EVALUATING UNPERMITTED ENCROACHMENTS IN LEVEE SYSTEMS

Kevin R. Severson, PE1

Colin Rowan2
Michael R. Meyer, PE3

ABSTRACT

Levee districts participating in the US Army Corps of Engineers (USACE) PL 84-99, the
Rehabilitation and Inspection Program (RIP) are subject to poor inspection ratings for
any unpermitted encroachments in their levee systems. Some of the primary concerns
include an encroachment’s potential for destabilizing embankment, shortening seepage
paths, compromising scour protection, altering interior drainage, impeding flood fighting
equipment, and restricting the ability to visually detect developing issues. This paper
describes the coordinated efforts utilized to evaluate 60 structural encroachments within
the Peninsula Drainage District No. 2 (PEN 2) levee system located along the lower
Columbia River in Portland, Oregon. Following comprehensive investigation and
analysis, the encroachments were ultimately permitted as “Legacy Encroachments” by
USACE Portland District, which helps streamline future RIP inspections.

The PEN 2 District investigation program started with surveying and mapping all of the
60 structural encroachments. Cross-sections taken at each encroachment were then
examined to determine if the encroachments penetrated into the original USACE design
levee section. Select cross-sections were modeled using seepage and slope stability
software. Additional qualitative analyses were performed to evaluate access limitations
posed by the encroachments. The combined analysis results were used to rate each
structural encroachment into low, medium, and high-risk categories. Results were
summarized in a technical report as well as a more accessible report aimed at the public.
Individualized reports were sent to property owners with encroachments. The Project
team also held a community meeting to review findings and answer questions. Staff
submitted the reports with a letter request to USACE for review and determination on the
Legacy Encroachments.

INTRODUCTION

The US Army Corps of Engineers (USACE) Levee Owner’s Manual (LOM) states
“Excavations, structures, or other obstructions present within the project easement area
are generally prohibited” (USACE, 2006). The “project” in this instance refers to the
levee system and is also referred to as a Flood Control Work in USACE documents. The
LOM also states “The Corps may make certain exceptions to this rule, provided the

1
Project Engineer, Cornforth Consultants, Inc. | 10250 SW Greenburg Road, Portland, OR 97223 | 503-
452-1100 | kseverson@cornforthconsultants.com
2
Senior Project Manager, Levee Ready Columbia, Multnomah County Drainage District |1880 NE Elrod
Drive, Portland, OR, 97211 | 503-281-5675 | crowan@mcdd.org
3
Senior Associate Engineer, Cornforth Consultants, Inc. | 10250 SW Greenburg Road, Portland, OR 97223
| 503-452-1100 | mmeyer@cornforthconsultants.com
Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 1
encroachment does not impact the operation, maintenance, or structural integrity of the
project.” The project easement under these guidelines typically consists of the levee
embankment and 10 to 15 feet from the levee toe on either side. These rules presented a
challenge for the Peninsula Drainage District No. 2 (PEN 2) levee district in Portland,
Oregon, where 60 unpermitted structural encroachments were identified within the
restricted footprint. These encroachments were historically rated “unacceptable” in the
USACE’s routine and periodic inspections under the Rehabilitation and Inspection
Program (RIP) PL 84-99.

The purpose of this levee encroachment evaluation was to determine if the unpermitted
structural encroachments impact the operation, maintenance, or structural integrity of the
PEN 2 levee system. In the cases where analyses determined the existing encroachments
did not significantly impact the levee, a request for an encroachment exemption was
submitted to USACE. Ultimately, the granted exemptions would result in the
encroachments being accepted as Legacy Encroachments, which would no longer
negatively impact the PEN 2 levee system’s rating during RIP inspections (Helwig,
2016). An additional goal of the encroachment evaluation was to better inform the public
benefitting from the risk reduction provided by PEN 2 about the levee system, the
concept of levee encroachments, and their responsibility in flood monitoring and the
flood fighting efforts in the PEN 2 district.

