finished its work in February 2005 and did not meet during this permit
reporting period.



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Coordinating Council for Salmon Recovery Efforts in Clackamas County
The Coordinating Council is comprised of multiple County departments and the
Cities of West Linn, Lake Oswego and Happy Valley. The Council continued to
meet quarterly throughout 2005-06. Discussion continued on, regional
coordination, status of pending litigation and decisions, permitting, public
awareness, programs, projects, and policies related to natural resources, habitat
protection and restoration, and fish recovery planning. The WES ESA website:
(http://www.co.clackamas.or.us/wes/sr/main.htm) contains meeting
summaries and highlights projects such as fish passage improvement and
restoration projects and other information on County activities and programs.
WES made significant upgrades to its website during 2006.

Johnson Creek TMDLs
Water Environment Services, in partnership with the cities of Gresham, Happy
Valley, Milwaukie, and Portland, Multnomah County, the Johnson Creek
Watershed Council, and the DEQ (via the 319 grant program), contributed funds
and technical expertise to the completion of a pesticide study during the 2005-
2006 reporting period. Storm-driven and routine water samples had been
collected from 16 points in the upper portion of the Johnson Creek watershed.
The study’s report was completed and a fact sheet was developed & distributed
in 2005. The following parameters are being analyzed: TSS, turbidity, DDT and
Dieldrin. See Appendix C, 2005-2006 Water Quality Monitoring Report, for more
information.

Johnson Creek Interjurisdictional/Technical Committee:
Staff chairs the Interjurisdictional Committee (IJC), which provides coordination
amongst the jurisdictions on joint projects, monitoring and exchange of
information. A monitoring subcommittee has been established to determine data
needs for Johnson Creek and make recommendations to the Interjurisdictional
Committee for funding. Work performed by the IJC in the 2005-2006 reporting
period includes, but isn't limited to, joint water quality and water quantity
monitoring projects.

USGS’ Continuous Monitoring Stations in the Johnson Creek Watershed.
WES, in partnership with the cities of Gresham, Happy Valley, Milwaukie,
Portland, Multnomah County and the U.S. Geological Survey, contributed funds
towards the operation of five continuous monitoring stations in the Johnson
Creek watershed during the 2005-2006 reporting period. Four (4) stations
provide real-time flow and temperature data while the fifth station provides only
temperature data. In addition, two (2) stations now provide continuous turbidity
data. See Appendix C, 2005-2006 Water Quality Monitoring Report, for more
information.




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NPDES Clackamas County Co-Permittee Meetings
Coordinated forum for discussion of Best Management Practices, coordination of
the annual report, and stormwater issues of interest to each permittee.

Oregon Division of State Lands (DSL)
Coordination with DSL - Staff schedules meetings as needed with the Oregon
Division of State Lands (DSL) to discuss coordination issues and specific
projects.

Oregon Association of Clean Water Agencies (ACWA)
WES staff served on the Board of ACWA as the chair of the Finance Committee.
Staff attend regular meetings of the Groundwater, Stormwater and Public
Education Committees.

Statewide Stormwater Summit
This event was sponsored by the Oregon Association of Clean Water Agencies
(ACWA) to share water quality information between MS4 permit holders and
among ACWA members.

Pollution Prevention Outreach (P2O) Team
Staff attended several monthly Pollution Prevention Outreach (P2O) Team
meetings during the 2005-2006 reporting period. The P2O Team is comprised of
representatives from state and local government agencies in the greater Portland
metropolitan area that works toward achieving a cleaner environment through
cooperative efforts. Improving the water quality of discharges to and from storm
sewer systems continues to be one of the P2O Team’s highest priorities.

Regional Coalition for Clean Rivers and Streams
In response to shared needs to meet NPDES municipal stormwater permit
requirements, WES joined with a number of other jurisdictions in 1994 to form the
Regional Coalition for Clean Rivers and Streams to develop and implement a
five-year coordinated pollution prevention awareness campaign.

