System-Wide Assessment
Individual WPCF Permit for Class V Stormwater Underground Injection Control Systems
Applicant:
Applicant
Street Address
City, State ZIP
Permit Number:
XXXXXX
WQ File Number:
XXXXXX
Date:
MM/DD/YYYY
Prepared By:
Consultant Company or Applicant
Instructions (do not include in final document):
1. This document is a template for a System-Wide Assessment that meets Schedule B,
Condition 1 of an individual UIC WPCF permit issued by the Oregon Department of
Environmental Quality. This document should be modified so it is customized to the
applicant.
2. The YELLOW TEXT needs to be updated by the permittee.
3. Comment bubbles provide instruction to the permittee.
CERTIFICATION
“I certify under penalty of law that this document and all attachments were prepared under my
direction or supervision in accordance with a system designed to assure that qualified personnel
properly gather and evaluate the information submitted. Based on my 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 my knowledge and belief, true, accurate,
and complete. I am aware that there are significant penalties for submitting false information,
including the possibility of fine and imprisonment for knowing violations.”
Signature
Name
Title
Signature
Date
Table of Contents
1 Introduction .................................................................................................................. X
2 UIC Inventory ............................................................................................................... X
2.1 UIC Identifier, Status and Location ........................................................................ X
2.2 Vehicle Trips Per Day............................................................................................ X
2.3 UICs that Discharge Directly to Groundwater ........................................................ X
2.4 UICs that Do Not Meet Setbacks to Water Wells ................................................... X
2.5 UICs Prohibited Under OAR 340-044-0015(2)....................................................... X
3 Commercial and Industrial Facilities that Pose a Risk of
Pollutant Discharge to Permittee-Owned UICs .............................................................. X
4 Procedures for Keeping UIC Inventory Current ............................................................ X
Tables
Table 1-1
System-Wide Assessment Content
Table 2-1
DEQ UIC Facility Identification Numbers
Table 3-1
Commercial and Industrial Facilities that Pose a Risk of Pollutant Discharge to
Permittee-Owned UICs
Figures
Figure 2-1
UIC Locations
Appendices
Appendix A
UICs Owned and Operated by Permittee
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1 Introduction
Permitee owns and operates approximately X Underground Injection Control (UIC) devices that
manage stormwater runoff by infiltrating it into the subsurface. The UICs drain stormwater from
X.
Permittee applied for a UIC Water Pollution Control Facilities (WPCF) permit for its UICs on
date, and expects to receive its permit on date. Schedule B, Condition 1 of the permit requires
that the permittee develop a System-Wide Assessment that describes the injection systems
owned and operated by permittee.
It is necessary to develop a UIC inventory to identify the nature of the fluids that are infiltrated at
UICs and assess the potential for impacts to groundwater. The goal of the System-Wide
Assessment is to ensure that stormwater infiltration occurs in a manner that is protective of
human health and the environment. The objectives of the System-Wide Assessment are:




Develop an inventory of permittee-owned and -operated UICs to support tracking and
management of UICs;
Identify high-risk UICs to inform stormwater sampling under the UIC Stormwater
Management Plan. High risk UICs are identified on the basis of vehicle trips per day,
direct discharge to groundwater, proximity to water wells, and proximity to
industrial/commercial facilities that pose a risk of pollutant discharge to the UIC;
Identify high-risk UICs to assist with the prioritization of UIC retrofit or closure; and
Develop a dataset that can be used to adaptively manage permittee’s stormwater
monitoring program.
The permit references for the content of the System-Wide Assessment, and the location of the
content in this report is summarized in Table 1-1.
Table 1-1
System-Wide Assessment Content
Permittee
Item
Permit Reference
UIC Identifier, Status and Location
Vehicle Trips Per Day
UICs that Discharge Directly to
Groundwater
UICs that Do Not Meet Setback
Requirements to Water Wells
UICs Prohibited by
OAR 340-044-0015(2)
Commercial and Industrial Facilities that
Pose a Risk of Pollutant Discharge to
Permittee-Owned UICs
Schedule B, Condition 1.a
Schedule B, Condition 1.b
Section in
Document
Section 2.1
Section 2.2
Schedule B, Condition 1.c
Section 2.3
Schedule B, Condition 1.d
Section 2.4
Schedule B, Condition 1.e
Section 2.5
Schedule B, Condition 1.f
Section 3
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2 UIC Inventory
2.1 UIC Identifier, Status and Location
Appendix A provides UIC status (under construction, active or closed), UIC identifier, and UIC
location by latitude and longitude for all permittee-owned UICs known to exist at the time this
report was prepared.
Each UIC has two identifiers, one that is used by the permittee and another that is assigned by
DEQ:

Permittee Identification Number. Permittee assigns a unique identifying number to
each UIC. Explanation.