Levee System Description

The PEN 2 levee system is located along the lower Columbia River in north Portland and
within Multnomah County, Oregon. The district protects an area of about 1,475 acres;
approximately 1,300 acres are improved, and 20 acres are sloughs and drainage canals.
Ground surface elevations range from 13 to 30 feet (NAVD88). Land use in the district is
divided among commercial, residential, industrial, recreation, and agriculture.
Developments within the district include Columbia Edgewater Golf and Country Club,
Delta Park Sports Complex, Portland Meadows Race Track, Bridges Middle School,
numerous commercial and retail businesses, small industrial buildings, and many
residences. Residential areas make up approximately 35 percent of PEN 2's area and
include single family homes, a mobile home park, a prefabricated home complex, long-
term stay suites, apartments, and condominiums. PEN 2 is bounded to the west by the
Interstate 5 / Denver Avenue embankment, to the east by the Peninsula Drainage Canal
cross-levee, to the north by the Bridgeton Road and N Marine Drive levee, and to the
south by the Columbia Slough levee.

The PEN 2 levee system is approximately 6.5 miles in length. Construction of the
original levee embankments and pumping/drainage facilities was completed from 1917 to
1921 by local interests. From 1939-1940, the USACE improved portions of the system by
reinforcing and raising segments of the levee, placing riprap revetment erosion
protection, constructing nearly 1,000 linear feet of concrete wall, installing culverts and
drain pipes, and constructing a drainage ditch and pump station.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 2

A Vicinity Map of the PEN 2 district is provided in Figure 1. The interior drainage
system consists of the Peninsula Drainage Canal, Leonard Lake drainage ditch, Switzler
Lake east drainage ditch, and smaller ditches, pipes, and channels that drain to two pump
stations. The pump stations combined have a pumping capacity of 80,000 gallons per
minute.

Figure 1. Project Location Map

The majority of the unpermitted structural encroachments are located in the Bridgeton
neighborhood of PEN 2 (shown on Figure 2), which features view homes along the levee
and houseboats on the Columbia River. The crest of the levee through this area serves as
a paved road named NE Bridgeton Road. Within a length of approximately one mile, 29
unpermitted structural encroachments were identified and evaluated. The encroachments
vary from parking structures, docks and gangways, homes, condominiums, and
businesses. These structures were constructed without proper design review and permits
from USACE. Many of the current property owners are not the original developers of
these properties, and most were unaware of their property’s potential impacts on the levee
function before the encroachment evaluation was conducted.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 3

 Figure 2. Bridgeton Neighborhood of Portland, OR

Community / Government Partnership – Levee Ready Columbia

Peninsula Drainage District #2 (PEN 2) is a local levee operator and is one of four
independent, contiguous drainage districts in the Portland metropolitan region that reduce
the risk of flooding to 5,500 residents, 43,000 employees, and many of the region’s key
assets such as the Portland International Airport. Due to new levee certification
requirements and a changing regulatory environment, USACE expired the levee
certifications four years early for PEN 2 and Peninsula Drainage District #1, located
immediately to the west of PEN 2. These early expirations were in response to the
heightened flood risk in the two districts identified by USACE, the federal agency that
previously certified the levees.

The expiration of the certifications, the divided responsibility of certification,

accreditation, capital funding, and land use oversight; and the recognized regional
importance of the levee system brought together a partnership of local and regional
governments, the State of Oregon, as well as community groups. From inception to the
present, the partnership has grown to include the Cities of Portland, Gresham, Fairview,
and Troutdale; Multnomah County; Metro regional government, the Port of Portland, the
State of Oregon, and a strong coalition of business, neighborhood, environmental, and
other groups. This group, now known as Levee Ready Columbia (LRC), is working to
ensure that the levee system along the Columbia River in the Portland Metropolitan
region, from Sauvie Island to the Sandy River, meets the requirements for participation in
federal programs and continues to reduce the risk of flooding for important regional
assets. In so doing, LRC will help provide a safe and stable future for the residential,
commercial, industrial, ecological, and recreational land-uses now present in the area.