Members of the Regional Coalition of Clean Rivers and Streams (RCCRS)
include the City of Portland, Clean Water Services, City of Gresham, and the
Clean River Partners of Clackamas County (Milwaukie, Rivergrove, Gladstone,
Happy Valley, Oak Lodge Sanitary District, Wilsonville, Lake Oswego, Oregon
City and West Linn) to combine resources in developing an advertising campaign
that addresses stormwater in the Metro area.

This cooperative effort resulted in a media campaign targeted at more than one
million residents of 26 cities in the tri-county area. The campaign uses a
combination of media to reach a broad audience with a water quality/pollution
prevention message. The message, media and effective number of residents
reached by the campaign are outlined in the annual report attachment. This past
year’s campaign utilized bus transit signs, bilingual (English/Spanish) newspaper



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print, print media ads, and social-marketing incentives. The website was
updated and social-marketing incentives such as the All Natural Lawn Care kit
were effective elements in the campaign. WES continues leadership in the
Coalition media events with contributions of $4,000 per year. The campaign was
also recognized with a Superior Award by the National Association of County
Information Officers. See The RCCRS Annual Report, Appendix E and the
website at: www.cleanriversandstreams.org.

Tualatin Designated Management Agencies Group
WES participated as a Designated Management Agency (DMA) in the Tualatin
Watershed Group that meets to coordinate reports, responses and
implementation plans. The DMA group typically meets on an as-needed basis,
and more often as necessary. In addition, four of the DMAs, including
SWMACC, funded 50% of the operational cost of the continuous water flow
measuring system on the Tualatin River in SWMACC during the 2005-2006
reporting period. The other three DMAs are Washington County’s Clean Water
Services, and the Cities of Lake Oswego and West Linn. The U.S. Geological
Survey funded the other 50%.

Tualatin Basin Public Awareness Committee (TBPAC)
To comply with the DEQ regulations set by the Environmental Quality
Commission in the Tualatin Subbasin Nonpoint Source Management
Implementation Compliance Schedule and Order, WES is an active member of
this public awareness committee. The group continues to develop materials and
programs and increase activities that encourage individuals to protect water
quality and endangered species in the Tualatin River Watershed. This last
permit period, the TBPAC sponsored several naturescaping workshops and
storytelling assemblies.

Water Resources Policy Advisory Committee (WRPAC)
Staff provides membership and alternate membership to the Water Resources
Policy Advisory Committee. The committee reviews issues related to improving
water quality, preserving natural resources, buffer requirements, and sharing of
environmentally relevant information around the region. Staff was involved in
several committees to develop and review Metro’s Nature in the Neighborhoods
program to comply with Statewide Goal 5 (Protection of Open Spaces, Scenic
and Historic Areas, and Natural Resources). Staff made a presentation on
August 16, 2005 regarding WES’s proposed Stormwater Management Program
Master Plan Update project.

West Nile Virus
WES staff in cooperation with the Public Health Department was asked to serve
on a technical review committee for the Clackamas County Vector Control
District’s West Nile Virus Response Plan. Several meetings were held during the
spring of 2005 and staff reviewed and commented on five versions of the
response plan. During 2006 WES was asked to serve on a technical advisory



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committee to revise the Vector Control’s West Nile Virus Annual Work Program
and Response Plan. WES staff continues to develop a departmental West Nile
Virus Response Plan to focus on monitoring, maintenance, and public outreach
and educational activities associated with the stormwater drainage system and
minimization of vectors. During 2006, WES completed a Stormwater Facilities
and West Nile Virus Frequently Asked Questions Brochure and Insect Repellent
kit. These were sent out in bill inserts and added to our web site. Local resident
could call in to request the insect repellant kits. WES also hired a temporary
employee to inventory more than 180 stormwater detention facilities. These
facilities were inventoried for both maintenance needs and as part of a biological
characterization project that will begin in the fall of 2006. WES in partnership
with Portland State University and the Clackamas County Vector Control District
will conduct the biological characterization project.

