Document Kalispell_doc_f176c1e2ca

Permit Years: 2017-2021 Updated: 3/1/2021 STORMWATER MANAGEMENT PROGRAM Permit Number: MTR040005 201 1st Ave E Kalispell, MT 59937 City of Kalispell ---PAGE BREAK--- Contents 1 Purpose of Program 1 2 Description of Permit Area 1 3 Summary of Stormwater Regulations and Program 3 3.1 Effluent Limits 3 3.2 Stormwater Management Program (SWMP) Requirements 4 3.3 Training 4 3.4 Special Conditions 5 3.4.1 Impaired Waterbodies Pre-TMDL 5 3.4.2 Impaired Waterbodies with Approved TMDL Wasteload Allocations (WLAs) 5 3.5 Monitoring and Reporting 5 4 Program Performance 6 4.1 Capital Improvement Plan and Infrastrcuture Imprvements Overview 6 4.2 Performance Measures 8 4.2.1 Annual Pollutant Reduction Totals 8 4.2.2 Annual Performance Summary 9 4.3 Infrastructure Information 12 5 Minimum Control Measure Management Program 14 5.1 Public Education and Outreach & Involvement and Participation 15 5.1.1 Permit Requirements 15 5.1.2 Performance Tracking of Completed and Ongoing Initiatives 16 5.1.3 Planned Initiatives 22 5.2 Illicit Discharge Detection and Eliminations 25 5.2.1 Permit Requirements 25 5.2.2 Performance Tracking of Completed and Ongoing Initiatives 26 5.2.3 Planned Initiatives 28 5.3 Construction Site Stormwater Management 32 5.3.1 Permit Requirements 32 5.3.2 Performance Tracking of Completed and Ongoing Initiatives 33 5.3.3 Planned Initiatives 35 5.4 Post-Construction Site Stormwater Management in New Development and Redevelopment . 37 5.4.1 Permit Requirements 37 5.4.2 Performance Tracking of Completed and Ongoing Initiatives 38 ---PAGE BREAK--- 5.4.3 Planned Initiatives 40 5.5 Pollution Prevention/Good Housekeeping for Permittee Operations 44 5.5.1 Permit Requirements 44 5.5.2 Performance Tracking of Completed and Ongoing Initiatives 45 5.5.3 Planned Initiatives 48 6 Training 51 6.1 Stormwater Management Team 51 6.1.1 Frequency 51 6.2 Field Management-IDDE 51 6.2.1 Frequency 51 6.3 Construction Site Stormwater Management 51 6.3.1 Frequency 51 6.4 Post-Construction Stormwater Management 51 6.4.1 Frequency 52 6.5 Field Management-PPGH 52 6.5.1 Frequency 52 6.6 Municipal Employee Awareness 52 6.6.1 Frequency 52 7 Stormwater Management for Discharges to Impaired Waterbodies 52 7.1 Nutrients-Total Phosphorus (TP) and Total Nitrogen 53 7.1.1 Nutrient Target BMPs to Reduce Pollutant Loads 54 7.2 Dissolved Oxygen 55 7.2.1 Dissolved Oxygen Target BMPs to Reduce Pollutant Loads 55 7.3 Sediment 55 7.3.1 Sediment Target BMPs to Reduce Pollutant Loads 55 7.4 Temperature 57 7.4.1 Temperature Target BMPs to Reduce Pollutant Loads 57 8 TMDL Action Plan 57 9 Self-Monitoring 58 10 SWMP Management Team, Responsibilities, and Communications 59 10.1 SWMP Management Team 59 10.2 SWMP Management Team Communication 61 ---PAGE BREAK--- Appendix A: Drainage Basin Summary 62 Appendix B: Kalispell MS4 Map 68 Appendix C: Illicit Discharge Detection and Elimination (IDDE) Program 71 Appendix D: Ordinance 1831 112 Appendix E: Kalispell Municipal Pollution Prevention and Good Housekeeping Manual 141 Appendix F: Stormwater TMDL Action & Sampling Plan 243 Appendix G: 2020 Sample Results 301 ---PAGE BREAK--- 1 Purpose of Program Stormwater management is increasingly important for the purpose of maintaining clean water and preserving waterbodies such as streams, rivers, and lakes. A General Permit for Stormwater Discharge Associated with Small Municipal Separate Storm Sewer System (MS4) or “MS4 General Permit” was approved for the City of Kalispell in July of 2006 and subsequent re-approvals in 2009 and 2015. The MS4 General Permit provides authorization to discharge stormwater to waters of the state under the Montana Pollutant Discharge Elimination System (MPDES). The MS4 General Permit requires the City to develop, document, and maintain a Stormwater Management Program (SWMP), which includes management practices, control techniques, systems, designs, good standard engineering practices, and such other provisions necessary to reduce the discharge of pollutants from the permitted Small MS4 to the Maximum Extent Practicable (MEP). The objective of this Stormwater Management Program (SWMP) is to develop and effectively manage a stormwater program inclusive of the minimum control measures and reduce pollutant contribution from the City’s MS4 to waterbodies. This program was developed to meet state and federal program requirements, but also utilize current SWMP activities, address issues that are important to the community, and establish programs that are economically feasible. 2 Description of Permit Area The City of Kalispell’s permitted area is bound by its City limits. The City limits through 2019 encompass 12.66 square miles. The permitted area includes 112 drainage basins of which seventy-eight outfall to perennial surface waters (Figure The storm system is separated from the sewer system, with storm drains discharging into local streams and rivers (Figure Within the permitted area, the City and Montana Department of Transportation (MDT) operate and maintain multiple separate storm sewer systems. The City and MDT are no longer co-permittees but utilize some of the same outfalls throughout the City limits. In Kalispell, the following waterbodies flow through City limits or receive stormwater discharges from the City’s MS4: • Ashley Creek • Bowser / Little Spring Creek (Unnamed tributary to Spring Creek – aka Kids Creek) • Dry Bridge Slough • Spring Creek • Stillwater River • Stillwater Slough / Muskrat Slough • Whitefish River • An unnamed perennial surface water tributary to Ashley Creek from Foys Lake 1 of 334 ---PAGE BREAK--- Figure 1. Map of Kalispell’s 2020 MS4 system 2 of 334 ---PAGE BREAK--- Figure 2. Overview of separated storm and sewer systems. Taken from www.seattle.gov. 3 Summary of Stormwater Regulations and Program Requirements The Montana Pollutant Discharge Elimination System (MPDES) General Permit MTR040000 is a fourth- generation General Permit for stormwater discharges associated with Small Municipal Separate Storm Sewer Systems (MS4s). Regulated Small MS4s are required to apply for and obtain authorization for the discharge of stormwater into state waters per requirements of the MS4 General Permit. To maintain permit coverage, permittees are required to adhere to all permit requirements and are responsible for: • Maintaining Effluent Limits • Stormwater Management Program Development/Implementation • Training Development/Implementation • Special Conditions for Impaired Waters • Monitoring, Recoding, and Reporting 3.1 Effluent Limits The following conditions apply to all Small MS4s covered under the MS4 General Permit. There must be no discharge of pollutants via stormwater runoff to state waters except as provided below: • Implementation of Best Management Practices (BMPs) consistent with the provisions of the Stormwater Management Program (SWMP) and the requirements in the MS4 General Permit shall constitute compliance with the requirement of reducing pollutants to the maximum extent practicable (MEP). • Discharges of stormwater containing pollutants associated with Small MS4s covered under the MS4 General Permit will be controlled through the development, implementation, and enforcement of an SWMP designed to reduce the discharge of pollutants from the permitted Small MS4 to the MEP, to protect water quality, and to satisfy the appropriate water quality requirements of the Montana Water Quality Act (MWQA). • For regulated Small MS4s which have been designated through ARM 17.30.1102(23) and had initial authorization under the preceding January 1, 2005 to December 31, 2009 General Permit for Stormwater Discharge Associated with Small Municipal Separate Storm Sewer System, the 3 of 334 ---PAGE BREAK--- permittee was required to develop, implement, and enforce a SWMP, as stated in Part II of the 2005 MS4 General Permit, no later than the December 31, 2009 expiration date. This requirement is still valid and binding under this reissued January 1, 2017 to December 31, 2021 MS4 General Permit for Stormwater Discharge Associated with Small Municipal Separate Storm Sewer System (MS4), although for the new inclusions or revisions to the SWMP as stated in the reissued 2017 MS4 General Permit, the permittee must develop, implement, and enforce those additional or revised components as per the implementation timeframe specified. 3.2 Stormwater Management Program (SWMP) Requirements The MS4 General Permit requires permittees to develop, document, and maintain an SWMP which includes best management practices, control techniques, systems, designs, good standard engineering practices, and such other provisions necessary to reduce the discharge of pollutants from the permitted Small MS4 to the MEP. The SWMP describes required Best Management Practices (BMPs) and implementation schedules for each BMP. DEQ requires that BMPs are selected, designed, installed, implemented, inspected, and maintained (or replaced based on inspections) in accordance with good engineering, hydrologic, and pollution control practices. The SWMP must include and the permittee shall effectively manage a program inclusive of the following six minimum control measures: 1. Public Education and Outreach on Stormwater Impact 2. Public Involvement / Participation 3. Illicit Discharge Detection and Elimination (IDDE) 4. Construction Sites Stormwater Runoff Control 5. Post-Construction Stormwater Management for New Development and Redevelopment 6. Pollution Prevention/Good Housekeeping for Municipal Operations All permittees must develop a stormwater management team, including a primary SWMP Coordinator, and organizational chart which identifies the position responsible for implementing each minimum measure. Any updates to this information shall be submitted with Annual Reports. During the entire permit term, all permittees must establish, document, and execute formalized mechanisms for regular communication between stormwater management team members to allow for the exchange of information and submittal of information necessary for permit compliance tracking and reporting. The City of Kalispell’s 2015-2016 SWMP was used and improved upon to meet the new permit requirements. The SWMP is further described in section 5. 3.3 Training The permittee is required to conduct and/or coordinate the following training and track/document all municipal staff participating in the following areas: 1. Stormwater Management Team permit education and implementation responsibilities. 2. Stormwater awareness for City field staff specifically addressing stormwater impacts, the permit, detection and elimination of illicit discharges, and BMPs to minimize the discharge of pollutants during City activities or operations. 3. Inspector and plan review staff responsible for construction site stormwater management. 4 of 334 ---PAGE BREAK--- 4. Inspector and plan review staff responsible for post-construction stormwater management in new development and redevelopment. 5. Staff responsible for implementation of Standard Operating Procedures (SOPs) developed as a requirement of the Pollution Prevention/Good Housekeeping Minimum Measures. Training is further outlined in section 6. 3.4 Special Conditions 3.4.1 Impaired Waterbodies Pre-TMDL The permittee's Stormwater Management Plan (SWMP) must identify all outfalls that discharge to impaired waterbodies, the impaired waterbodies, and the associated pollutant(s) of impairment. Additionally, the permittee’s SWMP must include a section that describes BMPs that target and reduce discharges of the identified pollutant(s) of impairment to impaired waterbodies without an approved pollutant Total Maximum Daily Load (TMDL). The permittee’s Annual Report must contain a summary of BMPs implemented over the reporting period and a schedule of BMPs planned for the following year. Currently, there are no Pre TMDL Impaired Waterbodies receiving City stormwater discharges. 3.4.2 Impaired Waterbodies with Approved TMDL Wasteload Allocations (WLAs) The permittee’s SWMP must identify all outfalls that discharge to impaired waterbodies with an approved TMDL WLAs, the impaired waterbodies, and the associated pollutant(s) of impairment. This information will be submitted with each Annual Report. The permittee must include in its SWMP a section identifying the measures and BMPs it plans to implement, describing the MS4’s impairment priorities and long-term strategy, and outlining interim milestones a schedule for action items) for controlling the discharge of the pollutants of concern and making progress towards meeting the TMDL. The permittee must supplement the Self-Monitoring Requirements in Part IV of the MS4 General Permit with additional monitoring targeted at further evaluating MS4 loading to impaired waterbodies (Option 1) or at evaluating the effectiveness of BMPs selected for reducing MS4 loading to impaired waterbodies (Option The TMDL section of the SWMP must be submitted in the 4th Year Annual Report for MDEQ approval, and begin to be implemented no later than the beginning of the 5th permit year. 3.5 Monitoring and Reporting All permittees are required to perform sampling, testing, and reporting of stormwater discharges from their Small MS4s under this MS4 General Permit, or as otherwise required by the department. Permittees are required to choose one of two monitoring options and submit their selected option to the department with their application for MS4 General Permit coverage. Sampling, testing, and reporting must be conducted at least semi-annually (two times per year) for each of the parameters listed in the MS4 General Permit. Monitoring results shall be used by permittees to self-evaluate measures taken to improve the quality of stormwater discharges. An Annual Report is required to be prepared and submitted by the permittee to the department for each calendar year within the MS4 General Permit term by March 1st. The Annual Report is a descriptive 5 of 334 ---PAGE BREAK--- summary of the permittee’s past year performance and accomplishments, evaluation of SWMP effectiveness, proposed updates, changes or improvements. 4 Program Performance 4.1 Capital Improvement Plan and Infrastructure Improvements Overview Capital Improvement Plan Annually, the MS4 allocates funding towards structural and treatment infrastructure projects to improve the integrity of the stormwater collection network, expand system conveyance, and meet water quality requirements. Pollutants of concern of impaired waterbodies are targeted by a prioritization strategy (for more information see Appendix The five-year Capital Improvement Plan (CIP) outlines future capital projects (Table The CIP process occurs annually and is open for public comment, approved by the City Council, and is incorporated into the fiscal year operating budget. Completed MS4 Improvement Projects: The MS4 requires private projects over 10,000 square feet to treat stormwater on-site. Additionally, the City also prioritizes stormwater management and treatment. In total, stormwater treatment has been provided for over 1,047 acres of the MS4 with 236 acres in 2020 alone. For more information, see Appendix F (Stormwater TMDL Action Plan – Appendix A: TMDL Progress Reporting). 6 of 334 ---PAGE BREAK--- Table 1. Proposed treatment projects and structural repairs from fiscal year (FY) 2021-2025. 7 of 334 ---PAGE BREAK--- 4.2 Performance Measures 4.2.1 Annual Pollutant Reduction Totals The MS4 tracks pollutant reduction totals using a variety of methods and data tracking mechanisms, including: Total Suspended Solids (Sediment)  Treatment Unit Maintenance: The MS4 calculates tonnage totals by measuring the depth of sediment within each unit before cleaning. The MS4 subtracts a top of sediment depth measurement from a total depth measurement. The MS4 then calculates a volume of sediment (cubic yards) using dimension information for each unit. Finally, the MS4 converts the volume to tons by using an assumed sand weight ratio of 1.5 tons = 1 cubic yard. o 2017: 22.62 tons  6 out of 6 total units cleaned and inspected • Middle Ashley Creek Watershed: 4.185 tons • Stillwater River Watershed: 18.435 tons o 2018: 45 tons  8 out of 6 total units cleaned and inspected (2 units are cleaned semi- annually) • Middle Ashley Creek Watershed: 1.875 tons • Stillwater River Watershed: 43.125 tons o 2019: 38.63 tons  8 out of 6 total units cleaned and inspected (2 units are cleaned semi- annually) • Middle Ashley Creek Watershed: 8.37 tons • Stillwater River Watershed: 30.27 tons o 2020: 59.55 tons  13 out of 12 total units cleaned and inspected (2 units are cleaned semi-annually) • Middle Ashley Creek Watershed: 5.55 tons • Stillwater River Watershed: 54 tons  Infrastructure Maintenance: The MS4 calculates tonnage totals by estimating the depth of sediment vacuumed out of manholes and inlets before cleaning. The depth of sediment inside the structures is determined by a ¼, ½, ¾, or full method. The MS4 multiplies the area of each asset’s sump by the estimated depth. Then, the MS4 multiplies the volume by the total assets maintained for that calendar year. Finally, the MS4 converts the volume to tons by using an assumed sand weight ratio of 1.5 tons = 1 cubic yard of sand. o 2017: 35.55 tons  99 cleaned, 196 inspected o 2018: 49.5 tons  422 cleaned and inspected o 2019: 151.755 tons  31.755 tons – 251 catch basins and manholes cleaned and inspected  120 tons – 48,494’ stormwater gravity main and lateral line cleaned o 2020: 115.5tons  273 catch basins and manholes cleaned and inspected 8 of 334 ---PAGE BREAK---  Street Sweeping: The MS4 calculates tonnage totals for reoccurring, spring, and fall Street sweeping operations. Streets Division personnel track yards total for each of the activities, which is then stored in Omnitracs and reported on. The MS4 converts yards to tons using an assumed sand weight ratio of 1.5 tons = 1 cubic yard for reoccurring and spring street sweeping. The MS4 converts yards to tons using an assumed leaf weight ratio of .18 tons = 1 cubic yard for fall street sweeping. o 2017: 1,536.54 tons  Sweepings: 1,245 tons  Leaves: 291.54 tons o 2018: 2,162 tons  Sweepings: 1,362 tons  Leaves: 800 tons o 2019: 1,311.494 tons  Sweepings: 912 tons  Leaves: 399.494 tons o 2020: 3,631 tons  Sweepings: 3,265 tons  Leaves: 366 tons Sediment Prevented from Discharging into Waterways Sediment is the MS4’s primary pollutant of concern. Significant efforts are completed and tracked annually to reduce the amount entering local waterways. The MS4’s plans maintain existing and implement new improvements, increasing totals annually.  Performance Measure: 127 tons per year reduction (TMDL WLAs for MS4) o Middle Ashley: 24.2 tons per year reduction o Lower Ashley: 75.9 tons per year reduction o Stillwater River: 26.9 tons per year reduction  Calculation Type: Total tons  2017: 1,594.71 tons  2018: 2,256.5 tons  2019: 1,501.879 tons  2020: 3,806.05 tons 4.2.2 Annual Performance Summary The MS4 utilizes performance measures to determine the effectiveness of implemented programs, best management practices, and infrastructure projects. The MS4 updates the following performance measures annually: Inlets and Manholes Cleaned Stormwater inlets collect runoff from the MS4’s streets, parking lots, alleyways, and other hard surfaces, reducing flooding. Stormwater manholes allow for maintenance access to underground infrastructure. Both structures treat stormwater by capturing sediment, trash, and other pollutants in their sumps. The MS4 maintains infrastructure year-round and documents operation totals, such as the number cleaned, labor hours accumulated, budget spent, and weight of material removed.  Performance Measure: Clean 100 inlets and manholes annually 9 of 334 ---PAGE BREAK---  Calculation Type: Total assets (includes duplicate effort)  2017: 99 inlets and manholes cleaned, 196 inspected  2018: 422 inlets and manholes cleaned and inspected  2019: 251 inlets and manholes cleaned and inspected  2020: 273 inlets and manholes cleaned and inspected Stormwater Mains and Lateral Lines Cleaned and Inspected Stormwater pipes serve two primary purposes: pipes convey stormwater collected by inlets to its point of discharge, and pipes capture sediment, trash, and other pollutants that fall out of suspension, requiring reoccurring maintenance to remain functional. The MS4 maintains stormwater pipes year-round, documenting operation totals, such as the length of feet cleaned and inspected, labor hours accumulated, budget spent, and weight of material removed.  Performance Measure: Maintain mains and lines and clean as needed  Calculation Type: Total assets (mains and laterals, includes duplicate effort)  2017: 2,814’  784’ stormwater gravity main cleaned  2,030’ stormwater gravity main and lateral line inspected  2018: 594’  164’ stormwater gravity main cleaned  430’ stormwater gravity main and lateral line inspected  2019: 48,494’  28,284’ stormwater gravity main cleaned  20,210’ stormwater lateral line cleaned  2020: 0’ Infrastructure Repairs Infrastructure repairs or “spot repairs” serve two primary purposes: repairs fix known pipe and manhole failures and restrictions to ensure the adequate flow of stormwater, and repairs open sections of pipe where scouring of subgrade soils occur, mitigating the chance of a road failure and sediment load contribution. The MS4 completes infrastructure repairs year-round, documenting operation totals, such as the number of repairs, labor hours accumulated, and budget spent.  Performance Measure: Indicator measure  Calculation Type: Total repairs  2017: 4 Repairs  2018: 0 Repairs  2019: 5 Repairs  2020: 0 Repairs Streets Cleaned Pollutants accumulate on the MS4’s streets during dry weather and flush into local waterways during rain events. Street sweeping mitigates impacts by proactively picking up accumulated pollutants. The MS4 disposes of collected sweepings at the local landfill. Street sweepers work year round and document operation totals, such as the number of miles swept, labor hours accumulated, budget spent, and weight of material removed.  Performance Measure: Indicator measure 10 of 334 ---PAGE BREAK---  Calculation Type: Miles swept (total linear miles, multiple passes and sweeping and travel included)  2017: 8,735 miles  2018: 7,849 miles  2019: 8,831 miles  2020: 9,421 miles Construction Site Inspections The MS4 tracks the totals and types of compliance inspections completed annually. Two separate construction site permits types exist and are subject to review: under one acre and over one acre.  Performance Measure: Conduct regular inspections  Calculation Type: Percentage of total inspections  2017: 58.5% (100 inspections/171 total new projects*)  2018: 134% (219 inspections/164 total new projects*)  2019: 120% (216 inspections/180 total new projects*)  2020: 83.2% (233 inspections/280 total new projects*) (*total new projects only include approved permits in the calendar year – additional permits may be open from previous years) 11 of 334 ---PAGE BREAK--- Illicit Discharges Resolved Illicit discharge events can threaten public safety and environmental health and pose difficulties to MS4 infrastructure operations and maintenance. The MS4 responds to a variety of illicit discharge events, ranging from minimal to severe on an annual basis.  Performance Measure: Indicator measure  Calculation Type: Total events  2017: 2 Events  2018: 4 Events  2019: 3 Events  2020: 9 Events MS4 Area Improved through Public and Private Treatment Projects The MS4 contains aged conveyance infrastructure that discharges stormwater directly into waterways without treatment or flood control. A primary component of the MS4’s Stormwater Program is to retrofit or install enhancement improvements that bring these areas up to current water quality and, when applicable, quantity standards. Example projects include the installation of mechanical separation units, regional pond facilities, and green infrastructure.  Performance Measure: Indicator measure  Calculation Type: Total acres  2016: 401 Acres  2017: 38 Acres  2018: 75 Acres  2019: 87 Acres  2020: 236 Acres 4.3 Infrastructure Information Infrastructure Totals (includes City, State, and private assets)  2017:  Manholes: 1,362  Inlets: 3,892  Stormwater Basins: 79  Outfalls: 69  Underground Pipes (laterals and mains): 103 miles  2018:  Manholes: 1,406  Public: 768  Private: 638  Inlets: 3,998  Public: 1,874  Private: 2,124  Stormwater Basins: 79  Outfalls: 69  Underground Pipes (laterals and mains): 158.3 miles  Public: 74.8 miles  Private: 83.5 miles  2019:  Manholes: 1,451 12 of 334 ---PAGE BREAK---  Public: 796  Private: 655  Inlets: 4,074  Public: 1,920  Private: 2,154  Stormwater Basins: 79  Outfalls: 70  Underground Pipes (laterals and mains): 162.44 miles  Public: 76.44 miles  Private: 86 miles  2020:  Manholes: 1,540  Public: 869  Private: 671  Inlets: 4,208  Public: 1,992  Private: 2,216  Stormwater Basins: 115  Outfalls: 78  Underground Pipes (laterals and mains): 109.37 miles  Public: 49.85 miles  Private: 59.52 miles 13 of 334 ---PAGE BREAK--- 5 Minimum Control Measure Management Program The MS4 General Permit requires development, implementation, and management of Best Management Practices (BMPs) for the minimum control measures necessary to reduce the discharge of pollutants from the permitted Small MS4. DEQ requires that BMPs are selected, designed, installed, implemented, inspected, and maintained (or replaced based on inspections) in accordance with good engineering, hydrologic, and pollution control practices. This section describes the minimum measure’s BMPs and provides: • Permit requirements • Performance tracking of completed and ongoing initiatives • Planned initiatives o A description of the BMP o The rationale for BMP selection o The implementation activity and schedule for each year of the 2017-2021 permit cycle 14 of 334 ---PAGE BREAK--- 5.1 Public Education and Outreach & Involvement and Participation 5.1.1 Permit Requirements Per Permit Part II.A.1., the permittee is required to implement a stormwater public education program to develop or adapt, distribute, and evaluate educational materials and outreach activities to key target audiences in the MS4. The program will raise awareness about the impacts of stormwater discharges on waterbodies, educate audiences about the behaviors and activities that have the potential to pollute stormwater discharges, and motivate action to change behaviors to reduce pollutants in stormwater runoff. Additionally, per Permit Part II.A.2., the permittee is required to develop a strategy to involve key target audiences in the development and implementation of the SWMP that complies with state and local public notice requirements. An effective public education program can significantly reduce other program costs such as inspection and enforcement costs for the illicit discharge program. Informed citizens and business owners will usually take steps to reduce potential pollution from their own activities. The public can provide valuable input and assistance to a municipal stormwater management program. An active and involved community is crucial to the success of a stormwater management program. It allows for broader public support since the citizens who participate in the development and decision making processes are responsible for the programs. 15 of 334 ---PAGE BREAK--- 5.1.2 Performance Tracking of Completed and Ongoing Initiatives Key Audiences The City of Kalispell has identified the following list of key audiences due to the potential of each group to contribute pollutants to stormwater and subsequently local waterbodies.  Construction Industry  City Residents  Pet Owners  Restaurants  Commercial Carwashes  Commercial Parking Lot Cleaning  Gas Stations  Lawn Care Companies The goal of engaging in stormwater public education and outreach programs is to increase knowledge and encourage behavior change to help create an informed public and reduce pollutants entering the MS4 and local waterways. Completed and ongoing initiatives include:  Public Education and Involvement Program • Utility Bill Inserts: Printed flyers provide timely information and are utilized to convey a variety of stormwater-related messages including pet waste pollution and proper disposal, stormwater participation programs, stormwater website information, illicit discharge identification and reporting, advertise Flathead Household Hazardous Waste Program, general pollution prevention practices, and pollution prevention practices for businesses. o Key audience(s): Residents, public service employees, commercial businesses o Target Pollutant(s): Escherichia coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Cost: $1,200 o Performance: Number of inserts mailed with utility bills  2015: 727  2016: 824  2018: 8,691  2019: 17,450  2020: 16,926 • Bulk Mailings: Mailings provide targeted messages for key businesses (i.e. commercial carwashes, restaurants) regarding topics related to stormwater management practices. In 2018, mailings were updated to emails and in person deliveries that are on rotational schedules. o Key audience(s): Commercial businesses o Target Pollutant(s): Nitrogen, phosphorous, trash, and sediment o Treatment Area: Citywide o Performance: Number of mailings sent and businesses contacted Year Mailings sent Hand delivered flyers Number of businesses contacted 2013 ~600 NA ~600 2014 ~600 NA ~600 2015 ~600 NA ~600 2016 ~827 NA ~600 2018 ~1061 36 ~1097 2019 ~1056 34 ~1090 16 of 334 ---PAGE BREAK--- 2020 ~1078 NA ~1078 • Pamphlets: Printed brochures are distributed at public events, directly to businesses, and at the Public Works office. Pamphlets convey information on stormwater management and pollution prevention and have been created for the following: general pollution prevention, lawn care, automotive waste, and pet waste. o Key audience(s): Residents, public service employees, commercial businesses o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance:  2015-2020: No tracking mechanism • Parks and Recreation Newspaper: Twice a year Kalispell Parks and Recreation prints a newspaper to provide information on the City’s par and recreation programs. Stormwater pollution prevention information is printed in the newspaper. o Key audience(s): Residents, commercial businesses o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Cost: $353 o Performance: Number of advertisements in Parks and Recreation Newspaper  2013: 2X, 23,000 newspapers printed and distributed  2014: 2X, 20,000 newspapers printed and distributed  2015: 2X, 20,000 newspapers printed and distributed, 1 ad in MT Ag News Magazine with ~5,000 copies printed and distributed  2016: 2X, 20,000 newspapers printed and distributed  2017: 2X, 20,000 newspapers printed and distributed  2018: 2X, 20,000 newspapers printed and distributed  2019: 2X, 20,000 newspapers printed and distributed  2020: 2X, 20,000 newspapers printed and distributed • School Book Covers: Book covers provide protection to textbooks in addition to advertising stormwater education and pollution prevention information. o Key audience(s): Residents o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Cost: $279.22 o Performance: Number of book covers printed for high school and junior high students  2013: ~250  2014: ~250  2015: ~300  2016: ~300  2018: 1,000  2019: 1,000  2020: 1,000 • Student Education: This program helps educate students on stormwater issues and BMPs in Kalispell. City participation in classrooms and other events provides a community connection and a chance for students to learn what City employees do and for City employees to understand interests and questions of residents. 17 of 334 ---PAGE BREAK--- o Key audience(s): Residents o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: Participation in at least one classroom session per year  2013: Yes, 3 third-grade class presentations, eighth graders from Kalispell, and City and MDT staff presented to elementary students  2014: Yes, 3 third-grade class presentations and City and MDT staff presented to third-grade students  2015: Yes, 3 third-grade class presentations (no staff attendance) and 1 presentation to all third-grade students by MDT (no City staff)  2016: Yes, 3 third-grade class presentations and 1 presentation to all third-grade students  2018: Arbor Day Booth and Activity – Worked directly with 131 3rd grade students  2019: ~1882 students a. Rolling Rivers Trailer with Flathead Conservation District i. Glacier High School 10th Grade Class – 233 students, 9 adults ii. Hedges Middle School – 40 5th grade students b. Arbor Day Booth and Activity – District 5’s third graders, over 300 students c. Forestry Expo with Flathead Conservation District – all Flathead County 5th graders, ~1300 students  2020: Unknown (Covid-19 pandemic resulted in most events being cancelled) a. Canceled: Rolling Rivers Trailer with Flathead Conservation District i. 4/21-22/20 19 Glacier High School (entire 10th grade class) 1. Replacement: Sent Remarkable Riparian video series ii. Hedges Middle School b. Canceled: Arbor Day Booth and Activity – District 5’s third graders, over 300 students c. Canceled: Forestry Expo with Flathead Conservation District – all Flathead County 5th graders i. Replacement: Collaborated with Flathead Conservation District to compile resources • General Education and Outreach: The City participates on numerous committees and boards to maintain and build connections, learn and collaborate with others, and present on City initiatives. o 2019  Montana Stormwater Committee 18 of 334 ---PAGE BREAK--- a. Presented at the MT Stormwater Committee’s first Short Talk Webinar Series on Kalispell’s Stormwater Maintenance Permit Program i. ~35-40 attendees  Flathead Basin Commission a. City representative was appointed by the governor to be a Commissioner b. The City is actively collaborating with the Flathead Basin Commission on a watershed wide stormwater inventory utilizing a Big Sky Watershed Corps Member o 2020  Montana Stormwater Committee a. Member  Flathead Basin Commission a. City representative as Commissioner b. The City is actively collaborating with the Flathead Basin Commission on a watershed wide stormwater inventory, prioritization, and water quality improvement campaign utilizing a Big Sky Watershed Corps Member  Flathead Watershed Through the Seasons a. Presented a stormwater talk at the event to 8 teachers from the Flathead Valley and numerous agencies, education partners, etc. • Flathead Rain Garden Initiative: The City in collaboration with the Flathead Conservation District developed the Flathead Rain Garden Initiative. The program is designed to help private landowners create rain gardens on their property to help protect local waterways from pollution and flooding. Address: o Key audience(s): Residents o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: Workshops and rain gardens built  2019: 2 workshops, 12 attendees  2020: 2 workshops, 24 attendees, 5 rain gardens built in City limits • Website: Kalispell’s public website provides information on stormwater, pollution prevention, reporting pollution, construction and post-construction design standards and permits, and more. Address: o Key audience(s): Residents, public service employees, commercial businesses, construction o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: Total unique page views tracked by Google Analytics and Civic Plus (new webpage mid-2018) annually 19 of 334 ---PAGE BREAK---  2015: 751  2016: 646  2017: 1,002  2018: 2,977  2019: 3,353  2020: 4,221 • Advertising Campaign: The public TV station runs educational stormwater videos created by the local high school audio/video classes. o Key audience(s): Residents, public service employees, commercial businesses, construction o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: 2 videos aired per year  2013: 2 videos aired 6-8 times per day  2014: 2 videos aired 10-15 times per week  2015: 2 videos aired 10-15 times per week  2016: 2 videos aired 10-15 times per week • Dog Waste Stations: The City has invested in dog waste cleanup stations with signs and plastic bags in all of the City parks. o Key audience(s): Residents o Target Pollutant(s): E.coli, nitrogen, phosphorous o Treatment Area: Citywide o Cost: ~$858.44 - $1,300 o Performance: Number of dog waste disposal bags purchased  2017: 50,000  2018: 40,000  2019: 60,000  2020: 60,000 • Stormwater Advisory Committee Meetings: Public meetings to review progress on SWMP implementation and suggest changes to improve BMPs or program elements. o Key audience(s): Residents, public service employees, commercial businesses, construction o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: Number of meetings held annually  2013: Kickoff meeting  2014: 4  2015: 5  2016: 3 • Storm Drain Identification: Community volunteers affix decals with a pollution prevention message to storm drain inlets in all areas of the City. o Key audience(s): Residents, public service employees, commercial businesses, construction o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Performance: Program Active  2013-Current • Charity Carwash Program: The program provides education and organizational equipment to prevent waste wash water from entering the storm drain system. The City 20 of 334 ---PAGE BREAK--- provides a car wash kit with essential equipment to prevent pollutants from entering the storm system. o Key audience(s): Residents, commercial businesses o Target Pollutant(s): Nitrogen, phosphorous, sediment o Treatment Area: Citywide o Performance: Program active  2013-Current • Public Contact Program: This provides a means for Kalispell residents to contact City staff to relay comments, concerns, or gain information concerning stormwater. o Key audience(s): Residents, public service employees, commercial businesses, construction o Target Pollutant(s): E.coli, nitrogen, phosphorous, trash, sediment o Treatment Area: Citywide o Performance: Number of stormwater complaints tracked and answered  2013: 5  2014: 1  2015: 12  2016: 5  2017: 2  2018: 2  2019: 4  2020: 11 21 of 334 ---PAGE BREAK--- 5.1.3 Planned Initiatives Kalispell plans to continue many of the initiatives listed above, in addition to developing more focused and targeted approaches to improve public education and outreach and increase the involvement of key target audiences. As specified in the MS4 General Permit, the following BMPs will be continued from previous permit cycles with updates to include new MS4 General Permit requirements or new BMPs will be developed and implemented throughout the current permit cycle. STORMWATER OUTREACH PROGRAM PE-1 DESCRIPTION: The Stormwater Outreach Program develops and formalizes distribution of educational materials and outreach activities to key target audiences in the MS4 that raise awareness about the impacts of stormwater discharges on waterbodies, educate audiences about the behaviors and activities that have the potential to pollute stormwater discharges, and motivate action to change behaviors to reduce pollutants in stormwater runoff. The current program will be updated to meet the requirements of the current MS4 General Permit. RATIONALE FOR SELECTION: Stormwater Outreach Program provides the educational material for the source of pollution, target audience, and distribution sources for the current permit cycle. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 Determine key target audiences and relative pollutant source 1st Annual Report 2018 1. Develop outreach message which promotes benefits of non- polluting behaviors to key target audience and benefits to stormwater discharge a. Analyze business/residential type and behaviors that are common source of illicit discharges, spill, and dumping b. Develop list, description, and rationale for selection of key target audience and associated pollutants 2. Develop outreach format and distribution channels 3. Update current program to meet MS4 General Permit requirements 2nd Annual Report 2019- 2021 Distribute outreach material to target audiences 3rd, 4th, 5th Annual Report 22 of 334 ---PAGE BREAK--- PUBLIC INVOLVEMENT PROGRAM PI-1 DESCRIPTION: The Public Involvement Program involves continuing current public participation programs and updating the program by identifying approaches for involving key target audiences in SWMP development and implementation. RATIONALE FOR SELECTION: The public can provide valuable input and assistance to a municipal stormwater management program. An active and involved community is crucial to the success of a stormwater management program. It allows for broader public support since the citizens who participate in the development and decision making processes are responsible for the programs. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Identify approaches for involving the key target audience identified in PE-1. For each key audience describe the approach, target for implementation, and purpose of involvement approach. 2. Id existing organization with memberships that represent some or all of the key target audiences. 3. Describe opportunities for partnering to involve organization with SWMP development and implementation. 4. Document collaboration with the organization if this is an approach for involving key target audiences. 5. Continue the following Participation Programs if feasible: a. Stormwater Advisory Committee Meetings b. Storm Drain Identification Program c. Charity Carwash Program d. Student Participation in Stormwater Awareness 1st Annual Report 2018- 2021 1. Update current program and implement identified involvement approaches for each key target audience. 2. Document participation and key target audience feedback on the approach. 2nd, 3rd, 4th, 5th Annual Report 23 of 334 ---PAGE BREAK--- STORMWATER OUTREACH & PUBLIC INVOLVEMENT WEBSITE PE-2 & PI-2 DESCRIPTION: Maintain a stormwater website for access by key target audiences, interested stakeholders, and the general public. The website will advertise stormwater education and solicit input from key target audiences, interested stakeholders, and the general public. The current Stormwater Website will be updated to meet the requirements of the current MS4 General Permit. RATIONALE FOR SELECTION: Stormwater outreach website provides access to stormwater outreach material, permit documents, and a mechanism for public input. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 Develop and update website available to public containing: 1. Link to MS4 General Permit 2. Access to outreach material and events 3. SWMP documents and updates 4. Annual Reports 5. Mechanism for receiving public input on SWMP 6. Information on illicit discharges-how to identify and report 7. Information on construction activities and complaints 1st Annual Report 2018- 2021 Maintain website and update as required annually 2nd, 3rd, 4th, 5th Annual Report 24 of 334 ---PAGE BREAK--- 5.2 Illicit Discharge Detection and Eliminations 5.2.1 Permit Requirements Discharges into storm conveyance systems often include wastes and wastewater from non-stormwater sources. A portion of these dry weather flows may be from illicit and inappropriate discharges and connections to the storm conveyance systems. Illicit discharges enter the system through either direct or indirect connections. The results are untreated discharges that contribute high levels of pollutants, including heavy metals, toxins, oil and grease, solvents, nutrients, viruses, and bacteria to receiving streams and rivers. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality, threaten aquatic wildlife, and human health. Per Permit Part II.A.3., the permittee is required to develop, implement and enforce a program to detect and eliminate illicit discharges into the permitted Small MS4. 25 of 334 ---PAGE BREAK--- 5.2.2 Performance Tracking of Completed and Ongoing Initiatives The goal of an illicit discharge detection and elimination program is to reduce pollution to local waterways and increase knowledge and encourage behavior change. Completed and ongoing initiatives include: • Kalispell Stormwater System Mapping: The City of Kalispell’s storm drain system is mapped through GPS and is consistently updated. The stormwater map identifies the locations of current storm conveyance systems including pipes, manholes, ditches, drainage basins, and outfalls within City limits. o Years implemented:  2013-Current • Illicit Discharge Detection and Elimination (IDDE) Program: The IDDE program (Appendix C) is used to detect and address illicit discharges to municipal storm conveyance systems. This includes storm system audits, illicit discharge potential assessments, dry weather screenings, isolating and fixing discharges, and tracking and evaluation. The IDDE program is updated regularly to include progress and improve the program. o Years implemented:  2013: No illicit discharges identified  2014: No illicit discharges identified  2015: 6 outfalls screened and no illicit discharges identified  2016: 26 outfalls screened and no illicit discharges identified  2018: 18 outfalls screened and no illicit discharges identified  2019: 13 outfalls screened and no illicit discharges identified  2020: 23 outfalls screened and no illicit discharges identified • Illicit Discharge Investigations: The goal is to track, evaluate, educate, and eliminate illicit discharges into the City’s MS4. This provides a means to conduct investigations as needed based on public and City staff input. The public and municipal staff are educated on illicit discharges and how to inform the City through the Public Education Program, Public Contact program, the website, and the Pollution Prevention and Good Housekeeping Program. o Years implemented:  2013: 1 illicit discharge reported and resolved  2014: 0 illicit discharges reported  2015: 2 illicit discharges reported and resolved  2016: 4 illicit discharges reported and resolved  2017: 2 illicit discharges reported and resolved  2018: 4 illicit discharges reported and resolved  2019: 5 illicit discharges reported (3 confirmed) and resolved  2020: 9 illicit discharges reported and resolved • Illicit Discharge Ordinance: Ordinance 1831 (updated in 2019) (Appendix D) establishes regulations controlling the introduction of pollutants into the City’s MS4. The ordinance prohibits illicit discharges and illegal connections to the MS4, as well as sanctions to ensure compliance to the extent allowable under State and local law. o Ordinance developed and enforced:  2008-Current 26 of 334 ---PAGE BREAK--- • Public Education through Public Education Program: The City trains municipal employees on illicit discharges through the Pollution Prevention and Good Housekeeping annual training, Kalispell residents as outlined in the Public Education Program, and all new municipal employees through an orientation video. o Years implemented:  2013-Current • Non-Stormwater Discharge Evaluation: Significant and occasional non-stormwater discharges are evaluated including pollutants associated with each contributor and local controls and conditions placed on these discharges. This evaluation is updated annually. o Years evaluated:  2017-Current 27 of 334 ---PAGE BREAK--- 5.2.3 Planned Initiatives As specified in the MS4 General Permit, the following BMPs will be continued from previous permit cycles with updates to include new MS4 General Permit requirements or new BMPs will be developed and implemented throughout the current permit cycle. ASSESSMENT OF “SIGNIFICANT” NON-STORMWATER DISCHARGES IDDE-1 DESCRIPTION: Evaluate non-stormwater discharges the City would consider as a significant contributor of pollutants. This list excludes non-stormwater discharges the City considers to be occasional incidental and are exempt per City Ordinance 1634. RATIONALE FOR SELECTION: Assesses and evaluates illicit discharges annually to ensure significant pollutants are not introduced into the receiving waters. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017- 2021 1. Evaluate a list of non-stormwater discharges identified as a significant contributor of pollutants. 2. List pollutants associated with each non-stormwater significant contributor. 3. Document and track local controls or conditions placed on these discharges. 1st, 2nd, 3rd, 4th, 5th Annual Report ASSESSMENT OF “OCCASIONAL INCIDENTAL” NON-STORMWATER DISCHARGES IDDE-2 DESCRIPTION: Evaluate exempt non-stormwater occasional incidental discharges as identified in Ordinance 1634. The City has developed a list of occasional incidental non-stormwater discharges considered except as outlined in City Ordinance 1634. The City will assess the occasional incidental discharges and update ordinances if conditions change and the discharges are considered to be significant. RATIONALE FOR SELECTION: Assesses and evaluates illicit discharges annually to ensure only non- significant pollutants are introduced into the receiving waters. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017- 2021 1. Evaluate the list of non-stormwater discharges that the City has determined will not be addressed as illicit discharges in Ord 1634. 2. List pollutant associated with each non-stormwater non- significant contributor. 3. Document and local control or conditions placed on these discharges. 1st, 2nd, 3rd, 4th, 5th Annual Report 2018 Update ordinance to include a provision prohibiting an occasional incidental non-stormwater discharge that is determined to be contributing a significant amount of pollutants. 2nd Annual Report 28 of 334 ---PAGE BREAK--- KALISPELL STORMWATER SYSTEM MAPPING IDDE-3 DESCRIPTION: Kalispell stormwater map captures global position system (GPS) locations of current storm conveyance systems including pipes, manholes, ditches, and outfalls within the City limits. The map is updated annually. RATIONALE FOR SELECTION: The map inventories stormwater sewer infrastructure to thoroughly track illicit discharges, contain spills, and determine high priority areas. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Update existing map showing location and number of outfalls and the names and location of all surface water that receive discharges from those outfalls. 2. Update map showing high priority areas. 1st Annual Report 2018- 2021 Update map annually 2nd, 3rd, 4th, 5th Annual Report ILLICIT DISCHARGE ORDINANCE AND ENFORCEMENT RESPONSE PLAN (ERP) IDDE-4 DESCRIPTION: Ordinance 1634, adopted in 2008, establishes regulations controlling the introduction of pollutants into the City’s Municipal Separate Storm Sewer System (MS4). The ordinance prohibits illicit discharges and illegal connections to the MS4, as well as sanctions to ensure compliance to the extent allowable under state and local law. An Enforcement Response Plan (ERP) will be developed for illicit discharges and Ordinance 1634 will be updated accordingly to meet MS4 General Permit requirements. RATIONALE FOR SELECTION: The Phase II MPDES regulations require the establishment of a regulatory mechanism to prohibit illicit discharges. City Ordinance 1634 establishes a regulation controlling and removing the introduction of illicit pollutants into the City’s MS4. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 Continue implementation and enforcement of current ordinance 1st Permit Year 2018 1. Review and update ordinance as needed to meet significant discharge assessment conclusions. 2. Develop and implement a formal ERP for illicit discharges and update ordinance to meet ERP requirements as outlined in the MS4 General Permit. 2nd Annual Report 2019- 2021 Continue implementation and enforcement of current ordinance Annually 29 of 334 ---PAGE BREAK--- IDDE COLLABORATION WITH NEIGHBORING MS4 -MDT IDDE-5 DESCRIPTION: Collaborate with MDT (neighboring MS4s) as necessary to detect and eliminate illicit discharges. RATIONALE FOR SELECTION: Collaboration with neighboring MS4 permittee increases the potential to detect and eliminate illicit discharges in a watershed. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 Continue collaboration as necessary. 1st Permit Year 2018 1. Solicit assistance from neighboring MS4s as necessary to detect and eliminate illicit discharges. 2. Formalize cooperative agreements as necessary to implement the IDDE program. Agreements should specify investigation and enforcement responsibilities. 3. Submit a summary of agreement in second Annual Report. 2nd Annual Report 2019- 2021 Continue neighborly collaboration and agreement objectives. Annually 30 of 334 ---PAGE BREAK--- ILLICIT DISCHARGE DETECTION AND ELIMINATION (IDDE) PROGRAM IDDE-6 DESCRIPTION: Kalispell’s IDDE program was developed in 2008 and is used to detect and address illicit discharges to the municipal storm conveyance systems. The measures used to accomplish the goals of the program are as follows: • Audit storm system • Assess illicit discharge potential • Dry weather screening (inspect and screen all outfalls by the end of the permit cycle) • High/Low priority outfalls screening • Investigation and Correction Action Plan • Execution of Enforcement Actions A complete copy of the IDDE Program can be obtained at the Public Works Department front office. The IDDE Program will be reviewed, updated, and protocol implement as required to meet the new requirement of the MS4 General Permit. RATIONALE FOR SELECTION: Participation in the IDDE Program enables the City to implement and enforce a program to detect and eliminate illicit discharges. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Review IDDE Program and update to meet new permit requirements. 2. Develop an illicit discharge investigation and corrective action plan. Incorporate into IDDE Program. 1st Annual Report 2018 1. Update IDDE Program- use inspection and screening results to determine high priority outfalls. Priority determination is outlined in the permit. 2. Submit the list of high-priority outfall with each remaining Annual Reports. The list may change with additional annual screenings. 3. Incorporate inspection and screening schedule for all of the City’s outfalls during permit cycle. 4. Implement illicit discharge investigation and corrective action plan. 5. Maintain documentation of investigation/correction and submit incidents with every Annual Report. 2nd Annual Report 2019- 2021 1. Inspect and screen high priority outfalls 2. Submit a summary of screening results 3. Reevaluate additional high priority sites determined from annual screening. 3rd, 4th, 5th Annual Report 31 of 334 ---PAGE BREAK--- 5.3 Construction Site Stormwater Management 5.3.1 Permit Requirements Sediment from construction sites is considered a leading cause of water quality problems. During a short period of time, construction sites can contribute more sediment to streams than can be deposited naturally during several decades. Per the Permit Part II.A.4, the permittee is required to develop, implement and enforce a program to reduce pollutants in stormwater runoff to the permitted Small MS4 from construction activities. 32 of 334 ---PAGE BREAK--- 5.3.2 Performance Tracking of Completed and Ongoing Initiatives The goal of construction site stormwater management is to reduce violations and increase knowledge and encourage behavior change to help reduce pollutants entering the MS4 and local waterways. Completed and ongoing initiatives include: • Land Disturbance Ordinance 1831: The City of Kalispell’s Ordinance 1831 (updated in 2019) “Stormwater Regulations” (Appendix D) established land disturbance, erosion, and sediment standards. The ordinance outlines construction site stormwater management permit procedures and ensures compliance and enforcement of construction site stormwater management. The 2019 ordinance update includes an adopted Enforcement Response Plan. o Ordinance developed and enforced:  2007-Current • Kalispell Construction Site Stormwater Management Permit: Land disturbing activity, or any construction activities disturbing 5 CY or 1,000 SF, shall prepare and submit a Construction Site Stormwater Management Permit to the Public Works Department. The permit developed and implemented an erosion and sediment control plan to minimize construction site pollution from entering the City storm conveyance systems, streams, and rivers. o Number of permits issued:  2013: 148  2014: 128  2015: 128  2016: 140  2017: 171  2018: 164  2019: 180  2020: 280 • Construction Site Inspections: City staff perform construction inspections regularly to ensure compliance and help educate contractors of appropriate stormwater management controls. o Years implemented:  2013: 60.8% (~90 inspections/148 total projects*)  2014: 46.1% (~59 inspections/128 total projects*)  2015: 6.25% (8 inspections/128 total projects*)  2016: 2.9% (4 inspections/140 total projects*)  2017: 58.5% (100 inspections/171 total projects*)  2018: 134% (219 inspections/164 total projects*)  2019: 120% (216 inspections/180 total projects*)  2020: 83.2% (233 inspections/280 total new projects*) (*total new projects only include approved permits in the calendar year – additional permits may be open from previous years) • Erosion Control Plan Review Procedures: Site plan review and inspection programs aid in compliance, enforcement, and provide an opportunity for guidance and education. The City performs a site plan review for potential water quality impacts at the time the Stormwater Management Permit is submitted and will conduct regular inspections of the construction sites. o Number of erosion control plan reviews:  2013: 148  2014: 128  2015: 128  2016: 140  2017: 171  2018: 164  2019: 180  2020: 280 33 of 334 ---PAGE BREAK--- • Annual Erosion and Sediment Control Training: Annual erosion and sediment control training provides participants from the local community (i.e. contractors, developers, and engineers) with the following knowledge, skills, and abilities: erosion and sedimentation processes and impacts, state and local regulations, stormwater planning, monitoring, reporting, recordkeeping, best management practices, and adaptive management. o Number of participants:  2013: 23  2014: 65  2015: 77  2016: 19  2018: 42  2019: 11  2020: 2 scheduled and canceled due to low sign-ups 34 of 334 ---PAGE BREAK--- 5.3.3 Planned Initiatives As specified in the MS4 General Permit, the following BMPs will be continued from previous permit cycles with updates to include new MS4 General Permit requirements or new BMPs will be developed and implemented throughout the current permit cycle. LAND DISTURBANCE ORDINANCE AND ENFORCEMENT RESPONSE PLAN C-1 DESCRIPTION: The City of Kalispell’s Ordinance 1600 “Stormwater Discharges Resulting from Construction and Land Disturbance Activities” establishes land disturbance, erosion, and sediment standards, as well as sanctions to ensure compliance to the extent allowable under state and local law. The ordinance outlines construction site stormwater management permit procedures and ensures compliance and enforcement of construction site stormwater management. An Enforcement Response Plan (ERP) will be developed to ensure compliance with construction stormwater management regulatory mechanisms. Ordinance 1600 will be updated accordingly to meet MS4 General Permit requirements. RATIONALE FOR SELECTION: Ordinance 1600 establishes regulations controlling the introduction of pollutants into the City’s MS4 from land disturbance activities. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Continue implementation and enforcement of current ordinance 2. Start review and development of ERP, submit documentation of progress toward creation of ERP in 1st Annual Report 1st Permit Year 2018 Continue implementation and enforcement of current ordinance 2nd Permit Year 2019 1. Review and update ordinance as needed to meet requirements established in the MDEQ General Permit for Stormwater Discharges Associated with Construction Activities. 2. Develop and adopt a formal ERP to ensure compliance with Ordinance 1600 and update ordinance to meet ERP requirements as outlined in the permit. 3rd Annual Report 2020 1. Implement ERP 2. Continue implementation and enforcement of ordinance 4th Permit Year 2021 Continue implementation and enforcement of ordinance 5th Permit Year 35 of 334 ---PAGE BREAK--- KALISPELL CONSTRUCTION SITE STORMWATER MANAGEMENT C-2 DESCRIPTION: Kalispell’s Construction Site Stormwater Management is regulated through a permitting process outlined in Ordinance 1600 “Stormwater Discharges Resulting from Construction and Land Disturbance Activities”. Administration of the permitting process is performed by Public Works and includes a policy for construction site plan review, management of project inventory, inspection protocol and frequency, and enforcement protocol. RATIONALE FOR SELECTION: Construction Site Stormwater Management Permitting is a component of Ordinance 1600 “Stormwater Discharges Resulting from Construction and Land Disturbance Activities”. The Kalispell permit program ensures compliance with construction site erosion and sediment controls. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Develop protocol and checklist for construction stormwater management plan review that ensures requirements of current DEQ Construction Activity Permit have been included on all regulated construction stormwater management plans. a. Implement construction stormwater management plan review checklist and protocol. 2. Update existing inspection form to ensure consistent and thorough project site inspection and ensure requirements of current DEQ Construction Activity Permit are met. a. Implement updated construction stormwater management inspection form. 3. Develop and maintain/update a construction site project inventory as described in the MS4 General Permit (4.c.iv). 4. Develop protocol for inspection frequency based on the priority of project as described in MS4 General Permit 1st Annual Report 2018 Continue implementation and enforcement of Kalispell Construction Site Stormwater Management protocols. 2nd Permit Year 2019 1. Update Kalispell Construction Site Stormwater Management plan review/inspection protocols and documents as required with an update of Ordinance 1600. 2. Continue implementation and enforcement of Kalispell Construction Site Stormwater Management protocols. 3rd Annual Report 2020- 2021 Continue implementation and enforcement of Kalispell Construction Site Stormwater Management protocols. 4th and 5th Permit Year 36 of 334 ---PAGE BREAK--- 5.4 Post-Construction Site Stormwater Management in New Development and Redevelopment 5.4.1 Permit Requirements Numerous studies have documented that stormwater runoff from developed sites contributes significant pollutant loads to receiving waters. The increase in impervious surfaces such as rooftops, roads, and parking lots can increase urban runoff and have a detrimental impact on aquatic systems due to increased concentrations of sediment, nutrients, road salts, heavy metals, pathogenic bacteria, and petroleum hydrocarbons. The best way to mitigate stormwater impacts from new development and redevelopment is to use practices to treat, store, and infiltrate runoff on-site before it can affect waterbodies. Per Permit Part II.A.5., the permittee is required to develop, implement, and enforce a program to address stormwater runoff from new development and redevelopment projects in the City. The program must ensure that controls are in place that would prevent or minimize water quality impacts. 37 of 334 ---PAGE BREAK--- 5.4.2 Performance Tracking of Completed and Ongoing Initiatives The goal of post-construction site stormwater management is to increase knowledge and maintenance of stormwater management controls to help reduce pollutants entering the MS4 and local waterways. Completed and ongoing initiatives include: • Kalispell Stormwater Quality Management Plan for New Development and Redevelopment: The Kalispell Stormwater Quality Management Plan is to ensure controls are in place to prevent or minimize water quality impacts from new development and redevelopment. The plan develops and implements strategies that include non-structural and structural best management practices. o Years implemented:  2013: 14 projects reviewed, 13 approved  2014: 17 projects reviewed, 13 approved  2015: 19 projects reviewed, 17 approved  2016: 18 projects reviewed, 18 approved  2017: 21 projects reviewed, 21 approved  2018: 30 projects reviewed, 26 approved  2019: 29 projects reviewed, 21 approved  2020: 37 projects reviewed, 34 approved • City Standards for Design and Construction: Standards for Design and Construction provide a regulatory mechanism to address post-construction runoff from new development and redevelopment, implementation of structural and non-structural practices to minimize water quality impacts, including low impact development practices where practicable, and ensure long-term operation and maintenance of structural practices. Standards for Design and Construction were originally adopted in 2009 and updated in 2018 and 2019. o Implemented and enforced:  2009-Current • Site Inspection and Enforcement of Post-Construction BMPs: Site inspection and enforcement of post-construction BMPs ensure compliance with approved plans for project sites located within the City. Post-construction inspections allow the City to compare approved site designs for stormwater quality BMPs to the final constructed project. Inspections identify deficiencies in constructed stormwater quality BMPs. o Years implemented:  2013: 4 BMPs inspected  2014: 4 private and 3 public BMPs inspected  2015: 2 private BMPs and 13 new BMPs inspected  2016: 2 private BMPs and 5 new BMPs inspected  2017: 9 new BMPs inspected  2018: 11 new BMPs inspected  2019: Transitioned into Stormwater Maintenance Permit Program (below) • Stormwater Maintenance Permit Program: In 2019, the City implemented the Stormwater Maintenance Permit Program. The program permits post-construction water quality treatment devices and requires yearly inspections and a five-year renewal that is submitted by a 38 of 334 ---PAGE BREAK--- professional engineer certifying that the structure is being maintained and operating as designed. o Years implemented:  2019: 1. 12 applications submitted and permits pending construction 2. 12 privately-owned structures inspected 3. 8 publicly-owned structures inspected  2020: 1. 19 applications submitted and permits pending construction 2. 12 privately-owned structures inspected 3. 9 publicly-owned structures inspected • Post-Construction Ordinance 1831: The City of Kalispell’s Ordinance 1831 “Stormwater Regulations” (Appendix D) established requirements for the Stormwater Maintenance Permit Program. The ordinance outlines stormwater maintenance permit procedures and ensures compliance and enforcement. The 2019 ordinance update includes an adopted Enforcement Response Plan. o Ordinance developed and enforced:  2019-Current • Post-Construction Stormwater Management Controls Inventory: An inventory of existing and new post-construction stormwater management controls allows for more accurate tracking on the function and impact on the MS4 system. o Years implemented:  2018-Current • Low Impact Development (LID) Concept Review: City-wide department review of LID concepts including review of barriers of in current codes, ordinances, and policies and future opportunities for adoption and implementation of LID policies. o 2020 Completed – See 2020 Annual Report 39 of 334 ---PAGE BREAK--- 5.4.3 Planned Initiatives As specified in the MS4 General Permit, the following BMPs will be continued from previous permit cycles with updates to include new MS4 General Permit requirements or new BMPs will be developed and implemented throughout the current permit cycle. CITY STANDARDS FOR DESIGN AND CONSTRUCTION AND ENFORCEMENT RESPONSE PLAN PC-1 DESCRIPTION: The City of Kalispell’s Standards for Design and Construction establishes post- construction stormwater quality management controls for new and redevelopment projects. The post-construction stormwater quality management controls are prescribed to meet the requirements depicted in the current MS4 General Permit. The City Standards for Design and Construction ensure the following requirements for this minimum measure: • Regulatory mechanism to address post-construction runoff from new development and redevelopment. • Implementation of structural and non-structural practices to minimize water quality impacts, including Low Impact Development (LID) practices, where practicable. • Ensure long-term operation and maintenance of structural practices. An Enforcement Response Plan (ERP) will be developed to ensure regulatory mechanisms for compliance with design, installation, operation, and maintenance of post-construction stormwater management controls. Ordinances will be developed or updated accordingly to meet MS4 General Permit requirements. RATIONALE FOR SELECTION: Kalispell implements and routinely updates the Standards for Design and Construction to comply with the MS4 General Permit to ensure controls are in place to prevent or minimize water quality impacts. The MS4 General Permit regulations require the establishment of a regulatory mechanism to require post-construction stormwater quality management controls and enforcement mechanisms on regulated projects. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Review and update Standards for Design and Construction as needed to meet stormwater control performance standards described in MS4 General Permit (Part II.A.5.b.iii). 2. Review and update as necessary new development and redevelopment project plan review checklist to ensure and document compliance with MS4 General Permit requirements. 1st Permit Year/Annual Report 2018 1. Continue implementation of current Standards for Design and Construction. 2. Develop and implement an inspection form or checklist for post- construction stormwater management controls for new/redevelopment projects to ensure proper construction. 2nd Permit Year/Annual Report 2019 Continue implementation of current Standards for Design and Construction. 3rd Permit Year 2020 1. Develop and adopt a formal ERP to ensure regulatory mechanisms for compliance with design, installation, operation, and maintenance of post-construction stormwater management controls. 4th Annual Report 2021 1. Implement ERP 5th Permit Year 40 of 334 ---PAGE BREAK--- 2. Continue implementation and enforcement of Standards for Design and Construction. POST-CONSTRUCTION STORMWATER MANAGEMENT PC-2 DESCRIPTION: Administration of stormwater post-construction management is performed by Public Works and includes policy and protocols for installation, operation, maintenance, and regulatory compliance for stormwater quality management controls from new development and redevelopment projects. Management practices include: 1. Inventory and classifying projects for high priority stormwater quality management controls 2. Inspection programs, establishing protocols for inspection of stormwater quality management controls. Ensuring long-term operations and maintenance of the control. 3. Ensuring regulatory mechanisms for compliance with installation, operation, and maintenance of post-construction stormwater management controls. An Enforcement Response Plan (ERP) will be developed to ensure regulatory mechanisms for compliance with installation, operation, and maintenance of post-construction stormwater management controls. Ordinances will be developed or updated accordingly to meet permit requirements. RATIONAL FOR SELECTION: Implements post-construction stormwater management controls on regulated projects and implements required enforcement procedures and actions. Meets State General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2018 1. Develop and maintain inventory (including description and locations) of all new permittee-owned and new private post-construction stormwater management controls since 2017. 2. Develop protocol for inspection frequency of post-construction stormwater management controls based on priority as described in MS4 General Permit (Part II.A.5.c.vi). 3. Develop a program to conduct annual inspections of Public and private high-priority post-construction stormwater controls. a. Inspections can be performed by the municipality or oversight of City requiring self-inspection and reporting by property owners. 2nd Permit Year/Annual Report 2019 1. Develop and maintain inventory (including description and locations) of all existing permittee-owned and private high priority post-construction stormwater management controls. a. Priority to be determined as described in MS4 General Permit (Part II.A.5.c.iv). 2. Inspect permittee-owned high priority post-construction stormwater management controls annually. Document findings and resulting compliance actions. 3. Implement inspection program for privately owned high-priority post- construction stormwater controls. Document findings and resulting compliance actions. 3rd Annual Report 41 of 334 ---PAGE BREAK--- 2020 4. Inspect permittee-owned high priority post-construction stormwater management controls annually. Document findings and resulting compliance actions. 5. Implement inspection program for privately owned high-priority post- construction stormwater controls. Document findings and resulting compliance actions. 6. Develop and adopt a formal ERP to ensure regulatory mechanisms for compliance with installation, operation, and maintenance for post- construction stormwater management controls on private projects. 7. Update or create ordinance as needed to ensure regulatory mechanisms for compliance with installation, operation, and maintenance of post- construction stormwater management controls on private property. 4th Permit Year/Annual Report 2021 8. Inspect permittee-owned high priority post-construction stormwater management controls annually. Document findings and resulting compliance actions. 9. Implement inspection program for privately owned high-priority post- construction stormwater controls. Document findings and resulting compliance actions. 10. Implement ERP for compliance with installation, operation, and maintenance of post-construction stormwater management controls on private property. 5th Permit Year 42 of 334 ---PAGE BREAK--- LOW IMPACT DEVELOPMENT (LID) CONCEPT REVIEW PC-3 DESCRIPTION: The MS4 General Permit requires the permittee to review the feasibility of utilizing Low Impact Development (LID) concepts on public and private property, and identify opportunities to establish LID policies for new and redevelopment projects. RATIONALE FOR SELECTION: Participation in City department-wide review of LID concepts, reviews feasibility implementation, barriers of implementation in current codes, ordinances, and policies, and identifies future opportunities for adoption and implementation of LID policies. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2020 Municipal internal review of LID concepts and barriers to implementation. Submit discussion and outcome summary with Annual Report. 4th Annual Report 43 of 334 ---PAGE BREAK--- 5.5 Pollution Prevention/Good Housekeeping for Permittee Operations 5.5.1 Permit Requirements Municipalities conduct numerous activities that can pose a threat to water quality if practices and procedures are not in place to prevent pollutants from entering the MS4. These activities include winter road maintenance, minor road repairs, infrastructure work, automotive fleet maintenance, landscaping and park maintenance, and facility/ building maintenance. Pollution Prevention/Good Housekeeping for municipal operations minimum control measure is a key element of the MS4 Permittee stormwater management program. This measure requires the MS4 Permittee to examine and subsequently alter their own actions to help ensure a reduction in the amount and type of pollution that: collects on streets, parking lots, open spaces, storage and vehicle maintenance areas, and facility management are discharged into local waterways; and results from actions standard operating and maintenance practices of City infrastructure and facilities. Per Permit Part II.A.6., the permittee is required to develop, implement an operation and maintenance program which includes a training component, and has the ultimate goal of preventing or reducing pollution runoff from the permittee operations. 44 of 334 ---PAGE BREAK--- 5.5.2 Performance Tracking of Completed and Ongoing Initiatives The goal of a pollution prevention good housekeeping program for operations is to increase knowledge require behavior to reduce pollutants entering the MS4 and local waterways. Completed and ongoing initiatives include: • Kalispell Municipal Pollution Prevention Good Housekeeping Guidance Manual: The manual (Appendix E) presents a summary of City fixed facilities, field operations, good housekeeping measures, training procedures, and best management practices to be employed by the City. The objective of the Manual is to reduce the potential for polluting or negatively impacting local receiving water from stormwater runoff (updated 2019). o Years implemented:  2013-Current • Stormwater Pollution Prevention Training: The City of Kalispell trains employees on how to incorporate pollution prevention/good housekeeping techniques into municipal facility and field operations. All employees of the MS4 owner, operator, and leaseholders whose activities can potentially impact surface waters are required to receive training regarding stormwater quality and municipal operation. o Number of participants trained:  2013: 93 employees of the MS4  2014: 84 employees of the MS4  2015: 48 employees of the MS4  2016: 60 Public Works employees  2017: 51 Public Works employees  2018: 31 Public Works employees  2019: 59 employees of the MS4  2020: 91 employees of the MS4 45 of 334 ---PAGE BREAK--- • Street Sweeping: Kalispell streets are swept on a routine basis. During spring sweeping operations, streets are swept more often to collect winter sanding material. Routine sweeping practices include: operating sweeper to get optimal debris removal, if a storm drain is plugged or high pollutant loading has been found in certain areas additional sweeping will be scheduled, sweeping is scheduled immediately after street repair projects and water and sewer repair projects, sweeping is immediately scheduled after special events such as street fairs, art shows, and parades. Starting in 2019, drones were used to measure sweepings piles. o Years implemented: 1100 962 896 921 830 [PHONE REDACTED] 1650 1443 1344 1382 1245 1362 912 3265 0 500 1000 1500 2000 2500 3000 3500 2013 2014 2015 2016 2017 2018 2019 2020 Cubic yards of sweepings & Tons of sand/sediment Year Cubic yards of sweepings Tons of sand/sediment 46 of 334 ---PAGE BREAK--- • Leaf Collection: Kalispell streets are swept and cleaned on a routine basis in the fall to collect leaves. During fall leaf sweeping operations, leaves are collected from streets, curbs, and gutters using sweepers, loaders, and vacuum trucks. Public service announcements are sent to inform Kalispell citizens of the correct leaf collection and disposal method and routes. The leaves are collected and deposited at the City compost site. Starting in 2019, drones were used to measure leaf piles. o Years implemented: • Storm Drainage System Inspection and Cleaning Program: To ensure a function and performance, maintenance of the storm drainage system must be conducted. Catch basins, storm drain inlets, and other conveyance structures in high pollutant load areas are identified and cleaned before the wet season to remove sediments and debris accumulated during the summer. During routine maintenance and inspections and the condition of the sewer and areas that need repair or maintenance are noted, evidence of illegal discharge or illicit connections are looked for and reported to supervisors. The MS4 has a goal to clean 100 manholes and storm drain inlets each year. o Years implemented:  2013: 117 inspected and cleaned  2014: 237 inspected and cleaned  2015: 319 inspected, 114 cleaned  2016: 295 inspected, 212 cleaned  2017: 196 inspected, 99 cleaned  2018: 422 inspected and cleaned  2019: 251 inspected and cleaned  2020: 273 inspected and cleaned 1701 1220 1612 1588 1620 3703 2219 2032 306 220 290 286 292 667 399 366 0 500 1000 1500 2000 2500 3000 3500 4000 2013 2014 2015 2016 2017 2018 2019 2020 Cubic yards of leaves & Tons of leaves Year Cubic yards of leaves Tons of leaves 47 of 334 ---PAGE BREAK--- 5.5.3 Planned Initiatives As specified in the MS4 General Permit, the following BMPs will be continued from previous permit cycles with updates to include new MS4 General Permit requirements or new BMPs will be developed and implemented throughout the current permit cycle. POLLUTION PREVENTION/GOOD HOUSEKEEPING GUIDANCE MANUAL AND TRAINING GH-1 DESCRIPTION: The Kalispell Municipal Pollution Prevention/Good Housekeeping Guidance Manual presents a summary of City fixed facilities, field operations, standard operating procedures for good housekeeping measures, training procedures, and best management practices (BMPs) to be employed by the City. The objective of the Manual is to reduce the potential for polluting or negatively impacting local receiving water from stormwater runoff. RATIONALE FOR SELECTION: An operation and maintenance program which includes a training component, and has the ultimate goal of preventing or reducing pollutant runoff from municipal facilities and field activities. Meets MS4 General Permit requirements. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017 1. Review and update PPGH Guidance Manual as necessary for: a. Facilities and activities that have the potential to release contaminants to the MS4. b. List of possible contaminants associated with each facility and activity. c. List local departments and positions responsible for pollution prevention with each facility and activity. 1st Permit Year 2018- 2021 1. Review and update PPGH Guidance Manual facility/activity inventory as necessary. 2. Review and update PPGH Guidance Manual map ensuring identification of the location of facilities and activities. 3. Review and update PPGH Guidance Manual as necessary to: a. Develop PPGH standard operation procedures (SOPs) for inventoried facilities and activities categorized by similar operations. b. SOPs will include documented inspections and communication with relevant personnel of 2 facilities/activities per category prior to SOP category completion. 4. Complete SOPs as noted in the MS4 General Permit: a. One-fourth by end of the second permit year b. One-half by end of the third permit year c. Three-fourths by end of the fourth permit year d. All by end of the fifth permit year 5. PPGH Training a. Develop and document training in conjunction with the development of the facility/activities SOPs 2nd, 3rd, 4th, 5th Annual Report 48 of 334 ---PAGE BREAK--- b. Conduct annual training for all permittee staff directly involved with the implementation of the SOPs. c. Retain a record of completed training and attendance. STREET SWEEPING PROGRAM GH-2 DESCRIPTION: Kalispell streets are swept on a routine basis. During spring sweeping operations, streets are swept more often to collect winter sanding material. Routine sweeping practices include: • Operations of sweeper to get optimal debris removal • If storm drain plugging or high pollutant loading has been found in certain areas, schedule additional sweeping in those areas • Schedule sweeping immediately after street repair projects and water/sewer repair projects • Schedule sweeping immediately after special events like street fairs, art shows, and parades RATIONALE FOR SELECTION: Implementation of operational controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, and municipal parking lots. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017- 2021 1. Implement the Street Sweeping Program 2. Track the quantity of street sweepings collected Annually LEAF COLLECTION PROGRAM GH-3 DESCRIPTION: Kalispell streets are swept and cleaned on a routine basis in the fall to collect leaves. In the fall season, leaves are collected from streets, curbs, and gutters using sweepers, loaders, and vacuum trucks. Public Service Announcements are sent to inform Kalispell citizens of the correct leaf collection disposal method and routes. The leaves are collected and deposited at the City compost site. RATIONALE FOR SELECTION: Implementation of operational controls for reducing or eliminating the discharge of pollutants from streets, roads, highways, and municipal parking lots. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017- 2021 1. Implement the Leaf Collection Program 2. Track quantity of leaves collected Annually 49 of 334 ---PAGE BREAK--- STORM DRAINAGE SYSTEM INSPECTION AND CLEANING PROGRAM GH-4 DESCRIPTION: Kalispell created and implemented a storm drainage system inspection and cleaning protocol in 2008 and ensures the following goals: • Clean 100 manholes and storm drain inlets each year. • Catch basins, storm drain inlets, and other conveyance structures in high pollutant load areas are identified and cleaned to remove sediments and debris accumulated during the summer. • During routine maintenance and inspections, note the condition of the sewer and identify areas that need repair or maintenance, look for evidence of illegal discharge or illicit connections, and report the illicit discharge to a supervisor. RATIONALE FOR SELECTION: The implementation of operation/maintenance controls reduce floatables, sediment, nutrients and other pollutant loadings from municipal systems to receiving waterbodies. YEAR IMPLEMENTATION ACTIVITY SCHEDULE 2017- 2021 1. Inspect and clean catch basins and manholes in areas outlined in the program annually. 2. Track the number of catch basins and manholes inspected and cleaned to ensure program conformance. Annually 50 of 334 ---PAGE BREAK--- 6 Training Kalispell will create, conduct, and document training to meet the MS4 General Permit requirements as outlined in the following sections. All training presentations will be saved on the Public Works Server in a designated Stormwater Folder and will be updated as needed to meet progress changes to the SWMP and BMPs as required by the MS4 General Permit. Training participation will be tracked, documented, and saved in each employee’s individual account in the City’s ADG Database. 6.1 Stormwater Management Team Stormwater Management training provides comprehensive information regarding the MS4 General Permit, the SWMP and respective BMPs, timelines, goals, and define implementation responsibilities of each stormwater management member to ensure MS4 General Permit compliance. Regular meetings and frequent contact between team members ensure that the management team is current and meeting permit requirements. 6.1.1 Frequency The initial training will be conducted the 1st year of the permit (2017). New members of the stormwater management team will receive the equivalent amount of training within 90 days of their hire date. 6.2 Field Management-IDDE Stormwater Field Management training provides education regarding stormwater impacts, the MS4 General Permit, the detection and elimination of illicit discharges, the implementation of the ERP, and address BMPs necessary to minimize discharges of pollutants during permittee activities or the operation of permittee facilities. 6.2.1 Frequency The training will be conducted at a minimum, during 1st (2017) and 4th (2020) years of the permit term for all appropriate permittee field staff (and pretreatment inspection staff) and staff who work at permittee facilities. Appropriate new field staff and staff who work at permittee facilities will receive the equivalent amount of training within 90 days of their hire date. 6.3 Construction Site Stormwater Management Construction Site Stormwater plan review and inspection training is provided for all inspectors and plan reviewers responsible for implementation of the Construction Site Stormwater Management Control Minimum Measure. Training topics include plan review and inspection protocol, ordinance updates requirements, and the implementation of the ERP as outlined in the Construction Site Stormwater Management Control Minimum Measure. 6.3.1 Frequency The training will be conducted at a minimum, during the 1st (2017) and 4th (2020) years of the permit term for all inspectors and plan reviewers responsible for implementation of the Construction Site Stormwater Management Control Minimum Measure. New inspectors and plan reviewers will receive the equivalent amount of training within 90 days of their hire date. 6.4 Post-Construction Stormwater Management Post-Construction Stormwater Management training is provided for all inspectors and plan reviewers responsible for implementation of the Post-Construction Stormwater Management in New 51 of 334 ---PAGE BREAK--- Development and Redevelopment Minimum Measure. Training will include plan review and inspection protocol, ordinance update requirements, and the implementation of ERP as outlined in the Post- Construction Stormwater Management Minimum Measure. 6.4.1 Frequency The training will be conducted at a minimum, during the 1st (2017) and 4th (2020) years of the permit term for all inspectors and plan reviewers responsible for implementation of the Post-Construction Stormwater Management in New Development and Redevelopment Minimum Measure. New inspectors and plan reviewers will receive the equivalent amount of training within 90 days of their hire date. 6.5 Field Management-PPGH Stormwater Field Management training provides education for staff responsible for implementing Standard Operating Procedures (SOPs) developed as a requirement of the Pollution Prevention/Good Housekeeping Minimum Measure. Training will be oriented to staff involved with the specific duties addressed for each SOP. 6.5.1 Frequency The training will be conducted at the schedule outlined in Part II.6.a.v of the MS4 General Permit. Appropriate new field responsible for implementing SOPs will receive the equivalent amount of training within 90 days of their hire date. 6.6 Municipal Employee Awareness All new employees of the City of Kalispell are required to watch two videos on stormwater to complete orientation. One video provides information on what is stormwater and why it is important and the second video provides information on how to detect illicit discharges. 6.6.1 Frequency The training is conducted during new hire training and orientation. 7 Stormwater Management for Discharges to Impaired Waterbodies - Overview For the full Stormwater TMDL Action Plan and additional details see Appendix F. There are six named or perennial surface waters that receive stormwater discharges from outfalls within the City of Kalispell’s MS4 boundary. These receiving waters are as follows: • Whitefish River • Stillwater River • Ashley Creek • Spring Creek • Bowser/Little Spring Creek- Aka Kids Creek-Classified as an unnamed perennial • Unnamed perennial surface water tributary to Ashley Creek from Foys Lake Appendix B provides the most up to date map of the City’s outfalls and associated water bodies. Whitefish River, Stillwater River, Spring Creek, and Ashley Creek are classified as impaired surface waters 52 of 334 ---PAGE BREAK--- of the state and each has an approved pollutant Total Maximum Daily Loads with waste load allocations (WLA). The following sections summarize the associated pollutant impairment for each listed impaired waterbody, the corresponding TMDL WLA, and the best management practices that target and reduce pollutants of concern from the MS4 discharge. The table below summarizes the impaired waterbody with within the Kalispell MS4 General Permit boundary and the associated pollutant(s) of impairment. Waterbody TMDL/ Impairment Pollutant for Kalispell’s MS4 Permit Total Phosphorus (TP) Total Nitrogen1 (TN) Dissolved Oxygen (DO) Sediment (Sed) Temperature (Temp) Whitefish River • Stillwater River • Spring Creek • • • Ashley Creek (Middle and Lower Segments) • • • • • 1. TN is a surrogate TMDL for Nitrate + Nitrite 2. More information on the TMDL’s related to Kalispell can be found in the Flathead-Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan 7.1 Nutrients-Total Phosphorus (TP) and Total Nitrogen (TN) DEQ performed a water quality assessment on listed waterbodies to determine pollutant impairments and TMDL WLAs. In the adopted Flathead-Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan the City of Kalispell has been identified as a contributing source of pollutants for Nutrients specified as Total Phosphorus and Total Nitrogen to Middle Ashley Creek and Lower Ashley Creek segments, and Spring Creek. WLAs for each segment are provided in the following table. Nutrient TMDL WLA Middle Ashley Creek Lower Ashley Creek Spring Creek Total Phosphorus (TP) 15 lbs/growing season1 (44% reduction) 54 lbs/growing season (44% reduction) 13 lbs/growing season (44% reduction) Total Nitrogen 292 lbs/growing season (30% reduction) 1030 lbs/growing season (30% reduction) 269 lbs/growing season (30% reduction) 1. Growing season is defined in TMDL from July 1st to September 30th As represented in the MS4 General Permit, the Kalispell’s MS4 does not continuously discharge, and it only sporadically discharges during the dry summer growing season. Percent reduction allocations were developed, but the WLAs were not intended to add actual load limits to the MS4 General Permit. The TMDL WLAs are met by adhering to the General MS4 Permit requirements. 