While the initial impetus of the LRC partnership was to re-certify and maintain
accreditation, an expanded scope was identified as necessary to understand risks and
opportunities of the project work. The work plan for LRC expanded beyond the
engineering assessments of the levees to also include: comprehensive economic,
environmental, and community asset inventories of the leveed land; a climate change
study modeling future river conditions; a comprehensive Hazus-MH user defined risk
assessment at the building level; a governance study to modernize oversight, planning,
and capital funding of the levee system, and a risk-informed decision-making framework
to identify and select project alternatives and investments.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 4

From the outset of this project to today, the PEN 2 levee system maintains active status in
the RIP and the levees are accredited under the Federal Emergency Management
Agency’s (FEMA) National Flood Insurance Program (NFIP). Active status in PL 84-99
means that PEN 2 works with USACE to maintain and operate the levee system to
federal standards, identifying areas that require maintenance or capital investments
through annual Routine Inspections and quinquennial Periodic Inspections. These
inspections provide PEN 2 with a detailed summary of maintenance, operations, and
capital needs. The relationship between USACE and the local sponsor is vital. USACE
provides oversight to assure the local sponsor maintain the federal investment to a high
standard; in exchange, the local sponsor receives in-depth assessments of their systems,
assistance in response activities during high water events, and rehabilitation assistance if
an eligible flood risk reduction system is damaged by a flood event.

Levee accreditation under FEMA’s NFIP means that the levees are certified by a
Professional Engineer, or a federal agency that designs levees, that the system follows
requirements outlined in Section 65.10 of Title 44, Emergency Management and
Assistance in the Code of Federal Regulation (44 CFR 65.10). Certification means that
the levee meets federal design, construction, maintenance, and operation standards to
adequately reduce the risk of flooding from at least a 1% annual chance flood. If the local
sponsor can provide evidence that the levee meets these standards, FEMA will accredit
the levee, recognizing the levee on flood maps and mapping the land behind the levees as
moderate risk zones (shaded Zone X) on maps rather than as special flood hazard areas.
Accreditation allows jurisdictions to develop land behind levees, limits the flood
insurance required by property owners, and avails property owners to discounted
voluntary flood insurance. Levee systems that do not maintain active status in the RIP are
unlikely to be considered for accreditation.

Focus on Encroachments

Understanding the importance to people living behind the levees and to the regional
economy, the two principal goals of the LRC partnership are to maintain active status in
USACE’s RIP and to remain accredited under FEMA’s NFIP. As the LRC partnership
began to identify the extent of work necessary for levee re-certification to maintain
accreditation under the NFIP, the group consulted with FEMA to develop a scope of
work for the re-certification. Beyond the geotechnical assessment of the levee, freeboard
analysis, and hydrology and hydraulics (H&H) investigation, FEMA identified a need to
assess the risk to the levee posed by structural encroachments built into the levee in PEN
2. Encroachments are defined as elements built or growing in or on the levee (pipes, sign
poles, trees, sheds, houses, roads, etc.). These are natural or man-made obstructions or
physical intrusions into the levee. These obstructions or intrusions increase the risk of
damage to the levee during high water events and intensify the risk to areas for which the
levees were designed to protect.

These structural encroachments were areas of concern identified by USACE during RIP
inspections; resulting in recurring unacceptable ratings for each structural encroachment.
As the regulatory agency responsible for oversight of the levee’s operation and
Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 5
maintenance activities, USACE also requested a specialized analysis of these
encroachments. The focus of the analysis centered on: (i) the potential impact of the
structural encroachment on the levee with regard to slope stability, seepage and scour
protection; (ii) risks posed by the encroachments on impeding the access of flood fighting
equipment; and (iii) the potential for the encroachments to prevent early visual detection
of stability, seepage and scour problems. The flood level modeled in these evaluations
was the USACE’s authorized design surface water elevation that served as the basis for
the original levee design (roughly a 470-year return period flood).