The purpose of project is to assess the biological make-up of a select number of
representative stormwater pond facilities and to determine their predator-prey
relationships. The proposed project would characterize the biological make-up of
different Retention/Detention (R/D) ponds, in various locations, throughout the
growing and mosquito season. A literature search would be conducted to focus
the efforts on the expected predators and life forms that might be present and
have the ability to feed on immature mosquitoes (larvae and pupae). The focus
would be on those specific aquatic insects or other predators that may be present
and are known to have the ability and preference for this type of food source.
Potential species could generally include but are not limited to: dragonfly and
damselfly naiad’s, backswimmers, water beetles and bugs, and other aquatic
insects and potential predators. A general characterization of the biological
make-up of each pond within the study set would be completed. A graduate
student from PSU will collect plankton, benthos, and other standard
physiochemical constituents.

The Clackamas County Vector Control District (CCVCD) will also participate by
cooperatively sampling and identifying mosquito larvae and adult species, sex,
and testing for West Nile Virus. A predictive model will be developed to assist in
what biota/predator may negatively associate with mosquito larvae. An
assessment of the predator-prey relationships would be compiled. Biotic index
scores for individual taxa could also be developed for pollution tolerance scores.
Other biological sampling and appropriate methodologies could be conducted if
deemed appropriate from results of the literature search – for example fisheries,
frog egg masses, other macro-invertebrates, or birds. Bi-weekly and one-time
sampling of various selective stormwater pond facilities is proposed. A pilot test
sampling of a select number of ponds may be conducted during the late summer
and early fall 2006. A literature search would than be conducted over the winter
period with more intensive and targeted sampling program would commence
during the spring/summer of 2007. Water levels within the pond would also be
measured along with potential sampling and testing of basic water quality and
sediment constituents. Other objectives may include: 1) assess habitat conditions



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and other contributing factors of potential vector habitats; 2) develop a prioritized
list of potential risk threats and retrofitting challenges and opportunities; and 3)
develop a list of preliminary recommendations for design considerations and
maintenance best management practices to minimize and control potential vector
habitats associated with stormwater pond facilities.

A report summarizing the results would be completed or a graduate MS thesis
could be generated. Recommendations for reducing mosquito breeding habitats
and retrofitting each pond sampled would also be summarized in cooperation
with WES staff. Water quality and quantity control and management measures
may also be incorporated.



4.12 Monitoring Program [Schedule B(1)]
On May 1, 2006, WES submitted revised Surface/Stormwater Monitoring Plans
for: a) CCSD#1 and the City of Happy Valley, and b) SWMACC and the City of
Rivergrove to DEQ. Copies of these Plans are available upon request by calling
Andrew Swanson of WES at 503-353-4598. These Plans:
    • Meet the monitoring requirements that are within the current MS4 permit,
        issued July 27, 2005, including each of the objectives in the MS4 permit’s
        schedule B(1)(b), and
    • For CCSD#1, meet the requirements that are present within the Three
        Basin Rule (OAR 340-041-470) for those areas that drain into the
        Clackamas River watershed, and
    • Allow the District to track the long-term progress of the Stormwater
        Management Plans (SWMP) towards achieving improvements in receiving
        water quality, if improvements in receiving water quality are needed, and
    • Will yield information that can be used to support the adaptive
        management process that could lead to refinements of the SWMP, and
    • Have protocols that will be used for quality assurance/quality control for
        sample collection and analysis that are consistent with the quality
        assurance protocols described in the Department's 2004 303(d) List/Delist
        Data Submittals Minimum Data Requirements.

See Appendix C of this report for the 2005-06 Water Quality and Flow Monitoring
Reports for CCSD#1 and SWMACC.