53 of 334 ---PAGE BREAK--- 7.1.1 Nutrient Target BMPs to Reduce Pollutant Loads The table below outlines pollutants of concern, contributors, and the specifically identified measures and BMPs that will collectively control the discharges of the pollutants of concern. Response BMPs for Nutrients Possible Contributors Minimum Measure* BMP Rational Residential Yard Maintenance 1 PE-1 Public Outreach Program Pollution Message, Education & Distribution to Target Audience PE-2 Public Outreach Website Pollution Message on Web 6 GH-3 Leaf Collection Greatly minimizes contribution of leaves to MS4 Pet Waste 1 PE-1 Public Outreach Program Pollution Message, Education & Distribution to Target Audience PE-2 Public Outreach Website Pollution Message on Web 2 PI-1 Public Involvement Program Awareness and participation at City Parks and designated Dog Parks 6 GH-1 PPGH Guidance Manual and Training Awareness and participation of City Parks Staff Land Development and Redevelopment 5 PC-1 Stormwater Quality Design Standards Stormwater Quality Controls to reduce nutrient contributions PC-2 Post-construction Stormwater Management Stormwater Quality Controls maintained to continue to reduce nutrient contributions PC-3 LID Concept Review LID Concept review, which has potential to reduce pollutant loads Public Education and Outreach on Stormwater Impacts, 2=Public Involvement/Participation, 3=Illicit Discharge Detection and Elimination, 4=Construction Site Stormwater Runoff Control, 5=Post-Construction Stormwater Management in New Development and Redevelopment, 6= Pollution Prevention/Good Housekeeping for Municipal Operations 54 of 334 ---PAGE BREAK--- 7.2 Dissolved Oxygen In the adopted Flathead-Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan the City of Kalispell has been identified as a contributing source of pollutants for Dissolved Oxygen (DO) to Middle Ashley Creek and Lower Ashley Creek segments, and Spring Creek. TMDL WLAs for each segment are provided in the following table. Dissolved Oxygen TMDL WLA Middle Ashley Creek Lower Ashley Creek Spring Creek Dissolved Oxygen None Specified None Specified None Specified As represented in the MS4 General Permit, there are no WLAs associated with this pollutant of concern. However, the City is still required to monitor and assess the potential for pollutant impact from the MS4’s discharge. 7.2.1 Dissolved Oxygen Target BMPs to Reduce Pollutant Loads The water quality improvements and target BMPs addressed in the Nutrient will result in improved DO concentrations. Therefore, the DO concentrations will improve by adhering to the permit requirements, discharge volumes and by utilizing the same Nutrient reducing BMPs listed above. 7.3 Sediment In the adopted Flathead-Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan the City of Kalispell has been identified as a contributing source of pollutants for Sediment to Middle Ashley Creek and Lower Ashley Creek segments, Spring Creek, and the Stillwater River. TMDL WLAs for each segment are provided in the following table. Sediment TMDL WLA Middle Ashley Creek Lower Ashley Creek Stillwater River Sediment 15.4 tons/year (62% reduction) 46.5 tons/year (62% reduction) 16.5 tons/year (62% reduction) As represented in the MS4 General Permit, percent reduction allocations were developed, but the WLAs are not intended to add load limits to the MS4 General Permit. The TMDL WLAs are met by adhering to the MS4 General Permit requirements. 7.3.1 Sediment Target BMPs to Reduce Pollutant Loads The table below outlines pollutants of concern, contributors, and the specifically identified measures and BMPs that will collectively control the discharges of the pollutants of concern. 55 of 334 ---PAGE BREAK--- Response BMPs for Sediment Possible Contributors Minimum Measure* BMP Rational Construction Activities 4 C-1 Land Disturbance Ordinance Ordinance establishes regulation/enforcement mechanism for construction site preventative controls C-2 Construction Site Stormwater Management Program for training, plan review, permit, inspections, and tracking to ensure pollution prevention during construction 1 PE-1 Public Outreach Program Pollution Message, Education, Training & Distribution to Target Audience PE-2 Public Outreach Website Pollution Message, Permit Access on Website 2 PI-1 Public Involvement Program Education and Participation from Public to solicit input and notify City of pollution PI-2 Public Involvement Website Participation from Public and Stakeholders to solicit input and notify City of pollution 6 GH-1 PPGH Guidance Manual and Training Awareness, SOPs, and participation of City Staff for City projects to reduce pollutants Municipal Facilities and Activities 6 GH-2 PPGH Guidance Manual and Training Awareness, SOPs, and participation of City Staff for City activities and facility operations to reduce pollutants GH-2 Street Sweeping Program Program greatly minimizes contribution of sediment to MS4 GH-3 Leaf Collection Program Program greatly minimizes contribution of pollutants to MS4 GH-4 Strom Drainage System Inspection and Cleaning Program Program greatly minimizes contribution of pollutants to MS4 Land Development and Redevelopment 5 PC-1 Stormwater Quality Design Standards Stormwater Quality Controls to reduce pollutant contributions PC-2 Post-construction Stormwater Management Stormwater Program for Water Quality Controls to track and maintained in order to continue reduction of pollutant contributions PC-3 LID Concept Review LID Concept review which has potential reduce pollutant loads Public Education and Outreach on Stormwater Impacts, 2=Public Involvement/Participation, 3=Illicit Discharge Detection and Elimination, 4=Construction Site Stormwater Runoff Control, 5=Post-Construction Stormwater Management in New Development and Redevelopment, 6= Pollution Prevention/Good Housekeeping for Municipal Operations 56 of 334 ---PAGE BREAK--- 7.4 Temperature In the adopted Flathead-Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan the City of Kalispell has been identified as a contributing source of pollutants for Temperature to Middle Ashley Creek and Lower Ashley Creek segments, and the Whitefish River. TMDL WLAs for each segment are provided in the following table. Temperature TMDL WLA Middle Ashley Creek Lower Ashley Creek Whitefish River Temperature None Specified None Specified None Specified As represented in the MS4 General Permit, there are no WLAs associated with this pollutant of concern. However, the City is still required to monitor and assess the potential for pollutant impact from the MS4’s discharge. 7.4.1 Temperature Target BMPs to Reduce Pollutant Loads As stated in the MS4 General Permit, the discharge temperatures will be consistent with naturally occurring conditions by the City of Kalispell MS4 adhering to the permit requirements. Therefore, the City will meet the TMDL and MS4 General Permit through the implementation, monitoring, and evaluation outlined in the SWMP. 8 TMDL Action Plan In order to meet the TMDL requirements of the MS4 General Permit, Kalispell will include as a part of the SWMP a section titled “TMDL Action Plan” (Appendix The plan will identify how Kalispell will progress toward meeting the TMDL by: • Identify the measures and BMPs it plans to implement • Describing the MS4’s impairment priorities and long-term strategy • Outlining interim milestones a schedule for action items) for controlling the discharge of the pollutants of concern • Evaluation of the progress towards meeting the TMDL Additionally, TMDL related monitoring will be performed to evaluate the effect of the BMPs selected for reducing MS4 loading (option 2) to the impaired waterbodies. A sampling plan including strategy rationale, monitoring frequency, parameters, and locations has been developed and submitted with the 1st Annual Report (2017) (Appendix Upon MDEQ approve of the sampling plan, the City must provide a mechanism for the Public to review and submit comments. The TMDL sample plan will begin no later than March 1st of the 2nd permit year. The TMDL Action Plan has been developed and submitted with the 4th year Annual Report for MDEQ approval (Appendix Upon approval, the permittee will begin to implement the approved section no later than the start of the 5th permit year. The Action Plan will be evaluated annually based on monitoring results, revised as needed, and resubmitted with Annual Reports beginning with the 5th year Annual Report. A rationale will be provided for any revisions to the Action Plan and revisions are required to be approved by the MDEQ. 57 of 334 ---PAGE BREAK--- 9 Self-Monitoring The City is required to collect stormwater samples semiannually at four locations for the following parameters: • Sediment (Total Suspended Solids) • Nutrients (Total Nitrogen, Total Phosphorus) • Metals (Copper, Lead, Zinc) • Oils & Grease • pH • Organics (Chemical Oxygen Demand) • Water Temperature Kalispell selected Option 2, as outlined in the MS4 General Permit, for monitoring locations. One location represents stormwater runoff from a predominantly residential area, the second location represents stormwater runoff from a predominantly commercial/industrial area, the third location represents stormwater runoff from a large drainage area combining both commercial and residential areas, and the fourth location is in Ashley Creek outside of the MS4 boundary. The following table provides location, land use correlation, and naming scheme. Monitoring results will be used by the City to self-evaluate measures taken to improve the quality of stormwater discharges. Each annual report will include an evaluation of the monitoring results relative to the long-term median. The evaluation will include comparisons between monitoring locations, discuss determinations for trends and outliers in monitoring results compared to the calculated long- term median or results outside a pH range of 6.0 to 9.0 standard units, and a schedule and rationale for BMPs planned to improve water quality of stormwater discharges based on monitoring results. The monitoring results from 2020 can be found in Appendix G. Self-Monitoring Option 2-Monitoring Summary Permit Identification Residential/ Commercial Drainage Area (Acre) Lat/Long Kalispell ID Waterbody DEQ Location SWR-4 Residential 30% Commercial 70% 266 Lat: 48°11’40” N Long: 114°17’56” W Sylvan Drive Stillwater River 001 SWR-7 Commercial /Industrial 100 Lat: 48°12’27” N Long: 114°18’49” W Wyoming ST Stillwater River 002 AC-A In-stream Outside MS4 Boundary NA Lat: 48°11’43” N Long: 114°22’23” W In-stream at Dern Road Ashley Creek 003-A AC-11 Residential 294 Lat: 48°11’10” N Long: 114°19’18” W 11 St West Ashley Creek 004 58 of 334 ---PAGE BREAK--- 10 SWMP Management Team, Responsibilities, and Communications The City is responsible to implement a coordinated stormwater program inclusive of the development of a stormwater management team comprised of persons responsible for implementation of the SWMP and the establishment of formal mechanisms for communication and coordination between team members (e.g. meetings, email updates, etc.) to ensure cooperation necessary to facilitate permit compliance and timely reporting. 10.1 SWMP Management Team The City of Kalispell is governed by the Mayor and Council and is managed by a City Manager. The City Manager is the principal executive officer and therefore is the certified official to sign documents for the MS4 General Permit. The Public Works Department is responsible to develop, implement, adhere, and enforce all aspects of the MS4 General Permit. The primary SWMP Coordinator will be the responsibility of the personnel performing the Engineer II position within the Public Works Department. The following is an organizational chart identifying City staff and MS4 General Permit responsibilities. 59 of 334 ---PAGE BREAK--- 60 of 334 ---PAGE BREAK--- 10.2 SWMP Management Team Communication The MS4 has established, formalized mechanisms for regular communication between stormwater management team members to allow for the exchange of information and submittal of information necessary for permit compliance tracking and reporting. The SWMP Coordinator will be responsible for the management and compliance of the Kalispell’s MS4 General Permit. Communication mechanisms will be performed using email, phone, webpage, and a data storage server, database through the following avenues: Direct communication between team members: - Meetings o Meetings will be held on a basis, when applicable, with all management team members to review all aspects of permit compliance. o Public Works Director’s Meeting – Held weekly with Public Works office staff  In 2021, this meeting was changed to just supervisors. Staff provide weekly updates to supervisors which are discussed at the meeting. o Engineering Meeting – Held weekly for engineering staff to review new and re- development projects o City Engineer’s Meeting – Short morning meeting held daily with staff supervised by the City Engineer (not held on days with the Director’s and Engineering Meeting) o Additional informal, in-person meetings will be held as needed and as issues arise. - Email updates o Update emails will be sent on a basis to the entire management team. This will ensure the team stays informed and involved with deadlines and updates. o Email will be utilized to correspond with Stormwater Management Team Members regarding questions, information distribution, etc. - Phone o Phone calls and messages will be used as required to coordinate with Team Members. Informational communication between team members: - Shared network server o Shared access to stormwater data storage on a shared network server will allow easy document coordination and accessibility. o The server will store all information for the SWMP including training presentation, programs, BMPs, required contact information, monitoring, evaluation, and annual reports. - Memorandums o Memorandums will be distributed, as needed, to ensure all Team Members are up to date and in permit compliance. 61 of 334 ---PAGE BREAK--- Appendix A: Drainage Basin Summary Within Kalispell City limits there are 112 drainage basins. The drainage basins within the City limits outfall to several different systems including perennial surface waters, infiltration trenches, sloughs, and natural depressions. Within those 112 drainage basins, the City and Montana Department of Transportation (MDT) operate and maintain multiple separate storm sewer systems. There are six named or perennial surface waters that receive stormwater discharges from the City of Kalispell’s MS4. These receiving waters are as follows: • Whitefish River • Stillwater River • Ashley Creek • Spring Creek • Little Spring Creek-aka Kids Creek or Unnamed perennial surface water tributary to Spring Creek • Unnamed perennial surface water tributary to Ashley Creek from Foys Lake The Whitefish River, Stillwater River, Spring Creek, and Ashley Creek are classified as impaired surface waters of the state and accumulatively have seventy-eight delineated outfalls. The table below and Outfall Map (Appendix B) summarize the inventoried outfalls, discharge locations, associated waterbody, and City/MDT responsibility. 62 of 334 ---PAGE BREAK--- City of Kalispell and MDT MS4 Outfalls – MTR040005 No. Location Waterbody Sub- basin City MDT Sub-basin (Acres) Impaired Waterbody Pollutants of Impairment* 1 E Treatment Road Ashley Creek AC1 X X 27.22 YES TP, TN, Sed, DO, Temp 2 Teal Dr Ashley Creek AC2 X 48.00 YES TP, TN, Sed, DO, Temp 3 Rudy Duck Ditch Ashley Creek AC3 X 34.85 YES TP, TN, Sed, DO, Temp 4 Begg Park Dr Ashley Creek AC4 X 40.15 YES TP, TN, Sed, DO, Temp 5 N Belmar Dr Ashley Creek AC5 X 7.95 YES TP, TN, Sed, DO, Temp 6 17 St W Ashley Creek AC6 X X 542.30 YES TP, TN, Sed, DO, Temp 7 Sunny Side Dr Ashley Creek AC7 X 35.89 YES TP, TN, Sed, DO, Temp 8 Rimrock Ct Ashley Creek AC8 X 3.05 YES TP, TN, Sed, DO, Temp 9 Denver Ave (south) Ashley Creek AC9 X 17.88 YES TP, TN, Sed, DO, Temp 10 Denver Ave (north) Ashley Creek AC10 X 2.74 YES TP, TN, Sed, DO, Temp 11 11 St W Ashley Creek AC11 X 291.49 YES TP, TN, Sed, DO, Temp 12 Old School Station Outfall 1 Ashley Creek AC13 X 39.59 YES TP, TN, Sed, DO, Temp 13 Kalispell Bypass South Ashley Creek AC14 X 0.82 YES TP, TN, Sed, DO, Temp 14 Kalispell Bypass South Ashley Creek AC15 X 35.03 YES TP, TN, Sed, DO, Temp 15 Southside Estates (South) Ashley Creek AC16 X 2.60 YES TP, TN, Sed, DO, Temp 16 Southside Estates (North) Ashley Creek AC17 X 5.08 YES TP, TN, Sed, DO, Temp 17 Rankin and Airport Rd Ashley Creek AC18 X 10.59 YES TP, TN, Sed, DO, Temp 18 Ashley Heights Ashley Creek AC19 X 8.38 YES TP, TN, Sed, DO, Temp 19 Hwy 93 S to south of Ashley Meadows Ashley Creek AC20 X 18.14 YES TP, TN, Sed, DO, Temp 20 Meadow Creek / Kenway Ashley Creek AC21 X 3.15 YES TP, TN, Sed, DO, Temp 21 Lonepine Meadow Detention Outfall Ashley Creek UT1 X 22.05 YES TP, TN, Sed, DO, Temp 22 Captain's Marine-Natural Depression Ashley Creek UT2 X 9.61 YES TP, TN, Sed, DO, Temp 23 Gardner Auction Services Ashley Creek UT3 X 7.60 YES TP, TN, Sed, DO, Temp 24 Kalispell Bypass North Little Spring Creek LSC1 X X 60.30 NO NA 25 Kalispell Bypass South Little Spring Creek LSC2 X X 18.52 NO NA 26 Spring Creek Retention Basin Outlet Spring Creek SC1 X X 703.78 YES TP, TN, Sed, DO 27 McDonalds and Car Lot Drainage-Hwy 2 Spring Creek SC2 X X 4.27 YES TP, TN, Sed, DO 63 of 334 ---PAGE BREAK--- City of Kalispell and MDT MS4 Outfalls – MTR040005 No. Location Waterbody Sub- basin City MDT Sub-basin (Acres) Impaired Waterbody Pollutants of Impairment* 28 Hwy 2 West So of Hampton Inn Spring Creek SC4 X X 4.18 YES TP, TN, Sed, DO 29 Hwy 2 West from Glenwood Dr and Gateway West Mall Detention Outfall Spring Creek SC6 X X 34.64 YES TP, TN, Sed, DO 30 Cooper Lane Spring Creek SC7 X 6.45 YES TP, TN, Sed, DO 31 Diamond Ridge Outfall 1 Spring Creek SC8 X 7.16 YES TP, TN, Sed, DO 32 Aspen Creek Detention Outfall 1 Spring Creek SC9 X 6.32 YES TP, TN, Sed, DO 33 Aspen Creek Detention Outfall 2 Spring Creek SC10 X 4.75 YES TP, TN, Sed, DO 34 Aspen Creek Detention Outfall 3 Spring Creek SC11 X 9.13 YES TP, TN, Sed, DO 35 Aspen Creek Detention Outfall 4 Spring Creek SC12 X 3.63 YES TP, TN, Sed, DO 36 Diamond Ridge Outfall 2 Spring Creek SC13 X 6.65 YES TP, TN, Sed, DO 37 Spring Creek Estates Under Ground Detention Facility Outfall Spring Creek SC14 X 51.11 YES TP, TN, Sed, DO 38 Mountain Vista Detention Outfall Spring Creek SC15 X 44.40 YES TP, TN, Sed, DO 39 Three Mile Drive, Stillwater Road, Northland Subdivision, Cottonwood Estates, Blue Heron Estates Spring Creek SC16 X 118.92 YES TP, TN, Sed, DO 40 Cascade Business Park- Financial Drive Spring Creek SC17 X 11.14 YES TP, TN, Sed, DO 41 Hampton Inn Spring Creek SC18 X 3.22 YES TP, TN, Sed, DO 42 Mountain Vista Phase 4 Spring Creek SC19 X 10.14 YES TP, TN, Sed, DO 43 Spring Creek Apartments Spring Creek SC20 X 4.66 YES TP, TN, Sed, DO 44 Fuel Fitness Spring Creek SC21 X 2.19 YES TP, TN, Sed, DO 45 Meadow's Edge Spring Creek SC22 X 62.55 YES TP, TN, Sed, DO 46 Greenbriar Spring Creek SC23 X 17.61 YES TP, TN, Sed, DO 47 Cottage Gardens Spring Creek SC24 X 11.97 YES TP, TN, Sed, DO 48 Appleway Edge Apartments Spring Creek SC25 X 1.22 YES TP, TN, Sed, DO 49 Glacier Village Greens-E Nicklaus Ave Outfall 1 Whitefish River WFR1 X 8.68 YES Temp 50 Glacier Village Greens-E Nicklaus Ave Infiltration Trench Whitefish River WFR2 X 5.54 YES Temp 51 Buttercup Loop-Willows Subdivision Stillwater River SWR1 X 60.03 YES Sed 52 Leisure Dr-Leisure Heights Stillwater River SWR2 X 8.49 YES Sed 53 Willow Glen-N of Woodland Dr Stillwater River SWR3 X X 1.38 YES Sed 64 of 334 ---PAGE BREAK--- City of Kalispell and MDT MS4 Outfalls – MTR040005 No. Location Waterbody Sub- basin City MDT Sub-basin (Acres) Impaired Waterbody Pollutants of Impairment* 54 Sylvan Dr-Detention Outfall Stillwater River SWR4 X X 267.70 YES Sed 55 Woodland Park Dr Stillwater River SWR5 X 63.08 YES Sed 56 Hwy 2 E at City limits Stillwater River SWR6 X X 8.12 YES Sed 57 E Wyoming St Stillwater River SWR7 X X 95.71 YES Sed 58 1st Ave EN Stillwater River SWR8 X 8.03 YES Sed 59 Lawrence Park Rd Stillwater River SWR9 X 1.37 YES Sed 60 River View Drive Stillwater River SWR1 0 X 25.67 YES Sed 61 Juniper Bend Drive Stillwater River SWR1 1 X 6.18 YES Sed 62 Stillwater Bluffs Detention Outfall Stillwater River SWR1 4 X 6.03 YES Sed 63 Eisinger Car Lot Stillwater River SWR1 5 X X 43.19 YES Sed 64 Silverbrook Estates Outlet1 Stillwater River SWR1 6 X X 151.49 YES Sed 65 Silverbrook Estates Outlet2 Stillwater River SWR1 7 X X 58.88 YES Sed 66 Silverbrook, Hwy 93, Church Dr Stillwater River SWR1 9 X X 26.71 YES Sed 67 Buffalo Hill Golf Course Outlet 1 Stillwater River SWR2 0 X 4.00 YES Sed 68 Buffalo Hill Golf Course Outlet 2 Stillwater River SWR2 1 X 9.23 YES Sed 69 Kalispell Bypass Outfall 1 (River Church) Stillwater River SWR2 2 X X 392.62 YES Sed 70 Greendale Ct Dry Bridge Slough DBS1 X 2.56 NO NA 71 Rogers Drive Dry Bridge Slough DBS2 X 4.03 NO NA 72 14 St E Dry Bridge Slough DBS3 X 82.07 NO NA 73 Kelly Road Outlet 1 Muskrat Slough MS1 X 3.01 NO NA 74 Condor Drive Muskrat Slough MS2 X 6.78 NO NA 75 Russel Drive Muskrat Slough MS3 X 2.17 NO NA 76 Muskrat Slough Outfall Muskrat Slough MS4 X 2.32 NO NA 77 Kelly Road Outlet 2 Muskrat Slough MS5 X X 82.36 NO NA 78 Muskrat Slough Outfall 2 Muskrat Slough MS6 X 1.07 NO NA 79 FVCC and Hutton Ranch - Natural Depression No Discharge to Water Body CB1 X X 212.90 NO NA 80 Glacier Village Greens-E Nicklaus Ave Infiltration Trench No Discharge to Water Body CB2 X 11.80 NO NA 65 of 334 ---PAGE BREAK--- City of Kalispell and MDT MS4 Outfalls – MTR040005 No. Location Waterbody Sub- basin City MDT Sub-basin (Acres) Impaired Waterbody Pollutants of Impairment* 81 Old School Station - Natural Depression No Discharge to Water Body CB5 X 16.06 NO NA 82 Grandview Drive - Natural Depression No Discharge to Water Body CB6 X X 154.63 NO NA 83 Gardner's PUD - Improved Natural Depression No Discharge to Water Body CB7 X 66.26 NO NA 84 Spring Prairie 4 No Discharge to Water Body CB8 X 55.50 NO NA 85 Glacier Village Greens - Ph 21 No Discharge to Water Body CB9 X 4.21 NO NA 86 Glacier Village Greens - Ph 21 No Discharge to Water Body CB10 X 3.30 NO NA 87 Mountain View Plaza No Discharge to Water Body CB12 X X 55.35 NO NA 88 Glacier Commons No Discharge to Water Body CB13 X 36.76 NO NA 89 Village Plaza No Discharge to Water Body CB14 X 4.71 NO NA 90 Physical Therapy Associates No Discharge to Water Body CB15 X 0.81 NO NA 91 Sunnyview / KRMC No Discharge to Water Body CB16 X 32.44 NO NA 92 Westview Estates Ph 1/2/3 No Discharge to Water Body CB17 X 32.05 NO NA 93 Glacier Rail Park No Discharge to Water Body CB18 X 44.59 NO NA 94 Kalispell North Town Center No Discharge to Water Body CB19 X X 102.07 NO NA 95 Buffalo Stage No Discharge to Water Body CB20 X 69.26 NO NA 96 Village Heights No Discharge to Water Body CB21 X 1.91 NO NA 97 Westwood Park No Discharge to Water Body CB22 X 6.91 NO NA 98 Empire Estates Park No Discharge to Water Body CB23 X 3.55 NO NA 99 Beehive Homes No Discharge to Water Body CB24 X 3.82 NO NA 100 Glacier Village Greens - Ph 20 No Discharge to Water Body CB25 X 2.84 NO NA 101 Glacier Village Greens - Ph 3/4 No Discharge to Water Body CB26 X 28.54 NO NA 102 KRMC Parking - E Meridian / Hwy 93 N No Discharge to Water Body CB27 X X 0.86 NO NA 103 KRMC Helipad No Discharge to Water Body CB28 X 4.36 NO NA 104 KRMC - Surgical Services Dr & Sunnyview Ln No Discharge to Water Body CB29 X 2.69 NO NA 105 Stratford Village No Discharge to Water Body CB30 X 33.81 NO NA 106 Murdoch's No Discharge to Water Body CB31 X X 4.51 NO NA 107 Owl View No Discharge to Water Body CB32 X 4.05 NO NA 66 of 334 ---PAGE BREAK--- City of Kalispell and MDT MS4 Outfalls – MTR040005 No. Location Waterbody Sub- basin City MDT Sub-basin (Acres) Impaired Waterbody Pollutants of Impairment* 108 Westview Ph 4 No Discharge to Water Body CB33 X 7.96 NO NA 109 Peterson Acre No Discharge to Water Body CB34 X 1.17 NO NA 110 Timberwolf Center No Discharge to Water Body CB35 X 12.11 NO NA 111 Appleway Apartments - Appleway Dr No Discharge to Water Body CB36 X 4.43 YES NA 112 Appleway Apartments - Appleway Dr No Discharge to Water Body CB37 X 3.15 YES NA * TP=Total Phosphorus, TN =Total Nitrogen, DO=dissolved Oxygen, Sed=Sediment, Temp=Temperature 67 of 334 ---PAGE BREAK--- Appendix B: Kalispell MS4 Map 68 of 334 ---PAGE BREAK--- Kalispell’s MS4 Map Stormwater infrastructure in Kalispell changes often due to new development or infrastructure improvements. On the next page is a snapshot, overview of Kalispell’s stormwater infrastructure. Kalispell’s MS4 infrastructure is best viewed online with an interactive map that is regularly updated. 69 of 334 ---PAGE BREAK--- 70 of 334 ---PAGE BREAK--- Appendix C: Illicit Discharge Detection and Elimination (IDDE) Program 71 of 334 ---PAGE BREAK--- ILLICIT DISCHARGE DETECTION AND ELIMINATION PROGRAM City of Kalispell 201 1st Street E Kalispell, MT 59901 72 of 334 ---PAGE BREAK--- 1 Contents 1 INTRODUCTION 3 2 ORDINANCE 3 2.1 City Ordinance 3 3 ASSESSMENT OF ILLICIT DISCHARGE POTENTIAL 4 3.1 Delineate Subwatersheds 4 3.2 Compile Mapping Layers and Subwatershed data 4 3.3 Compute Discharge Screening Factors 4 3.3.1 SF1: Past Discharge Complaints and Reports 4 3.3.2 SF2: Areas Prone to Incidents of Illegal Dumping 5 3.3.3 SF3: Age of Storm Sewer in Subwatershed 5 3.3.4 SF4: Areas Primarily Served by Onsite Sewage Disposal Systems 5 3.3.5 SF5: Outfall Drains in Industrial Areas 5 3.3.6 SF6 Outfall Discharges to an Impaired Water Body 5 3.3.7 SF7 Size of Drainage Basin 5 3.4 Screening for Illicit Discharge Potential at the Subwatershed and Community 5 3.5 Generate Maps to Support Field Investigations 6 3.6 Products and Outcomes 6 3.6.1 Delineated stormwater subwatersheds throughout the City 6 3.6.2 GIS database of subwatershed information 6 3.6.3 Subwatersheds screened, ranked, and prioritized for illicit discharge potential 6 3.6.4 Maps generated to support field investigation 7 4 SEARCHING FOR ILLICIT DISCHARGE PROBLEMS IN THE FIELD 7 4.1 Outfall Reconnaissance Inventory (ORI) 7 4.2 Interpreting ORI Data 8 4.3 Resources and Timing 9 4.3.1 Timing 9 4.3.2 Field Maps 9 4.3.3 Field Sheets 9 4.3.4 Equipment 9 4.3.5 Staffing 9 4.4 Completing the ORI 9 4.4.1 Section 1: Background Data 10 4.4.2 Section 2: Outfall Description 10 4.4.3 Section 3: Quantitative Characterization 10 73 of 334 ---PAGE BREAK--- 2 4.4.4 Section 4: Physical Indicators for Flowing Outfalls 10 4.4.5 Section 5: Physical Indicators for both Flowing and Non-flowing Outfalls 10 4.4.6 Section 6-8: Initial Outfall Designation and Actions 10 4.5 Obvious Discharges 10 5 INDICATOR MONITORING 11 5.1 Indicator Parameters to Identify Illicit Discharges 11 5.2 Methods to Analyze Indicator Samples 12 5.3 Techniques to Interpret Indicator Data 12 5.3.1 Flow Chart Method 12 5.3.2 Industrial Flow Benchmark 13 6 ILLICIT DISCHARGE INVESTIGATION AND CORRECTIVE ACTION PLAN 14 6.1 Source Detection and Investigation 14 6.1.1 Documentation 14 6.1.2 Site Visit 15 6.1.3 Prioritization 15 6.1.4 Notification of Appropriate Agencies 15 6.1.5 Select Appropriate Investigation Method 16 6.1.6 Document Investigation 17 6.2 Corrective Action Process and Procedures 17 6.2.1 Determine Type of Illicit Discharge 17 6.2.2 Assign Responsibility 17 6.2.3 Select Appropriate Corrective Action 18 6.2.4 Confirm and Document Elimination of Contamination Source 18 6.2.5 Enforcement Actions 18 7 IDDE PROGRAM TRACKING AND EVALUATION 19 7.1 Tracking System 19 7.2 Program Evaluation 19 8 REFERENCES 19 9 APPENDIX 20 9.1 Appendix A - Outfall Reconnaissance Inventory Field Sheet 20 9.2 Appendix B - Indicator Parameter Flow Chart 23 9.3 Appendix C – Enforcement Response Plan for Stormwater Management within the City of Kalispell, Montana 25 74 of 334 ---PAGE BREAK--- 3 1 INTRODUCTION Discharges into storm conveyance systems may include wastes and wastewater from non- storm sources. A portion of these flows are from illicit and/or inappropriate discharges and connections to the storm conveyance systems. Illicit discharges enter the system through either direct connections wastewater piping either mistakenly or deliberately connected to the storm drains) or indirect connections infiltration into the storm sewer from cracked sanitary systems, spills collected by drain outlets, paint or used oil dumped directly into a drain). The results are untreated discharges that contribute high levels of pollutants, including heavy metals, toxins, oil and grease, solvents, nutrients, viruses, and bacteria to receiving water bodies. Pollutant levels from these illicit discharges have been shown in EPA studies to be high enough to significantly degrade receiving water quality and threaten aquatic, wildlife, and human health. Requirements of the Clean Water Act (1987) necessitate National Pollutant Discharge Elimination System (NPDES) permits for stormwater discharges. Section 402 requires that permits for municipal separate storm sewers shall include a requirement to effectively prohibit problematic non-storm water discharges into storm sewers. This requires affected agencies to identify and locate sources of non-storm water discharges into storm drains so they may institute appropriate actions for their elimination. The City of Kalispell has an established Illicit Discharge Detection and Elimination (IDDE) program that has been reducing illicit discharges for nearly a decade. This plan updates and establishes methods for controlling the introduction of pollutants into the storm sewer system in order to comply with requirements of the Montana Pollutant Discharge Elimination System (MPDES) General Permit for stormwater discharges associated with Small Municipal Separate Storm Sewer Systems (Small MS4s) (Permit No. MTR040005). Part of this plan is intended to be in compliance with section II.A.3.f.i (Illicit Discharge Investigation and Corrective Action Plan) of the MS4 Permit (Section 2 ORDINANCE 2.1 City Ordinance The City of Kalispell’s Ordinance 1831 established regulations controlling the introduction of pollutants and prohibiting illicit connections and discharges into the City’s municipal separate storm sewer system (MS4). The ordinance can be found online at: City of Kalispell - Ordinance 1831: 75 of 334 ---PAGE BREAK--- 4 3 ASSESSMENT OF ILLICIT DISCHARGE POTENTIAL To determine the potential severity of illicit discharges within the City of Kalispell, mapping along with other available data were used in a desktop assessment. Subwatersheds or land uses were identified that merit priority investigation. This assessment had five basic elements: 1. Delineate subwatershed or drainage areas within the City 2. Compile available mapping and data for each drainage unit (e.g. land use, age, outfalls, infrastructure history) 3. Derive subwatershed discharge screening factors using GIS analysis 4. Screen and rank illicit discharge potential at the subwatershed and community level 5. Generate maps to support field investigations 3.1 Delineate Subwatersheds The City’s MS4 has been divided into smaller, more manageable planning subwatersheds based on outfalls. City staff used the contour and knowledge of drainage systems for subwatershed delineation and mapped the system in GIS. 3.2 Compile Mapping Layers and Subwatershed data The City acquired and compiled existing data for each subwatershed identified. The data layers collected per watershed are listed below: • Aerial photos • Subwatersheds • MPDES stormwater permittees • Hydrology including pipes and streams • Outfalls • Storm sewer system • Standards Industrial Classification Codes for all industries • Land use or Zoning • Street Map • Topography • Area served by septic systems 3.3 Compute Discharge Screening Factors To determine illicit discharge potential (IDP), discharge factors were defined and computed for each subwatershed. The City used 6 different discharge screening factors (SF). The screening factors are listed below, along with how they are measured or defined. 3.3.1 SF1: Past Discharge Complaints and Reports The frequency of past discharge complaints, reports, and spill responses per subwatershed within the last 5 years. IDP was determined with the following scale: < 3 = 1; 3-8 = 2; > 8 = 3 76 of 334 ---PAGE BREAK--- 5 3.3.2 SF2: Areas Prone to Incidents of Illegal Dumping Areas prone to illicit discharges have been identified using Table A.1 from the IDDE manual created by the Center for Watershed Protection. All sites in Table A.1 with an illicit discharge potential of medium or higher associated with illegal dumping were counted. The IDP was determined for each subwatershed on the following scale: < 5 = 1; 5-10 = 2; >10 = 3 3.3.3 SF3: Age of Storm Sewer in Subwatershed The average age of the storm sewer system in a subwatershed can predict the potential of illicit discharge problems. IDP was determined on the following scale: < 20 years old = 1; 20 to 50 years old = 2; > 50 years old = 3 3.3.4 SF4: Areas Primarily Served by Onsite Sewage Disposal Systems Subwatersheds that are served by septic systems have a high IDP. IDP was determined on the following scale: 0-20% of area = 1; 20-50% of area = 2; > 50% of area = 3 3.3.5 SF5: Outfall Drains in Industrial Areas Outfalls that drain industrial areas have an elevated IDP compared to other zoning types. IDP was determined on the following scale based on the percentage of the watershed made up of industrial development: 0-20% of area = 1; 20-50% of area = 2; > 50% of area = 3 3.3.6 SF6 Outfall Discharges to an Impaired Water Body Stormwater outfalls to impaired waters require greater monitoring. Impaired waters have elevated levels of pollutants of concern and therefore, pollution needs to be reduced and/or eliminated to improve water quality. The IDP was determined on the following scale: outfall discharges to an unimpaired water = 1; outfall discharges to a water body impaired for 1 pollutant = 2; outfall discharges to a water body impaired for more than one pollutant = 3 3.3.7 SF7 Size of Drainage Basin The size of a drainage basin has a strong correlation with the IDP potential. Large drainage basins can have multiple land uses and more opportunities for negligent stormwater practices. The IDP was determined on the following scale dependent on the size (acres) of the drainage basin: 1 – 20 acres = 1; 20 – 70 acres = 2; >70 acres = 3 3.4 Screening for Illicit Discharge Potential at the Subwatershed and Community Level The City used the above listed and defined seven screening factors to evaluate each subwatershed’s illicit discharge potential. The total subwatershed score for all the screening factors was then used to designate whether it has low, medium, or high illicit discharge potential. Table 1 provides an example of the City’s prioritizing of subwatersheds using the IDP screening factors. 77 of 334 ---PAGE BREAK--- 6 Table 1: Prioritizing Subwatersheds Using IDP Screening Factors Subwatershed SF1 SF2 SF3 SF4 SF5 SF6 SF 7 Raw IDP Score Averaged IDP Score** AC6 5 33 16 1% 0% 5 546 14 2.0 SWR-4 0 20 39 0% 0% 1 266 13 1.9 Notes: *The number in parentheses is the IDP “score” (with 3 having a high IDP) earned for that subwatershed and screening factor. Basis for assigning scores (based on benchmarks) to assess IDP is as follows: SF1: Past discharge complaints/reports: < 3 = 1; 3-8 = 2; >8 = 3 SF2: Areas prone to incidents of illegal dumping: < 5 = 1; 5-10 = 2; >10 = 3 SF3: Age of storm sewer in subwatershed: < 20 years old = 1; 20-50 years old = 2; >50 years old = 3 SF4:Areas primarily served by onsite sewage disposal systems: 0-20% of area = 1; 20-50% of area = 2; >50% of area = 3 SF5: Outfall drains industrial areas: 0-20% of area = 1; 20-50% of area = 2; >50% of area = 3 SF6: Outfall discharges to an impaired water body: discharge to an unimpaired water body = 1; discharge to a water body impaired for 1 pollutant = 2; discharge to a water body impaired for more than 1 pollutant = 3 SF7: Size of sub watershed: 1-20 acres = 1; 20 - 70 acres = 2; >70 acres = 3 **Averaging the raw IDP scores (by dividing the raw score by the number of screening factors assessed produces scores that fall into a standard scale of 1 to 3 for low to high IDP 3.5 Generate Maps to Support Field Investigations Maps were generated as needed for field crews to use to screen outfalls in priority subwatersheds. The maps show streams, channels, streets, aerial photos, and known outfall locations. 3.6 Products and Outcomes Through performing these steps, the following was accomplished: 3.6.1 Delineated stormwater subwatersheds throughout the City The subwatersheds within the City of Kalispell were identified. In all, there are 78 different watersheds draining to surface water in the City of Kalispell. 3.6.2 GIS database of subwatershed information The subwatershed delineations, as well as the screening factors for each subwatershed, were put into the City of Kalispell’s GIS map. 3.6.3 Subwatersheds screened, ranked, and prioritized for illicit discharge potential Using the information compiled into ArcGIS, an analysis was run to compute each IDP score. A summary of the results indicating the number of high, medium, and low IDP subwatersheds are listed in Table 2. Table 2: Subwatersheds IDP Ranking IDP Averaged IDP score Number of Subwatersheds High 2 .33– 3 0 Medium 1.66 – 2.32 4 Low 1.0 – 1.65 74 78 of 334 ---PAGE BREAK--- 7 Subwatersheds marked as a high priority will be screened every year. 3.6.4 Maps generated to support field investigation Subwatersheds along with their corresponding IDP and ranking were put into the City of Kalispell’s GIS map. Maps can be quickly generated that are tailored directly to the needs of City staff for field investigations. 4 SEARCHING FOR ILLICIT DISCHARGE PROBLEMS IN THE FIELD Locating illicit discharge problems in the field involves investigative work, inducing rapid field screenings of outfalls in priority subwatersheds followed by indicator monitoring at suspected outfalls to characterize flow type and trace sources. The primary field screening tool is the Outfall Reconnaissance Inventory (ORI), which is used to find illicit discharge problems and develop a systematic outfall inventory and a map of the MS4. The ORI may be supplemented with more intensive indicator monitoring methods to test suspect outfalls. The search for illicit discharge problems yields important management products including: • An updated map of the locations of outfalls within the MS4 • Incorporation of the ORI data into the outfall inventory/tracking system • Design and implementation of an indicator monitoring strategy to test suspect outfalls • Creation of a local chemical fingerprint of pollutant concentrations for various discharge flow types 4.1 Outfall Reconnaissance Inventory (ORI) The City of Kalispell uses the Outfall Reconnaissance Inventory as a field screening technique. The ORI is designed to fix the geospatial location and record the basic characteristics of individual storm drain outfalls, evaluate suspect outfall, and assess the severity of illicit discharge problems in a community. The results of the ORI are then used to help guide future outfall monitoring and discharge prevention efforts. The ORI will be completed for every subwatershed outfall starting with priority subwatersheds identified in the illicit discharge potential assessment (see section Table 3 summarizes the four basic steps to conduct an ORI. 79 of 334 ---PAGE BREAK--- 8 Table 3: ORI Field Screening Step Strategies Step 1. Acquire necessary mapping, equipment, and staff 1. Use maps generated from IDP assessment 2. Minimal field equipment required 3. Two staff per crew with basic field training required Step 2. Determine when to conduct field screening 1. During dry season 2. After a dry period of at least 48 hours 3. Low groundwater levels Step 3. Identify where to conduct field screening based on priority from desktop assessment 1. Low IDP: integrate field screening with broader watershed or stream assessments 2. Medium IDP: screen drainage areas ranking high and medium first for illicit discharge potential 3. High IDP: screen all outfalls systematically Step 4. Conduct field screening 1. Mark and photograph all outfalls 2. Record outfall characteristics 3. Sample monitoring at flowing outfalls 4. Take flow sample at outfalls with likely problems 5. Deal with major problems immediately 4.2 Interpreting ORI Data The ORI data analysis will follow four basic steps outlined in Table 4. Table 4: Field Data Analysis Step Considerations Step 1. Compile data from the ORI 1. Compile GIS data and photographs of outfall locations 2. Enter ORI data into database 3. Send any samples for laboratory analysis Step 2. Develop ORI designation for outfalls 1. Use ORI data to designate outfalls as having obvious suspect, potential, or unlikely discharge potential Step 3. Characterize the extent of illicit discharge problems 1. Use data from initial assessment 2. Use outfall designation data 3. Update initial assessment of illicit discharge problems as minimal, critical, or severe Step 4. Develop a monitoring strategy 1. Inspect and screen high priority outfalls each year 2. Use various monitoring methods depending on outfall designation and subwatershed characteristics 80 of 334 ---PAGE BREAK--- 9 4.3 Resources and Timing The ORI requires modest mapping, field equipment, staffing, and training resources. 4.3.1 Timing Timing is important when performing ORI field work. City staff will conduct ORI fieldwork during the seasons with low groundwater levels and at least 48 hours after the last runoff-producing rain event. 4.3.2 Field Maps The field maps used for the ORI will be generated from the IDP assessment of the IDDE Program. At a minimum, the field maps will show streets, hydrologic features, delineated subwatershed, outfalls, storm drain systems, and aerial photos. 4.3.3 Field Sheets ORI field sheets will be used to record descriptive and qualitative information about each outfall inventoried. A copy of the ORI field sheet is provided in Appendix A. 4.3.4 Equipment Basic field equipment needed for the ORI includes: • Waders • Surgical gloves • 5 one liter sample bottles • Camera • Clipboards and pencils • Field sheets • Spray paint • Tape measure • Temperature probe • Watch • Pepper spray • Ammonia test strips • pH and conductivity meter • Color test strips • Wide-mouth container to measure flow 4.3.5 Staffing The ORI requires a least a two-person crew for safety and logistics. All crew members will be trained on how to complete the ORI and have a basic understanding of illicit discharges and their water quality impact. 4.4 Completing the ORI Field crews will visit each outfall location and physically mark them with spray paint or another permanent marker. City crews will also photograph each outfall and characterize its dimension, shape, and component material and record observations on basic sensory and physical indicators. If dry weather flow occurs at the outfall, additional flow and water quality data will be collected. Field probes or test strips will be used to measure indicators such as temperature, pH, and ammonia at flowing outfalls. The ORI field sheet (Appendix A) is divided into eight 81 of 334 ---PAGE BREAK--- 10 sections that address both flowing and non-flowing outfalls. Guidance on completing each section of the ORI field sheet is presented in the following sections. 4.4.1 Section 1: Background Data The first section of the ORI field sheet is used to record basic data about the survey. Every outfall will be photographed and marked by directly writing a unique identifying number on each outfall that serves as its subwatershed “address”. Land use of the drainage area contributing to the outfall is determined and marked to help characterize the discharge. 4.4.2 Section 2: Outfall Description This section identifies basic outfall characteristics, including pipe material and dimension, and presence of flow at the outfall. These measurements will be used to confirm and supplement existing storm drain maps. 4.4.3 Section 3: Quantitative Characterization This section of the ORI records direct measurement of flowing outfalls, such as flow temperature, pH, and ammonia. Field crews will measure the rate of flow using one of two techniques. The first technique simply records the time it takes to fill a container of a known volume, such as one-liter sample bottle. The second technique the field crew measures the velocity of flow and multiplies it by the estimated cross-sectional area of the flow. 4.4.4 Section 4: Physical Indicators for Flowing Outfalls This section of the ORI field sheet records data about four sensory indicators associated with flowing outfalls – odor, color, turbidity, and floatables. The field sheet records whether the sensory indicators are present, and if so, what is the severity on a scale of one to three. 