DEQ UIC Identification Number. Each UIC that has been registered with DEQ is
assigned an identification unique number using the format XXXXX-YYY. The “XXXXX”
number is the 5-digit UIC facility number that is assigned on the basis of the property
address or tax lot OR UIC owner X. The permittee’s UIC facility numbers are
summarized in Table 2-1.
Table 2-1
UIC Facility Identification Numbers
Permittee
Facility
Address
X
X
X
X
X
X
X
Street, City, State Zip
Street, City, State Zip
Street, City, State Zip
Street, City, State Zip
Street, City, State Zip
Street, City, State Zip
Street, City, State Zip
UIC Facility
Number
XXXXX
XXXXX
XXXXX
XXXXX
XXXXX
XXXXX
XXXXX
The “YYY” number is sequentially assigned to each UIC under the UIC facility number
(for example, -001, 002, 003, etc.). If a UIC has not been registered with DEQ, then it
does not have a DEQ UIC Identification Number.
Latitude and longitude are provided in decimal degrees the North American Datum 1983 (NAD
83) coordinate system. Latitude and longitude were determined by X. The permittee’s UICs are
shown in Figure 2-1.
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2.2 Vehicle Trips Per Day
Pollutant concentrations in stormwater draining municipal rights of way are dependent on the
traffic volume. Specifically, pollutant concentrations are higher on streets with over 1,000 vehicle
trips per day (TPD) and are lower on streets with less than 1,000 TPD [Kennedy/Jenks (2009,
2011); City of Gresham (2013); City of Portland BES (2006, 2007, 2008a, 2009, 2010, 2011,
2012)]. DEQ has also assumed that pollutant concentrations are higher in parking lots with more
than 1,000 TPD for the purpose of evaluating risk at UICs. TPD data is considered when
selecting UICs for stormwater monitoring.
Appendix A provides vehicle trips per day in the area(s) drained by the UICs. Vehicle trips per
day were determined by X.
2.3 UICs the Discharge Directly to Groundwater
UICs that discharge directly to groundwater (“wet feet” UICs) are identified in Appendix A, and
were identified using two methods:

Wet Feet UICs identified on the basis of local hydrogeologic studies and UIC
construction. X. Hydrogeologic studies were used in combination with UIC depths to
calculate the vertical separation distance between the bottom of a UIC and the seasonal
high groundwater table. The following formula was used:
SD  DTW   d 
(1)
Where:
SD is vertical separation distance between the seasonal high groundwater and
the bottom of the UIC (feet)
DTW is the depth to seasonal high groundwater (feet)
d is the depth of the UIC (feet)
If SD in Equation (1) is a negative number, then the UIC discharges directly to
groundwater. If SD in Equation (1) is a positive number, then the UIC does not discharge
directly to groundwater.
The depth to seasonal high groundwater in the permittee’s UIC area was reported in
(reference). Total depths at each City UIC were measured X. Values of DTW, d, and SD
at each UIC are listed in Appendix A.

Wet Feet UICs identified on the basis of field observations. X.
2.4 UICs That Do Not Meet Setbacks to Water Wells
Schedule A, Condition 8 of the permittee’s UIC WPCF permit establishes horizontal setbacks
between UICs and water wells. Specifically, the setbacks are the two-year time-of-travel of a
public water well (if a two-year time-of-travel has been determined by the Oregon Health
Authority) or 500 feet of a public or private drinking water or irrigation water supply well (if the
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Oregon Health Authority has not designated a two-year time-of-travel). A groundwater
protectiveness demonstration is required if a UIC is located within a well setback. If groundwater
protectiveness cannot be demonstrated, then the permittee must retrofit or decommission the
UIC.
Water wells were identified using the following methods:

Oregon Water Resources Department (OWRD) On-Line Well Log Query. The
OWRD on-line well log query contains well construction information that well drillers are
required to file after a well is installed, and includes location information for most of the
wells drilled in Oregon since 1955 (OWRD, 2008). Water well logs located within the
permittee’s UIC area were downloaded from this database on date (OWRD, XXXX).
Water wells were plotted by address or tax lot to determine if the water wells were within
the Schedule A, Condition 8 setbacks. Water wells without address or tax lot information
could not be located with a sufficient degree of accuracy, and were excluded from the
analysis.

OWRD On-Line Water Right Mapping Tool. The OWRD on-line water right mapping
tool contains location information for water wells that are authorized to withdraw
groundwater under a water right. Well location information for water wells located within
the permittee’s UIC area were downloaded from this database on date (OWRD, YYYY).