At the request of DEQ, the Districts coordinated and participated in a joint study
among the interested Clackamas Co-permittees to develop a coordinated
monitoring plan to meet the objectives in schedule B(1)(b). URS Corporation
was hired to evaluate the co-permittees’ existing programs and develop a
coordinated monitoring plan that would be jointly implemented by participating
co-permittees. The evaluation was completed in the spring of 2006 and the final
recommendations were made in October 2006. If approved by DEQ,


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implementation would begin in July 2007. If this coordinated MS4 monitoring plan
is approved by DEQ, implementation could begin as soon as July 2007 if the
relevant portions of the MS4 permit (tables B-1 and B-2) have been modified by
then.

Until authorization to implement the coordinated MS4 monitoring plan has been
provided by DEQ, WES will continue to implement the monitoring plans (dated
May 1, 2006) for SWMACC (includes the City of Rivergrove) and CCSD#1
(includes the City of Happy Valley. A copy of the proposed coordinated
monitoring plan is included as Appendix D.



4.13 Non-Stormwater Discharges [Schedule B(2)(b)(iii)]
The July 27, 2005 MS4 permit which was issued to SWMACC, The Cities of
Rivergrove and Happy Valley, CCSD#1, and Clackamas County (hereafter
referred to as “the co-permittees”) requires that an Interim Evaluation Report
(IER) be submitted to the DEQ by May 1, 2006. One component of the IER is an
identification of the “…appropriate control measures and the rationale for the
selection of these BMPs, or the rationale for why BMPs are deemed not
necessary” for each of the twenty-four (24) non-stormwater discharges that are
listed in Schedule A(1)(3) of the permit if that discharge is expected to occur in a
co-permittee’s area. According to Schedule A(1)(3) of the MS4 permit, the 24
non-stormwater discharges “…need not be addressed by the co-permittee’s illicit
discharge program, provided appropriate BMPs, if needed, to minimize the
impacts of such sources are developed under the SWMP…”. The 24 non-
stormwater discharges are divided into the following ten (10) categories in this
document:
As this information is not required on an annual basis, please refer to the IER
and SWMP for details.




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5.0 FUNDING, STAFF, AND EQUIPMENT [Schedule
B(2)(b)(iii)]

5.1   Funding – CCSD#1 & SWMACC
The Stormwater Management Program for CCSD#1 is funded through three
primary sources: monthly stormwater utility fees, systems development charges
(SDCs), and permit fees.

CCSD#1
The monthly fees are separated into two categories: program fees and
maintenance agreement fees. All CCSD#1 customers pay the monthly program
fee of $6 per Equivalent Service Unit (ESU) which is defined as one single-family
residence or 2500 square feet of impervious surface for nonresidential
customers. New single-family residential customers since 1998 also pay a
monthly maintenance agreement fee of $3 per ESU which is dedicated for
maintenance of local subdivision stormwater conveyance, detention, treatment,
and infiltration facilities. In the July 2005 to June 2006 fiscal year, CCSD#1
collected approximately $3,113,000 in program fees and $177,000 in
maintenance agreement fees.

SWMACC
All SWMACC customers pay the monthly program fee of $4 per Equivalent
Service Unit (ESU), which is defined as one single-family residence. In the July
2005 to June 2006 fiscal year, SWMACC collected approximately $152,000 in
program fees. Only a small portion of this revenue was collected within the MS4-
permitted area.

SDCs are collected from new development and dedicated to planning, design,
and construction of additional stormwater infrastructure capacity needed to
accommodate growth. The current SDC rate is $205 per ESU. In the July 2005
to June 2006 fiscal year, CCSD#1 collected approximately $253,000 in SDCs.

Permit fees for stormwater and erosion control plan review and inspection are
collected with every new development application. The current stormwater plan
review fee is $250 per subdivision or commercial/industrial development and $50
per single-family residential building permit. The erosion control review and
inspection fee is $450 for the first acre, plus $80 per additional acre for
subdivisions and commercial/industrial developments, while new single family
residences are charged a flat rate of $300.