4.4.5 Section 5: Physical Indicators for both Flowing and Non-flowing Outfalls Section 5 of the ORI field sheet examines physical indicators found at both flowing and non- flowing outfalls that can reveal the impacts of past discharges. Physical indicators include outfall damage, outfall deposits or stains, abnormal vegetation growth, poor pool quality, and benthic growth on pipe surfaces. 4.4.6 Section 6-8: Initial Outfall Designation and Actions The last three sections of the ORI field sheet are where the field crew designates the illicit discharge severity of the outfall and recommends appropriate management and monitoring actions. A discharge rating is designated as obvious, suspect, potential or unlikely, depending on the number and severity of discharge indicators checked in preceding sections. The ORI designation is only used as an initial determination of discharge potential. A more certain determination is made using a more detailed indicator monitoring method. The indicator monitoring method is detailed in Section 5. 4.5 Obvious Discharges When obvious discharges are encountered, such as sewage or other pollutants, often characterized by high turbidity, odors, floatables, and unusual colors, field crews will be 82 of 334 ---PAGE BREAK--- 11 directed to STOP the ORI survey. The field crews will then track down the source of the discharge and immediately contact the appropriate agency for enforcement. Crews will photograph and document the discharge, estimate its flow volume, and collect a sample for water quality analysis. 5 INDICATOR MONITORING Indicator monitoring is used to confirm illicit discharges characterized in the ORI as potential, suspect, or obvious. Indicator monitoring also provides clues about the source or origin of the illicit discharges. There is a wide range of indicator parameters and analytical methods to choose from when determining the presence and source of illicit discharges. The exact combination of indicator parameters and methods selected will be unique for each outfall. 5.1 Indicator Parameters to Identify Illicit Discharges At least fourteen different indicator parameters can confirm the presence or origin of an illicit discharge: • Ammonia • Boron • Chlorine • Color • Conductivity • Detergents • E. coli and total coliform • Fluorescence • Hardness • pH • Potassium • Surface Tension • Surfactants • Turbidity In most cases, however, only a small subset of indicator parameters (e.g. three to five) is required to adequately characterize an illicit discharge. Table 5 below summarizes the parameters that meet most of the indicator criteria and compares their ability to detect different flow types. A flow chart of indicator parameters is provided in Appendix B. Table 5: Indicator Parameters Used to Detect Illicit Discharges Parameter Discharge Types Parameter can Detect Sewage Wash water Tap Water Industrial or Commercial Liquid Wastes Ammonia 1 2 3 2 Boron 2 2 3 n/a Chlorine 3 3 3 2 Color 2 2 3 2 Conductivity 2 2 3 2 Detergent-Surfactants 1 1 3 2 E. Coli 2 3 3 3 Hardness 2 2 2 2 83 of 334 ---PAGE BREAK--- 12 Table 5: Indicator Parameters Used to Detect Illicit Discharges Parameter Discharge Types Parameter can Detect Sewage Wash water Tap Water Industrial or Commercial Liquid Wastes pH 3 2 3 2 Potassium 2 3 3 1 Turbidity 2 2 3 1 1 - Can almost always ( > 80% of samples) distinguish this discharge for clean flow types (e.g. tap water or natural water) 2 – Can sometimes (>50% of samples) distinguish this discharge form clean flow types depending on regional characteristics, or can be helpful in combination with other parameters. 3- Poor indicator. Cannot reliably detect illicit discharges, or cannot detect tap water 5.2 Methods to Analyze Indicator Samples Each sample will be analyzed by a contract lab, but the City is equipped to analyze conductivity, pH, and turbidity in the field to aid in a more rapid indication of the illicit discharge source. 5.3 Techniques to Interpret Indicator Data Two techniques will be used to interpret indicator parameter data: 1) the Flow Chart Method and 2) industrial flow benchmarks. Both techniques rely on benchmark concentrations for indicator parameters in order to distinguish among different flow types. 5.3.1 Flow Chart Method The flow chart method distinguishes four major discharge types found in residential watersheds, including sewage and wash water flows that are normally the most common illicit discharges. The basic decision points involved in the Flow Chart method are described below. A more complex flowchart developed for this program can be found in the IDDE manual created by the Center for Watershed Protection. Step 1: Separate clean flows from contaminated flow using detergents The first step evaluates whether the discharge is derived from sewage or wash water sources, based on the presence of detergents. Boron and surfactants are used as the primary detergent indicator, and values of boron or surfactants that respectively exceed 0.35 mg/l and 0.25 mg/L, respectively, signal that the discharge is contaminated by sewage or wash water. Step 2: Separate wash water from wastewater using the Ammonia/Potassium ratio If the discharge contains detergent, the next step is to determine whether they are derived from sewage or wash water, using the ammonia to potassium ratio. A ratio greater than one suggests a sewage contamination, and a ratio less than one indicates a wash water contamination. 84 of 334 ---PAGE BREAK--- 13 Step 3: Separate tap water from natural water If the sample is free of detergents, the next step is to determine if the flow is derived from spring/groundwater or tap water. The benchmark indicator used in this step is chlorine, with a concentration exceeding 0.20 mg/L, indicating that potable water is the source. 5.3.2 Industrial Flow Benchmark When a subwatershed has a high density of industrial generating sites, additional indicator parameters are needed to detect and trace these unique discharges. Seven indicator parameters serve as industrial flow benchmarks to help identify illicit discharges originating from industrial and commercial generating sites. The seven indicators (ammonia, color, conductivity, hardness, pH, potassium, and turbidity) are used to identify liquid wastes and other industrial discharges that cannot always be detected by the Flow Chart Method. Table 6 summarizes typical benchmark concentrations that distinguish between unique industrial or commercial liquid wastes. Note that two of the seven indicator parameters, ammonia and potassium, are already incorporated into the flow chart method. Table 6: Benchmark concentration to identify industrial discharges Indicator Parameter Benchmark Concentration Notes Ammonia > 50 mg/L Concentration higher than the benchmark can identify a few industrial discharges Color > 500 Units Supplemental parameter that identifies a few specific industrial discharges. Conductivity > 2,000 µS/cm Identifies a few industrial discharges and is useful to distinguish between industrial sources. Hardness < 10 mg/L as CaCO3 > 2,000 mg/L as CaCO3 Identifies a few industrial discharges and is useful to distinguish between industrial sources. pH < 5 Only capture a few industrial discharges. High pH value may also indicate an industrial discharge but residential wash water can have a high pH as well. Potassium > 20 mg/L Excellent indicator of a broad range of industrial discharges. Turbidity > 1,000 NTU Supplemental parameter that identifies a few specific industrial discharges. Industrial and other generating sites can produce a range of discharges that are hard to classify. The City of Kalispell will use identification techniques outlined in The Illicit Discharge Detection and Elimination Guidance Manual. Table K.1, Chemical and Physical Properties of Industrial Non-Storm Water Discharges, in Appendix K, summarizes possible chemical and physical characteristics of non-stormwater discharges, which could come from various industries. 85 of 334 ---PAGE BREAK--- 14 6 ILLICIT DISCHARGE INVESTIGATION AND CORRECTIVE ACTION PLAN ISOLATING AND FIXING INDIVIDUAL ILLICIT DISCHARGES A variety of tools are used to trace illicit discharge problems in order to isolate and fix the specific sources or improper connections at a site. Six basic tools will be used to isolate and fix individual discharges: 1. Pollution reporting hotline/website 2. Storm drain network investigations 3. Drainage area investigations 4. On-site investigations 5. Septic system instigations 6. Correction and enforcement Investigation of illicit discharges will be within 7 days of the City discovering a discharge. The illicit discharge will be fully eliminated within 6 months of the City becoming aware of it. Non- stormwater discharges suspected of being sanitary sewage and/or significantly contaminated shall be prioritized. 6.1 Source Detection and Investigation Procedures Potential illicit discharges can be revealed through various sources such as outfall inspections, reports from staff, or public complaints. If the source of a potential illicit discharge is not immediately clear, the City will begin an official illicit discharge investigation to trace the source of the illicit discharge following the procedures outlined in this section. In cases where the source of an illicit discharge is immediately known (e.g. when illegal dumping or illicit discharge problem is directly observed by a member of the City staff) it is generally not necessary to follow investigation procedures. In such cases, the steps outlined in Sections 6.1.1 - 6.1.4 will be completed and then the corrective action procedures provided in Section 6.2. 6.1.1 Documentation When a potential illicit discharge is identified, an investigation file will be started. An Illicit Discharge Investigation and Corrective Action Form, which includes a creation date, case description, and any information related to the observed or suspected problem, will be filled out. An accurate log of labor, materials and costs associated with the investigation for invoicing the responsible party will be kept, if necessary. The form will be started prior to completing any additional field work unless the nature of the discharge necessitates an immediate response. As the investigation proceeds, any field investigations, photographs, corrective actions, or other activities associated with the suspected problem area will be documented and saved on file as this becomes the City’s official record of the illicit discharge detection and elimination (IDDE) investigation. Additional documentation may include the following: • Copy of Outfall Inspection Report 86 of 334 ---PAGE BREAK--- 15 • Photographs • Additional field notes • Lab testing results • Compliance letters sent and responses received • Correspondence (mail, email, telephone logs) • Proof of corrected problems (contract and invoice or clean field investigation report) 6.1.2 Site Visit In cases where the City’s field crews did not discover the potential illicit discharge (e.g. the City was made aware via a public complaint), a site visit will be conducted to confirm the nature of the problem and determine the prioritization of the investigation. 6.1.3 Prioritization Each suspected illicit discharge has the potential to cause damage to the MS4 and receiving waters; however, certain situations may warrant more immediate attention than others and each investigation must be prioritized in order to protect public health and avoid serious threats to the environment or damage to property. The following items will be considered when determining the immediacy of the investigation: • Discharges posing an immediate threat to human health • Discharges near a surface or drinking water source • Discharges containing substances with significant potential to cause immediate damage to the environment • Large volume or continuous flow • Potential threat of contaminating groundwater 6.1.4 Notification of Appropriate Agencies Threat to Human Heath: Discharges and/or activities that are believed to be an immediate threat to human health or the environment will be reported to Montana DEQ. DEQ’s Enforcement Division may assist in the investigation and corrective action process if necessary. The phone number and website to access a Complaint/Spill Form are as follows: Phone: (406) 444-0379 Website: http://deq.mt.gov/DEQAdmin/ENF/spill The local health department protects people from health threats such as food-borne illnesses, natural and man-made disasters, toxic exposures, and preventable illness and injury. This includes hazardous spills near drinking water sources, parks with dogs and children, and potential to contaminant soils and groundwater. The health department phone number is: Phone: (406) 751-8100 Hazardous Materials: The Kalispell Fire Department will be contacted for situations requiring hazardous materials response. When hazardous materials are suspected Fire Department will be contacted to determine if hazardous materials response is necessary: Phone: (406) 758-7760 87 of 334 ---PAGE BREAK--- 16 6.1.5 Select Appropriate Investigation Method The four investigation methods which may be used to trace and identify the source of a suspected illicit discharge are as follows: • Storm Drain Network Investigations • Drainage Area Investigations • On-Site Investigations • Septic System Investigations The available information will be reviewed (e.g. initial documentation, previous investigations conducted in the vicinity, etc.) and select the appropriate method. Each method, as described by the Center for Watershed Protection (CWP), is briefly discussed below. Once the appropriate method is selected Chapter 13 of the CWP’s Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments will be consulted, which contains detailed guidance on how to efficiently conduct each investigation. After the appropriate investigation method has been selected, the appropriate resources will be coordinated to begin the investigation to trace and identify the source of the illicit discharge. 6.1.5.1 Storm Drain Network Investigations City personnel inspect manholes within the area of the suspected illicit discharge and examine the manhole contents for chemical or physical indicators of contaminants in an effort to narrow the illicit discharge location to an isolated pipe segment between two manholes. Indicators may include odor, color, staining, unusual films, floatables, or samples which may be taken for chemical testing in a laboratory. The City’s storm drainage system map will be helpful in determining which manholes to visit and inspect. After the pipe segment has been isolated, on- site investigations may be used to locate the exact location of the illicit discharge. 6.1.5.2 Drainage Area Investigations When there is strong evidence that suggests a specific and known contaminant or if the known contaminant points towards a short list of potential discharge sources, it is often most effective to survey the drainage area and focus on sites which are known to produce and/or contain the contaminant which has been identified within the storm drain network. The primary methods for conducting drainage area investigations include windshield surveys and mapping analyses. While conducting the investigation it is recommended to consult the mapped pipe network and compare this to maps of high priority businesses, land use types and zoning, and on- going construction projects. 6.1.5.3 On-Site Investigations The on-site investigation diagnoses the exact location and source of an illicit discharge and should be performed after the illicit discharge has been isolated to a specific section of the storm drain network. Techniques such as dye testing the plumbing systems of households and buildings, video testing, and smoke testing may be necessary for this type of investigation. It is important to understand when a 88 of 334 ---PAGE BREAK--- 17 technique would work best for the application and to understand limitations that may deem the technique unusable. 6.1.5.4 Septic System Investigations Some residential watersheds do not have sanitary sewer systems or stormwater conveyance piping, but rather have septic systems and alternative practices for dealing with stormwater volumes. Stormwater conveyance systems consisting of swales, ditches, and ponds are common in these watersheds and the illicit discharges often come from failing septic systems and illegal dumping. Two separate types of analyses are typically employed in these areas: on-site septic investigations and detailed system inspections. On-site septic investigations typically include homeowner system audits or surface condition analyses. Detailed system inspections are more thorough, typically involve the use of infrared imagery, and are usually appropriate if the on-site investigations are not successful in locating the source of an illicit discharge. 6.1.6 Document Investigation Findings Once the source of an illicit discharge has been identified, the findings and progress towards the corrective action process will be documented. Documentation may include but are not limited to: • Investigation method(s) • Photographs • Additional field notes • Lab testing results 6.2 Corrective Action Process and Procedures After the source of an illicit discharge has been identified, the corrective action process to eliminate the discharge will begin. Where applicable, corrective actions will focus first on education to promote voluntary compliance and escalate to increasingly severe enforcement actions as needed. 6.2.1 Determine Type of Illicit Discharge The type of an illicit discharge can be generalized as either behavioral or structural, each of which is discussed below. 6.2.1.1 Behavioral The nature of the illicit discharge is an action, operation, or conduct and the illicit discharge will be eliminated when this behavior is modified. 6.2.1.2 Structural The illicit discharge is caused by a physical configuration or connection which requires modification of the system in order to eliminate the discharge. 6.2.2 Assign Responsibility The party responsible to fix the illicit discharge will be identified based on the nature and location of the illicit discharge. • Private Property Owner • Municipality • Other Public Entity 89 of 334 ---PAGE BREAK--- 18 o Montana Department of Transportation (MDT) Stormwater Network MDT will be responsible for illicit discharges under any of the following circumstances: • Any illicit discharge caused by MDT • Any illicit discharge occurring within the MDT storm sewer network MDT will be responsible for dealing with illicit discharges according to their regulations if: • The illicit discharge is through one of MDT’s outfalls. • The illicit discharge occurs within the MDT right of way. • The illicit discharge is within the MDT storm sewer network. If the discharge affects areas outside of the MDT storm sewer network, the City of Kalispell will be responsible for cleaning up their system. The owner of the storm sewer impacted will be responsible for completing cleanup and assessing the charges associated with it. 6.2.3 Select Appropriate Corrective Action If deemed to be safe and within the City’s authority and capabilities, the illicit discharge may be eliminated immediately using appropriate and available methods. For situations requiring proper authorization and/or expertise, a work order will be generated and sent to the appropriate department. For cases where a private property owner is responsible, the City will coordinate with the Responsible Party to determine an appropriate method to eliminate the illicit discharge. If necessary, enforcement actions such as a compliance schedule will be created to ensure that the illicit discharge is eliminated in a timely manner (refer to the Enforcement Response Plan (ERP, Appendix C) to determine appropriate enforcement actions). Chapters 8 and 14 of the CWP’s Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments provides a list of methods to remove and eliminate illicit discharges and will be used, if necessary, to determine the appropriate corrective action. 6.2.4 Confirm and Document Elimination of Contamination Source A site visit may be necessary to confirm the source has been eliminated, the corrected operations are sufficient, and/or the structural problem has been fixed according to the approved corrective action. In other cases, it may be sufficient to allow a verbal confirmation from the property owner, a photograph of the modification, as-built drawings, or simply verify that all signs of the illicit discharge are gone. Once confirmed, the investigation and correction file will be closed by noting the elimination of the discharge within the Illicit Discharge Investigation and Corrective Action Form. 6.2.5 Enforcement Actions In circumstances where the responsible party does not volunteer compliance, refuses compliance, or disputes responsibility, the City will take enforcement actions consistent with the Enforcement Response Plan in order to ensure that the discharge is eliminated. 90 of 334 ---PAGE BREAK--- 19 Note that voluntary compliance in eliminating an illicit discharge may not preclude the responsible party from enforcement actions. The authority and responsibility for correction and enforcement are clearly defined in the City IDDE ordinance. The outfall through which the illicit discharge occurred will be considered a high priority outfall for at least 1 year after the event if not already labeled as such. 7 IDDE PROGRAM TRACKING AND EVALUATION As many communities initially have a poor understanding of the scope and nature of their illicit discharge problem, it is important to employ adaptive management. Using adaptive management to frequently review and maintain the IDDE Program can ensure the most severe illicit discharges are eliminated in the most cost-effective way. Program evaluation will assess progress towards meeting program goals. Each of the program components will be reviewed annually, using data collected, compiled, and assessed by the tracking system. 7.1 Tracking System City staff will develop an accurate and user-friendly system to track, report, and respond to illicit discharges problems within a GIS database program called Cityworks. The fundamental units of the tracking system are the individual outfalls along with any supporting information. Some of the key information the City will include when tracking outfalls will include: • Geospatial coordinates of outfall locations • Subwatershed and watershed address • Land use information • Diameter/physical characteristic of outfall • ORI data, as it is collected • Digital photos • Follow-up monitoring at the outfall • Hotline complaints and local response • Status of any enforcement action • Maintenance and inspection data 7.2 Program Evaluation The IDDE program will be evaluated annually, and modified as required to meet the program and permit goals. The tracking system will be used to assess progress towards meeting the permit’s measurable goals. 8 REFERENCES The following references were used to prepare this plan and contain supplemental information that may be helpful to City staff. Center for Watershed Protection and Robert Pitt. Illicit Discharge Detection and Elimination: A Guidance Manual for Program Development and Technical Assessments. October 2004. U.S Environmental Protection Agency. Washington, D.C. 91 of 334 ---PAGE BREAK--- 20 9 APPENDIX 9.1 Appendix A - Outfall Reconnaissance Inventory Field Sheet 92 of 334 ---PAGE BREAK--- 21 93 of 334 ---PAGE BREAK--- 22 94 of 334 ---PAGE BREAK--- 23 9.2 Appendix B - Indicator Parameter Flow Chart 95 of 334 ---PAGE BREAK--- 24 96 of 334 ---PAGE BREAK--- 25 9.3 Appendix C – Enforcement Response Plan for Stormwater Management within the City of Kalispell, Montana 97 of 334 ---PAGE BREAK--- 26 ENFORCEMENT RESPONSE PLAN FOR STORMWATER MANAGEMENT CITY OF KALISPELL, MONTANA Last updated 6/12/19 Introduction In accordance with the General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer System (MS4), issued by the Montana Department of Environmental Quality (DEQ), the City of Kalispell (the City) is required to develop and implement an Enforcement Response Plan (ERP) to ensure compliance with stormwater regulations. The purpose of this ERP is to specify criteria by which City personnel can determine the enforcement action most appropriate for instances of non-compliance and communicate how the enforcement tools available to City personnel will be used to achieve compliance following violations of the City’s stormwater regulations. This document addresses the Montana DEQ MS4 General Permit’s ERP requirements for the following Minimum Control Measures (MCM’s): • MCM 3: Illicit Discharge Detection and Elimination (Part II.A.3.d.iv.) • MCM 4: Construction Site Storm Water Management (Part II.A.4.a.iii.) • MCM 5: Post-Construction Site Storm Water Management in New and Redevelopment (Part II.A.5.a.iii.) The enforcement actions and procedures within this plan are generally applicable to each of the three MCMs listed above; however, enforcement actions and procedures which are specific to an individual MCM are addressed within the attachments, listed as follows: • Attachment A: Illicit Discharge Detection and Elimination • Attachment B: Construction Site Storm Water Management • Attachment C: Post-Construction Site Storm Water Management in New and Redevelopment The procedures within this ERP have been developed with the following objectives in mind: • Prevent pollutants from entering the MS4 and causing environmental harm • Communicate definitions for non-compliance • Establish appropriate enforcement action based on the nature and severity of the violation • Promote consistent and timely use of enforcement tools • Ensure that violators return to compliance in a timely manner • Recover costs incurred by the City due to operator non-compliance • Promote compliance through education and compliance assistance first and, if necessary, penalties second 98 of 334 ---PAGE BREAK--- 27 The City of Kalispell has the authority to enforce stormwater regulations under the following sections of its municipal code: Illicit Discharge Detection and Elimination: _ Ordinance 1831 Construction Site Storm Water Management: _ Ordinance 1831 Post-Construction Site Storm Water Management: Ordinance 1831 Acronyms The following acronyms shall have the following meaning: DEQ Department of Environmental Quality ERP Enforcement Response Plan MCM Minimum Control Measure MS4 Municipal Separate Storm Sewer System NOV Notice of Violation SWO Stop Work Order Enforcement Response Plan Overview The enforcement process consists of six basic steps beginning with identification of a violation and concluding with closing the complaint. The overall process is shown in the flowchart below and is further explained in the following sections. Enforcement Response Flowchart for the City of Kalispell Stormwater Management Program Determine Appropriate Level of Response Select & Implement Appropriate Response Compliance Achieved? Close Complaint Follow up Call/Visit Yes No Identify & Document the Violation 99 of 334 ---PAGE BREAK--- 28 • Identifying/Investigating Noncompliance The City may become aware of stormwater non-compliance or violations in a number of ways. • Permit-required inspections or monitoring may reveal non-compliance: the City’s programs include periodic or complaint-based compliance inspections of facilities subject to Construction/Post- Construction programs and routine monitoring and inspections to support the IDDE, as required by the MS4 permit. • Staff of other City agencies may also identify illicit connections or illicit discharges during the course of performing their regular job functions. • Finally, there may be complaints from the public. This section discusses the City’s plans for inspections in each of the three regulatory programs required by the MS4 permit: IDDE, Construction, and Post-Construction. IDDE The City may receive a complaint concerning an illicit connection or discharge through the City’s online or phone reporting system or an illicit discharge may be observed during the course of City operations. When one of these mechanisms triggers an IDDE investigation, the City conducts appropriate in-sewer and/or surface inspection(s) to identify the source of dry weather discharge/ pollutants of concern entering the MS4, consistent with applicable laws, and takes necessary enforcement action to require abatement of the discharge. When another City agency identifies an illicit connection or discharge on their property, the agency is responsible for tracking, eliminating, and reporting it. Construction/Post-Construction The MS4 permit Parts II.4 and II.5 require the City to address stormwater runoff to the MS4 from new construction activities and new development and redevelopment projects that result in soil disturbance of 1 acre or more. Sites that are less than 1 acre but the activity is part of a larger common plan of development or sale that would disturb one acre or more are also included. The City inspects sites that have received Stormwater Permit approval under the City’s MS4 construction/post-construction permitting, inspection, and enforcement program. With respect to construction permitting, the City uses announced and unannounced inspections, in addition to inspections triggered by complaints, in accordance with applicable laws, to determine whether projects have obtained appropriate permits under the City’s program and are complying with their Stormwater Pollution Prevention Plan The City prioritizes inspection sites most likely to have an adverse impact on water quality, based on the amount of exposed soil, the location of the site relative to a water body, and the past performance of the responsible parties. With respect to developed sites, the City performs inspections based on complaints of discharges entering City sewers. Following the completion of construction, the City performs, on a complaint basis and periodically, compliance verification inspections of sites with Kalispell Stormwater Maintenance Permits to determine whether the owners are complying with their Stormwater Maintenance Permits and maintaining their stormwater facilities. • Determining the Appropriate Level of Response Once a potential violation is identified, the appropriate level of response should be determined and an appropriate response remedy should then be selected. The City has five levels of responses, each of which is briefly described below. o Level 1: No Enforcement Action There may be situations where City personnel are made aware of a potential violation; however, sufficient evidence does not exist to prove a violation is taking place. An example of such situation may be if a complaint is received stating that a private stormwater control has not been properly maintained. However, after a brief site inspection and/or verbal discussion, City staff determines the stormwater control is within compliance and no enforcement action is required. In such situations, the potential 100 of 334 ---PAGE BREAK--- 29 violation and response should be documented using the Enforcement Response Documentation Form (Attachment D) or other equivalent form for future reference. o Level 2: Informal Response The City will pursue compliance with stormwater violations through informal methods whenever reasonable. Informal responses include telephone notifications, verbal notices, meetings, and notices of violation (NOV) each of which is described in Section 3.1. These methods are appropriate for situations where education is needed, violations do not pose a significant impact to human health or the environment, or the City believes that compliance can be achieved without the use of formal measures. In addition, implementation of informal measures often establishes the documentation necessary to implement formal enforcement actions if informal measures do not result in compliance. o Level 3: Formal Response Formal procedures will be implemented to resolve prolonged non-compliance or immediate impacts to human health and the environment. Additionally, formal responses may be implemented immediately when the responsible party has a history of non-compliance. A history of non-compliance is defined as receiving more than 3 informal or formal responses to stormwater violations in the past 2 years. Formal responses include stop work orders, administrative orders, compliance schedules, orders to show cause (OSC), monetary penalties (municipal infractions), and suspended service, each of which is described within Section 3.2. o Level 4: Judicial Response A judicial response involves civil or criminal prosecution and will be implemented when a violation is significant and/or the responsible party is uncooperative throughout the City’s attempts to achieve compliance using formal responses. Judicial responses include injunctive relief, consent decrees, civil penalties and criminal penalties, each of which is discussed in Section 3.3. o Level 5: Referral to Other Agencies If formal responses prove insufficient to resolve the situation, the City of Kalispell may enlist the help of the Montana DEQ or any other governmental agency involved. Help from the Montana DEQ may be solicited at an earlier stage of the process in the event the Montana DEQ has a vested interest in the site, has a history of dealing with the responsible party, or the violation is deemed significant enough for immediate action. • Selecting an Appropriate Response Remedy Once the severity of the violation is determined, the proper response must be identified and initiated. The City’s selected response remedies are described below. Each violation must be documented even if the decision is to take no action. Documentation must explain why such action was or was not taken. o Informal Remedies  Verbal/Email Notice A verbal notice will be used to obtain additional information pertaining to a potential violation or to resolve an infrequent violation. The initial contact will take place within 24 hours of determining a potential violation. At a minimum, the conversation shall be documented with the following information: 1. date/time of contact, 2. the City staff member who initiated contact, 3. the person contacted (responsible party), and 4. the content of the conversation. The initial contact will start the enforcement timeline. In the event the call/email is not answered, the Stormwater Coordinator or another delegated City employee will make a site visit and leave a note on the property if feasible. If no contact is made after attempting both methods, the 101 of 334 ---PAGE BREAK--- 30 enforcement timeline will begin on the date of the site visit. The length of the violation will be measured beginning with the initial contact or site visit depending on the situation. If a violation is found during a City inspection, the inspection will serve as the start of the enforcement timeline.  Notices of Violation A Notice of Violation (NOV) is an official communication from the City to the responsible party which informs the party a violation has occurred. The NOV will be issued as a warning for significant violations of the City’s stormwater ordinances and requirements or in cases where a verbal warning for a minor infraction has been ignored for at least 7 days. The NOV documents the initial attempts of the City to resolve the violation. The NOV will include the following information: 1. the specific violation, 2. photos (if possible), 3. timeframe and actions required to return to compliance, and 4. a warning that further enforcement action may be taken for failure to comply. The NOV's shall be sent via certified mail/return receipt or hand delivered and signed by the responsible party.  Compliance Schedule A compliance schedule directs the responsible party to address the violation and restore compliance by a specified date. The compliance schedule will include the following: 1. the specific violation, 2. the City’s previous correspondence and attempts to achieve compliance, 3. required actions to be completed by the responsible party, and 4. dates by which the actions must be completed to return to compliance. Issuance of a compliance schedule does not necessarily relieve the responsible party of having to meet any existing stormwater control commitments, nor protect the responsible party.  Meeting A meeting will be requested with the responsible party within 2 working days (or a timeframe deemed appropriate for the situation) of the initial contact without fully mitigating the violation, or in the opinion of the Stormwater Coordinator, when the responsible party is not putting forth a good faith effort. The meeting will serve to educate the responsible party regarding the violation and to discuss necessary measures for correction. The meeting will be conducted by the Stormwater Coordinator or another delegated City employee. At a minimum, the meeting shall be documented with the following information: 1. meeting location, 2. date/time of meeting, 3. meeting attendees, 4. content of the conversation, and 5. agreements made at the meeting. o Formal Remedies  Stop Work Order A stop work order (SWO) is a notice which informs the construction site operator of an ongoing stormwater management violation and requires a termination of work until the matter is resolved. No City permits, payments, or approvals of any kind will be issued for any project the owner or contractor is involved with as long as the SWO is in effect. The SWO will be issued for failure to comply with an NOV or for extreme violations of the City’s construction site stormwater requirements. The SWO will include the following information: 102 of 334 ---PAGE BREAK--- 31 1. the specific violation, 2. contact information for the City personnel who must be contacted to discuss required remediation procedures, 3. the mitigation goals necessary to remove the stop work order, and 4. a warning notifying the site operator of additional enforcement actions for continued noncompliance. A stop work order will not be removed until the situation is completely resolved as determined by the issuer of the stop work order.  Administrative Order An administrative order is a formal enforcement document that requires the responsible party to either cease the specified activity or implement specified corrective measures. An administrative order will be issued when informal remedies have been pursued and have not resulted in compliance.  Order to Show Cause An Order to Show Cause (OSC) directs the responsible party to appear before the City Manager, explain their noncompliance, and show cause why more severe enforcement actions should not be pursued. An OSC will be issued when an administrative order or other enforcement remedy has been disputed and has not resulted in compliance.  Municipal Infraction A municipal infraction is a civil offense punishable by a civil penalty. An administrative fine is assessed by the Municipal Court Judge to the responsible party for a violation of the City’s stormwater management requirements. The fine is considered punitive in nature and is not related to any specific cost borne by the City. The amount of the fine will be proportional to the harm caused by the violation at the discretion of the Municipal Court Judge. The City may also recover damages to its MS4 or for the cost of fixing/maintaining stormwater infrastructure as stated in City ordinances.  Suspend Service The City has the authority to suspend water service, solid waste removal, and any other City services deemed applicable. These actions will be used against a responsible party that fails to comply with previous remedies or to stop discharges considered to pose an immediate risk to the public or the environment. o Judicial Remedies  Injunctive Relief An injunction is a court order which directs the responsible party to cease a specified action or behavior. The City will seek injunctive relief if the responsible party refuses to comply with an administrative order or if delays in filing a civil suit would result in irreparable harm to the MS4 or receiving waterbody.  Consent Decree A consent decree is an agreement between the City and the responsible party reached after a lawsuit has been filed. A consent decree will be pursued when the City and the responsible party can reach a suitable agreement.  Civil Penalties If necessary, a civil suit will be used to recover costs borne by the City in responding to the responsible party’s noncompliance. 103 of 334 ---PAGE BREAK--- 32  Criminal Penalties Criminal prosecution is a formal process of charging the responsible party with violations of ordinance provisions punishable by fines and/or imprisonment. Criminal prosecution will be pursued when the responsible party has ignored all previous corrective actions for 2 weeks and in the view of the Kalispell City Attorney or the State DEQ the responsible party is not taking sufficient action to mitigate the violation. Criminal penalties may be started sooner at the discretion of the Kalispell City Attorney. o Additional Considerations The following criteria will be considered to aid in determining the correct level of response:  Magnitude Incidents which may cause damage to the MS4 or pose a threat to human health and/or the environment will be considered significant and necessitate a formal enforcement action.  Duration Violations which continue over prolonged periods of time will result in escalated enforcement actions.  Compliance History The responsible party’s compliance history will be an important factor in determining the appropriate remedy to apply. The City has the authority to issue informal or formal notices for less severe violations. However, recurring violations may lead the City to escalate the level of response in a shorter time frame than usual.  Good Faith of the Operator Good faith is a characteristic of actions showing the responsible party intends to achieve compliance in a timely manner. If the responsible party is attempting in good faith to correct the violation, the City’s enforcement responses may be less severe. However, potential threats to human health or the environment will always take precedence when considering the City’s level of response. In addition, while the responsible party’s good faith in correcting its noncompliance may be a factor in determining which enforcement response is suitable, good faith does not preclude the responsible party from enforcement action. • Enforcement Roles and Responsibilities The following table details the typical enforcement roles of City staff. 