Under this direction, the Encroachment Study in PEN 2 was identified and prioritized. It
was the charge of the LRC partnership to assess the risk posed by the encroachments and
project staff worked closely with USACE Portland District Levee Safety Program staff to
develop a methodology to adequately investigate and assess the risk. This evaluation was
focused on structural building encroachments and did not evaluate vegetation, fences,
poles, or utilities. In summary, the methodology included the identification and
cataloging of the encroachments, survey of the building corners and lowest floor
elevations, analyzing and determining the factor of safety of the encroachments in a
modeling environment, and qualitatively assessing flood risk. An important component
throughout the work was the communication of risk and risk reduction measures with the
community. Community outreach and engagement was vital to the project because the
community was concerned that regulations would require them to remove the
encroachments, calling to mind the potential bulldozing of houses or costly remediation.
While the LRC Project Team was not able to assure positive results of the study for
property owners, they were able to assuage fears and ensure that this was the best course
of action for the community at large. Community engagement was woven into the project
from the survey notices to a public open house held for the community after the project to
mailing results that included individualized risk reduction methods directly to property
owners.

LEVEE MANAGER RESPONSIBILITIES

As the local sponsor of the federally-authorized levee system, PEN 2 is responsible for
the ongoing operation and maintenance of the flood damage reduction infrastructure that
includes levees, floodwalls, relief wells, toe drain systems, and two pump stations that
pump water out of the district. PEN 2 does not have staff, but a Board of Directors
develops and adopts annual budgets and meets monthly to direct the ongoing operations
of the district. Through an intergovernmental agreement, PEN 2 contracts with
Multnomah County Drainage District (MCDD) to perform daily maintenance and
operations, perform all administrative and contracting activities, and provide engineering,
planning, and policy support for the district. PEN 2 is also an active partner in the LRC
partnership with Board members participating in the policy, administrative, and technical
oversight of the program and the district contributes to the funding of the LRC program.
In the Encroachment Study, PEN 2—through LRC program staff—was responsible for
the coordination efforts with the community, the LRC partnership, and the federal
partners.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 6

Coordination with Property Owners – Survey

MCDD’s Project staff, on behalf of PEN 2 and the LRC project, were responsible for
contracting and managing the survey of the ground elevations of the levee and corner
elevations of structures. A professional land surveying crew documented all structures
(residential, commercial, and industrial) on or adjacent to the levee. Most of the
structures were surveyed from the building exterior, with lowest floors estimated by the
surveyors based on available data. In several instances, interior surveys were performed
to increase accuracy. Cross-sections and plan views were developed by drafters for each
of the 60 encroachments. These documents were delivered to Cornforth Consultants, Inc.
(CCI) for the engineering analyses.
Project staff facilitated the survey effort in a variety of ways: articles were posted on
MCDD’s website and in MCDD’s newsletter distributed to land owners; staff presented
at neighborhood gatherings and communicated with community leaders; all owners and
residents of the identified encroachments received a mailing seeking permission for site
access that included project information; staff posted notice of survey access at each
residence and business in the area of the survey; staff called and emailed all property
owners seeking permission and survey timing preference; and staff directly contacted
residents and business, if needed, to gain permission.

Coordination with Federal Partners

A driving objective of the LRC program is to turn regulation into collaboration. This
means building long-term and collaborative relationships with federal agencies. The
Encroachment Study in PEN 2 was both a result of the collaborative relationship and a
building block to strengthening the relationship. The Encroachment Study was one
component of a comprehensive program to modernize the levees and maintain
accreditation. Throughout the project, staff closely coordinated with USACE Portland
District Levee Safety Program staff.

Project staff were responsible for the coordination of the project with USACE and
FEMA. Project Staff and CCI developed a methodology based on the geotechnical
evaluations performed on the levees. USACE Portland District Levee Safety Program
staff reviewed and strengthened the methodology. Comments provided by USACE
allowed CCI to develop an analysis that was adequately conservative to assess the risk
posed by the encroachments to the function of the levee. After the initial surveys and
selection of analysis sections, USACE reviewed the locations selected for more rigorous
modeling assessment. During this review and subsequent meeting, USACE staff
requested additional analysis segments for review. After CCI completed the modeling
assessments, results were reviewed and comments provided by USACE staff before
technical reports were drafted and finalized. This close coordination continued through
the public presentation of the results at a community open house as USACE staff
presented on the regulatory oversight and objectives of the Levee Safety Program.