CCSD#1
In the July 2005 to June 2006 fiscal year, CCSD#1 collected approximately
$126,000 in stormwater and erosion control permit fees.

SWMACC



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In the July 2005 to June 2006 fiscal year, SWMACC collected approximately
$2,500 in stormwater and erosion control permit fees.

5.2 Expenditures & Budget – CCSD#1 & SWMACC
For stormwater program expenditures, see Appendix F.

5.3 Staff – CCSD#1 & SWMACC
Staff for surface water management activities are integrated amongst the
sections of WES (Planning and Engineering, Environmental Permitting and
Laboratory Services, and Environmental Services.) The staffing levels listed
below are dedicated both the CCSD#1 and SWMACC.

Environmental Services
Stormwater System Maintenance
   • 0.2 FTE Program Manager
   • 2.0 FTE Surface Water Technicians
   • 3.3 FTE Collection System Technician
   • 1.2 FTE Seasonal Employees
   • Have also contracted with DTD for 1 FTE

Planning and Engineering Services
Planning, development review, capital projects and erosion control.
   • 0.2 FTE Program Manager
   • 0.2 FTE Development Review Supervisor
   • 1.0 FTE Administrative Support
   • 0.5 FTE Senior Civil Engineer
   • 0.5 FTE Civil Engineer
   • 1.0 FTE Surface Water Technician
   • 1.5 FTE Plan Reviewer
   • 1.5 FTE Erosion Control Inspectors
   • 0.5 FTE Single Family Plan Reviewer
   • Additional staff through DTD for floodplain and miscellaneous land use
      issues.

Environmental Permitting and Laboratory Services
MS4 Permit compliance (Field Screening, Inspection of Illicit Connections,
Management of Programs, Industrial Stormwater and Monitoring) within two
service districts.
   • 0.2 FTE Program Manager
   • 0.6 FTE Water Quality Analyst
   • 0.2 FTE Sample Collection (through Compliance Services).
   • 0.2 FTE Additional staff performs spill response, laboratory analysis on
       samples and continuous surface water monitoring

Public Involvement and Outreach


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Development of brochures, public awareness materials, inter-jurisdictional
coordination on public education, public meetings and workshops, etc.
   • 0.6 FTE Community Relations Specialist
   • 0.2 FTE Surface Water Technician

Environmental Policy Review and Implementation
   • 1.0 FTE Environmental Policy Analyst


5.4 Training – CCSD#1 & SWMACC
Staff attended the following conferences and events:
   • National Nonpoint Educational Conference – October 18-21, 2005
   • State Programmatic General Permit (SPGP) – February 13, 2006
   • Fish Passage Training – May 3, 2006
   • Stormwater Management Program Master Plan Modeling – May 17, 2006
   • ORACWA Stormwater Summit (5/06)
   • Annual Roads and Maintenance Short School (10/05)

5.5 Equipment – CCSD#1 & SWMACC
Stormwater management activities require a range of equipment. This
equipment is owned by the County Road Department or by WES. Additional
equipment is rented or contracted out. A partial list of equipment used for
stormwater management activities includes:
    • Combination Vacuum/Hydrocleaner trucks
    • Regenerative air sweepers
    • 1/2 ton utility vehicles
    • Dye testing and smoke testing equipment
    • Sampling stations and sampling gear
    • Volunteer stream restoration tool trailer

WES created specifications, purchased, and took delivery of an Aquatech®
Series B-10 Combination Cleaner in the latter portion of the 2004-2005 reporting
year. This will enhance WES’ stormwater maintenance efforts and free DTD’s
combination cleaner to focus on roadway/transportation issues outside CCSD#1
and SWMACC.