1st level indicates primary responsibility, 2nd level represents secondary responsibility, and NA indicates staff does not have the authority to make the decision. Table 4-1: Staff Enforcement Roles Enforcement Action Stormwater Coordinator or Construction Manager Delegated City Employee Public Works Director Verbal/Email Notice 1st Level 1st Level 2nd Level Meetings 1st Level 1st Level 2nd Level Notice of Violation 1st Level 1st Level 2nd Level Compliance Schedule 1st Level 1st Level 2nd Level Stop Work Order NA NA 1st Level Administrative Order NA NA 1st Level (City Manager) Order to Show Cause NA NA 1st Level (City Manager) Monetary Penalty NA NA 1st Level (Municipal Court) 104 of 334 ---PAGE BREAK--- 33 Enforcement Action Stormwater Coordinator or Construction Manager Delegated City Employee Public Works Director Suspend Service NA NA 1st Level (City Attorney) All Judicial Remedies NA NA 1st Level (City Attorney) All significant violations and the responses shall be reported to the Stormwater Program Manager and the Public Works Director. The Stormwater Coordinator or delegated City employee will be primarily responsible for informal responses to achieving compliance. If compliance is not achieved or the risk to the environment or safety and health of the community increases, the Public Works Director will take over primary responsibility for enforcement. When the situation requires a formal response, the Public Works Director will assume the responsibility for deciding the proper approach to achieve compliance. The City Attorney and the Stormwater Coordinator will be copied on all formal enforcement responses. The Public Works Director will consult with the City Attorney and City Manager on judicial actions. • Escalation Process and Schedule for Site Violations The common violations and enforcement response schedules differ for each MCM. Therefore, refer to the following attachments for this information: • Attachment A: Illicit Discharge Detection and Elimination • Attachment B: Construction Site Storm Water Management • Attachment C: Post-Construction Site Storm Water Management in New and Redevelopment 105 of 334 ---PAGE BREAK--- 34 ATTACHMENT A ESCALATION PROCESS AND SCHEDULE FOR ILLICIT DISCHARGE VIOLATIONS Table’s A-1 and A-2 (below) provide typical responses to common illicit discharge violations and a typical schedule for escalation of enforcement actions. Each violation has unique circumstances and concerns. Therefore, the tables below serve as guidance only. Violations which pose a significant threat to human health and/or the environment will utilize more severe enforcement actions on a compressed timeframe in order to quickly eliminate the violation, abate any damages, and prevent recurrence. Table A-1: Examples of Common Illicit Discharge Violation Responses Violation Circumstances of Violation Initial Level of Response Initial Response Remedy Dumping household toxins in a storm drain Isolated Incident Informal Verbal Notice or NOV Repeat Violation Formal Municipal Infraction Contractor discharging paint, concrete wash water, or other deleterious substance into a storm drain First Incident Informal Verbal/Email Notice or Meeting or NOV Repeat Violation Formal Municipal Infraction Restaurant or business discharging fat, oil, grease, or mop wash water to storm drain Isolated Incident Informal Verbal Notice or Meeting or NOV Repeat Violation Formal Municipal Infraction Direct connection of anything other than stormwater or clean groundwater to a storm sewer Isolated Incident/ Unaware of connection Informal Verbal Notice or Meeting or NOV Known issues previously ignored by the responsible party or new connection Formal Municipal Infraction Discharging wastewater from RV, camper, or another source to a storm sewer Any Instance Formal Municipal Infraction Table A-2: Possible Escalation Process, Response Schedule, and Responsibilities for Illicit Discharge Violations Response Time Frame Responsibility Verbal Notification Within 24 hours of determining a potential violation Stormwater Coordinator Notice of Violation Within 2 days of violation Stormwater Coordinator Meeting Within 3 days of violation Stormwater Coordinator Compliance Schedule Within 3 days of violation Stormwater Coordinator Stop Work Order Within 4 days of violation Public Works Director Administrative Order Within 4 days of violation Public Works Director/City Manager Order to Show Cause Within 2 days of violation dispute Public Works Director/City Manager Monetary Penalty Within 10 days of violation Municipal Court Suspend Service Within 6 days of violation Public Works Director/City Manager Judicial Actions As deemed appropriate by the Public Works Director Public Works Director/City Attorney Referral to other agencies As deemed appropriate by the Public Works Director Public Works Director 106 of 334 ---PAGE BREAK--- 35 ATTACHMENT B ESCALATION PROCESS AND SCHEDULE FOR CONSTRUCTION VIOLATIONS Tables B-1 and B-2 (below) provide typical responses to common construction site violations and a typical schedule for escalation of enforcement actions. Each violation has unique circumstances and concerns. Therefore, the tables below will serve as guidance only. Violations which a pose a significant threat to human health and/or the environment will utilize more severe enforcement actions on a compressed timeframe in order to quickly eliminate the violation, abate any damages, and prevent recurrence. Table B-1: Examples of Common Construction Site Stormwater Violation Responses Violation Circumstances of Violation Initial Level of Response Initial Response Remedy Conducting earth disturbing activities without stormwater construction permit Operator is unaware of requirements Informal Verbal Notice Operator is aware but has chosen not to obtain appropriate permit Formal Stop Work Order Best management practices (BMPs) not maintained or installed correctly, no runoff First Violation Informal Verbal/Email Notice Repeat Violation Informal Notice of Violation BMPs not maintained/installed, runoff First Violation Informal Verbal/Email Notice Previously warned of deficiencies (dry or wet weather) Formal Notice of Violation or Stop Work Order/ Municipal Infraction Site conditions require BMPs listed on plans but BMPs are not installed First Violation Informal Verbal/Email Notice or Notice of Violation Repeat Violation Formal Stop Work Order and/or Municipal Infraction Tracking soil offsite, dust blowing offsite First Violation Informal Verbal/Email Notice Repeated Violation Formal Notice of Violation or Stop Work Order/ Municipal Infraction Extreme infractions First Violation Informal Notice of Violation Second warning or history of violation Formal Stop Work Order Not conducting regular inspections and maintenance as specified in the permit First Violation Informal Verbal/Email Notice Second Violation, no discharge issues Informal Notice of Violation Second Violation, BMPs non- compliant, discharge happening, no good faith effort by responsible party Formal Stop Work Order and/or Municipal Infraction not updated when site inspected First Violation Informal Verbal Notification Repeat Violation Informal Notice of Violation >2 Violations Formal Municipal Infraction not on site First Violation Informal Verbal Notification Second Violation Informal Notice of Violation >2 Violations Formal Municipal Infraction 107 of 334 ---PAGE BREAK--- 36 Table B-2: Possible Escalation Process, Response Schedule, and Responsibilities for Construction Site Stormwater Violations Response Time Frame Responsibility Verbal Notification Within 24 hours of determining a violation Stormwater Coordinator/ Construction Manager Notice of Violation Within 2 days of violation Stormwater Coordinator/ Construction Manager Compliance Schedule Within 3 days of violation Stormwater Coordinator/ Construction Manager Stop Work Order Within 7 days of notice of violation Public Works Director Municipal Infraction Within 1 day of issuing the stop- work order if work is not halted Municipal Court Administrative Order Within 4 days of SWO Public Works Director/City Manager Judicial Actions As deemed appropriate Public Works Director/City Attorney Referral to other agencies As deemed appropriate Public Works Director Minor infractions to the City of Kalispell ordinances are infractions not causing immediate harm to the environment or the public health and safety, but having a strong likelihood to do so if the weather changes. Examples of this are: • BMPs incorrectly installed, but no runoff is occurring on site • Contractor not following their own Stormwater Management Plan but there are no deleterious effects on the environment • Not installing sediment control BMPs and just sweeping street as needed • Allowing sediment to be tracked offsite during dry weather Significant infractions to the City of Kalispell ordinances are infractions creating an immediate risk to the environment or public health and safety such as: • Sediment plume from site reaches a City of Kalispell storm drain manhole • Sediment has remained in City right of way for 7 days or more • Sediment from construction site has been transported more than 50 feet offsite • Dust from the site is causing a safety hazard • Dust from site reduces visibility to less than 100 feet for any length of time • A visible layer of dust is deposited on parked cars or impervious surfaces a quarter mile or more from the site that was observed coming from a specific construction site or there is direct evidence of the origin of the dust Extreme infractions to the City of Kalispell ordinances are infractions having an immediate risk to the health and safety of the public or the environment on a large scale such as: • Sites over 30 acres with insufficient erosion controls implemented and dust reducing visibility to less than 30 feet at any time or causing an immediate safety hazard • Sites over 30 acres with insufficient erosion controls implemented and sediment flowing offsite to a surface water body or storm sewer drain The length of compliance timeline will vary with the severity of the violation. Compliance schedules will be determined by City staff using the following guidelines: • The City of Kalispell will determine the level of effort from the contractor that constitutes a good faith effort. • Mitigating stormwater issues is the top priority on-site. • When computing working days, the weekend (Saturday and Sunday) will only be counted as one working day. 108 of 334 ---PAGE BREAK--- 37 • The minimum compliance timeline will be 24 hours. • The availability of materials can be a factor. For example, if the contractor is unable to obtain rock for a tracking pad after checking with all local suppliers, the timeline can be lengthened to accommodate this issue. • All immediate risks to the public health and safety or the environment shall be mitigated to the point where the site is not continuing to pollute the environment within a maximum of 24 hours. 109 of 334 ---PAGE BREAK--- 38 ATTACHMENT C ESCALATION PROCESS AND SCHEDULE FOR POST-CONSTRUCTION STORMWATER MANAGEMENT VIOLATIONS Tables C-1 and C-2 (below) provide typical responses to common post-construction stormwater management violations and a typical schedule for escalation of enforcement actions. Each violation has unique circumstances and concerns. Therefore, the tables below will serve as guidance only. Violations which a pose a significant threat to human health and/or the environment will utilize more severe enforcement actions on a compressed timeframe in order to quickly eliminate the violation, abate any damages, and prevent recurrence. Table C-1: Examples of Common Post-Construction Stormwater Management Violation Responses Violation Circumstances of Violation Initial Level of Response Initial Response Remedy Failure to obtain a stormwater maintenance permit First warning Informal Verbal/Email Notice Repeat Violation Formal Municipal Infraction and/or suspend service Failure to submit an annual inspection for the stormwater maintenance permit First warning Informal Verbal/Email Notice Repeat Violation Formal Municipal Infraction and/or suspend service Failure to renew a stormwater maintenance permit First warning Informal Verbal/Email Notice Repeat Violation Formal Municipal Infraction and/or suspend service Failure to maintain a post- construction stormwater control Isolated incident Informal Notice of Violation Repeat violation Formal Municipal Infraction and/or suspend service Failure to get approval to modify a practice First warning Informal Notice of Violation Fail to make requested changes Formal Municipal Infraction and/or suspend service Failure to notify the Public Works Department of a change of ownership First Incident Informal Verbal/Email Notice Repeat Violation Informal Notice of Violation Table C-2: Possible Escalation Process, Response Schedule, and Responsibilities for Post- Construction Stormwater Management Violations Response Time Frame Responsibility Verbal Notification Within 24 hours of determining a potential violation Stormwater Coordinator Notice of Violation Within 2 days of violation Stormwater Coordinator Compliance Schedule Within 3 days of violation Stormwater Coordinator Administrative order Within 4 days of violation Public Works Director/City Manager Monetary Penalty Within 5 days of violation Municipal Court Suspend Service Within 6 days of violation Public Works Director/City Manager Judicial Actions As deemed appropriate Public Works Director/City Attorney Referral to other agencies As deemed appropriate Public Works Director 110 of 334 ---PAGE BREAK--- 39 ATTACHMENT D ENFORCEMENT RESPONSE DOCUMENTATION FORM City Personnel Involved Date Description of Violation Location of Violation (address) ( ) - Responsible Party Telephone Street City Zip Description of Violation: Level of Response Selected Remedy Date for Follow-Up Additional Notes: 111 of 334 ---PAGE BREAK--- Appendix D: Ordinance 1831 112 of 334 ---PAGE BREAK--- ORDINANCE NO. 1831 AN ORDINANCE AMENDING ORDINANCE NO. 1600 AND ORDINANCE NO. 1634 THAT REGULATE THE PUBLIC USE OF THE CITY OF KALISPELL STORMWATER FACILITIES THROUGH THE REGULATION OF CONSTRUCTION AND POST CONSTRUCTION ACTIVITIES THAT IMPACT THE CITY STORMWATER SYSTEM PURSUANT TO THE NPDES PHASE II STORMWATER PROGRAM OF THE ENVIRONMENTAL PROTECTION AGENCY, AND THROUGH THE REGULATION OF THE INTRODUCTION OF POLLUTANTS INTO THE CITY MUNICIPAL SEPARATE STORM SEWER SYSTEM ( MS4) PURSUANT TO THE NPDES PHASE II STORMWATER PROGRAM OF THE ENVIRONMENTAL PROTECTION AGENCY, DIRECTING THE CITY ATTORNEY TO CODIFY SAME, AND DECLARING AN EFFECTIVE DATE. WHEREAS the City of Kalispell owns, operates and maintains stormwater facilities for the benefit and welfare of its inhabitants; and WHEREAS the City of Kalispell has the obligation to comply with all federal and state regulations regarding the operation and maintenance of its stormwater facilities to minimize the risks to people and the environment that may be compromised by stormwater discharge; and WHEREAS the purpose of regulating, and controlling the design, construction, use, and maintenance of any development or other activity which disturbs or breaks the topsoil or results in the movement of earth on land in the city is to safeguard persons, protect property, prevent damage to the environment and promote the public welfare, as well as meet the requirements set forth in the NPDES Phase II Storm Water Program of the Environmental Protection Agency as administered by the Montana State Department of Environmental Quality; and WHEREAS the purpose of regulating, and controlling the maintenance and function of post— construction stormwater management controls in the city is to safeguard persons, protect property, prevent damage to the environment and promote the public welfare, as well as meet the requirements set forth in the NPDES Phase II Storm Water Program of the Environmental Protection Agency as administered by the Montana State Department of Environmental Quality; and WHEREAS, the purpose of regulating the introduction of pollutants into the municipal separate storm sewer system ( MS4) is to comply with requirements set forth in the NPDES Phase II Storm Water Program of the Environmental Protection Agency as administered by the Montana State Department of Environmental Quality and to ultimately protect the environment as well as the health, safety, and general welfare of the citizens of Kalispell; and WHEREAS, it is necessary and prudent to update the stormwater regulations from time to time in order to maintain compliance with federal and state law and to insure that the ordinances are consistent and unambiguous. 113 of 334 ---PAGE BREAK--- NOW THEREFORE, BE IT ORDAINED BY THE CITY COUNCIL OF THE CITY OF KALISPELL, MONTANA, AS FOLLOWS: SECTION 1. Ordinances No. 1600 and Ordinance No. 1634, codified at Chapter 23A of the Kalispell Municipal Code shall be and are amended as set forth in Exhibit " attached hereto and incorporated fully herein. SECTION 2. The City Attorney is directed to cause this Ordinance to be codified in the Kalispell Municipal Code. SECTION 3. This Ordinance shall be effective thirty ( 30) days from and after the date of its final passage and approval. PASSED AND APPROVED BY THE CITY COUNCIL AND SIGNED BY THE MAYOR THIS 18TH DAY OF NOVEMBER, 2019. Mark Johns ATTEST: w Mayor Ainlee Brunckhorst, CMC City Clerk\\ SEAL 1892 114 of 334 ---PAGE BREAK--- EXHIBIT " A" Kalispell Municipal Code Chanter 23A Article I TITLE AND DEFINITIONS 23A- 1 Title. The City of Kalispell hereby adopts the following ordinance codified in this chapter, which shall be entitled REGULATION OF STORMWATER DISCHARGES. 23A- 2 Definitions. The following words, terms, and phrases, when used in this chapter, shall have the meanings ascribed to them in this chapter, except where the context clearly indicates a different meaning: AUTHORIZED ENFORCEMENT AGENCY: The City of Kalispell and its employees and agents as designated by the City Manager. BELOWGROUND INSTALLATIONS: Activity that causes sediment laden water, concrete sawing wash water, wash water or drilling mud pumped from an excavation or structure and shall be treated as sediment laden runoff for erosion control purposes. BEST MANAGEMENT PRACTICES ( BMPS): Schedules of activities, prohibitions of practices, general good housekeeping practices, pollution prevention and educational practices, maintenance procedures, and other management practices to prevent or reduce the discharge of pollutants directly or indirectly to stormwater, receiving waters, or stormwater conveyance systems. BMPs also include treatment practices, operating procedures, and practices to control site runoff, spillage or leaks, sludge or water disposal, or drainage from raw materials storage. CITY: The City of Kalispell and its employees designated by the City Manager with the authority to inspect or enforce stormwater compliance. CLEAN WATER ACT: The federal Water Pollution Control Act ( 33 U. S. C. Section 1251 et seq.), and any subsequent amendments thereto. CONSTRUCTION ACTIVITIES: Construction activities subject to MPDES construction permits and/ or activities subject to City Construction Stormwater Permits. These include construction projects resulting in land disturbance in which the total volume of material disturbed, stored, disposed of or used as fill exceeds five ( 5) cubic yards or the area disturbed exceeds one thousand ( 1000) square feet. Such activities include but are not limited to clearing and grubbing, grading, excavating, and demolition. CONSTRUCTION SITE BMP MANUAL: The Montana Department of Transportation Erosion and Sediment Control Best Management Practices ( BMP) Reference Manual and Field Manual, as amended from time to time. 115 of 334 ---PAGE BREAK--- EPA: Environmental Protection Agency. ESC: Erosion and sediment control. FINAL APPROVAL: Completion of a project, site or building in accordance with City requirements and ordinances. In the case of a building, a certificate of occupancy is issued. In case of a subdivision, when the two year warranty and maintenance bond has been submitted and the appointed public works employee certifies all work is complete. HAZARDOUS MATERIALS: Any material, including any substance, waste, or combination thereof, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may cause, or significantly contribute to, a substantial present or potential hazard to human health, safety, property, or the environment when improperly treated, stored, transported, disposed of, or otherwise managed. ILLEGAL DISCHARGE: Any direct or indirect non- stormwater discharge to the storm drain system, except as exempted in Section 23A- 13 of this article. ILLICIT CONNECTIONS: An illicit connection is defined as: 1. Any drain or conveyance, whether on the surface or subsurface that allows an illegal discharge to enter the storm drain system including but not limited to any conveyances that allows any non- stormwater discharge including sewage, process wastewater, and/ or wash water to enter the storm drain system and any connections to the storm drain system from indoor drains and sinks, regardless of whether said drain or connection had been previously allowed, permitted, or approved by an authorized enforcement agency, or 2. Any drain or conveyance connected from a commercial or industrial land use to the storm drain system that has not been documented in plans, maps, or equivalent records and approved by an authorized enforcement agency. INDUSTRIAL ACTIVITY: Activities subject to NPDES industrial stormwater permits as defined in 40 CFR, Section 122. 26 ( 14). LAND DISTURBING ACTIVITY: Any activity, including, but not limited to, excavation, planting, tilling, and grading, which disturbs the natural or improved vegetative ground cover so as to expose soil to the erosive forces of rain, stormwater runoff or wind. All installations and maintenance of franchise utilities such as telephone, gas, electric, etc., shall be considered land disturbing activities. MPDES: The Montana Pollutant Discharge Elimination System as administered by the State Department of Environmental Quality. MUNICIPAL SEPARATE STORM SEWER SYSTEM ( MS4): The system of conveyances including sidewalks, roads with drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man- made channels, or storm drains) owned and operated by the City of Kalispell and 116 of 334 ---PAGE BREAK--- designed or used for collecting or conveying stormwater, and that is not used for collecting or conveying sewage. NPDES: The National Pollutant Discharge Elimination System as administered by the Environmental Protection Agency. NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM ( NPDES) STORMWATER DISCHARGE PERMIT: A permit issued by EPA (or by a state under authority delegated pursuant to 33 U. S. 0 Section 1342( that authorizes the discharge of pollutants to waters of the United States, whether the permit is applicable on an individual, group, or general area -wide basis. NON- STORMWATER DISCHARGE: Any discharge to the storm drain system that is not composed entirely of stormwater. OFF- SITE BORROW AREA: A source of earth fill material used in the construction of embankments or other earth fill structures, that is located on another parcel of property within the City limits other than where the principal construction is occurring. OFF- SITE SEDIMENTATION: Deposit of soil material beyond the limits of the property undergoing land disturbing activity or in City streets, alleys or drainage facilities in an amount sufficient to constitute a threat to public safety and comfort or to the environment. OFF- SITE SPOIL AREA: An area on another parcel of property, within the City limits, other than where the principal construction is occurring, where excess earth, rock or construction material is disposed. PERMANENT EROSION CONTROL ( FINAL STABILIZATION): Practices installed prior to final approval and maintained after final approval to prevent or minimize the erosion and deposit of soil materials. Such controls may include, but shall not be limited to, permanent seeding, sod, landscaping/ vegetation, and hydroseed. PERSON: Any individual, association, organization, partnership, firm, corporation or other entity recognized by law and acting as either the owner or as the owner' s agent. POLLUTANT: Anything which causes or contributes to pollution. Pollutants may include, but are not limited to: paints, varnishes, and solvents; oil and other automotive fluids; non -hazardous liquid and solid wastes and yard wastes; sediment, refuse, rubbish, garbage, litter, or other discarded or abandoned objects, articles, and accumulations, so that same may cause or contribute to pollution; floatables; detergents, pesticides, herbicides, and fertilizers; hazardous substances and wastes; sewage, fecal coliform and pathogens; dissolved and particulate metals; animal wastes; wastes and residues that result from constructing a building or structure; and noxious or offensive matter of any kind. POST -CONSTRUCTION STORMWATER MANAGEMENT CONTROLS: Best management practices ( BMPs) which are used to control stormwater and potential pollutants in stormwater 117 of 334 ---PAGE BREAK--- discharges that will occur after construction operations have been completed. Such controls may include, but shall not be limited to, biofiltration swale, bioretention, dispersion, extended detention basin, infiltration basin, proprietary treatment devices, and wet detention basin. PREMISES: Any building, lot, parcel of land, or portion of land whether improved or unimproved including adjacent sidewalks and parking strips. RELATED LAND AREA: Includes the property where the principal land disturbing activity is taking place, all adjacent property, off-site borrow areas, off-site spoil areas, off-site properties necessary for required utility extensions, and off-site areas for required street improvements. RESPONSIBLE PARTY: A business entity, franchised utility company, developer, property owner, contractor or holder of a stormwater permit who is required to comply with the terms of this chapter. STAGING AREA: An on- site or off-site location used by a contractor to store materials for a project, to assemble portions of equipment or structures, to store equipment or machinery, to park vehicles, or for other construction - related uses. STOP WORK ORDER: The suspension of all City permits with no approvals or inspections of work for the site or project being performed. Apart from stabilizing ESC BMPs, no work shall be done on the site. STORM DRAINAGE SYSTEM: Publicly -owned facilities by which stormwater is collected and/or conveyed, including but not limited to any roads with drainage systems, municipal streets, gutters, curbs, inlets, piped storm drains, pumping facilities, retention and detention basins, natural and human -made or altered drainage channels, reservoirs, and other drainage structures. STORMWATER: Any surface flow, runoff, and drainage consisting entirely of water from any form of natural precipitation, and resulting from such precipitation. STORMWATER MANAGEMENT PLAN: A document which describes the Best Management Practices and activities to be implemented by a person or business to identify sources of pollution or contamination at a site and the actions to eliminate or reduce pollutant discharges to stormwater, stormwater conveyance systems, and/or receiving waters to the maximum extent practicable. WASTEWATER: Any water or other liquid, other than uncontaminated stormwater, discharged from a facility. Article 2 CONSTRUCTION SITE STORMWATER MANAGEMENT 23A- 3 Required Best Manap-ement Practices ( BMPs). A. Duty ofParty in Control ofProperty to Prevent Soil, Mud, Rock, Pollutants or Debris From Washing, Tracking or Being Carried by the Wind, Off -Site Onto Public 118 of 334 ---PAGE BREAK--- Streets, Alleys. etc.: It shall be unlawful and shall constitute a public nuisance for any person or business entity, whether owner, lessee, agent, employee, or otherwise, having control of real property within the city to permit soil, mud, rock, pollutants or debris to wash, slide, erode or otherwise be moved from said real property onto streets, alleys, utility facilities, storm drains, rights- of-way or easements or receiving waters. It shall be the duty of each party in control thereof to prevent soil, mud, rock, pollutants or debris from such real property being deposited or otherwise transported onto the streets, alleys, storm drains, utility facilities, rights- of-way, easements or receiving waters of the city. B. Implementation and Compliance of Best Management Practices: A responsible party engaging in any land disturbing activity, or any construction activities shall prepare and submit a Construction Stormwater Permit to the Kalispell Department of Public Works. If applicable, a building permit will not be issued for the site until the associated Construction Stormwater Permit is approved. 1. Greater or Equal to One Acre: Land disturbing activity of one acre or greater or construction activity that is part of larger common plan of development or sale that would disturb one acre or more shall submit shall prepare and submit a Construction Stormwater Permit, for review and approval by the City of Kalispell Public Works Department, containing the following: a. A copy of the notice of intent ( NOI), the stormwater pollution prevention plan ( and the confirmation letter in accordance with the Montana Pollutant Discharge Elimination System General Permit for Stormwater Discharges Associated with Construction Activity, permit number MTR100000; b. A complete Construction Stormwater Permit application form; c. A map of the construction site showing the location of the selected BMPs; d. A City of Kalispell Construction Stormwater Permit fee of forty-five dollars 45. 00) for one acre or greater shall be submitted by the responsible party at the time of filing. 2. Less Than One Acre: Land disturbing activity of less than one acre is not required to comply with MPDES general permit number MTR100000, but shall prepare and submit a Construction Stormwater Permit, for review and approval by the City of Kalispell Public Works Department, containing the following: a. A complete Construction Stormwater Permit application form; b. A map of the construction site showing the locations of the selected BMPs. 119 of 334 ---PAGE BREAK--- c. A City of Kalispell Construction Stormwater Permit fee of ten dollars 10. 00) for less than one acre shall be submitted by the responsible party at the time of filing. 3. Notice of Termination ( NOT): Land disturbing activity with a Construction Stormwater Permit shall submit an NOT once permanent erosion control has been established on seventy percent ( 70%) or greater of disturbed areas. Additionally, for NOT approval all temporary BMPs must be removed, all construction equipment and vehicles must be removed, and all potential pollutant -generating actives due to construction activity must cease. C. Implementation and Maintenance ofBest Management Practices: Each responsible party shall implement and maintain BMPs to minimize the erosion and the transport of silt, earth, topsoil, etc., by water runoff or construction activities, beyond the limits of the responsible party' s site onto city streets, drainage easements, drainage facilities, storm drains or other City property prior to beginning any land disturbing activity. On all regulated construction projects, the construction stormwater minimum standards described as Non -Numeric Technology Based Effluent Limits in the most current Montana DEQ General Permit for Storm Water Discharges Associated with Construction shall be implemented. D. Off -Site Borrow, Spoil and Staging Areas: Where applicable, off-site borrow areas, spoil areas and construction staging areas within the City limits shall be considered as part of the project site and shall be governed by this chapter. E. Related Land Areas: The erosion control requirements of this chapter shall apply to all related land areas. Additionally, when land disturbing activity occurs on a project, all disturbed land areas related to the project shall have permanent erosion control BMPs established before final occupancy of structures located thereon or final acceptance of the subdivision may be obtained. This subsection applies whether or not a building permit is required. F. Below -Ground Installations: All discharges resulting from below -ground installations shall be passed through City -approved BMPs or removed from the site and properly disposed. G. Exclusions: No Construction Stormwater Permit is required for the following activities: Any emergency activity that is immediately necessary for the protection of life, property or natural resources. 23A- 4 Franchised Utilities Comt) anies. Subject to the terms of its franchise agreement with the City, including, but not limited to, terms regarding permits, a franchised utility company engaging in land disturbing activities within the City shall comply with the following: 120 of 334 ---PAGE BREAK--- A. Construction Stormwater Permit: Prior to beginning any land disturbing activity a Construction Stormwater Permit shall be obtained as outlined in Section 23A- 3, Required Best Management Practices ( BMPs). B. Emergency Construction: Construction activity in response to emergencies where services are being restored by a franchised utility company are not subject to the requirements for filing a Construction Stormwater Permit. At the conclusion of emergency construction activity, the utility company responsible for construction activities should take any needed action to clean up or contain sediment or debris resulting from the emergency construction activity. 23A- 5 Design Reauirements. A. Design Criteria: Grading, erosion control practices, sediment control practices, and waterway crossings shall meet the design criteria set forth in the most recent version of the Erosion and Sediment Control Best Management Practices ( BMP) Reference Manual, and shall be adequate to prevent transportation of sediment from the site to the satisfaction of the City. B. Clearing and Grading: 1. Clearing and grading of natural resources, such as water bodies and wetlands, shall not be permitted, except when in compliance with all other required permits. 2. Clearing techniques that retain natural vegetation and retain natural drainage patterns, as described in the Construction Site BMP Manual, shall be used to the satisfaction of the City. 3. Phasing shall be required on all sites disturbing equal to or greater than thirty acres, with the size of each phase to be established at plan review and as approved by the City. 4. Clearing, except that necessary to establish sediment control devices, shall not begin until all sediment control devices have been installed and have been stabilized. C. Erosion Control: 1. Soil must be stabilized using recommended methods described in the Construction Site BMP Manual. a. Erosion seeding is the immediate seeding on cut and fill slopes steeper than 3: 1 that will not undergo further disturbance. 121 of 334 ---PAGE BREAK--- b. Temporary seeding is the establishment of a temporary vegetative cover on areas with a slope of 3: 1 or flatter that will be exposed for longer than fourteen ( 14) days and can undergo further disturbance. 2. Soil stockpiles must be stabilized or covered at the end of each workday. 3. Techniques shall be employed to prevent the blowing of dust or sediment from the site. 4. Techniques that divert upland runoff past disturbed slopes shall be employed. D. Sediment Controls: 1. Sediment controls shall be provided in the form of settling basins or sediment traps or tanks, temporary seeding, perimeter controls or other methods described in the Construction Site BMP Manual. 2. Where possible, settling basins shall be designed in a manner that allows adaptation to provide long-term stormwater management. 3. Adjacent properties shall be protected by the use of a vegetative buffer, silt fence, fiber rolls, or other BMPs outlined in the Construction Site BMP Manual. E. Winterization: 1. Winterization BMPs described in the Construction Site BMP Manual shall be implemented on projects prior to seasonal shut downs or downtime of one month or longer. F. Waterways and Watercourses: 1. When a watercourse must be crossed regularly during construction, a temporary stream crossing shall be provided and an approval obtained from the City and all other authorized permitting agencies. 2. When in -channel work is conducted, the channel shall be stabilized before, during and after work. 3. All on- site stormwater conveyance channels shall be designed according to the criteria outlined in the current edition of the City of Kalispell Standards for Design and Construction. 4. Stabilization adequate to prevent erosion must be provided at the outlets of all pipes and paved channels. 122 of 334 ---PAGE BREAK--- G. Construction Site Access: 1. A temporary access entrance shall be provided at all sites and shall be in accordance with the current edition of the City of Kalispell Standards for Design and Construction. 2. Other measures may be required at the discretion of the City in order to ensure that sediment is not tracked onto public streets by construction vehicles, or washed into storm drains. H. Removal of Temporary BMPs: Upon establishing seventy percent ( 70%) or greater permanent ground cover on a lot, all temporary erosion control devices shall be removed. 23A- 6 Construction Waste Manaizement. Construction site operators must, at a minimum, control waste such as discarded building materials, concrete truck washout water, chemicals, litter, and sanitary waste at the construction site that may cause adverse impacts to water quality. This includes: A. Operators must keep solid waste materials in either a secure enclosed container or an enclosed waste collection area on site that does not receive a substantial amount of runoff from upland areas and that does not drain directly to a water body, and that prohibits pollutant runoff from the construction site, and that does not allow wind- blown debris to leave the site. B. Chemicals, paint, petroleum, fertilizer, and pesticides must be stored in a covered enclosure C. Above ground petroleum storage tanks must be placed in a bermed enclosure. D. Empty/unused chemical containers must be disposed of in accordance with label instructions. E. Potentially hazardous waste must be segregated from nonhazardous waste. F. Daily cleanup of construction sites must ensure that all litter is contained in an appropriate enclosure or container so as not to accumulate on the ground. G. All construction site wastes must be disposed of at authorized disposal facilities. H. Recycling of waste material is encouraged where feasible. I. Concrete truck washout water that is contained on site shall be in a designated washout pit, and concrete residue removed at conclusion of construction. 123 of 334 ---PAGE BREAK--- J. Sanitary waste facilities should be located a minimum of fifteen feet ( 15') from storm drain inlets and receiving waters, and the facilities must be self-contained. 23A- 7 Inspection and Review. A. Permit review and inspection programs aid in compliance and enforcement, and provide an opportunity for guidance and education. 1. The City shall perform a site plan review for consideration of potential water quality impacts at the time of filing the Construction Stormwater Permit. 2. The City shall establish appropriate frequencies for inspection of construction stormwater pollution prevention measures at all active construction sites. 3. The City shall require notification from a construction site operator prior to start or upon completion of various stages of construction on a schedule approved by the City. B. The permittee or his or her agent will be required to perform regularly scheduled site inspections ( at least every fourteen ( 14) days) and after major storm events to ensure all accepted BMPs have been constructed and are functioning properly. The purpose of such inspections will be to determine the overall effectiveness of the control plan and the need for additional control measures. All inspections shall be documented in written form and made available for review by the City. Article 3 POST- CONSTR UCTION STORMWA TER MANAGEMENT 23A- 8 Applicability. This program applies to the permitting of post -construction stormwater control structures within the MS4 area of the City of Kalispell. Both new and existing structures that meet the criteria will be permitted. 23A-9 A2encv Inspections. The City of Kalispell' s Public Works Department or an authorized inspection agent may inspect, at a reasonable time and in a reasonable manner, anything that affects or may affect the quality of the waters of the state, including but not limited to the premises of existing post -construction stormwater control structures; or the premises for which an application has been filed with the department for plan or permit approval; or the premises for which the department has issued a stormwater construction permit or stormwater maintenance permit. 23A- 10 Stormwater Maintenance Permit. A. Permit Application 124 of 334 ---PAGE BREAK--- 1. Projects required to obtain and maintain a stormwater maintenance permit are projects that require post -construction stormwater management practices under the City of Kalispell' s Standards for Design and Construction. The application is initiated during the City of Kalispell' s engineering plan review. 2. The developer and owner of a site must certify that the application is being submitted on their behalf. 3. To obtain a permit, an owner must file an application on the Public Works Department' s website. The application must be accompanied by the following: a. Permanently responsible party, including the name and contact information for the person or company designated to inspect and maintain the practices; b. An operation and maintenance manual, in an electronic format acceptable to the department; c. As -built plan of the site' s stormwater management practices, including inverts in and out of all structures, at a scale no less than 1" to 50' in an electronic format acceptable to the department signed and sealed by a qualified professional; d. Notice of termination (NOT) submitted electronically for the related construction stormwater management permit. B. Permits for post -construction stormwater management practices are not required for the following: 1. Development projects that do not trigger a post -construction stormwater management practice under the City of Kalispell Standards for Design and Construction; and 2. Installation of underground, linear utilities, such as gas lines, fiber- optic cable, cable TV, electric, telephone, sewer mains, and water mains where surface will be restored to the existing condition and no stormwater facility is constructed. C. Permit Conditions 1. Perform an inspection every year by October 1. The owner or owner' s representative must electronically file inspections to the department that certify the stormwater management practices are operating as designed. Inspections forms are located on the Public Works Department' s website. 125 of 334 ---PAGE BREAK--- a. Permits approved after April 1 will not be required to submit an inspection until the subsequent year. 2. The owner of the site must renew the stormwater maintenance permit every five years. An electronic application for renewal found on the Public Works Department' s website must be submitted by October 1 of the fifth year and must be accompanied by a report certified by a professional engineer that the stormwater management practices are operating as designed. a. At a minimum, the report must include an inspection of the control comparing the as -built plan and operation and maintenance manual to determine if the control is operating as designed and if maintenance is required. If the control requires maintenance or other changes, the report shall contain mitigation measures required and a timeline to complete measures prior to the next required inspection. 3. A licensed professional engineer must perform inspections and certifications of any post -construction stormwater management practices that include structural components. 4. The owner of the site must notify the department of any sale or conveyance of the premises and must provide the name of and contact information for the new owner. D. Modification ofa post -construction stormwater management practice design covered by a stormwater maintenance permit 1. Should the owner wish to modify the design of a stormwater management practice covered by a stormwater maintenance permit, the owner must submit notification of the modification for engineering review and approval by Public Works. 2. The modification of the stormwater maintenance permit must include calculations and supporting documentation to demonstrate that the practice is at least as protective of water quality as the existing practice and that it controls stormwater flows as required by the City of Kalispell' s Standards for Design and Construction. 3. The department will review the modification and supporting material following the criteria for new stormwater maintenance applications. E. Agency Inspections. The City of Kalispell' s Public Works Department or an authorized inspection agent may conduct periodic inspections to ensure that post - construction stormwater management practices are maintained in good working condition to meet the applicable design and water quality standards. 126 of 334 ---PAGE BREAK--- F. Recordkeeping. The owner must keep and maintain records of all inspections and tests required after construction for five years after performance of such inspections or tests. The owner must keep and maintain all as -built drawings for the life of the post - construction stormwater management facility. Article 4 CONTROL OF POLLUTANTS INTO STORM SEWER SYSTEM 23A- 11 Abblicability. This article shall apply to all water entering the storm drain system generated on any developed and undeveloped lands unless explicitly exempted by the City of Kalispell. 23A- 12 Responsibility for Administration. The City of Kalispell, through the Office of City Manager and those he shall delegate within the Department of Public Works or as agents of the City shall administer, implement, and enforce the provisions of this article. Any powers granted or duties imposed upon the City of Kalispell may be delegated in writing by the City Manager to persons or entities acting in the beneficial interest of or in the employ of the City. 23A- 13 Discharee Prohibitions. A. Prohibition ofIllegal Discharges. No person shall throw, drain, or otherwise discharge, cause, or allow others under its control to throw, drain, or otherwise discharge into the MS4 any pollutants or waters containing any pollutants, other than stormwater. The commencement, conduct or continuance of any illegal discharge to the storm drain system is prohibited except as described as follows: 1. The following discharges are exempt from discharge prohibitions established by this article: a. A discharge or flow resulting from fire fighting by the Fire Department; b. A discharge or flow from lawn watering, or landscape irrigation; c. A discharge or flow from a riparian habitat or wetland; d. A discharge of flow from a diverted stream flows, or natural spring; e. Uncontaminated ground water infiltration, and rising ground waters; f. A discharge or flow from individual residential car washing; g. Uncontaminated discharge of flow from a foundation drain, crawl space pumps, or footing drains; 127 of 334 ---PAGE BREAK--- h. A discharge of flow from a potable water sources not containing any harmful substance or material from the cleaning or draining of a storage tank or other container; i. A discharge or flow from air conditioning condensation that is unmixed with water from a cooling tower, emissions scrubber, emissions filter, or any other source of pollutant; j. De -chlorinated drainage from private residential swimming pool and hot tubs; drainage from swimming pool and hot tub filter backwash is prohibited. 2. The following discharges are exempt from discharge prohibitions established by this article with written permission from the Director of Public Works: a. A discharge flow from water line flushing or disinfection that contains no harmful quality of total residual chlorine or any other chemical used in line disinfection; b. A discharge or flow of uncontaminated stormwater and groundwater pumped from an excavation; A discharge or flow from pumped uncontaminated groundwater; d. A discharge or flow from water used in street washing or cosmetic cleaning that is not contaminated with any soap, detergent, degreaser, solvent, emulsifier, dispersant, or any other harmful cleaning substance; e. Discharges associated with dye testing; f. Discharges associated with non- commercial or charity car washes. 3. The prohibition shall not apply to any non- stormwater discharge permitted under an MPDES permit, waiver, or waste discharge order issued to the discharger and administered under the authority of the Montana Department of Environmental Quality ( DEQ) provided that the discharger is in full compliance with all requirements of the permit, waiver, or order and other applicable laws and regulations, and provided that written approval has also been granted for such discharge to the storm drain system by the City of Kalispell Director of Public Works. B. Prohibition of Illicit Connections. 