Based on the findings, presented below, MCDD’s Project Staff wrote a letter to USACE
Levee Safety Program for review of the findings. This letter included the request to find
Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 7
the studied encroachments to be “Legacy Encroachments,” meaning they would no
longer trigger unacceptable rating during Routine and Periodic Inspections by USACE.
USACE reviewed the risk analysis and findings of the Encroachment Study and issued a
letter finding the analysis to be acceptable, meaning that the encroachments would not be
considered unacceptable in future RIP Inspections. The USACE letter emphasized the
importance of PEN 2 and property owners to follow the recommendations outlined in the
analysis about flood risk reduction measures, specifically monitoring items that were
found to be medium risk in the evaluation.

Coordination with the Levee Ready Columbia Project Team

MCDD’s Project Staff were responsible for continuous communication and coordination
with the LRC Project Partners. The Project Partners are the representatives from the
various entities participating in the program. This included receiving direction on
communication and outreach from the LRC Communication Subcommittee, obtaining
review and recommendations on methodology and results from the LRC Technical
Advisory Subcommittee, and providing routine updates to the LRC Administrative
Subcommittee and the Project Partners responsible for the overall oversight of the LRC
program.

Coordination with Property Owners – Post-Study

The results of the Encroachment Study were delivered to LRC Staff as technical reports.
These technical reports provided a detailed assessment of each property, providing
factors of safety for each modeled segment, qualitative risk scores, and individualized
recommendations for risk reduction measures for each property. Staff interpreted these
findings into a public-facing report that summarized the findings. These findings included
information about general flood risk, risk reduction measures, and the regulatory
oversight of the levees. For each of the addresses analyzed in the Encroachment Study,
LRC Staff created a report that included a summary of findings, qualitative risk score
(with ordinal ratings of low, medium, high), and individualized risk reduction measures
to assist MCDD and USACE with flood monitoring and response. These reports were
directly mailed to the property owners with individualized flood risk reduction measures
and recommendations for each property.

At a public meeting, LRC Staff, CCI, USACE, and others presented the findings to the
community and answered questions. A positive and lively conversation took place, all to
increase the public’s awareness of the risk posed by encroachments and to inform the
public about flood risk living behind levees.

At a separate public meeting during the annual land owners’ meeting for PEN 2,
MCDD’s Project Staff updated the community regarding the outcome of the study, the
result of the letter request, and about ongoing flood risk reduction measures and
development oversight.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 8

 ENCROACHMENT EVALUATIONS

Geotechnical Investigations & Laboratory Testing

Through the course of the levee accreditation process, a geotechnical exploration

program was conducted in 2014 that consisted of 74 exploratory borings in the PEN 2
levee district. The exploration program was reviewed and approved by USACE Portland
District staff before the work began. The borings were patterned to generate cross-
sections, with three borings performed along each section at the riverward toe, levee
crest, and landward toe. The levee embankments were drilled using a hollow-stem auger
to reduce potential for hydrofracturing the levee fill from pressurized drilling mud. Mud-
rotary drilling techniques were used when drilling in native soils below the levee
embankment when necessary to limit heave into the boring. None of the borings were
instrumented and all borings were backfilled with a bentonite-grout mixture immediately
after drilling.

The representative geotechnical exploration cross-sections were spaced between 600 and
1,400 feet apart along the levee alignment, one within each levee reach. An average
boring spacing of approximately 1,000 feet along the levee alignment was maintained in
accordance with USACE recommendations for evaluating levees segments (USACE,
2005). A total of 19 Falling head tests were performed in 14 borings to determine the in-
situ hydraulic conductivity parameters using Hvorslev’s method (Hvorslev, 1951). An
extensive laboratory testing program consisting of moisture contents, Atterberg limits,
unit weights, direct shear, and triaxial testing was also conducted on the disturbed and
undisturbed soil samples taken during drilling. The lab testing program helped verify
field stratigraphy interpretations as well as provide the necessary soil strength parameters
for stability modeling of the levee embankment and foundation soils.