5.6   Funding for Development Review, Erosion Control & Street
      Sweeping - City of Happy Valley

Permit fees for development and erosion control plan review and inspection fees
are split into two categories; a) Subdivision and PUD Projects, and b)
Commercial and High-Density Residential Projects. The fee structure for
Subdivision and PUD Projects is a $485 base fee up to 1 acre plus $85 per acre
or fraction thereof for sites greater than 1 acre. The fee structure for Commercial
and High-Density Residential Projects is a $500 base fee up to 1 acre plus $100


MS4 Permit Compliance Report for CCSD#1 & SWMACC                             109
per acre or fraction thereof for sites greater than 1 acre. In the July 2005 to June
2006 fiscal year, the City collected approximately $379,736 in development
review and erosion control permit fees.

Funds for Street Sweeping are budgeted through General Funds. In the July
2005 to June 2006 fiscal year, the City budgeted $ 2,600 in Street Sweeping
funds. City staff provided primary street sweeping services.

5.7 City Staff
Public Works Department
Street Sweeping
   • 1.0 FTE Program Manager
   • 1.0 FTE Street Maintenance Employee

Engineering Services
Engineering development review, capital projects, and erosion control.
   • 1.0 FTE Program Manager
   • 1.0 FTE Senior Civil Engineer
   • 1.0 FTE Erosion Control Inspectors
   • Additional staff as needed.

5.8 Training for City Staff
City staff attended the following conferences and events:
    • APWA Spring Conference, Salishan Resort, Gleneden Beach, Oregon,
       2006
    • Seminar on Erosion Prevention and Sediment Control, presented by
       Environmentally Wright, Tualatin, Oregon, 2006.

5.9 City Equipment
Street Sweeping and erosion control activities require a range of equipment.
This equipment is owned by the City. Additional equipment is rented or
contracted out. A partial list of equipment used for these activities includes:
   • Regenerative air sweepers
   • ¾-ton utility vehicle
   • 1-ton utility vehicle
   • Rubber tired backhoe




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6.0 LEGAL AUTHORITY [Schedule B(2)(b)(vii)]
6.1   County Planning/Development Review: General

Comprehensive Plan
The Clackamas County Comprehensive Plan for the unincorporated parts of the
County was last updated May 31, 2000. This Plan addresses planning goals and
policies, including land use, transportation, community and design plans,
drainage, natural resources and open space/parks.

Current policies regarding development, implementation, and enforcement of
stormwater controls for new development or redevelopment are identified in the
Public Facilities and Services element of the Comprehensive Plan. The
Comprehensive Plan provides authority to adopt measures that protect surface
waters.

Oregon Revised Statutes (ORS), Chapters 215 and 197, require the County to
provide opportunities for citizen participation and to establish a citizens'
committee to assist the County in implementing and evaluating its citizen
involvement program.

County Planning Procedures
Clackamas County and the Districts review all plans for new development and
redevelopment, in unincorporated parts of the County, through the development
process. All development plans are checked for conformance with the following:

      •   Clackamas County Zoning and Development Ordinance
      •   Service District Rules and Regulations (Surface Water Management
          Agency of Clackamas County and Clackamas County Service District
          No.1)
      •   Grading and Excavation Ordinance
      •   Roadway Standards Manual

The planning review process is summarized as follows:

Proposed developments are reviewed by the Planning Division to verify
consistency with zoning and land use requirements. A pre-application conference
is set with departments in the County having oversight requirements for
construction, including the permits, plumbing, surface water, technical services,
traffic, and zoning sections. Developers are provided with standards regarding
water quality requirements, drainage requirements, regulations for wetlands and
floodplains, and standards for construction. Plans are submitted by the developer
and reviewed by each section responsible for the ordinances or requirements.
Plans are either returned for additional information, or are reviewed through the
applicable process with those approved subject to a list of conditions which must
be met during the construction process


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6.2    County Planning Specific to Stormwater

Surface Water Management Program
Surface Water Management (SWM) in Clackamas County involves numerous
jurisdictions within several watersheds. In order to coordinate efforts in an
ongoing basis, a committee of NPDES co-permittees meet on a periodic basis or
as needed to discuss issues of concern and areas of combined interest. A large
amount of coordination currently occurs on a staff level and is encouraged to
optimize resources of personnel and equipment.