1. The construction, use, maintenance or continued existence of illicit connections to the storm drain system is prohibited. 128 of 334 ---PAGE BREAK--- 2. This prohibition expressly includes, without limitation, illicit connections made in the past, regardless of whether the connection was permissible under law or practices applicable or prevailing at the time of connection. 3. A person is considered to be in violation of this article if the person connects a line conveying sewage to the MS4, or allows such a connection to continue. 4. Improper connections in violation of this article must be disconnected and redirected, if necessary, to an approved onsite wastewater management system or the sanitary sewer system upon approval of the Public Works Department. 5. Any drain or conveyance that has not been documented in plans, maps or equivalent, and which may be connected to the storm sewer system, shall be located by the owner or occupant of that property upon receipt of written notice of violation from the City of Kalispell requiring that such locating be completed. Such notice will specify a reasonable time period within which the location of the drain or conveyance is to be determined, that the drain or conveyance be identified as storm sewer, sanitary sewer or other, and that the outfall location or point of connection to the storm sewer system, sanitary sewer system or other discharge point be identified. Results of these investigations are to be documented and provided to the City of Kalispell Public Works Department. 23A- 14 Watercourse Protection. Every person owning property through which a watercourse passes, or such person' s lessee, shall keep and maintain that part of the watercourse within the property free of trash, debris, yard waste, and other obstacles that would pollute, contaminate, or significantly retard the flow of water through the watercourse. In addition, the owner or lessee shall maintain existing privately owned structures within or adjacent to a watercourse, so that such structures will not become a hazard to the use, function, or physical integrity of the watercourse. 23A- 15 Industrial and Construction Activitv. A. Submission ofNotice ofIntent (NOI), Stormwater Pollution Prevention Plan and Confirmation Letterfrom the State Department ofEnvironmental Quality DEQ) to City ofKalispell. 1. Any person subject to an industrial or construction activity MPDES discharge permit shall comply with all provisions of such permit. Proof of compliance with said permit may be required in a form acceptable to the City of Kalispell Public Works prior to the allowing of discharges to the MS4. 2. The operator of a facility, including construction sites, required to have an MPDES permit to discharge stormwater associated with industrial activity shall submit a copy of the Notice of Intent (NOI), Stormwater Pollution Prevention 129 of 334 ---PAGE BREAK--- Plan ( and Confirmation Letter from the State Department of Environmental Quality ( DEQ) to the City of Kalispell Public Works Department at the same time the operator submits the original NOT and to the State Department of Environmental Quality ( DEQ) as applicable. 3. The copy of the NOI, shall be delivered electronically to the City of Kalispell Public Works Department. 4. A person commits a violation of this Chapter if the person operates a facility that is discharging stormwater associated with industrial activity without having submitted a copy of the NOI, and Confirmation Letter from the State Department of Environmental Quality ( DEQ) to the City of Kalispell Public Works Department. 23A- 16 Combliance Monitorin, 2. A. Right of Entry: Inspection and Sampling. The City of Kalispell shall be permitted to enter and inspect facilities subject to regulation under this article as often as may be necessary to determine compliance with this article. 1. If a discharger has security measures in force that require proper identification and clearance before entry into its premises, the discharger shall make the necessary arrangements to allow access to representatives of the City. 2. Facility operators shall allow the City of Kalispell ready access to all parts of the premises for the purposes of inspection, sampling, examination and copying of records that must be kept under the conditions of an MPDES permit to discharge stormwater, and the performance of any additional duties as defined by state and federal law. 3. The City shall have the right to set up on any permitted facility such devices as are necessary in the opinion of the City to conduct monitoring and/ or sampling of the facility' s stormwater discharge. 4 The City has the right to require the discharger to install monitoring equipment as necessary. The facility' s sampling and monitoring equipment shall be maintained at all times in a safe and proper operating condition by the discharger at its own expense. All devices used to measure stormwater flow and quality shall be calibrated to ensure their accuracy. 5. Any temporary or permanent obstruction to safe and easy access to the facility to be inspected and/ or sampled shall be removed by the operator at the written or oral request of the City and shall not be replaced. The costs of clearing such access shall be borne by the operator. 130 of 334 ---PAGE BREAK--- 6. Unreasonable delays in allowing the City access to a permitted facility is a violation of a stormwater discharge permit and of this article. A person who is the operator of a facility with an MPDES permit to discharge stormwater associated with industrial activity commits an offense if the person denies the City reasonable access to the permitted facility for the purpose of conducting any activity authorized or required by this article. B. Search Warrants. If the City has been refused access to any part of the premises from which stormwater is discharged, and it is able to demonstrate probable cause to believe that there may be a violation of this article, or that there is a need to inspect and/or sample as part of a routine inspection and sampling program designed to verify compliance with this article or any order issued hereunder, or to protect the overall public health, safety, and welfare of the community, then the City may seek issuance of a search warrant from any court of competent jurisdiction. 23A- 17 Reauirement to Prevent. Control and Reduce Stormwater Pollutants by the Use of Best Management Practices. The City of Kalispell will adopt requirements identifying best management practices for any activity, operation, or facility that may cause or contribute to pollution or contamination of stormwater, the storm drain system, or waters of the United States. The owner or operator of such activity, operation, or facility shall provide, at their own expense, reasonable protection from accidental discharge of prohibited materials or other wastes into the municipal storm drain system or watercourses through the use of these structural and non- structural BMPs. Further, any person responsible for a property or premises that is, or may be, the source of an illicit discharge, may be required to implement, at said person' s expense, additional structural and non- structural BMPs to prevent the further discharge of pollutants to the MS4. Compliance with all terms and conditions of a valid MPDES permit authorizing the discharge of stormwater associated with industrial activity, to the extent practicable, shall be deemed compliance with the provisions of this section. These BMPs shall be part of a storm pollution prevention plan as necessary for compliance with requirements of the MPDES permit. 23A- 18 Notification of Shills. Notwithstanding other requirements of law, as soon as any person responsible for a facility or operation, or responsible for emergency response for a facility or operation has information of any known or suspected release of materials which are resulting or may result in illegal discharges or pollutants discharging into stormwater, the storm drain system, or waters of the United States, said person shall take all necessary steps to ensure the discovery, containment, and cleanup of such release. In the event of such a release of hazardous materials said person shall immediately notify emergency response agencies of the occurrence via emergency dispatch services. In the event of a release of non- hazardous materials, said person shall notify the City of Kalispell Director of Public Works in person or by phone or facsimile no later than the next business day. 131 of 334 ---PAGE BREAK--- Notifications in person or by phone shall be confirmed by written notice addressed and mailed to the City of Kalispell Department of Public Works within seven ( 7) business days of the phone notice. If the discharge of prohibited materials emanates from a commercial or industrial establishment, the owner or operator of such establishment shall also retain an on- site written record of the discharge and the actions taken to prevent its recurrence. Such records shall be retained for at least five ( 5) years. Failure to provide notification of a release as provided above is a violation of this Chapter. Article S ENFORCEMENT, PENALTIES AND EXEMPTIONS 23A- 19 Enforcement. Enforcement of this Chapter will follow the procedures outlined in the most current Enforcement Response Plan (ERP) for Stormwater Management as approved by Resolution of the Kalispell City Council. A. Violations ofArticle 2 of this Chapter: It is unlawful for any person to violate any provision or fail to comply with any of the requirements of Article 2 of this Chapter. Any person who has violated or continues to violate the provisions of this article, may be subject to the enforcement actions outlined in this section and the ERP or may be restrained by injunction or otherwise abated in a manner provided by law. Violations of Article 2 of this Chapter shall be a municipal infraction pursuant to Chapter 1, Article 2 of the Kalispell City Code for a responsible party or a third party performing work on a project to violate any of the requirements of those articles, including, but not limited to, the following: 1. Conducting any land disturbing or construction activity of greater than one acre without submitting a notice of intent to comply with NPDES or MPDES general permit for stormwater discharge associated with construction activity requirements for the location where the land disturbing activity occurred 2. Failing to install BMPs or to maintain BMPs throughout the duration of land disturbing activities 3. Failing to obtain an approved Construction Stormwater Permit from the City prior to any land disturbing activity 4. Failing to remove off-site sedimentation that is a direct result of land disturbing activities where such off-site sedimentation results from the failure to implement or maintain BMPs as specified in this chapter 5. Allowing sediment laden water resulting from belowground installations to flow from a site without being treated through a BMP 6. Failing to repair damage to existing BMPs, including replacement of existing grass or sod 132 of 334 ---PAGE BREAK--- 7. Failing to provide adequate measures to contain and properly dispose of solid waste, sanitary waste, hazardous waste, chemicals, petroleum products, or concrete truck washout at or from a construction site B. Exemptions. The following activities are exempt from the requirement of Article 2 to obtain a permit and from following the above- described procedures: 1. Emergencies posing an immediate danger to life or property, or substantial flood or fire hazards. 2. Any activity where the total volume of material disturbed, stored, disposed of or used as fill does not exceed five ( 5) cubic yards or the area disturbed does not exceed one thousand ( 1000) square feet provided it does not obstruct a watercourse, and is not located in a floodplain. C. Violations ofArticle 3 ofthis Chapter. It is unlawful for any person to violate any provision or fail to comply with any of the requirements of Article 3 of this Chapter. Any person who has violated or continues to violate the provisions of this article, may be subject to the enforcement actions outlined in this section and the ERP or may be restrained by injunction or otherwise abated in a manner provided by law. In the event the violation constitutes an immediate danger to public health or public safety, the City of Kalispell is authorized to enter upon the subject private property, without giving prior notice, to take any and all measures necessary to abate the violation and/ or restore the property. The City is authorized to seek costs of the abatement as outlined in this article. Violations of Article 3 of this Chapter shall be a municipal infraction pursuant to Chapter 1, Article 2 of the Kalispell City Code for a responsible party or a third party performing work on a project to violate any of the requirements of those articles, including, but not limited to, the following: Failure to obtain a stormwater maintenance permit 2. Failure to submit an annual inspection to the Public Works Department for a post - construction stormwater control 3. Failure to renew a stormwater maintenance permit 4. Failure to notify the Public Works Department of a change of ownership 5. Failure to get approval to modify a practice covered by a stormwater maintenance permit 6. Failure to maintain a post -construction stormwater control in good working condition to meet the applicable design and water quality standards 133 of 334 ---PAGE BREAK--- 7. Failure to keep and maintain records D. Stormwater Maintenance Permit Inspections: If the required annual inspections are not being completed, the City may perform the inspections or hire a contractor to perform the required maintenance and invoice the HOA, POA, or responsible property owner the cost to perform and administer the work. E. Maintaining Stormwater Maintenance Permit Facilities: If the required maintenance and repairs are not being performed and inhibit the intended function ofthe stormwater system, the City may hire a contractor to perform the required maintenance and invoice the HOA, POA, or responsible property owner the cost to perform and administer the work. F. Stormwater Maintenance Districts: In the event the HOA, POA, or responsible property owner fail to perform the required maintenance and repairs to the stormwater facility and inhibit the intended function of the stormwater system, a stormwater maintenance district program may be formed in accordance with 7- 12- 4102 MCA incorporating all the lots within a development. The taxes levied within the maintenance district shall be determined by the Public Works Department with approval of the Kalispell City Council. G. Violations ofArticle 4 ofthis Chapter. It is unlawful for any person to violate any provision or fail to comply with any of the requirements of Article 4 of this Chapter. Any person who has violated or continues to violate the provisions of this article, may be subject to the enforcement actions outlined in this section and the ERP or may be restrained by injunction or otherwise abated in a manner provided by law. In the event the violation constitutes an immediate danger to public health or public safety, the City of Kalispell is authorized to enter upon the subject private property, without giving prior notice, to take any and all measures necessary to abate the violation and/ or restore the property. The City is authorized to seek costs of the abatement as outlined in this article. Violations of Article 4 of this Chapter shall be a municipal infraction pursuant to Chapter 1, Article 2 of the Kalispell City Code for violations any of the requirements of those articles, including, but not limited to, the following: Dumping household toxins in a storm drain 2. Contractor discharging paint, concrete wash water, or other deleterious substance into a storm drain 3. Restaurant or business discharging fat, oil, grease, or mop wash water into a storm drain 4. Direct connection of anything other than stormwater or clean groundwater to a storm sewer 134 of 334 ---PAGE BREAK--- 5. Discharging wastewater form RV, camper, or another source to a storm sewer H. Violation Response: Dependent on the severity of the violation, the proper response( s) will be identified and initiated. Escalation will follow the ERP. The City' s response remedies are described below. 1. Warning Notice: A warning notice will be used to obtain additional information pertaining to a potential violation or to resolve an infrequent violation. The initial contact will take place within 24 hours of determining a potential violation. At a minimum, the conversation shall be documented with the following information: date/ time of contact, 2. the City staff member who initiated contact, 3. the person contacted ( responsible party), and 4. the content of the conversation. 2. Notices of Violation: The NOV will be issued as a warning for significant violations of the City' s stormwater ordinances and requirements or in cases where a verbal warning for a minor infraction has been ignored for at least 7 days. The NOV documents the initial attempts of the City to resolve the violation. The NOV will include the following information: 1. the specific violation, 2. photos ( if possible), 3. timeframe and actions required to return to compliance, and 4. a warning that further enforcement action may be taken for failure to comply. Such notice may require without limitation: The performance of monitoring, analyses, and reporting; 2. The elimination of illicit connections or discharges; 3. That violating discharges, practices, or operations shall cease and desist; 135 of 334 ---PAGE BREAK--- 4. The abatement or remediation of stormwater pollution or contamination hazards and the restoration of any affected property 5. Payment of a fine to cover administrative and remediation costs; and 6. The implementation of source control or treatment BMPs. 3. Compliance Schedule: A compliance schedule directs the responsible party to address the violation and restore compliance by a specified date. The compliance schedule will include the following: 1. the specific violation, 2. the City' s previous correspondence and attempts to achieve compliance, 3. required actions to be completed by the responsible party, and 4. dates by which the actions must be completed to return to compliance. Issuance of a compliance schedule does not necessarily relieve the responsible party of having to meet any existing stormwater control commitments, nor protect the responsible party. 4. Meeting: A meeting will be requested with the responsible party within 2 working days ( or a timeframe deemed appropriate for the situation) of the initial contact without fully mitigating the violation, or in the opinion of the Stormwater Coordinator, when the responsible party is not putting forth a good faith effort. The meeting will serve to educate the responsible party regarding the violation and to discuss necessary measures for correction. The meeting will be conducted by the Stormwater Coordinator or another delegated City employee. At a minimum, the meeting shall be documented with the following information: meeting location, 2. date/ time of meeting, 3. meeting attendees, 4. content of the conversation, and agreements made at the meeting. 5. Stop Work Order: A stop work order (SWO) is a notice which informs the construction site operator of an ongoing stormwater management violation and 136 of 334 ---PAGE BREAK--- requires a termination of work until the matter is resolved. No City permits, payments, or approvals of any kind will be issued for any project the owner or contractor is involved with as long as the SWO is in effect. The SWO will be issued for failure to comply with an NOV or for extreme violations of the City' s construction site stormwater requirements. The SWO will include the following information: the specific violation, 2. contact information for the City personnel who must be contacted to discuss required remediation procedures, 3. the mitigation goals necessary to remove the stop work order, and 4. a warning notifying the site operator of additional enforcement actions for continued noncompliance. A stop work order will not be removed until the situation is completely resolved as determined by the issuer of the stop work order. 6. Administrative Order: An administrative order is a formal enforcement document that requires the responsible party to either cease the specified activity or implement specified corrective measures. An administrative order will be issued when informal remedies have been pursued and have not resulted in compliance. 7. Order to Show Cause: An Order to Show Cause ( OSC) directs the responsible party to appear before the City Manager explain their noncompliance, and show cause why more severe enforcement actions should not be pursued. An OSC will be issued when an administrative order or other enforcement remedy has been disputed and has not resulted in compliance. 8. Municipal Infraction: A municipal infraction is a civil offense punishable by a civil penalty. An administrative fine is assessed by the Municipal Court Judge to the responsible party for a violation of the City' s stormwater management requirements. The fine is considered punitive in nature and is not related to any specific cost borne by the City. The amount of the fine will be proportional to the harm caused by the violation at the discretion of the Municipal Court Judge. The City may also recover damages to its MS4 or for the cost of fixing/maintaining stormwater infrastructure as stated in City ordinances. 9. Suspend Service: The City has the authority to suspend water service, solid waste removal, and any other City services deemed applicable. These actions will be used against a responsible party that fails to comply with previous remedies or to stop discharges considered to pose an immediate risk to the public or the environment. 137 of 334 ---PAGE BREAK--- 10. Injunctive Relief: An injunction is a court order which directs the responsible party to cease a specified action or behavior. The City will seek injunctive relief if the responsible party refuses to comply with an administrative order or if delays in filing a civil suit would result in irreparable harm to the MS4 or receiving waterbody. 11. Consent Decree: A consent decree is an agreement between the City and the responsible party reached after a lawsuit has been filed. A consent decree will be pursued when the City and the responsible party can reach a suitable agreement. 12. Civil Penalties: If necessary, a civil suit will be used to recover costs borne by the City in responding to the responsible party' s noncompliance. 13. Criminal Penalties: Criminal prosecution is a formal process of charging the responsible party with violations of ordinance provisions punishable by fines and/or imprisonment. Criminal prosecution will be pursued when the responsible party has ignored all previous corrective actions for 2 weeks and in the view of the Kalispell City Attorney or the State DEQ, the responsible party is not taking sufficient action to mitigate the violation. The filing of criminal charges may be started sooner at the discretion of the Kalispell City Attorney. I. Appeal of Notice of Violation. Any person receiving a notice of violation may appeal the determination of the City Manager. The notice of appeal must be received within ten ( 10) days from the date of the notice of violation. Hearing on the appeal before the City Council shall take place within twenty ( 20) days from the date of receipt of the notice of appeal. The decision of the City Council shall be final. J. Enforcement Measures After Appeal. If the violation has not been corrected pursuant to the requirements set forth in the notice of violation, or, in the event of an appeal, within ten ( 10) days of the decision of the City Council upholding the decision of the City Manager, then representatives of the City shall enter upon the subject private property and are authorized to take any and all measures necessary to abate the violation and/or restore the property. It is unlawful for any person, owner, agent or person in possession of any premises to refuse to allow the government agency or designated contractor to enter upon the premises for the purposes set forth above. 23A- 20 Cost of Abatement of the Violation. Within twenty ( 20) days after abatement of the violation, the owner of the property will be notified of the cost of abatement, including administrative costs. The liability shall be paid in not more than twelve ( 12) equal payments. Interest at the rate of ten ( 10) percent per annum shall be 138 of 334 ---PAGE BREAK--- assessed on the balance beginning on the twentieth ( 20th) day following discovery of the violation. The property owner may file a written protest objecting to the amount of the assessment within twenty (20) days. If the amount due is not paid within a timely manner as determined by the decision of the municipal authority or by the expiration of the time in which to file an appeal, the charges shall become a special assessment against the property and shall constitute a lien on the property for the amount of the assessment. 23A- 21 Violations Deemed a Public Nuisance. In addition to the enforcement processes and penalties provided, any condition caused or permitted to exist in violation of any of the provisions of this article is a threat to public health, safety, and welfare, and is declared and deemed a nuisance, and may be abated or restored at the violator' s expense, pursuant to City article, and/ or a civil action to abate, enjoin, or otherwise compel the cessation of such nuisance may be taken. Article S General Terms 23A- 22 Remedies Not Exclusive. The remedies listed in this Chapter are not exclusive of any other remedies available under any applicable federal, state or local law and it is within the discretion of the City to seek cumulative remedies. The City may recover all attorneys fees, court costs and other expenses associated with enforcement of this Chapter, including sampling and monitoring expenses. 23A-23 Comt)atibility with Other Regulations. This Chapter is not intended to modify or repeal any other chapter, article, rule, regulation, or other provision of law. The requirements of this Chapter are in addition to the requirements of any other ordinance, rule, regulation, or other provision of law, and where any provision of this article imposes restrictions different from those imposed by any other article, rale, regulation, or other provision of law, whichever provision is more restrictive or imposes higher protective standards for human health or the environment shall control. 23A-24 Severabilitv. The provisions of this Chapter are hereby declared to be severable. If any provision, clause, sentence, or paragraph of this Chapter or the application thereof to any person, establishment, or circumstances shall be held invalid, such invalidity shall not affect the other provisions or application of this Chapter. 23A- 25 Ultimate Resbonsibility. The standards set forth herein and promulgated pursuant to this Chapter are minimum standards; therefore this Chapter does not intend or imply that compliance by any person of this Chapter 139 of 334 ---PAGE BREAK--- will ensure that there will be a determination of no contamination, pollution, or unauthorized discharge of pollutants by a state or federal agency. 140 of 334 ---PAGE BREAK--- Appendix E: Kalispell Municipal Pollution Prevention and Good Housekeeping Manual (Operations and Maintenance Program) 141 of 334 ---PAGE BREAK--- i MS4 Stormwater Program CITY OF KALISPELL PUBLIC WORKS - 201 1st Ave East, Kalispell, MT KALISPELL OPERATIONS AND MAINTENANCE PROGRAM REDUCING POLLUTANT RUNOFF FROM CITY OPERATIONS STANDARD OPERATING PROCEDURES 142 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual ii Contents 1 Introduction 4 2 Fixed Facilities 5 2.1 City Shop Complex 6 2.2 Composting Yard 12 2.3 Woodland Water Park Facility 15 2.4 City Parks 18 2.5 Fire Station 21 2.6 Waste Water Treatment Plant (WWTP) 25 2.7 Well and Pump Facilities 28 3 Field Operations 32 3.1 Street Department 32 3.2 Parks and Recreation Department 33 3.3 Signs and Signals Department 33 3.4 Water Department 34 3.5 Storm and Sewer Department 34 3.6 Fire Department 35 3.7 Solid Waste 36 4 Best Management Practices (BMPs) 37 4.1 Introduction 37 4.2 Facility Activity (FA) BMPs 37 FA-BMP 1: Building Maintenance and Repair 38 FA-BMP 2: Parking and Grounds Maintenance and Repair 40 FA-BMP 3: Solid Waste Handling and Disposal 42 FA-BMP 4: Small Equipment Fueling 43 FA-BMP 5: Small Equipment Maintenance and Repair 44 FA-BMP 6: Vehicle Parking and Storage 46 FA-BMP 7: Vehicle Maintenance and Repair 47 FA-BMP 8: Vehicle and Equipment Washing 49 FA-BMP 9: Outdoor Container Storage 50 FA-BMP 10: Outdoor Storage of Raw Materials Such As Asphalt, Sand, Gravel, Concrete, Topsoil, Mulch, Compost, Landscape Maintenance Waste 52 FA-BMP 11: Hazardous Materials Management-used oil, antifreeze, used batteries 53 FA-BMP 12: Concrete Mixing and Equipment Cleaning 55 FA-BMP 13: Landscape Maintenance 56 4.3 Municipal Field Operations (FO) BMPs 59 FO-BMP 1: Street and Alley Repair and Maintenance 60 FO-BMP 2: Plaza and Sidewalk Cleaning 63 143 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual iii FO-BMP 3: Winter Street Operations 65 FO-BMP 4: Landscape Maintenance 66 FO-BMP 5: Tree Removal 68 FO-BMP 6: Annual Curb Painting 70 FO-BMP 7: Street Sign/Traffic Loop Maintenance and Replacement 72 FO-BMP 8: Concrete Removal and Installation 74 FO-BMP 9: Water Utility Operation and Maintenance 76 FO-BMP 10: Sanitary Sewer Utility Operation and Maintenance 78 FO-BMP 11: Lift Station Maintenance 80 FO-BMP 12: Storm Utility Operations and Maintenance 82 FO-BMP 13: Construction Dewatering 84 FO-BMP 14: Fire Fighting Response and Practices 86 FO-BMP 15: Solid Waste Handling and Disposal 88 5 Good Housekeeping Activities and Operations 89 GH-BMP 1: Facility Yard Sweeping 90 GH-BMP 2: Storm Sewer Maintenance 91 GH-BMP 3: Spill Prevention, Response, and Containment 93 GH-BMP 4: Good Housekeeping 96 GH-BMP 5: Street Sweeping 97 GH-BMP 6: Leaf Collection 98 GH-BMP 7: Surface Water Buffer Management 99 GH-BMP 8: Illicit Discharge Management 100 6 Employee Training 101 6.1 Annual Training 101 144 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 4 1 Introduction The City of Kalispell is a designated small Municipal Separate Storm Sewer System (MS4) owner and operator under the Montana Pollutant Discharge Elimination System (MPDES) Phase II Stormwater Program. Within the State of Montana, the MPDES Phase II program is administered by the Montana Department of Environmental Quality (DEQ). Each designated MS4 owner or operator must submit an application to the DEQ for coverage to discharge stormwater from the MS4 to waters of the State. One of the requirements for MS4 permit coverage is for the City of Kalispell to develop pollution prevention/good housekeeping for permittee operations. The permittee is required to develop and implement an operations and maintenance program, which includes a training component that has the goal of preventing or reducing pollutant runoff form permittee operations. According to the regulations, the operator of a regulated Municipal Separate Storm Sewer System (MS4) community must develop a program to: • Maintain an inventory of permittee owned/operated facilities and activities that have the potential to release contaminants to the MS4, including possible contaminant(s) from each facility/activity and the local department(s)/position(s) responsible for pollution prevention with each facility/activity. • Develop standard operating procedures to prevent or reduce the amount of stormwater pollution generated by municipal operations and conveyed into receiving State waters. • Train employees on procedures to incorporate pollution prevention/good housekeeping techniques into municipal operations. This document presents a summary of City fixed facilities, field operations, best management practices (BMPs), good housekeeping measures, and training procedures, to be employed by the City to reduce the potential for polluting or negatively impacting local receiving waters from stormwater runoff. The intent of the manual is to ensure that municipal practices are performed in ways that will minimize contamination of storm drainage discharges to receiving waters. As the permittee, it is important that a municipality’s own operations minimize contamination of stormwater discharges and serve as a model for the entire regulated area. The manual is outlined to provide pollution awareness to municipal employees regarding operations and maintenance activities. The Phase II Permit Coordinator will work with City Departments and develop schedules for the implementation of the recommendation based on the availability staffing, resource, and budgets. 145 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 5 2 Fixed Facilities The City of Kalispell owns and operates multiple types of facilities. The following section outlines the facilities and inventories the municipal pollutant generating activities associated with each facility. The inventory also correlates City departments to pollution generating activities at each facility. The following City facilities may have pollution generating operations and activities: 1. City Shop Complex 2. Composting Yard 3. Woodland Water Park Facility 4. City Parks 5. Fire Stations 6. Wastewater Treatment Plant 7. Well and Pump Facilities Departments and Positions Responsible for Pollution Prevention with Each Facility/Activity The Stormwater Program Coordinator will work with the responsible positions for each department on what best practices are for reducing/eliminating pollutants from entering the MS4. Daily operations will be the responsibility of each supervisor to ensure best practices are performed. Further information can be found in the recommendations of each fixed facility. Department Position Central Garage Road and Fleet Superintendent Fire Department Fire Chief Parks and Recreation Parks Superintendent Sewer Utility Management Superintendent Solid Waste Road and Fleet Superintendent Streets Road and Fleet Superintendent Traffic Signs-Signals Road and Fleet Superintendent Water Utility Management Superintendent 146 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 6 2.1 City Shop Complex The City Shop Complex is located at 1400 1st Ave W. The Shop Complex is occupied by multiple City Departments. There is a main stormwater trunk line which runs between the department buildings and discharges into a drainage ditch which flows to Ashley Creek, see City Shop Complex Map. The following table summarizes the facility activities, potential pollutants, and associated City departments. Table 2-1: Potential Pollutants Likely Associated with the City Shop Complex and Associated Departments Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X ALL FA-BMP 2: FA-BMP 2: Grounds Maintenance and Repair X X X X X X X X ST, S FA-BMP 3: Solid Waste Handling and Disposal X X X X X X X X X SW FA-BMP 4: Small Equipment Fueling X X X ALL FA-BMP 5: Small Equipment Maintenance and Repair X X X ALL FA-BMP 6: Vehicle Parking and Storage X X X X X X ALL FA-BMP 7: Vehicle Maintenance and Repair X X X X CG, ST FA-BMP 8: Vehicle and Equipment Washing X X X X X ALL FA-BMP 9: Outdoor Container Storage X X X X X X ST, PR, CG FA-BMP 10: Outdoor Storage of Raw Material-Asphalt, Sand, Gravel, Concrete, Topsoil, Mulch, Compost, Leaves, Landscape Waste X X X X X X X X X ST, TSS, PR, W, S FA-BMP 11: Hazardous Material Management- used oil, antifreeze, used batteries, tires X X CG, ALL FA-BMP 12: Concrete Mixing and Equipment Cleaning X X X ST, W, S, TSS, PR Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR), All Departments (ALL) 147 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 7 148 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 8 149 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 9 150 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 10 Recommendations The City Shop Complex has multiple facility activities with potential to introduce pollution to waters of the State. Table 2-1 indicates those activities and the City departments associated with the facility activities. The following are recommendations on pollution prevention and good housekeeping measures, which department should implement the recommendation, and which departments should maintain the recommendation. 1. Raw Material Management: Raw material such as sand, gravel, mulch, and asphalt should have a signed designated area in the yard. a. Implementation: Public Works Superintendent should designate the areas and Signs and Signals should install the signs. b. Maintenance: All departments operating out of the City Shop Complex 2. Waste Material Management: Waste material such as yard waste, concrete, waste asphalt, tires, and sweepings should have a signed designated area in the yard. a. Implementation: Public Works Superintendent should designate the areas and Signs and Signals should install the signs. b. Maintenance: All departments operating out of the City Shop Complex. 3. Hazardous Material Management: The used oil tank, used antifreeze drums, and used battery storage should have containment, secondary containment, and proper labeling. a. Implementation: Public Works Superintendent should designate the areas and Signs and Signals should install the signs. Phase II Permit Coordinator will work with supervisor to obtain correct secondary containment and labeling. b. Maintenance: All departments operating out of the City Shop Complex. 4. The material storage area adjacent to the drainage ditch should be delineated to provide a 20’ grass filter strip. The area should be signed, ‘No Material Storage’. a. Implementation: Public Works Superintendent should designate which department spreads the topsoil and native grass seed. b. Maintenance: All departments operating out of the City Shop Complex should halt storage of material within the 20’ buffer. 5. Designate and sign an area for concrete mixing and equipment washout. a. Implementation: Public Works Superintendent should designate the area and Signs and Signals should install the signs. b. Maintenance: All departments operating out of the City Shop Complex. 6. A central spill kit should be placed in the complex for all departments to be aware of and use. a. Implementation: Public Works Superintendent should designate the areas and Signs and Signals should install the signs. Phase II Permit Coordinator will work with supervisor to obtain correct supplies for the spill kits. b. Maintenance: All departments operating out of the City Shop Complex. 7. All outside liquid storage of 15 gallons or greater should be properly labeled and have secondary containment. Specific areas are: a. Deicer tanks west of the Water Department Building - Secondary containment should be constructed around the tanks. 151 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 11 i. Public Works Superintendent is responsible. b. 20 plus 55-gallon drums with unknown liquid (polypropylene?) south of the Parks and Recreation Department building. The unknown liquid belongs to the Parks and Recreation Department. The drums should be removed from the site or contained in secondary containment. i. Parks and Recreational Department is responsible. c. Used oil tank and used antifreeze drums outside the Central Garage building. Secondary containment should be constructed around the tank. i. Public Works Superintendent is responsible. d. Any outdoor liquid storage of 15 gallons or greater should have secondary containment. 8. Implement regular facility maintenance activities and designate department responsibility. Maintenance activities include sweeping and storm drain cleanout. a. Implementation: Public Works Superintendent should designate which department performs the maintenance and how often. b. Maintenance: Sweeping-once per week, Storm drain cleanout - twice per year. 9. Each department should organize their outside storage area. Organizations should include disposing of all old and unusable waste material and equipment stored in the yard. a. Implementation: Supervisor of each department should organize the cleanup. b. Maintenance: All departments operating out of the City Shop Complex. 10. Weekly inspections of each department’s area should be performed by the department supervisor: a. Implementation: Department supervisors or foreman. 11. Annual review of the Pollution Prevention / Good Housekeeping Guidance Manual. The Guidance Manual review should involve meeting with the department supervisor to review the needed additions or changes to the manual. a. Implementation: Phase II Permit Coordinator 12. Annual Employee Training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practice for the facility activities outlined in Table 2-1. a. Implementation: Phase II Permit Coordinator. b. Trainees: All departments operating out of the City Shop Complex. 152 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 12 2.2 Composting Yard The City Composting Yard is located south of the Wastewater Treatment Plant and adjacent to Ashley Creek. The composting operation is primarily handled by the Street Department. Leaves swept during Fall leaf collection operations are delivered to the compost area, mixed with grass clippings, rotated and mixed periodically, and then used by City departments on landscaping projects. Surface flow is to the south west which flows into Ashley Creek. The following table summarizes the facility activities, potential pollutants, and associated City departments. Table 2-2: Potential Pollutants Likely Associated with the Composting Area and Associated Departments Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 10: Outdoor Storage of Raw Material-Asphalt, Sand, Gravel, Concrete, Topsoil, Mulch, Compost, Leaves, Landscape Waste X X X X X X X X ST, PR Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR) 153 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 13 154 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 14 Recommendations Storage of compost has the potential to introduce pollution to waters of the State. The following are recommendations to be implemented for the Kalispell Compost Area. 1. Provide a 20’ grass buffer between the compost pile and the top bank of Ashley Creek. a. Public Works Superintendent should designate which department places topsoil and seeds the area. b. Maintenance: No maintenance required; natural area. 2. Annual Employee Training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practice for the facility activities outlined in Table 2-2. a. Implementation: Phase II Permit Coordinator. b. Trainees: All departments utilizing the compost area. 155 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 15 2.3 Woodland Water Park Facility The City of Kalispell Woodland Water Park is a swimming pool / park facility located in Woodland Park. The operation and maintenance of the facility is performed by the Kalispell Parks and Recreation Department. The pool facility has a dechlorination overflow system which outfalls to a boggy area west of the facility. Surface drainage inside the Water Park flows to a drywell in the southwest area of the facility. Parking lot runoff flows to two separate drywell/infiltration systems. Table 2-3: Potential Pollutants Likely Associated with the City Swimming Pool Facility and Associated Departments Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X PR FA-BMP 3: Solid Waste Handling and Disposal X X X X X X X X X PR FA-BMP 2: Parking and Grounds Maintenance and Repair X X X X X X X X X ST FA-BMP 4: Small Equipment Fueling X X X PR FA-BMP 6: Vehicle Parking and Storage X X X X X PR FA-BMP 9: Outdoor Container Storage X PR FA-BMP 11: Hazardous Material Management- oil, antifreeze, batteries, chlorine X X PR FA-BMP 14: Discharge Chlorinated Wastewater X X PR Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR) 156 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 16 157 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 17 Recommendations The City of Kalispell Woodland Water Park has multiple facility activities with potential to introduce pollution to waters of the State. Table 2-4 indicates those activities and the City Departments associated with the facility activities. The following are recommendations on pollution prevention and good housekeeping measures, which departments should implement the recommendation, and which departments should maintain the recommendation. 1. Good housekeeping procedures should be developed to prevent pollution from facility cleaning, specifically the bathrooms and concession building. a. Implementation: Parks Superintendent should develop the procedure. Phase II Permit Coordinator will work with Superintendent to obtain development procedures and provide employee training. b. Maintenance: Parks and Recreation Department. 2. Dechlorinated water is discharged from the water facility to a boggy area west of the facility. Procedures should be set up to check the quality of the dechlorinated water being discharged. a. Implementation: Parks Superintendent should develop the procedure. b. Maintenance: Parks and Recreation Department. 3. All outside liquid storage should be properly labeled and have secondary containment. Hydrochloric acid is stored adjacent to the west side of the building. The hydrochloric acid drum should be stored in secondary containment. a. Implementation: Parks Superintendent should designate the area, create the containment area, and Signs and Signals should install the signs. b. Maintenance: Parks and Recreation Department. 4. Annual Employee Training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practice for the facility activities outlined in Table 2-3. a. Implementation: Phase II Permit Coordinator. b. Trainees: Parks and Recreation staff. 