~2eiated Litt' roiicies <br />Goal 3 of the Comprehensive Stormwater Management flan (1993) provides the policy <br />framework for addressing NPDES requirements. Most relevant to the "water quality <br />limited" listing of Amazon Creek for arsenic is the following: <br />Policy 3.I - "Meet or exceed federal and state stormwater quality requirements especially <br />where. they conform with existing local policy;" <br />Monitor Water Quality as Required by the City of Eugene's NPDES Permit <br />Although the City of Eugene has performed some water quality monitoring, it has failed <br />to adequately address the parameter of arsenic as required in the current NPDES permit. <br />The Second Annual Report Part 1-Status Report (December 2005),1Vlonitoring Section <br />(page I-126) states: <br />"Program activities for the permit period. primarily consisted of permit <br />compliance monitoring, a site survey for conformance with suspended solids <br />ordinance, surface flow bacteria caharacterizatiori; and source characterization for <br />a fish kill in Amazon Creek." <br />The limited arsenic monitoring data collected by the City was collected in Amazon Creek <br />near 29th Avenue (Appendix 3). This data indicates that Amazon Creek at that point does <br />not meet the water quality standard for arsenic. The data does not indicate source areas <br />upstream of 29th Avenue that are providing the majority of the arsenic loading to the <br />stream. Since the City of Eugene has failed to monitor source areas for this parameter to <br />determine what areas in the. watershed inay be disproportionately adding to the arsenic <br />loading, the City lacks the pertinent information necessary to adequately complete a <br />quantitative or qualitative review of BMP effectiveness in regard to this pollutant. <br />Site. Specific Arsenic Monitoring <br />In an effort to assess the potential for the Green Valley Glen PUD site to be a significant <br />source area of arsenic into Amazon Creek, on October 9, 2006, I collected a soil sample <br />from the. site. On October 16, 2004, I collected a surface water samples from the site. <br />These samples were collected using proper sampling techniques to ensure no <br />contamination of the samples occurred (e.g. obtained clean bottles from laboratory and <br />use of disposable gloves during sampling). These samples where subsequently analyzed . <br />in laboratories for total arsenic. <br />To reduce the number of samples necessary, I collected a composite soil sample by <br />combining approximately equal potions of soils from 3 locations on the PUD site <br />(Appendix <br />