Surface Water Management Utility
Two separate ORS 451 service
districts provide SWM in the urban unincorporated areas of Clackamas County.
The Surface Water Management Agency of Clackamas County (SWMACC)
addresses SWM in the Tualatin Basin. Clackamas County Service District No.1
(CCSD#1) addresses surface water management in the North Clackamas Urban
Area.

Surface Water Management Agency of Clackamas County (Lower Tualatin
Basin}:
County Board Order No. 92-289, signed March 19, 1992, empowers the Surface
Water Management Agency of Clackamas County (SWMACC) to construct
capital improvements, to address surface water quality and quantity, and to
provide nonpoint source pollution controls to meet state and federal regulations.
The Rules and Regulations of SWMACC establish the permit fees and rates -
charged per residential and non-residential equivalent service units.

The program was established as a requirement by DEQ to meet the TMDLs
established for the Tualatin Basin.

Clackamas County Service District No.1 (North Clackamas Urban Area):
County Board Order No. 93-196, signed February 25, 1993, empowers
Clackamas County Service District No.1 to provide nonpoint source pollution
controls to meet state and federal regulations and to construct capital
improvements necessary to address both surface water quality and quantity
problems. Rules and regulations of CCSD#1 establish the permit fees and rates
charged per residential and non-residential equivalent service units. In addition to
the North Clackamas Urban Service Area, the Rules and Regulations for
CCSD#1 apply to applications for development located in two other service areas
within the District, Boring and Hoodland.

Drainage Master Plans
Drainage master plans have been completed
for the following watersheds: Clackamas River Direct, Cow Creek, Sieben Creek,
Johnson Creek, Kellogg Creek and Mt. Scott Creek Watersheds, Oak Lodge


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Area and Lake Oswego (including surrounding unincorporated areas). A
Surface Water Management Program Masterplan to conduct a complete
review and evaluation of the WES’ Surface Water Management Program was
completed in April 2006.

Drainage Utility Maps
The Districts maintain storm drainage system
records in an Arclnfo database. This work is performed and stored at Water
Environment Services.

Planning for Drainage and Pollution Control Facilities
Planning for capital improvements for public storm drainage and pollution control
facilities occurs through completion of the drainage master planning effort and
updating of existing master plans. Prioritization of capital improvements are
based on:
         • Citizens' input;
         • Ability to improve water quality;
         • Review of existing problem areas;
         • Coordination with other departments and jurisdictions.


6.3   County Development Review: Specific to Stormwater
      Quality

Zoning and Development Ordinance
The Zoning and Development Ordinance provides the rules, regulations and
standards that implement the goals and policies of the Comprehensive Plan. The
sections that serve to protect surface waters in Clackamas County are:
Floodplain Management District (Section 703), River and Stream Conservation
Area (Section 704), Conservation Wetland District (Section 704), Willamette
River Greenway (Section 705), Protection of Natural Features (Section 1002),
Utility Lines and Facilities (Section 1006), Storm Drainage (Section 1008), and
Open Space and Parks (Section 1011), Density Standards, Transfers and
Bonuses (Section 1012), Planned Unit Developments (Section 1013), and Open
Space Review (Section 1103).

Stormwater quality control regulations are promulgated in the Zoning and
Development Ordinance, Section 1008, the Rules and Regulations for SWMACC
and the Rules and Regulations for CCSD#1. New development and
redevelopment projects must meet standards for stormwater detention and
treatment.

For implementation of the water quality standard, the Districts provide guidelines
for design of approved vegetated systems and provide copies of the Clackamas
County Surface Water Quality Facilities - Technical Guidance Handbook (1994).



MS4 Permit Compliance Report for CCSD#1 & SWMACC                            113
Erosion control regulations are promulgated in the Zoning and Development
Ordinance, Section 1008, the Rules and Regulations for the Surface Water
Management Agency of Clackamas County (SWMACC) and the Rules and
Regulations for Clackamas County Service District No.1 (CCSD#1). For land
development projects, erosion control plans must be submitted that include
methods and/or interim facilities to be constructed or used concurrently with
development to control the discharge of sediment in stormwater runoff.