Assessment of Potential Failure Modes

As previously described, MCDD provided cross-sections for 60 structural encroachments

around the PEN 2 levee perimeter. Each of these cross-sections were reviewed to check
for conditions that might present a potential failure mode (e.g. piping or slope instability).
Key situations of concern included locations where structures had been embedded
relatively deep in the levee embankment. This type of occurrence can negatively impact
the structural integrity of the levee by: (1) shortening the seepage path across the
embankment, and thereby raising the risk of internal erosion (or, “piping”); and (2)
causing slope stability problems by either loading the crest or unloading the toe of the
levee embankment.

Following a detailed review of the cross-sections, CCI (with USACE concurrence)

selected 13 encroachment sections for seepage and stability analyses. The remaining 47
encroachments were judged to be much lower risk because they occur in locations where
the levee is exceptionally wide and/or has an elevated ground surface on the landward
side, which results in flatter slopes and low seepage potential. The 13 selected sections

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 9

featured either buildings with basements set deeper into the levee, or steeper riverward
and landward slopes.

Seepage and Stability Modeling

The stratigraphy interpreted from the exploratory borings was combined with the
encroachment survey to generate cross sections in geotechnical modeling software to
analyze seepage and stability under the USACE authorized Design Water Surface
Elevation (DWSE). The encroachment cross-sections selected for modeling were
assigned the in-situ and laboratory derived soil parameters. The soil parameters used in
the seepage and stability analyses are shown on Table 1.

Table 1. Seepage and Stability Modeling Parameters

Soil Type Unit Hydraulic Angle of Cohesion Flow
Weight Conductivity Internal [c, psf] Aniostropy
[γ, pcf] [k, ft/sec] Friction [ky/kx]
[ϕ,°]
Alluvium – Clayey Silt
110 1.45x10-5 32 0 0.25
& Silty Clay
Alluvium – Silty Sand
113 2.37x10-5 33 0 0.25
and Sandy Silt
0
Building Interface N/A N/A N/A N/A
(impermeable)
Fill – Clayey Silt 112 6.72x10-5 31 0 0.25
Fill – Silty Sand and
108 8.29x10-5 33 0 0.25
Sandy Silt
Foundation Base Rock 140 1.0 (free flow) 35 0 1

Analyses were performed using two products within the GeoStudio software suite.
SEEP/W was used to perform two-dimensional, steady-state seepage analyses using the
USACE authorized DWSE. Seepage mesh elements were set to 2-foot by 2-foot, and exit
gradients were averaged over two adjacent mesh nodes in accordance with the software
recommendations. A cross-section used for seepage modeling is shown on Figure 3.
Landward groundwater table levels were assumed to be at the landward side ground
surface.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 10

 Figure 3. Seepage Model of Levee Section

Seepage models were used as the parent analysis to establish the groundwater conditions
for the stability analyses. SLOPE/W was used to perform limit equilibrium stability
analyses using the Morgenstern-Price method (Morgenstern, 1965), satisfying moment
and force equilibrium. The riverward and landward slopes of the levees were analyzed for
slope stability failures impacting the design levee section. A building dead load surcharge
of 230 psf was applied within the stability models to approximate the stress applied by
the one to two-story homes and small commercial buildings. Shallow (or surficial) failure
surfaces that did not significantly impact the original design levee cross-section, were not
selected for the reported values. A cross-section used for stability modeling, with a
riverward slope failure analysis, is shown on Figure 4.