158 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 18 2.4 City Parks City owned parks encompass about 445 acres throughout City limits. City parks are operated and maintained by the Parks and Recreation Department and include: • Begg Park • Buffalo Head Park • Cottonwood Park • Courthouse Park • Depot Park • Dry Bridge • Empire Estates Park • Gallagher Park • Greenbriar Park • Hawthorn Park • Heritage Park • Kalispell Youth Athletic Complex • Laker & Archie Roe • Lawrence Park • Lions Park • Meridian Park • Miscellaneous Green Space • Northridge Park • Park View Terrace • Spring Prairie Tree • Sunset Park • Tennis Court Complex • Thompson Memorial Park • Washington St. Park • Western Park • Westview Park • Woodland Park The following table summarizes the facility activities, potential pollutants, and associated City departments. Table 2-4: Potential Pollutants Likely Associated with City Parks and Associated Departments Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X PR FA-BMP 2: Parking and Grounds Maintenance and Repair X X X X X X X X X ST FA-BMP 13: Landscape Maintenance X X X X X PR FO-BMP 5: Tree Removal X X X PR Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR) 159 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 19 Kalispell City Parks Interactive Map: 160 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 20 Recommendations Maintenance and operation of city parks has the potential to introduce pollutants to waters of the State. The following are recommendations to be implemented for Kalispell City Parks. 1. Provide a 20’ vegetated buffer around waterways that are either adjacent or intersect City parks. a. Implementation: Parks and Recreation Department. b. Maintenance: No maintenance required; natural area. 2. Annual Employee Training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practice for the facility activities outlined in Table 2-4. a. Implementation: Phase II Permit Coordinator. b. Trainees: Parks and Recreation staff. 161 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 21 2.5 Fire Station Facilities The City of Kalispell has two Fire Stations, Fire Station #61 located on 1st Ave E in downtown Kalispell and Fire Station #62 located on Reserve Loop in the north area of Kalispell. The Kalispell Fire Department maintains and operates both Fire Station Facilities. Surface drainage for both fire stations flows into City’s MS4 which outfall to waters of the State. The following table summarizes the facility activities, potential pollutants, and associated City departments. Table 2-5: Potential Pollutants Likely Associated with the City Fire Stations Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X FD FA-BMP 3: Solid Waste Handling and Disposal X X X X X X X X X SW FA-BMP 4: Small Equipment Fueling X X X FD FA-BMP 6: Vehicle Parking and Storage X X X X X FD FA-BMP 8: Vehicle and Equipment Washing X X X X X X FD Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR), Fire Department (FD) 162 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 22 163 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 23 164 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 24 Recommendations Fire Stations have multiple facility activities with potential to introduce pollution to waters of the State. Table 2-5 indicates those activities and the departments associated with the facility activities. The following are recommendations on pollution prevention and good housekeeping measures, which department should implement the recommendation, and which departments should maintain the recommendation. 1. Annual training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practices for the facility activities outlined in Table 2-5. a. Implementation: Phase II Permit Coordinator and Fire Department Staff. b. Trainees: Fire Department Staff. 165 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 25 2.6 Wastewater Treatment Plant (WWTP) The City WWTP is located on Airport Road in the Southwest area of Kalispell. The WWTP treats raw sewage and discharges the effluent into Ashley Creek. Surface drainage from the site sheet flows to the south and east and discharges into Ashley Creek. The following table summarizes the facility activities, potential pollutants, and associated City departments. Table 2-6: Potential Pollutants Likely Associated with the Wastewater Treatment Plant Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X WWTP FA-BMP 2: Grounds Maintenance and Repair X X X WWTP, ST FA-BMP 3: Solid Waste Handling and Disposal X X X X X X X X X WWTP FA-BMP 4: Small Equipment Fueling X X X WWTP FA-BMP 5: Small Equipment Maintenance and Repair X X X WWTP FA-BMP 6: Vehicle Parking and Storage X X X X X WWTP FA-BMP 8: Vehicle and Equipment Washing X X X X X X WWTP FA-BMP 11: Hazardous Material Management-used oil, antifreeze, used batteries X X WWTP FA-BMP 13: Landscape Maintenance X X X X X WWTP Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR), Fire Department (FD), Wastewater Treatment Plant (WWTP) 166 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 26 167 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 27 Recommendations The Kalispell WWTP has multiple facility activities with potential to introduce pollution to waters of the State. Table 2-6 indicates those activities and the City departments associated with the facility activities. The following are recommendations on pollution prevention and good housekeeping measures, which department should implement the recommendation, and which departments should maintain the recommendation. 1. Annual training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practices for the facility activities outlined in Table 2-6. a. Implementation: Phase II Permit Coordinator b. Trainees: WWTP Staff 2. A central spill kit should be placed in the complex for all to be aware of and use. a. Implementation: The WWTP Manager to get a spill kit and select the area to place the spill kit. b. Maintenance: The WWTP Manager is responsible for the supply upkeep for the spill kit. 3. All outside liquid storage should be properly labeled and have secondary containment. a. Implementation: WWTP Manager b. Maintenance: WWTP Manager 168 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 28 2.7 Well and Pump Facilities The City of Kalispell has multiple well production facilities throughout the City. Each facility has a diesel generator for backup power and uses liquid chlorine for production water disinfection. The following table summarized the facility activities, potential pollutants, and associated City departments. Table 2-7: Potential Pollutants Likely Associated with the City Well and Pump Facilities Facility Activity Potential Pollutants Department1 Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FA-BMP 1: Building Maintenance and Repair X X X X X W FA-BMP 4: Small Equipment Fueling X X X W FA-BMP 5: Small Equipment Maintenance and Repair X X X W FA-BMP 6: Vehicle Parking and Storage X X X X X X W FA-BMP 8: Vehicle and Equipment Washing X X X X X X X W FA-BMP 11: Hazardous Material Management-used oil, antifreeze, used batteries, chlorine X X W Note 1 Department Abbreviations: Streets (ST), Water Sewer Traffic Signs-Signals (TSS), Solid Waste (SW), Central Garage (CG), Parks and Recreation (PR) 169 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 29 170 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 30 171 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 31 Recommendations The City well and pump facilities have multiple facility activities which have the potential to introduce pollution to waters of the State. Table 2-8 indicates those activities. The following are recommendations on pollution prevention and good housekeeping measures to be implemented, which department should implement the recommendation, and which departments should maintain the recommendation. 1. Hazardous Material Management: a. Implementation: Liquid Chlorine should be labeled, in secondary containment, and Material Safety Data Sheets (MSDS) sheet located in the same building. i. Water Production Foreman responsibility. 2. A central spill kit should be placed in the complex for all departments to be aware of and use. a. Implementation: Supervisor of Water Production should designate the areas and Signs and Signals should install the signs. b. Maintenance: All departments. 3. All outside liquid storage should be properly labeled and have secondary containment. Specific areas are: a. Diesel tanks for generators. i. Water Production Foreman responsibility. 4. Annual Employee Training on municipal pollution prevention/good housekeeping measures for facility activities. Training will review employee best management practice for the facility activities outlined in Table 2-7. a. Implementation: Phase II Permit Coordinator. b. Trainees: All departments. 172 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 32 3 Field Operations The Field Operations sections outline potential pollutants associated with municipal field operations and activities. The tables are broken into department operations. Chapter 4 profiles BMPs for each field operation and activity. 3.1 Street Department Table 3-1: Street Department Potential Pollutants Likely Associated with Field Operations Field Operation Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 1: Road, Streets, and Alley Repair and Maintenance Chip Sealing X X Pavement Grinding X X Asphalt and Concrete Cutting X X Resurfacing Asphalt and Concrete X X Pothole Repair X X Excavation and Stockpiles X FO-BMP 2: Plaza, Sidewalk, and Parking Lot Maintenance and Cleaning Surface Sweeping and Washing X X X X X X X FO-BMP 3: Winter Street Operations Street Sanding X Snow Removal and Storage X X X Street Deicing X FO-BMP 4: Landscape Maintenance Landscaping Management Activities X X X X X X Fertilizer, Herbicide, & Pesticide Management X X X 173 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 33 3.2 Parks and Recreation Department Table 3-2: Parks & Recreation Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 4: Landscape Maintenance Landscape Management Activities X X X X X X Fertilizer, Herbicide, & Pesticide Management X X X FO-BMP 5: Tree Removal Excavation and Stockpiles X X Stump Grinding X X X 3.3 Signs and Signals Department Table 3-3: Signs and Signals Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 6: Annual Curb Painting Cleaning Curb X X X X X X Painting Curb X FO-BMP 7: Street Sign/Traffic Loop Maintenance and Replacement Excavation and Stockpiles X Asphalt and Concrete Cutting X X Resurfacing Asphalt and Concrete X X X FO-BMP 4: Landscape Maintenance Landscape Management Activities X X X X X X Fertilizer, Herbicide, & Pesticide Management X X X FO-BMP 8: Concrete Installation and Repair Excavation and Stockpiles X X Concrete Installation X 174 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 34 3.4 Water Department Table 3-4: Water Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 4: Landscape Maintenance Landscape Management Activities X X X X X X FO-BMP 9: Water Utility Operations and Maintenance Hydrant Testing X X X X X Water Main Dewatering X X X X X Water Main Flushing X X X X X Asphalt and Concrete Cutting X X Excavation and Stockpiling X X X X X FO-BMP 13: Construction Dewatering Construction Dewatering X X X X X 3.5 Storm and Sewer Department Table 3-5: Sewer Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 4: Landscape Maintenance Landscape Management Activities X X X X X X Fertilizer, Herbicide, & Pesticide Management X X X FO-BMP 10: Sewer Utility Operations and Maintenance Sanitary Sewer Maintenance X X X X X X X X X Asphalt and Concrete Cutting X X Excavation and Stockpiles X X X X X Spill Response and Containment X X X X X X FO-BMP 11: Lift Station Maintenance Lift Station Maintenance X X X X X X Landscape Management Activities X X X X Fertilizer, Herbicide, and Pesticide Management X X X X 175 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 35 Table 3-5: Sewer Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 12: Storm Utility Operations and Maintenance Storm Sewer Maintenance X X X X X X X X X Asphalt and Concrete Cutting X X Ditch Maintenance X X X X X Excavation and Stockpiles X X X X X FO-BMP 13: Construction Dewatering Construction Dewatering X X X X X 3.6 Fire Department Table 3-6: Fire Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 14: Fire Response and Training Spraying Fire with Water and Foam X X X X Training Exercises X X X X X Equipment Testing X X X X Accident Response X X X X X 176 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 36 3.7 Solid Waste Table 3-7: Solid Waste Department Potential Pollutants Likely Associated with Field Operations Field Operations Field Activity Potential Pollutants Sediment Nutrients Trash Metals Bacteria Oil, Grease, Hydrocarbons Organics Pesticides Hazardous Waste FO-BMP 15: Solid Waste Handling and Disposal Solid Waste Collection X X X X X X X X X Spill/Leak/Overflow, Response, and Containment X X X X X X X X X 177 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 37 4 Best Management Practices (BMPs) The development of the BMPs for municipal operations seeks to ensure consistent effective practices are implemented at all City-owned and operated facilities to minimize the potential for degrading local receiving water quality. These operating procedures do not address issues such as worker safety; in no case should worker safety be compromised to conform to pollution prevention operating procedures. The on-site changes described herein are not intended to be all encompassing, but rather provide a framework for improving processes at City Fixed Facilities and for City Field Operations. These procedures should be reviewed on an annual basis to ensure the procedures account for changing pollution prevention methods, control technologies, and potential changes in regulatory requirements. 4.1 Introduction This section provides a description of specific source control Best Management Practices (BMPs) for activities related to municipal fixed facilities and field operations. As noted in Sections 2 and 3 municipal fixed facilities and field operations conduct activities that have the potential to generate pollutants. The source control BMPs for field operations and fixed facilities are listed in table 4-2 and 4-3. 4.2 Facility Activity (FA) BMPs Table 4-2 Municipal Fixed Facility BMPs Facility Activity Building and Grounds Maintenance FA-BMP 1 Building Maintenance and Repair FA-BMP 2 Parking and Grounds Maintenance and Repair FA-BMP 6 Vehicle Parking and Storage FA-BMP 13 Landscape Maintenance Vehicle and Equipment Management FA-BMP 4 Small Equipment Fueling FA-BMP 5 Small Equipment Maintenance and Repair FA-BMP 7 Vehicle Maintenance and Repair FA-BMP 8 Vehicle and Equipment Washing FA-BMP 12 Concrete Mixing and Equipment Cleaning Material and Waste Management FA-BMP 3 Solid Waste Handling and Disposal FA-BMP 11 Hazardous Material Management – oil, antifreeze, batteries Outdoor Storage FA-BMP 9 Outdoor Container Storage FA-BMP 10 Outdoor Storage of Raw Material – Asphalt, Sand, Gravel, Concrete, Topsoil, Mulch, Compost, Landscape Waste Discharge Wastewater FA-BMP 14 Discharge Chlorinated Wastewater 178 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 38 FA-BMP 1: Building Maintenance and Repair Description of Pollutant Source Stormwater runoff from building maintenance activities can be contaminated with hydrocarbons in solvents, suspended solids, heavy metals, waste debris, trash, and corrosive agents. Waste wash water from building cleaning activities contains pollutants that can wash into the stormwater drainage system. Pollution Prevention Approach • Employee education • Facility inspections • Cover and/or contain the maintenance activity • Convey waste wash water to sanitary sewer or dead-end sump area • Store waste debris and trash in designated area or in solid waste container • Recycle residual paint, solvents, lumber, and other material as much as possible • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills keep spill kit nearby. 3. If possible, choose cleaning agents that can be recycled. 4. Use non-toxic chemicals for maintenance when possible. 5. Cover dumpsters or keep them undercover to prevent the entry of stormwater. Replace or repair leaking garbage dumpsters. Drain dumpster pads to sanitary sewer. Keep dumpster lids closed. 6. Sweep paved area regularly to collect loose particles and wipe up spills with rags and other absorbent materials immediately; do not hose down the area to a storm drain. a. The Street Department is responsible for regular sweeping of parking lots and paved areas. 7. Do not dump any toxic substance or liquid waste on the pavement, the ground, or toward a storm drain. Pressure Washing of Buildings and Other Larger Objects 1. Cleaning methods other than pressure washing will be used when feasible. If pressure washing needs to be used the following practices will be followed: a. When the surrounding area is paved use wastewater collection devices or filters that enable collection of wash water and associated solids. A collection device can be a sump pump and wet vacuum used to collect the runoff and loose materials. A filter can consist of filter fabric or a small mesh screen. b. When the surrounding area is grassed, runoff must be dispersed as sheet flow. The wash runoff must remain on the grass and not drain to pavement. 179 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 39 Painting 1. Use ground or drop cloths underneath outdoor painting, scraping, and sandblasting work, and properly dispose of collected material daily. 2. Clean paintbrushes and tools covered with water-based paint in sinks connected to sanitary sewer. Brushes and tools covered with non-water-based paints, finishes, or other materials must be cleaned in a manner that enables collection of used solvents paint thinners, turpentine, etc.) for recycling or proper disposal. Inspection Facilities and storage areas are entered and inspected daily to ensure pollutant sources are contained and best management practices are in place. 180 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 40 FA-BMP 2: Parking and Grounds Maintenance and Repair Description of Pollutant Source Stormwater runoff from grounds maintenance activities and parking lots can be contaminated with hydrocarbons, suspended solids, heavy metals, oils and grease, trash, and nutrients. Pollution Prevention Approach • Employee education • Facility inspections • Encourage proper landscaping and pest management techniques • Encourage proper onsite reuse and recycling of yard waste material • Use dry cleanup methods • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills keep spill kit nearby. 3. Use less-toxic chemicals for maintenance when possible. 4. Sweep paved areas regularly to collect loose particles and wipe up spills with rags and other absorbent materials immediately; do not hose down the area to a storm drain. 5. Do not dump any toxic substance or liquid waste on the pavement, the ground, or toward a storm drain. 6. Maintain solid waste containers. Empty on-site solid waste containers weekly. Do not over fill the container capacity. 7. Pick up and dispose of debris and trash around at the facility. Landscaping Management Activities 1. Do not apply any chemicals (insecticide, herbicide, or fertilizer) directly to surface waters. a. When chemicals are used for grounds maintenance, they will be waterway safe. 2. Dispose of grass clippings, leaves, sticks or other collected vegetation as garbage, as compost, or designate for reuse. Do not dispose of collected vegetation into waterways or storm drainage systems. 3. If the area is irrigated, check the irrigation schedule so chemicals will not be washed away and to minimize non-stormwater discharge. 4. Check the weather forecast; do not apply chemicals within 24 hours of a rain event. 5. Use mulch or other erosion control measures (i.e. mats, wattles, etc.) when soils are exposed. 181 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 41 6. When possible, material will not be stockpiled and will be hauled off at the end of the day. If stockpiling is needed the following practices will be followed: a. Place temporary stockpile material away from water course or storm drain inlet, and berm around or cover stockpiles to prevent release to the storm drain system. 7. Use hand or mechanical weeding where practical. Fertilizer and Pesticide Management 1. Follow manufacturer’s recommendations and label directions. 2. Do not apply pesticide or fertilizers within 100 feet of surface waters or well heads. 3. Calibrate fertilizer distributors to avoid excessive application. 4. Apply pesticides only when wind speed in the area is low. 5. Work fertilizers into the soil rather than dumping or broadcasting them onto the surface. 6. If irrigating, irrigate slowly to prevent runoff. 7. Dispose of empty pesticide containers according to the instructions on the container label. Parking Lot Management 1. Keep the parking areas clean and orderly. Remove debris in a timely fashion. 2. Use dry cleaning methods such as sweeping and vacuuming to prevent the discharge of pollutants into the stormwater conveyance system. 3. Sweep all parking lots before the spring wet season and prior to winter snow. 4. When cleaning heavy oily deposits, use absorbent materials prior to sweeping. Dispose of used absorbent material in a solid waste container. Inspection Parking and grounds maintenance areas are visually inspected on a weekly basis by City personnel. 182 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 42 FA-BMP 3: Solid Waste Handling and Disposal Description of Pollutant Source Improper storage and handling of solid waste can allow toxic compounds, oils and grease, heavy metals, nutrients, suspended solids, trash, and other pollutants to enter stormwater runoff. Pollution Prevention Approach • Employee education • Facility inspections • Cover storage containers • Store waste debris and trash in designated area or in solid waste container • Recycle materials whenever possible • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills keep spill kit nearby. 3. Cover storage containers with leak proof lids, cover all waste piles and use a berm when required to prevent runoff into storm drain systems. 4. Inspect storage container for leaks and replace any that are leaking, corroded, or otherwise deteriorated. 5. Sweep and clean the storage area regularly. Do not hose down the area to a storm drain. 6. Dispose of rinse and wash water from cleaning waste containers into sanitary sewer. Do not discharge waste wash water to the street or storm drain. 7. Take special care when loading or unloading waste to minimize losses. Pick up fallen waste and place in waste container. 8. Provide a sufficient number of solid waste containers for the facility. 9. Keep waste collection areas clean by sweeping and cleaning up spills immediately. 10. Do not fill waste container with washout water or any other liquid. 11. Place solid waste containers in areas that do not directly drain into the stormwater system. 12. Prohibit littering by workers and visitors. 13. Do not allow trash containers to overflow. Inspection Solid waste storage areas are visually inspected on a weekly basis by City personnel. 183 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 43 FA-BMP 4: Small Equipment Fueling Description of Pollutant Source Spills and leaks that occur during vehicle and equipment fueling can contribute hydrocarbons, oils and grease, and heavy metals to stormwater runoff. Pollution Prevention Approach • Employee education • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Do not fuel equipment directly over or next to the storm drain system. 3. Place an absorbent pad under the piece of equipment prior to filling. 4. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 5. Sweep and clean the storage area regularly. Do not hose down the spill area or absorbent material into a storm drain. 6. Report leaking vehicles to supervisor or fleet maintenance. Inspection Conduct a visual inspection of the fueling site prior to leaving the area. Ensure areas are clean and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 184 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 44 FA-BMP 5: Small Equipment Maintenance and Repair Description of Pollutant Source Equipment maintenance and repair is a significant source of stormwater pollution, due to the use of materials and wastes created that are harmful to humans and the environment. Pollutant sources include parts cleaning, spill/leaks of equipment liquids, replacement of fluids, equipment washing, and outdoor storage of batteries. Pollution Prevention Approach • Employee education • Recycle used motor oil, diesel oil, other maintenance liquids, and batteries • Control leaks and spills using good housekeeping spill response, cover, and containment practices Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Do not perform maintenance and repair activity directly over or next to the storm drain system. 3. The Central Garage is the designated location for equipment maintenance and repair. If maintenance and repair occur outside the Central Garage, the location should not have any connection to the storm drain system or direct connection to the sanitary sewer. The area should allow for easy cleanup of drips and spills and be under a cover whenever feasible. a. Central Garage has a drain connected to the sanitary sewer. The drain has an oil and grease separator, which is cleaned regularly. 4. Do not pour materials down drains or hose work areas; use dry absorbent and sweeping. Material and Waste Handling 1. Collect leaking or dripping fluids in drip pans or containers. Fluids are easier to recycle if kept separated. 2. Do not dispose of oil and gas filters in trash cans or dumpsters. Drain excess oil before disposal. Oil filters can be recycled. The oil filter recycle container is located in the Central Garage Shop. 3. Store cracked or dead batteries in a non-leaking covered secondary container and recycle. The battery recycle container is located outside the Central Garage Shop. Maintenance and Repair Activities 1. If temporary work is being conducted outside: Place a tarp, ground cloth, absorbent material, or drip pans beneath the equipment to capture all spills and drips. The collected drips and spills must be disposed, reused, or recycled properly. 185 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 45 2. If possible, perform all fluid removal or changing inside or under cover to prevent the run-on of stormwater and the runoff of spills: a. Keep a drip pan underneath equipment that might leak while work is being performed. b. transfer used fluids to the proper waste or recycle drums. 3. If equipment is being stored outdoors, oil and other fluids will be checked for leaks. If leaks are found, the Central Garage will fix all leaks prior to outdoor storage. 4. Monitor equipment closely for leaks and place pans under any leak to collect the fluids for proper disposal or recycling. 5. Do not mix dissimilar or incompatible waste liquids stored for recycling. Parts Cleaning 1. Clean vehicle parts without using liquid cleaners whenever possible to reduce waste. 2. Perform all liquid cleaning in a parts washer so the solvent and residual stay in one place. a. Locations with parts washers: i. Central Garage ii. WWTP Inspection Visual inspection will be conducted at the conclusion of the repair or maintenance activity to ensure all pollutant sources are removed or cleaned and that all best management practices are in place. 186 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 46 FA-BMP 6: Vehicle Parking and Storage Description of Pollutant Source Vehicle parking and storage areas can contribute pollutants to the storm drainage system such as trash, suspended solids, hydrocarbon, oils and grease, and heavy metals. Spills and leaks that occur are collected in the runoff and transported to the storm drain system. Pollution Prevention Approach • Employee education • Facility inspections • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Sweep and clean the storage area regularly. Do not hose down the spill area or absorbent material into a storm drain. 4. Report leaking vehicles to fleet maintenance. 5. If equipment is being stored outdoors for long periods of time, oil and other fluids will be checked for leaks. If leaks are found, the Central Garage will fix all leaks prior to outdoor storage. 6. Monitor vehicles closely for leaks and place drip pans under any leak to collect the fluids for proper disposal or recycling. 7. Keep the parking and storage areas clean and orderly. 8. Sweep all parking areas a minimum of once a month. Inspection Vehicle parking and storage areas are visually inspected on a weekly basis by City personnel. 187 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 47 FA-BMP 7: Vehicle Maintenance and Repair Description of Pollutant Source Vehicle maintenance and repair is a significant source of stormwater pollution, due to the use of materials and wastes created that are harmful to humans and the environment. Pollutant sources include parts cleaning, spill and leaks of equipment liquids, replacement of fluids, equipment washing, and outdoor storage of batteries. Pollution Prevention Approach • Employee education • Facility inspections • Perform vehicle maintenance in designated areas • Recycle used motor oil, diesel oil, other maintenance liquids, and batteries • Control leaks and spills using good housekeeping spill response, cover, and containment practices Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Do not perform maintenance and repair activity directly over or next to the storm drain system. 3. Designate a location for vehicle maintenance and repair to take place. The location should not have any connection to the storm drain system or direct connection to the sanitary sewer. The area should allow for easy cleanup of drips and spills and be under a cover whenever feasible. a. Vehicle maintenance should be performed in the Central Garage Shop, located at the City Shop Complex. b. Central Garage has a drain connected to the sanitary sewer. The drain has an oil and grease separator, which is cleaned regularly. 4. Do not pour materials down drains or hose work areas; use dry absorbent and sweeping. 5. Minimize the use of solvents. Clean parts without using solvents whenever possible. 6. Recycle used motor oil, diesel oil, and other vehicle fluids and parts. Material and Waste Handling 1. Collect leaking or dripping fluids in drip pans or containers. Fluids are easier to recycle if kept separated. 2. Drain and replace motor oil, coolant, and other fluids inside the Central Garage Shop. 3. Clean Central Garage oil water separator sumps every six months or more often if needed. 188 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 48 4. Do not dispose of oil and gas filters in trash cans or dumpsters. Drain excess oil before disposal. Oil filters can be recycled. The oil filter recycle container is located in the Central Garage Shop. 5. Store cracked or dead batteries in a non-leaking covered secondary container and recycle. The battery recycle container is located outside the Central Garage Shop. 6. Drain all fluids from wrecked vehicles immediately. Ensure that the drain pan or drip pan is large enough to contain drained fluids. Maintenance and Repair Activities 1. Perform vehicle maintenance in the Central Garage Shop, located at the City Shop Complex. 2. If temporary work is being conducted outside: Use a tarp, ground cloth, or drip pans beneath the vehicles to capture all spills and drips. The collected drips and spills must be disposed, reused, or recycled properly. 3. If possible, perform all fluid removal or changing inside or under cover to prevent the run-on of stormwater and the runoff of spills: a. Keep a drip pan underneath equipment that might leak while work is being performed. b. transfer used fluids to the proper waste or recycle drums. 4. If vehicle parts are being stored outdoors, oil and other fluids should be drained first. 5. Monitor equipment closely for leaks and place pans under any leak to collect the fluids for proper disposal or recycling. 6. Do not mix dissimilar or incompatible waste liquids stored for recycling. Parts Cleaning 1. Clean vehicle parts without using liquid cleaners whenever possible to reduce waste. 2. Perform all liquid cleaning at a central designated station so the solvent and residual stay in one place. The Central Garage Shop has a designated area for part cleaning. Inspection Vehicle maintenance and repair areas are entered and inspected daily to ensure pollutants sources are contained and best management practices are in place. 189 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 49 FA-BMP 8: Vehicle and Equipment Washing Description of Pollutant Source Wash water from vehicle and equipment cleaning activities can contain oil and grease, suspended solids, heavy metals, soluble organics, soaps, and detergents. Pollution Prevention Approach • Employee education • Facility inspections • Conduct washing activity at designated vehicle wash areas • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Conduct vehicle equipment washing in one of the following locations: a. At the City Shop Complex in the vehicle wash building, b. At the City Shop Complex in the outdoor vehicle wash area, c. At Fire Station 61 & 62 in wash bay, and d. At a commercial vehicle washing facility. 4. Any other outside washing operations will need approval from the Public Works Director. Waste wash water CANNOT runoff to the stormwater drainage system. 5. Clean wash areas oil water sumps at City Shop Complex and Fire Stations every six months or more if needed. Inspection Vehicle and equipment washing areas are visually inspected on a weekly basis by City personnel. 190 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 50 FA-BMP 9: Outdoor Container Storage Description of Pollutant Source Materials spilled, leaked, or lost from storage containers may accumulate in soils or on other paved surfaces and be carried away by rainfall runoff into storm conveyance systems. Leaks and spill of pollutants materials during handling and storage are sources of pollutants. Pollution Prevention Approach • Employee education • Facility inspections • Keep an accurate, up-to-date inventory of the material delivered and stored on-site • Keep materials in their original containers and labeled • Designate specific areas for material delivery and storage • Provide secondary containment around liquid containers • Implement good housekeeping spill response methods • Properly label product in each container Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Store containers on asphalt or concrete surface. 3. Install secondary containment (storage) for containers. Secondary containment systems can consist of using dikes, liners, vaults, jersey barriers, or double walled tanks. The secondary containment should be sloped to drain into a dead-end sump for the collection of leaks and small spills. 4. Keep containers sealed after use. 5. Place drip pans beneath all container taps and at all potential drip and spill locations during filling and unloading of containers. Drip pans must be cleaned periodically, and all collected liquid and soiled absorbent materials must be reused, recycled, or properly disposed. 6. Inspect container storage areas for corrosion, structural failure, spills, leaks, over fills, and failure of piping systems. 7. Replace containers as needed. 8. Clean up spills keep spill kit nearby. 9. Store container in designated areas, which is covered, bermed or diked, paved and impervious in order to contain leaks and spills. 10. Raise the container off the ground by use of pallets or a similar method, with provision for spill control and secondary containment. 11. Cover dumpsters or keep them undercover to prevent the entry of stormwater. Replace or repair leaking garbage dumpsters. 12. Drain dumpster pads to sanitary sewer. Keep dumpster lids closed. 191 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 51 Inspection Outdoor container storage areas are visually inspected on a weekly basis by City personnel. 192 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 52 FA-BMP 10: Outdoor Storage of Raw Materials Such As Asphalt, Sand, Gravel, Concrete, Topsoil, Mulch, Compost, Landscape Maintenance Waste Description of Pollutant Source The improper storage of materials outdoors can directly lead to the pollution of local receiving waters. Raw material, by-products, and products such as gravel, sand, salts, topsoil, compost, sawdust, wood chips, building materials, concrete, and metal products are typically stored outside in large piles and stacks. Stormwater can become contaminated when material washes off or dissolves into stormwater. Pollution Prevention Approach • Employee education • Facility Inspections • Manage inventory of raw material • Site management of raw material with signs and material designated locations Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Store raw material under cover and bermed, or enclosed and bermed to prevent stormwater contact. a. Physical barriers such as curbs, silt fencing, or jersey barriers can be used to prevent material migration to stormwater systems. b. For large stockpiles that cannot be covered, implement containment practices at the perimeter of the site to prevent discharge of the material offsite or to a storm drain. 3. Store raw material in an area where direct runoff from the material will not enter the stormwater system. Do not store raw material close to storm drain inlets or by drainage conveyance swales. 4. Keep storage areas swept and dry. Sweep areas regularly for collection and disposal of loose solid materials. 5. Store raw material on asphalt or concrete surfaces when feasible. 6. Store treated wood and metal products under cover (tarps, lean-to) or indoors. 7. Prevent run-on of uncontaminated stormwater from adjacent areas from contacting raw material. 8. Store materials in designated signed areas at the following facilities. a. City Shop Complex b. Compost Area Inspection Outdoor storage areas are visually inspected on a weekly basis by City personnel. 193 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 53 FA-BMP 11: Hazardous Materials Management-used oil, antifreeze, used batteries Description of Pollutant Source The improper disposal, handling, and storage of used oil, solvents, paints, antifreeze, batteries, and cleaners can allow runoff to come in contact with pollutants and discharge into the storm drainage system. Pollution Prevention Approach • Employee education • Facility inspections • Recycle used motor oil, diesel oil, other maintenance liquids, and batteries • Designate hazardous material storage locations • Reduce the amount of waste generated by using source controls • Control leaks and spills using good housekeeping spill response, cover, and containment practices Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Designate a location for waste storage and disposal areas. The location should not have any connection to the storm drain system or direct connection to the sanitary sewer. The area should allow for easy cleanup of drips and spills and be under a cover whenever feasible. 4. Do not pour materials down drains or hose work areas; use dry absorbents and sweeping. 5. Minimize the use of waste material. Manage waste amounts by buying only the amount needed to complete the activity. 6. Recycle used motor oil, diesel oil, and batteries. Storage 1. Segregate potentially hazardous waste from nonhazardous waste. 2. Keep chemicals in appropriate containers and under cover. 3. Ensure all containers are properly labeled and secure. All containers containing used products should be clearly and correctly labeled, identifying the material stored within the container. 4. Do not mix dissimilar or incompatible waste liquids stored for recycling. 5. Inspect containers for leaks and ensure that lids are on Immediately replace any containers that are leaking, corroded, or otherwise deteriorating. 194 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 54 6. Store chemicals away from storm drainage systems including ditches, catch basins, and manholes. 7. All pollutant containers with a storage capacity greater than 15 gallons should have secondary containment. 8. Waste vehicle and equipment batteries should be stored in the recycle container located outside the Central Garage Shop at the City Shop Complex. 9. Used oil from vehicle and equipment maintenance and repair should be stored in the “Used Oil” recycle container located outside the Central Garage Shop at the City Shop Complex. 10. Used antifreeze from vehicle and equipment maintenance and repair should be stored for recycling in the “Used Antifreeze” recycle container located outside the Central Garage Shop at the City Shop Complex. 11. Fuel filters should be stored for recycling in the signed container inside the Central Garage Shop at the City Shop Complex. 12. Parts cleaning should be performed in a parts washer and the waste solvent stored in the designated container. a. Locations with parts washers: i. Central Garage ii. WWTP Material and Waste Handling 1. Minimize water usage during paint wash-up. Dispose of paint wash water with other liquids waste. Do not dispose of wash water in or near storm drainage systems. 2. Retain and use all products such as paint, thinners, and so on until supplies are depleted. 3. Allow water-based paint rollers, drop clothes, and cans less than a third full to completely dry then discard into solid waste containers. 4. Any minor spill of wastes or product that occurs during transfer to storage containers should be cleaned up immediately. Inspection Hazardous material management areas are visually inspected on a weekly basis by City personnel. 195 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 55 FA-BMP 12: Concrete Mixing and Equipment Cleaning Description of Pollutant Source Excess fresh concrete mix and concrete equipment washing have the potential to impact water quality through stormwater runoff contact with the waste. Concrete waste affects the pH of runoff, causing significant chemical changes in water bodies and harming aquatic life. Pollution Prevention Approach • Employee education • Facility inspections • Conduct concrete mixing and washing activity at designated areas • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Conduct concrete mixing at one of the following locations: a. At the City Shop Complex behind the Signs and Signals Shop. b. In the field near the project site. Dump excess waste in areas prepared for new concrete pouring. 4. Conduct concrete washing at one of the following locations: a. At the City Shop Complex in a designated area. The washout area shall be lined with plastic. Once the product is dry, collect the waste and plastic and dispose in a solid waste container. Waste wash water CANNOT runoff to the stormwater drainage system. b. In the field near the project site in a designated waste wash area. The designated waste wash area should be lined with plastic and easily disposed of to a solid waste container. c. In the field in areas prepared for new concrete pouring. 5. Do not dispose of excess waste or wash equipment near a storm drain or on hard surfaces which directly runoff to stormwater systems. Inspection Visual inspection will be conducted at the conclusion of concrete mixing and equipment cleaning to ensure all pollutant sources are removed or cleaned and that all best management practices are in place. 196 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 56 FA-BMP 13: Landscape Maintenance Description of Pollutant Source Landscape maintenance activities include vegetation removal, herbicide and insecticide applications, fertilizer and pesticide application, grading, excavations, and watering. All of the listed maintenance activities have the potential to contribute pollutants to the storm drain system. Pollution Prevention Approach • Employee education • Facility inspections • Encourage proper landscaping and pest management techniques • Encourage proper on-site reuse and recycling of yard waste material • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Maps in Section 2. 2. Clean up spills keep spill kit nearby. 3. Use less-toxic chemicals for maintenance activities when possible. 4. Sweep paved areas regularly to collect loose particles and wipe up spills with rags and other absorbent materials immediately; do not hose down the area to a storm drain. 5. Do not dispose of collected vegetation into waterways or storm drainage systems. 6. Dispose of grass clippings, leaves, sticks or other collected vegetation by composting, if feasible. Alternatively, grass clippings may be broadcast and used as mulch. 7. If possible, raw materials will not be stored on site overnight. If needed, store raw material in an area where direct runoff from the material will not enter the stormwater system. Do not store raw material close to storm drain inlets or by any watercourse. Landscaping Management Activities 1. Dispose of grass clippings, leaves, sticks or other collected vegetation as garbage or by composting. Alternatively, grass clippings may be broadcast and used as mulch. Do not dispose of collected vegetation into waterways or storm drainage systems. 2. Check the irrigation schedule so chemicals will not be washed away and to minimize non-stormwater discharge. 3. Use mulch or other erosion control measures when soils are exposed. a. Water Department – All excavations will be backfilled, topsoil will be installed, and the area will be seeded. 4. Use hand or mechanical weeding where practical. 197 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 57 5. Sweep area around excavation sites to remove sediments from asphalt and concrete surfaces. Fertilizer, Herbicide, and Pesticide Management 1. Follow manufacturer’s recommendations and label directions for application rates and dosage. 