During the application review for development permits, the County uses its
Erosion Prevention and Sediment Control Planning and Design Manual (2000),
Stormwater Design Standards, and Rules and Regulations for each District, to
determine the necessary non-structural and/or structural BMP(s). The Rules and
Regulations are revised as needed to update information. The Design Standards
are upgraded as necessary to provide criteria to the development community for
implementation of the Rules and Regulations. The above-referenced Erosion
Prevention manual is in the process of being revised and updated and is
expected to be completed in the Summer 2007.

Design Standards for Storm Drainage
Design standards for storm drainage provide criteria on how to implement the
Rules and Regulations for Surface Water Management in CCSD#1 and
SWMACC. These address the design of surface water facilities for the purpose of
addressing water quality and providing drainage for new development.

Clackamas County Roadway Standards
This document provides requirements for drainage standards, roadway
standards, submittal requirements, including a section on hydrology, hydraulics,
and water quality. The manual was completed in January 1999.

Standards and Ordinances: Prevention of Illicit Connections
Rules and Regulations for SWMACC and CCSD#1 identify standards that define
illicit connections to storm sewers.

In addition, existing regulations that prohibit illicit connections to storm sewers
are promulgated in ORS 447.140. Board Order 81-1-36, "An Ordinance
Pertaining to Enforcement of the Building Code, Excavation and Grading
Standards, and Sewage Disposal System Standards" provides the authority to
enforce regulations for illicit connections. This Order was amended by Board
Order 88-179 to include grading and filling regulations.

6.4    City of Happy Valley – Erosion Prevention & Sediment
       Control Programs and Street Sweeping Program

The City of Happy Valley is currently seeking Agent status from DEQ for
responsibility for Erosion and Sediment Control plan review and permit issuance.
As of October 1, 2005, Clackamas County Water Environment Services (WES)


MS4 Permit Compliance Report for CCSD#1 & SWMACC                               114
relinquished authority back to DEQ for the City of Happy Valley. Currently DEQ
is responsible for plan review and approval of all NPDES 1200-C permits for site
development with an area of 1 acre and larger within the City limits. DEQ is also
responsible for enforcement of DEQ regulations during site development
construction. The City of Happy Valley provides additional plan review and
construction inspection of erosion control measures for private and public
development within the City limits as authorized under Municipal Code Sections
8 and 15. The City of Happy Valley has adopted Clackamas County WES
regulations and standards for erosion and sediment control.

The City of Happy Valley provides for public street maintenance and cleaning as
authorized under Municipal Code Section 10. The City’s Public Works Director
initiates and directs any public street maintenance/sweeping on an on going as
needed basis.




MS4 Permit Compliance Report for CCSD#1 & SWMACC                           115
7.0 IDENTIFICATION OF WATER QUALITY
IMPROVEMENTS
    OR DEGRADATION [Schedule B(2)(b)(vi)]
The Districts' program elements focus on preventing or minimizing pollution and
on source controls. This report describes and quantifies the numerous activities
which work toward keeping pollution from entering rivers and streams. The
maintenance activities, spill control, public education and erosion control, along
with all of the other activities implemented by the Districts, work toward keeping
pollution at its source. The Districts also continually evaluate the program to
assure optimal implementation of program elements and expenditure of funds.

Water quality monitoring continues to provide information on the current quality of
the water in the creeks and rivers in the Districts. See Appendix C for details of
the monitoring program and analysis results.



8.0 CHANGES TO SWMP [Schedule B(2)(b)(ii)]
No changes are proposed to the Surface Water Management Plan at this time.
The 2006-2007 MS4 annual report may propose changes, if any, to reflect
program revisions developed from the Surface Water Management Program
Masterplan project.




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