Figure 4. Stability Model of Levee Section

Findings. Seepage modeling indicated maximum hydraulic exit gradients ranging from
0.06 to 0.44, which were all below USACE’s maximum allowable gradient of 0.50
(USACE, 2000). Stability analyses of the landward and riverward design levee sections
indicated factors of safety (FS) greater than USACE’s minimum requirement of 1.40
(USACE, 2000) in all but one section. A section in the Bridgeton neighborhood had a
riverward slope FS of 1.30, under the USACE authorized DWSE. In subsequent
discussions with USACE staff, the consensus was reached that the appropriate measure
for this section along the levee would be to highlight the location in the Operations and
Maintenance Manual for increased monitoring during actual floods. Some of the items

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 11

considered by the project team were that the actual boring locations used to create the
stratigraphy on the section were within 200 feet of the section, providing more reliable
site-specific soil data, and the calculated FS of 1.30 indicates the levee’s resisting forces
are still 30 percent higher than the driving forces under the authorized DSWE conditions.

Encroachment Impact Assessment

After assessing potential failure modes and modeling seepage and stability, the following
task was to perform a qualitative assessment of the potential impacts that structural
encroachments may have on levee inspections, monitoring, and flood fighting efforts.
The approach taken included an evaluation of the types of encroachments, with
consideration toward the potential for the encroachments to impair access to the levee
and conceal evidence of developing seepage, stability, settlement, or erosion/scour
problems.

The encroachments were tabulated to create a more accessible encroachment inventory.

The detailed table included the cross-section number, levee Station and address of the
encroachment, a brief description of the encroachment type, check boxes noting the
conditions on the riverward and landward sides of the levee at that location,
representative borings that have been performed in the near vicinity (generally within
about 300 feet), a brief description of surficial subsurface conditions, notes on levee
inspection, monitoring, and flood fighting notes specific to the encroachment.

During the process of reviewing the flood fighting characteristics at the encroachment
locations, several locations along the levee were noted as “potential staging areas” for
flood fighting materials such as sandbags and heavy equipment. These areas were
typically found along the landward side of the levee system with large open areas that
were easily accessible from the levee crest and nearby major roads.

Findings. In general, the key encroachment impacts involved structures that could impede
flood fighting equipment or obscure the ground surface and limit early seep and scour
detection.

Qualitative Risk Assessment

After evaluating the encroachment impacts, the next task was to assign a qualitative level
of risk for each structural encroachment and to provide justification for the assigned risk
based on the risk the structure poses to levee integrity. The qualitative risk levels were
categorized into ratings of Low, Medium, and High. The justification for these ratings
stem primarily from the seepage and stability analyses in combination with the
encroachment impacts on levee inspection, monitoring, and flood fighting characteristics.
The qualitative risk definitions are provided below:

Low. Seepage and stability analyses meet USACE standards, and/or encroachment does
not appear to significantly impact levee performance, inspection, or flood fighting
capabilities.
Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 12
Medium. Seepage and stability analyses generally meet USACE standards (hydraulic
gradients lower than 0.5 and slope stability FS greater than 1.4). Minor exceptions for
sections expected to perform well during flooding, but not quite meeting USACE
standards are included. Structural encroachments could potentially hinder riverward or
landward inspection and flood fighting efforts.

High. Levee section does not meet USACE seepage and stability standards, and / or the
encroachment presents a clear concern for seepage or stability issues during flooding.
The encroachment may also severely hinder or prevent levee inspection and access
during flood fighting efforts. (No structural encroachment sections were categorized in
the High risk category.)

The majority of the PEN 2 levee structural encroachments were concluded to be in the
Low risk category due to the satisfactory results of the seepage and stability analyses
(i.e., results met or exceeded USACE standards), and relatively minor concerns regarding
inspection and flood fighting. Only 8 of the 60 structural encroachments (all located
along NE Bridgeton Road) were rated Medium risk, and these were primarily buildings
that could impair inspection and flood fighting efforts. A vicinity map with the Medium
risk locations (shown in yellow) and the potential flood fighting staging areas (shown in
green) was provided as a quick reference during flood fighting efforts. This map is shown
on Figure 5.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 13

 Figure 5. Vicinity Map Identifying Medium Risk Sections and Potential Flood Fighting
Staging Areas

Risk Reduction Measures

The final step of the evaluation involved site-specific identification of risk reduction
measures and recommended engineering actions for sections categorized as Medium or
High risk. The 2015 International Levee Handbook (CIRIA, 2015) provides guidance for
levee flood risk management and lists levee inspection frequency and hazard
communication as potential methods to reduce levee failure risks. The primary risk
reduction measure recommended for all Medium risk locations was increasing the
inspection frequency of the levee and surrounding foundation soils before, during, and
after flooding. An additional risk reduction measure was communicating potential risks to
homeowners, educating them about signs of levee failure (e.g. piping, sand boils, slope
failure, structural settlement), and providing these homeowners with current contact
information for reporting observations. The project team did not believe the risks posed
by the Medium risk encroachments at these sections were significant enough to merit
structure demolition, levee slope regrading, or vegetation removal.