OWRD Water Level Data Database. The OWRD water level data database contains
groundwater depth measurement at monitoring wells and water wells throughout the
state of Oregon. Well location information for water wells located within the permittee’s
UIC area were downloaded from this database on date (OWRD, ZZZZ).
The distance between UICs and water wells located using the databases above were
determined by X. UICs that are within water well setbacks are identified in Appendix A.
2.5 UICs Prohibited Under OAR 340-044-0015(2)
OAR 340-044-0015(2) prohibits the following types of UICs:





Residential or nonresidential cesspools designed to serve 20 or more people per day;
UICs that infiltrate fluids from industrial or commercial processes that use hazardous
substances or toxic materials including petroleum products;
UICs that infiltrate fluids from industrial or commercial operation areas where hazardous
substances or toxic materials including petroleum products are stored, used or handled
(e.g., fuel dispensing areas);
UICs that infiltrate fluids from floor pits or floor drains at industrial or commercial
facilities;
UICs that inject motor vehicle waste from repair or maintenance activities;
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

UICs that inject industrial or municipal wastewater directly into an underground source
of drinking water; and
UICs that inject agricultural drainage.
As shown in Appendix A . . .
3 Commercial and Industrial Facilities that Pose a Risk of
Pollutant Discharge to Permittee-Owned UICs
Methods.
Commercial and industrial facilities that pose a risk of pollutant discharge to UICs are identified
in Table 3-1 OR No commercial or industrial facilities pose a risk of pollutant discharge to
permittee owned and operated UICs because X.
Table 3-1
Commercial and Industrial Facilities that Pose a Risk of Pollutant Discharge to UICs
Permittee
Facility
X
X
X
X
X
X
X
Address
X
X
X
X
X
X
X
Impacted UIC
X
X
X
X
X
X
X
4 Procedures for Keeping UIC Inventory Current
The System-Wide Assessment will be maintained using the following methods:




As required by Schedule B, Condition 4.e, any closure, retrofit, or installation of UICs will
be identified in the annual UIC System Report, which is submitted to DEQ in month of
each year.
As required by Schedule B, Condition 4.h, any newly-discovered UIC will be identified in
the annual UIC System Report, which is submitted to DEQ in month of each year.
As required by Schedule B, Condition 1, the System-Wide Assessment will be revised
and submitted to DEQ by the end of the fifth year of the permit term (year).
Permittee will review Oregon Water Resources Department databases (OWRD, XXXX;
OWRD, YYYY; and OWRD ZZZZ) on an annual basis to identify if any new water wells
have been installed within setbacks to UICs.
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References
Permittee’s Stormwater Monitoring Plan
City of Gresham, 2013. WPCF Permit Annual Compliance Report—Permit Year 1. Prepared by:
City of Gresham. Submitted to: Oregon DEQ. December 31.
City of Portland BES, 2006. Annual Stormwater Discharge Monitoring Report—Year 1 (October
2005 – May 2006). Prepared by: City of Portland. Submitted to: Oregon DEQ. July.
City of Portland BES, 2007. Annual Stormwater Discharge Monitoring Report—Year 2 (October
2006 – May 2007). Prepared by: City of Portland. Submitted to: Oregon DEQ, July.
City of Portland BES, 2008a. Annual Stormwater Discharge Monitoring Report—Year 3
(October 2007 – May 2008). Prepared by: City of Portland. Submitted to: Oregon DEQ, July.
City of Portland BES, 2009. Annual Stormwater Discharge Monitoring Report—Year 4 (October
2008 – May 2009). Prepared by: City of Portland. Submitted to: Oregon DEQ, July.
City of Portland BES, 2010. Annual Stormwater Discharge Monitoring Report—Year 5 (October
2009 – May 2010. Prepared by: City of Portland. Submitted to: Oregon DEQ, July.
City of Portland BES, 2011. Annual Stormwater Discharge Monitoring Report—Year 6 (October
2010—May 2011). Prepared by: City of Portland. Submitted to: Oregon DEQ, July.
City of Portland BES, 2012. Annual Stormwater Discharge Monitoring Report—Year 7 (October
2011—May 2012). Prepared by: City of Portland. Submitted to: Oregon DEQ, November.
Kennedy-Jenks, 2009. Compilation and evaluation of existing stormwater quality data from
Oregon, prepared for the Oregon Association of Clean Water Agencies
OWRD, 2008. A Guide to the Well Identification Program. Available online at:
http://www.oregon.gov/owrd/pubs/docs/well_id_guide.pdf
OWRD, XXXX. Oregon Water Resources Department On-Line Well Log Query. Accessed on:
date. Available online at: http://apps.wrd.state.or.us/apps/gw/well_log/
OWRD, YYYY. Oregon Water Resources Department Water Rights Mapping Tool. Accessed
on: date. Available online at: http://apps.wrd.state.or.us/apps/gis/wr/Default.htm.
OWRD, ZZZZ. Oregon Water Resources Department Water Level Data and Hydrographs.
Accessed on: date. Available online at: http://www.oregon.gov/owrd/pages/gw/well_data.aspx
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