To simplify inspection efforts during flood fighting, the Medium risk sections were
grouped into larger station ranges requiring additional inspection efforts. The grouping
also helps communicate areas of higher concern to homeowners and the general public.
Apart from the increased inspection frequency recommended in the PEN 2 Operations
and Maintenance Manual, specific risk reduction language for each group was provided
in the final engineering analysis report. A sample of that language is provided below:

“This section of the PEN 2 levee contains three private residences located on the
riverward levee section with condominiums along the landward levee section. The crest
and landward sections of the levee are paved or covered by structures. Access to the
riverward and landward levee section is impaired around the homes. Additionally,
seepage issues will be more difficult to detect visually due to the structures and paved
areas on the landward side. Inspections should place additional emphasis on pavement
deformation and the visible areas of exposed soil. Homeowners should be encouraged to
report any observed seepage or settlement around the properties.”

CONCLUSION

A total of 60 structural encroachments located along the PEN 2 levee system, located in
Portland, Oregon, were evaluated through a process requiring coordination with multiple
project partners including Federal, State, and local governments as well as community
outreach. Early involvement and continued coordination with USACE provided excellent
project guidance and technical review throughout project completion. A comprehensive
geotechnical field investigation program, conducted following USACE guidance, and an
extensive laboratory testing program supplemented the seepage and stability modeling of
representative structural encroachments. Meetings with land owners communicated the
presence of the levee encroachments, risks, and reporting methods to supplement flood
Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 14
fighting. USACE reviewed the encroachment evaluations performed and accepted the
existing structural encroachments as “Legacy Encroachments,” which no longer
negatively affect the PEN 2 levee system during future RIP inspections.

ACKNOWLEDGEMENTS

We would like to take this opportunity to thank Lance Helwig, P.E., Chief of Engineering
& Construction Division, USACE Portland District, and Jeremy Britton, P.E., Resident
Technical Specialist, USACE Portland District, for their valuable contributions and
technical review efforts throughout the encroachment evaluation process.

REFERENCES

Construction Industry Research and Information Association (CIRIA) (2015). The

International Levee Handbook. Levee Inspection, Assessment, and Risk Attribution. Ch.
5.

Helwig, L.A. (2016, December 13). Legacy Encroachment Analysis, Review, and risk
Reduction Measures [Memorandum]. Portland, OR: U.S. Army Corps of Engineers.

Hvorslev, M.J. (1951). U.S. Army Corps of Engineers. Time Lag and Soil Permeability
in Ground-Water Observations. Bulletin No. 36. Waterways Experiment Station,
Vicksburg, Mississippi.

Identification and Mapping of Special Hazard Areas, 44 C.F.R. pt. 65.10 (1986).

Flood Control Act (1950) Public Law 81-516 Title II. Section 204.

Morgenstern, N.R. and Price, V.E. (1965). The Analysis of the Stability of General Slip
Surfaces. Geotechnique, Vol. 15, No. 1.

U.S. Army Corps of Engineers (2000). Engineering and Design. Design and Construction
of Levees. Engineer Manual 1110-2-1913.

U.S. Army Corps of Engineers (2005). Engineering and Design. Design Guidance for
Levee Underseepage. Technical Letter 1110-2-569.

U.S. Army Corps of Engineers (2006). Levee Owner’s Manual for Non-Federal Flood
Control Works. The Rehabilitation and Inspection Program. Public Law 84-99.

Copyright © 2018 U.S. Society on Dams. All Rights Reserved. 15