2. Do not apply any chemicals (insecticide, herbicide, or fertilizer) directly to surface waters. 3. Do not apply pesticide, herbicide, or fertilizers within 10 feet of surface waters and within 100’ of a City Well Head. 4. Check the weather forecast; do not apply chemicals within 24 hours of a rain event. 5. Calibrate fertilizer distributors to avoid excessive application. 6. Apply pesticides only when wind speed in the area is low. 7. Reduce the use of high nitrogen fertilizers that produce excess growth requiring more frequent mowing or trimming. 8. Work fertilizers into the soil rather than dumping or broadcasting them onto the surface. 9. Irrigate slowly to prevent runoff. 10. Dispose of empty pesticide containers according to the instructions on the container label. Mosquito Management for Flathead County To control mosquitoes, Flathead County applies larvicide in areas of Kalispell. The larvicide is applied to wet areas where mosquitoes live and lay eggs, such as storm water and drainage systems (catch basins), and areas where standing water can collect, such as small ponds and puddles, pool covers, and discarded automobile tires. Altosid and Bacillus thuringiensis subspecies israelensis, commonly referred to as Bti, are the two types of larvicide used by the Flathead Co. Mosquito Program Coordinator. Both larvicides are the least toxic to the environment that are available for mosquito control. 1. The Flathead Co. Mosquito Program Coordinator is the only person allowed to apply larvicides in or near surface waters in the City of Kalispell. 2. Implementation of the City Storm Drainage System Inspection and Cleaning Program, as outlined in GH-BMP 2 Storm Sewer Maintenance, will reduce the need to apply larvicide in the City. Inspection Landscape maintenance areas are visually inspected on a weekly basis by City personnel. 198 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 58 FA-BMP 14: Discharge Chlorinated Wastewater Description of Pollutant Source Chlorinated pool water can be toxic to the environment and wildlife if it is not properly contained and de-chlorinated. Pollution Prevention Approach • Employee education • Facility inspections • De-chlorinate pool water prior to discharging • Implement good housekeeping spill response methods Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. See Facilities Site Map in Section 2. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. De-chlorinate pool water by placing de-chlorination granules or tablets per manufacturer instructions in the mixing tank prior to discharging into the swale. 4. Test discharge water for chlorination. If tests show chlorine level of less than 0.5 mg/l, de-chlorination methods are working. If results are greater than 0.5 mg/l, reassess the method and test discharge. 5. Inspect discharge location to ensure the discharge water is being contained in the designated low area east of the pool building. 199 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 59 4.3 Municipal Field Operations (FO) BMPs Table 4-3 Municipal Field Operation Field Operation Activity FO-BMP 1 Road, Street, and Alley Repair and Maintenance FO-BMP 2 Plaza and Sidewalk Cleaning FO-BMP 3 Winter Street Operations FO-BMP 4 Landscape Maintenance FO-BMP 5 Tree Removal FO-BMP 6 Annual Curb Painting FO-BMP 7 Street Sign/Traffic Loop Maintenance and Replacement FO-BMP 8 Concrete Installation and Repair FO-BMP 9 Water Utility Operations and Maintenance FO-BMP 10 Sewer Utility Operations and Maintenance FO-BMP 11 Sewer Lift Station Maintenance FO-BMP 12 Sewer Utility Operations and Maintenance FO-BMP 13 Construction Dewatering FO-BMP 14 Fire Response and Training FO-BMP 15 Solid Waste Handling and Disposal 200 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 60 FO-BMP 1: Street and Alley Repair and Maintenance Description of Pollutant Source Street and alley repair and maintenance field activities which have potential to pollute stormwater consists of chip sealing, pavement grinding, paving, pothole repair, excavating in the right of way, and stockpiling in the right of way. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Use less-toxic chemicals for maintenance activities when possible. Sweep the project area regularly to collect loose particles. 4. DO NOT hose down the area to a storm drain. 5. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Chip Seal Asphalt Surface 1. Cover storm drainage inlets with filter fabric prior to applying seal coating along the project area. 2. Sweep excess chip from project site. 3. Remove filter fabric from storm drainage inlets immediately after sweeping the project area. Pavement Grinding 1. Cover storm drainage inlets with filter fabric prior to beginning grinding activity. 2. Sweep excess grinding from project site, and stockpile in a predetermined designated area. If needed, berm and cover stockpile to minimize contact with stormwater. 3. Remove filter fabric from storm drainage inlets immediately after field operation is complete. Asphalt and Concrete Cutting 201 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 61 1. When feasible, cover storm drainage inlets with filter fabric prior to starting saw cutting activity within the project area. 2. Spray water on saw during cutting activity to minimize dust. 3. Clean up excess slurry left on curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 4. Remove filter fabric from storm drainage inlets immediately after project site is swept. Resurfacing Asphalt and Concrete 1. Cover storm drainage inlets with filter fabric prior to starting resurfacing activity within the project area. 2. Clean up excess asphalt and concrete left in curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 3. Equipment Cleaning: a. Clean hand equipment over work area and use minimum amount of cleaning agent. b. Clean equipment over work areas when feasible. If cleaning cannot take place over work area collect excess waste wash in a container and dispose of properly. c. Clean equipment at City Shop Complex only in a designated area and collect excess waste wash for proper disposal. Ensure cleanup area will not contribute pollutant to the storm drainage system. d. DO NOT clean any equipment near or over a storm drainage system or a sanitary sewer system. 4. Remove filter fabric from storm drainage inlets immediately after resurfacing is complete. Pothole Repair 1. Clean up excess asphalt remaining in curb, gutter, and street. Dispose of in waste stockpile or solid waste container. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. If excavated material is placed in the curb and gutter and left overnight, berm or cover the stockpiled material. Place a pipe under the pile parallel to the curb to allow surface flow through the blocked curb. 4. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the Right of Way. 5. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material remaining in the curb, gutter, boulevard, and street. 202 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 62 6. Remove filter fabric from storm drainage inlets immediately after project site is swept. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 203 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 63 FO-BMP 2: Plaza and Sidewalk Cleaning Description of Pollutant Source Pollutants on sidewalks and plazas are typically due to littering and sediment accumulation throughout the year. Pollution Prevention Approach • Employee education • Use dry cleaning methods for surface cleaning • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Do not use soaps or solvents for cleaning sidewalks. 4. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Surface Sweeping and Washing 1. Dry clean first by sweeping, collecting, and disposing of sediment, trash, and debris. Sweep away from storm drainage systems. 2. Use absorbents to pick up oil; then sweep up absorbent. 3. Block the storm drain inlets or contain the runoff when cleaning with water. Discharge collected water to tank or pump to landscape area. a. Storm Drains can be bermed with a fiber roll around the top of the inlet grate. b. Wash water can be filtered using a filter product with a sump inside and under the grate inlet. c. Plug the outfall pipes in the catch basins and collect the water in the inlet sumps. 4. Schedule street sweeper to sweep and vacuum sediment, trash, and debris from curb and street immediately after washing the sidewalks. 5. Remove berm and filter inlet protectors. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. 204 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 64 Inspection will be performed by designated City personnel. 205 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 65 FO-BMP 3: Winter Street Operations Description of Pollutant Source Pollutants from winter street operations include sediment from street sanding and chemicals from deicing activities. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Street Sanding 1. Employ street sweepers to collect excess sanding material during thaw events. 2. Once the sanding operations are complete for the year, sweep every street to collect excess sanding material. Set up a routine route to ensure all areas are swept. Snow Removal and Storage 1. Store plowed snow in locations where runoff can be infiltrated into the ground or filtered prior to flowing into a storm drainage system. 2. If snow pile contains excess amounts of trash, debris or sediment, place a berm around the pile to contain the melting runoff. 3. Sweep and clean snow storage areas once snow has melted. Street Deicing 1. Mix deicing solution per manufacturer’s specifications. 2. Only spray the required amount onto the streets. Over spraying the amount of deicer onto the streets does not make the product more effective. 3. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 206 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 66 FO-BMP 4: Landscape Maintenance Description of Pollutant Source Landscape maintenance field activities include vegetation removal, herbicide and insecticide applications, fertilizer and pesticide application, grading, excavations, and watering. All of the listed maintenance activities have the potential to contribute pollutants to the storm drain system. Pollution Prevention Approach • Employee education • Facility inspections • Encourage proper landscaping and pest management techniques • Encourage proper reuse and recycling of yard waste material • Implement good housekeeping spill response methods Best Management Practices 1. Know the project sites runoff patterns and stormwater management system. 2. Clean up spills keep spill kit nearby. 3. Use less-toxic chemicals for field activities when possible. 4. Sweep paved area regularly to collect loose particles and wipe up spills with rags and other absorbent materials immediately; do not hose down the area to a storm drain. 5. Do not dispose of collected vegetation into waterways or storm drainage systems. 6. Dispose of grass clippings, leaves, sticks or other collected vegetation by composting, if feasible. Alternatively, grass clippings may be broadcast and used as mulch. 7. If possible, raw materials will not be stored on site overnight. If needed, store raw material in an area where direct runoff from the material will not enter the stormwater system. Do not store raw material close to storm drain inlets or by any watercourse. Landscaping Management Activities 1. Dispose of grass clippings, leaves, sticks or other collected vegetation as garbage, or by composting. Alternatively, grass clippings may be broadcast and used as mulch. Do not dispose of collected vegetation into waterways or storm drainage systems. 2. Use mulch or other erosion control measures when soils are exposed. 1. Water Department – All excavations will be backfilled, topsoil will be installed, and the area will be seeded. 3. Use hand or mechanical weeding where practical. 4. Sweep area around project site to remove sediments and debris from asphalt and concrete surfaces. Fertilizer, Herbicide, and Pesticide Management 207 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 67 1. Follow manufacturer’s recommendations and label directions for application rates and dosage. 2. Do not apply any chemicals (insecticide, herbicide, or fertilizer) directly to surface waters. 3. Do not apply pesticide, herbicide, or fertilizers within 10 feet of surface waters, and within 100’ of a City Well Head. 4. Check the weather forecast; do not apply chemicals within 24 hours of a rain event. 5. Calibrate fertilizer distributors to avoid excessive application. 6. Apply pesticides only when wind speed in the area is low. 7. Reduce the use of high nitrogen fertilizers that produce excess growth requiring more frequent mowing or trimming. 8. Work fertilizers into the soil rather than dumping or broadcasting them onto the surface. 9. Irrigate slowly to prevent runoff. 10. Dispose of empty pesticide containers according to the instructions on the container label. Surface Water Buffer Management 1. Where practicable leave a 20’ natural vegetative buffer between the surface water and park or landscaped area. For streams and rivers, the buffer edge should be delineated from the top of bank 20’ toward the park. Mosquito Management for Flathead County To control mosquitoes, Flathead County applies larvicide in areas of Kalispell. The larvicide is applied to wet areas where mosquitoes live and lay eggs, such as storm water and drainage systems (catch basins), and areas where standing water can collect, such as small ponds and puddles, pool covers, and discarded automobile tires. Altosid and Bacillus thuringiensis subspecies israelensis, commonly referred to as Bti, are the two types of larvicide used by the Flathead Co. Mosquito Program Coordinator. Both larvicides are the least toxic to the environment that are available for mosquito control. The Flathead Co. Mosquito Program Coordinator is the only person allowed to apply larvicides in or near surface waters in the City of Kalispell. Inspection Conduct inspections of the project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspection will be performed by designated City personnel. 208 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 68 FO-BMP 5: Tree Removal Description of Pollutant Source Tree removal field activities which have the potential to pollute stormwater consists of excavating and stockpiling, stump grinding, and managing tree waste. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. DO NOT hose down the area to a storm drain. 3. Clean up the site by the end of each day. Clean up includes removal of debris material, branches, wood chips and pieces, and remediate any disturbed areas. 4. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Stump Grinding 1. The stump grinder creates large amounts of small wood chips. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 2. Remediate areas disturbed by the stump grinder. 3. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. If excavated material is placed in the curb and gutter and left overnight, berm or cover the stockpiled material. Place a pipe under the pile parallel to the curb to allow surface flow through the blocked curb. a. The Parks Department does not utilize curbs for overnight storage. 4. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the right of way. 209 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 69 5. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in the curb, gutter, boulevard, and street. 6. Remove filter fabric from storm drainage inlets immediately after project site is swept. Inspection Conduct inspections of the project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 210 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 70 FO-BMP 6: Annual Curb Painting Description of Pollutant Source Curbs are exposed, spray washed, and painted annually for traffic safety. Paint, sediment and trash are pollutants of concern for curb painting field operations. Pollution Prevention Approach • Employee education • Use dry cleaning method for surface cleaning • Protect storm drainage inlets to prevent pollutants from entering • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Do not use soaps or solvents for cleaning curbs. 4. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Curb Cleaning 1. Dry clean first by sweeping, collecting, and disposing of sediment, trash, and debris. Sweep away from storm drainage systems. Swept material can be a. Collected and placed in trailer and transported off-site. b. Swept to the street lane and collected by a City Sweeper. This option can only be used if a City sweeper is available for same day sweeping. 2. Use absorbents to pick up oil; then sweep up absorbent. 3. Do not wash down curb material into storm drain system. Block the storm drain inlets or contain the runoff when cleaning with water. Discharge collected water to tank or pump to landscape area. a. Storm drains can be bermed with a fiber roll around the top of the inlet grate. b. Wash water can be filtered using a filter product with a sump inside and under the grate inlet. c. Plug the outfall pipes in the catch basins and collect the water in the inlet sumps. 4. Schedule street sweeper to sweep and vacuum sediment, trash, and debris from curb and street immediacy after washing the curbs. 211 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 71 5. Remove berm and filter inlet protectors. Curb Painting 1. Check the weather; do not perform curb painting on wet weather days. 2. Minimize painting area as much as possible. 3. Do not paint wet curb. Pay attention to irrigation schedules during painting activities. 4. Do not spray paint directly over the grated storm inlet. 5. Only paint the top face and back of curb. Do not paint the curb flowline. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 212 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 72 FO-BMP 7: Street Sign/Traffic Loop Maintenance and Replacement Description of Pollutant Source Street Sign and Traffic Loop repair and maintenance field activities which have potential to pollute stormwater consist of Asphalt and Concrete Cutting, Resurfacing, and Excavating and stockpiling in the right of way. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Asphalt and Concrete Cutting 5. When feasible, cover storm drainage inlets with filter fabric prior to starting saw cutting activity within the project area. 6. Spray water on saw during cutting activity to minimize dust. 7. Clean up excess slurry left on curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 8. Remove filter fabric from storm drainage inlets immediately after project site is swept. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. If excavated material is placed in the curb and gutter and left overnight, berm or cover the stockpiled material. Place a pipe under the pile parallel to the curb to allow surface flow through the blocked curb. 4. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the right of way. 213 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 73 5. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 6. Remove filter fabric from storm drainage inlets immediately after project site is swept. Resurfacing Asphalt and Concrete 9. Cover storm drainage inlets with filter fabric prior to starting resurfacing activity within the project area. 10. Clean up excess asphalt and concrete left in curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 11. Equipment Cleaning: a. Clean hand equipment over work area and use a minimum amount of cleaning agent. b. Clean equipment over work areas when feasible. If cleaning cannot take place over work area collect excess waste wash in a container and dispose of properly. c. Clean equipment at City Shop Complex only in a designated area and collect excess waste wash for proper disposal. Ensure cleanup area will not contribute pollutant to the storm drainage system. d. DO NOT clean any equipment near or over a storm drainage system or a sanitary sewer system. 12. Remove filter fabric from storm drainage inlets immediately after resurfacing is complete. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 214 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 74 FO-BMP 8: Concrete Removal and Installation Description of Pollutant Source Street and alley repair and maintenance field activities which have potential to pollute stormwater consists of chip sealing, pavement grinding, paving, pothole repair, excavating in the right of way, and stockpiling in the right of way. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for the field operation to prevent pollutants from entering the storm drainage system. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. If excavated material is placed in the curb and gutter and left overnight, berm or cover the stockpiled material. Place a pipe under the pile parallel to the curb to allow surface flow through the blocked curb. 4. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the right of way. 5. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 6. Remove filter fabric from storm drainage inlets immediately after project site is swept. Concrete Installation 1. Clean up excess concrete left in curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 215 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 75 2. If possible, dump waste and wash water into areas prepared for new concrete pouring. 3. Equipment Cleaning: a. Clean hand equipment over work area and use a minimum amount of cleaning agent. b. Clean equipment over work areas when feasible. If cleaning cannot take place over the work area, collect excess waste wash in a container and dispose of it properly. A wash out area can consist of an excavated hole lined with plastic or a plastic kid pool. c. Clean equipment at City Shop Complex only in a designated area and collect excess waste wash for proper disposal. Ensure cleanup area will not contribute pollutant to the storm drainage system. d. DO NOT clean any equipment near or over a storm drainage system or a sanitary sewer system. Inspection Conduct inspections of the project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspection will be performed by designated City personnel. 216 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 76 FO-BMP 9: Water Utility Operation and Maintenance Description of Pollutant Source Operations and maintenance of public water utilities may not be considered chronic sources of stormwater pollution. However, some activities can result in the discharge of pollutants that can pose a threat to water quality. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. Identify potential pollutants and means to prevent introducing them to the storm water system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. The following field activity procedures should be followed for field operations to prevent pollutants from entering the storm drainage system. Planned Discharges 1. Planned discharges include hydrant testing, dewatering water mains for maintenance, and flushing water lines. 2. Identify a suitable discharge option in the following order of preference: a. Apply to land not hydraulically connected to the MS4 or surface waters. b. Discharge to the storm drainage system using applicable pollution control measures (i.e. inlet protection). This option can only be used for clean water discharges such as water main, water storage, and hydrant flushing. i. When discharging to the storm drainage system, water will be dechlorinated using Vita-D-Chlor tablets or an equivalent product. 3. Prior to discharge, inspect discharge flow path and clear/clean up any debris or pollutants found remove trash, leaves, sediment, and wipe up liquids including oil spills). 4. Inspect flow path of discharged water. Identify erodible areas that may need to be repaired. Unplanned Discharges 1. Unplanned discharges can occur from water line breaks, sheared fire hydrants, and equipment malfunction. 2. Stop the discharge as quickly as possible. 217 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 77 3. Inspect flow path of discharged water. Identify erodible areas that may need to be repaired. 4. Inspect storm drains after a water leak or main break and clean the storm system as needed. Asphalt and Concrete Cutting 1. When feasible, cover storm drainage inlets with filter fabric prior to starting saw cutting activity within the project area. 2. Spray water on the saw during cutting activity to minimize dust. 3. If necessary, clean up excess slurry left on curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 4. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. Material will not be stockpiled overnight and will be hauled off at the end of the day. 4. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 5. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Inspection Conduct inspections of the project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 218 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 78 FO-BMP 10: Sanitary Sewer Utility Operation and Maintenance Description of Pollutant Source Operations and maintenance of sanitary sewer utilities can result in the discharge of pollutants that can pose a threat to water quality. Pollution Prevention Approach • Employee education • Clean sewer lines on a regular basis to prevent sewer backups • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. The following field activity procedures should be followed for field operations to prevent pollutants from entering the storm drainage system. Sanitary Sewer Maintenance 1. Clean sewer lines on a regular basis to remove grease, grit, and other debris that may lead to sewer backups. 2. During routine maintenance and inspection note the condition of the sanitary sewer and identify areas that need repairs or maintenance. 3. Use the City vacuum truck to perform maintenance activities on sanitary sewer lines. 4. Dispose of sanitary sewer in the designated locations at the City Shop Complex. 5. Wash out equipment at the designated location at the City Shop Complex. 6. Do not discharge waste wash water from sanitary sewer activities to the storm drainage system. Sanitary Sewer Spills 1. When spills, leaks, or overflows occur and when disinfecting a sewage-contaminated area, take every effort to ensure that the sewage, disinfectant, and sewage treated with the disinfectant is not discharged to the storm drainage system. Methods include: a. Blocking storm drain inlet and catch basins. b. Containing and diverting sewage and disinfectant away from drainage systems (examples include sandbags, booms, etc.). Asphalt and Concrete Cutting 219 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 79 1. When feasible, cover storm drainage inlets with filter fabric prior to starting saw cutting activity within the project area. 2. Spray water on the saw during cutting activity to minimize dust. 3. If necessary, clean up excess slurry left on curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 4. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. Material will not be stockpiled overnight and will be hauled off at the end of the day. 4. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the right of way. 5. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 6. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 220 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 80 FO-BMP 11: Lift Station Maintenance Description of Pollutant Source Lift station maintenance entails the maintenance and operation of the sewer lift stations and the immediate surrounding areas. Oils and hydrocarbons from equipment maintenance and pesticide and herbicides for vegetation removal have the potential to contribute pollutants to the storm drain system. Pollution Prevention Approach • Employee education • Facility inspections • Encourage proper weed and pest management techniques • Implement good housekeeping spill response methods Best Management Practices 1. Know the project sites runoff patterns and stormwater management system. 2. Clean up spills keep spill kit nearby. 3. Clean up spills with rags and other absorbent materials immediately and dispose in solid waste containers. 4. Use less-toxic chemicals for field activities when possible. 5. Do not dispose of collected vegetation into waterways or storm drainage systems. 6. Dispose of grass clippings, leaves, sticks, or other collected vegetation by composting, if feasible. Alternatively, grass clippings may be broadcast and used as mulch. 7. Designate a location for equipment maintenance and repair to take place. The location should not have any connection to the storm drain system or direct connection to the sanitary sewer. The area should allow for easy cleanup of drips and spills and be under a cover whenever feasible. 8. Store idle equipment containing fluids under cover. Lift Station Maintenance 1. Collect leaking or dripping fluids in drip pans or containers. Fluids are easier to recycle if kept separated. 2. Do not dispose of oil and gas filters in trash cans or dumpsters. Drain excess oil before disposal. Oil filters can be recycled. The oil filter recycle container is located in the Central Garage Shop. 3. If work is being conducted outside: Use a tarp, ground cloth, or drip pans beneath the equipment to capture all spills and drips. The collected drips and spills must be disposed, reused or recycled properly. 4. If possible, perform all fluid removal or changing inside or under cover to prevent the run-on of stormwater and the runoff of spills: a. Keep a drip pan underneath equipment that might leak while work is being performed. 221 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 81 b. transfer used fluids to the proper waste or recycle drums. 5. Monitor equipment closely for leaks and place pans under any leak to collect the fluids for proper disposal or recycling. 6. Clean vehicle parts without using liquid cleaners whenever possible to reduce waste. Landscaping Management Activities 1. Dispose of grass clippings, leaves, sticks or other collected vegetation as garbage or by composting. Alternatively, grass clippings may be broadcast and used as mulch. Do not dispose of collected vegetation into waterways or storm drainage systems. 2. Use mulch or other erosion control measures when soils are exposed. 3. Use hand or mechanical weeding where practical. 4. Sweep area around project site to remove sediments and debris from asphalt and concrete surfaces. Fertilizer, Herbicide, and Pesticide Management 1. Follow manufacturer’s recommendations and label directions for application rates and dosage. 2. Do not apply any chemicals (insecticide, herbicide, or fertilizer) directly to surface waters. 3. Do not apply pesticide, herbicide, or fertilizers within 10 feet of surface waters, and within 100’ of a City Well Head. 4. Check the weather forecast; do not apply chemicals within 24 hours of a rain event. 5. Calibrate distributors to avoid excessive application. 6. Apply pesticides and herbicides only when wind speed in the area is low. 7. Dispose of empty pesticide containers according to the instructions on the container label. Inspection Conduct inspections of project site prior to leaving the area. Ensure areas are cleaned and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 222 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 82 FO-BMP 12: Storm Utility Operations and Maintenance Description of Pollutant Source Stormwater conveyance systems collect and transport urban runoff that contains pollutants such as sediment, oils, metals, and nutrients. Operations and maintenance of storm utilities can result in the discharge of pollutants that can pose a threat to water quality. Pollution Prevention Approach • Employee education • Perform regular inspections and cleaning of storm drainage systems, also see Storm Drainage System Maintenance GH BMP 2 • Implement good housekeeping and spill response methods Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. Check the weather; do not perform field activities that will contaminate the stormwater runoff on rainy days. The following field activity procedures should be followed for field operations to prevent pollutants from entering the storm drainage system. Storm Sewer Maintenance 1. Clean catch basins, storm drain inlets, and other conveyance structures in high pollutant load areas before the wet season to remove sediments and debris accumulated during the summer. 2. Clean catch basin and inlet structure sumps before it is 40% full. 3. During routine maintenance and inspections note the condition of the sewer and identify areas that need repairs or maintenance. 4. Use the City vacuum truck to perform cleaning activities on storm sewer lines. When flushing pipes collect effluent water at sump. Do not discharge flushed water to waterbodies. Plug the catch basin and pipe with inflatable plugs, flush and clean the storm system upstream of the plug, vacuum out water of the plugged pipe or catch basin. 5. During routine maintenance staff should look for evidence of illegal discharge or illicit connections: a. Is there evidence of spills such as paint, discoloring, etc? b. Are there any odors associated with the drainage system? c. Report illicit discharge to supervision. 223 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 83 Ditch Maintenance 1. Ditch maintenance consists of cleaning the ditch for debris and trash, regrading the ditch flow line, and maintaining slopes to preserve the condition and capacity for which they were originally constructed. 2. When regrading flow line and performing slope work, revegetate disturbed area with topsoil and seed. Erosion measures and products may need to be applied where slopes and conveyance flow lines are steep. 3. Conduct ditch maintenance (seeding, fertilizer application, mowing) in late spring and/or early fall, where possible. 4. Ditch cleanings are not to be left on the road surfaces. Sweep dirt and debris remaining on the pavement at the completion of ditch cleaning operations. Asphalt and Concrete Cutting 1. When feasible, cover storm drainage inlets with filter fabric prior to starting saw cutting activity within the project area. 2. Spray water on saw during cutting activity to minimize dust. 3. If necessary, clean up excess slurry left on curb, gutter, and street. Dispose of in waste stockpile or solid waste container. 4. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Excavation and Stockpiling 1. Know the sites storm drainage system. If required, cover storm drainage inlets with filter fabric prior to starting excavation. 2. Place excavated material in a location that will not impact the storm drainage system. 3. Material will not be stockpiled and will be hauled off at the end of the day. If the excavated material will not be used for backfilling, haul as much of the material away without storing in the right of way. 4. Sweep the project site the day the project is complete. If a sweeper cannot be obtained use hand brooms and shovels. Clean up excess material left in curb, gutter, boulevard, and street. 5. Remove filter fabric from storm drainage inlets immediately after project site is swept and stabilized. Inspection Conduct inspections of the project site prior to leaving the area. Ensure areas are swept, cleaned and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 224 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 84 FO-BMP 13: Construction Dewatering Description of Pollutant Source Construction dewatering is a necessary operation for construction sites that either traps rainwater or groundwater within the excavation. For construction projects, this water needs to be removed before certain operations can be performed or to keep work conditions safe. It is typical to use pumps to dewater these trenched areas. Often the pumped water finds its way to storm drainage systems. This practice examines the best ways to treat and deal with this discharge of collected water. Pollution Prevention Approach • Employee education • Prevent the discharged water from eroding soil on the site • Choose the best location for discharge • Preserve down gradient natural resources and property • Ensure adequate sediment removal devices (witches’ hats) are included in jobsite equipment Best Management Practices 1. Know the project sites runoff patterns and the immediate area stormwater drainage system. 2. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 3. The discharge areas should be chosen with careful consideration to the down gradient water resources and the landscapes ability to treat water flows from the dewatering process. 4. The discharge should be stopped immediately if the receiving area is showing any sign of instability or erosion. 5. If the collected runoff is contaminated with sediment, oil, grease, or other petroleum products stop the discharge and implement filtration mechanism for discharge. 6. Clean groundwater discharge can be discharged to the storm drainage system. 7. Water main ruptures often result in sediment reaching the storm drainage system. Upon discovery, staff shall ensure storm drainage protection as necessary. If sediment-laden water has reached the storm drainage system, the extent of sediment conveyance will be inspected, cleaned, and removed as necessary. Dewatering excavated areas must be in two distinct phases, 1) The removal of the collected water within the excavation and 2) the treatment of the collected water. Physical Dewatering 225 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 85 The removal of water from the excavated area can be accomplished by numerous methods. The most common used for City operations are mechanical pumping and siphoning. • Never discharge to areas that are bare or newly vegetated. • Dewatering in periods of intense, heavy rain, when the infiltrative capacity of the soil is exceeded, should be avoided. Sediment Removal Many methods of settling or filtering sediment are available for consideration: • Removal and offsite disposal of the sediment by means of vacuum truck is the preferred method. • Temporary enclosure constructed with hay bales, silt fence, or both. • Direct discharge of sediment bearing water may be able to go directly into well buffered areas with a 0-2% slope as long as there is an available method of spreading the flow into sheet flow. • Discharge to a manufactured / pre-made structure specifically designed for sediment removal, like a Silt Sak, Silt Bag, or other similar product. • Concrete or steel settling chambered systems for sediment removal. • Excavated or bermed sedimentation ponds or structures. Side slopes no greater than 2 to 1, or with a combined interior and exterior slope of no greater than 5 to 1. Inspection Conduct inspections of project site during dewatering process. Special attention should be paid to the buffer area for any sign of erosion and concentration of flow that may compromise the buffer area. Observe the visual quality of the effluent and determine if additional treatment can be provided. Prior to leaving the site project ensure areas are swept, cleaned, and no contaminants can be washed into the storm drainage system. Inspections will be performed by designated City personnel. 226 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 86 FO-BMP 14: Fire Fighting Response and Practices Description of Pollutant Source The wastewater from firefighting can contain a variety of contaminates primarily sediment from ashes. Stormwater can also be contaminated with organics from car and engine fires. These contaminants can flow into surface water near the fire if wastewater is allowed to enter storm drainage systems. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. If hazardous materials are suspected contact the Kalispell Fire Department Hazardous Materials Team for emergency spill response. 2. When possible block storm drain inlets and entry to drainage ditches. Use covers, sandbag dams, inlet filter protectors. Contact Public Works Superintendent for assistance in the cleanup. Sweep up area around inlet prior to leaving the site. 3. During training exercises and equipment testing NO contaminated wastewater can discharge to the storm drainage system. The discharge areas should be chosen with careful consideration to the down gradient water resources and the landscape ability to treat water flows from the process. a. Fire extinguisher training: spray extinguisher only in areas where the foam can be collected. Sweep up any spilled foam and dispose of properly. b. Building burning training: Know the project sites runoff patterns and the immediate area stormwater drainage system. Install inlet protection, collect wastewater runoff, and dispose of properly. Disposal can consist of discharging to sanitary sewer if allowed or sprayed on a field with no direct runoff to a surface water or storm drainage system. c. Hose Testing: Know the project sites runoff patterns and the immediate area stormwater drainage system. Install inlet protection, collect contaminated water runoff, and dispose of properly. Disposal cans consist of discharge to sanitary sewer if allowed, sprayed on a field with no direct runoff to a surface water or storm drainage system, or water reuse for irrigation. d. Hydrant Testing: Completed by the Water Department. 4. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. 5. Vehicle accident response: Protect storm drainage systems when feasible. a. If hazardous materials are suspect or there is a large spill contact the Kalispell Fire Department Hazardous Materials Team for emergency spill response. 227 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 87 b. Block storm drain inlets and entry to drainage ditches, spread absorbent on minor spills, and sweep up absorbent material. See GH-BMP 3: Spill Prevention, Response, and Containment for more details. 228 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 88 FO-BMP 15: Solid Waste Handling and Disposal Description of Pollutant Source Stormwater can be contaminated from trash and debris lying on the ground and leaking out of solid water containers. These contaminants can flow into surface waters via the storm drainage systems. Pollution Prevention Approach • Employee education • Implement good housekeeping and spill response methods Best Management Practices 1. Clean up spills and leaks know the spill kit locations. Spills are not cleaned up until the absorbent is picked up and disposed of properly. Report large spills to the supervisor. See GH-BMP 3: Spill Prevention, Response, and Containment for more details. 2. If hazardous materials are suspect contact the Flathead Emergency Response Team for emergency spill response. 3. Regularly inspect solid waste containers for structural damage. Repair or replace damaged containers as necessary. 4. Collect trash or debris lying next to the solid water container. 229 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 89 5 Good Housekeeping Activities and Operations Good housekeeping practices include procedures and activities municipalities perform to prevent or minimize pollutant discharge into receiving waters. Good housekeeping practices seek to reduce or eliminate pollutants being added to runoff through analysis of pollutant sources, implementing proper handling and disposal practices, implementing regular maintenance schedules, employee education, and other actions. In general, good housekeeping focuses on keeping the municipal infrastructure clean and orderly, storing materials under roof whenever possible, and handling materials and wastes in a manner that minimizes risk and potential pollutant runoff. A variety of good housekeeping practices have been developed to reduce or eliminate runoff pollutants. These practices—along with relevant application information are summarized below. The Good Housekeeping BMPs for field operations and fixed facilities are listed in table 5-1. Table 5-1 Municipal Good Housekeeping BMPs Facility and Field Activity GH-BMP 1 Facility Yard Sweeping GH-BMP 2 Storm Sewer Maintenance GH-BMP 3 Spill Prevention, Response, and Containment GH-BMP 4 Housekeeping Practices GH-BMP 5 Street Sweeping GH-BMP 6 Leaf Collection GH-BMP 7 Surface Water Buffer Management GH-BMP 8 Illicit Discharge Management 230 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 90 GH-BMP 1: Facility Yard Sweeping Description of Pollutant Source This BMP applies to all facilities operated and leased by the City. Stormwater runoff from Facility Yards can be contaminated with hydrocarbons, solvents, suspended solids, heavy metals, waste debris, trash, and corrosive agents. Surface runoff water from yards contains pollutants that can wash into a stormwater drainage system. Pollution Prevention Approach • Employee education • Facility inspections • Sweep Facility Yards Regularly Best Management Practices 1. Know the facilities runoff patterns and stormwater management system. 2. Clean up spills keep spill kit nearby. 3. Sweep Municipal Facility Yards regularly (approximately or more if needed to collect loose particles on paved surfaces. 4. Convey facility yard sweepings to yard dumpsites. 5. Offsite facility sweepings should be picked up and put into solid waste containers. 6. Sumps in the City Shop Complex should be cleaned annually or more often if needed. 7. The sharps container pickup policy should be followed when encountering biohazards. 231 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 91 GH-BMP 2: Storm Sewer Maintenance Description of Pollutant Source Stormwater conveyance systems collect and transport urban runoff that contains pollutants such as sediment, oils, metals, and nutrients. Routine cleaning and maintenance of storm utilities can prevent the discharge of pollutants that pose a threat to water quality. Pollution Prevention Approach • Employee education • Perform regular inspections and cleaning of the storm drainage system; also see FO BMP 12: Storm Drainage System Operation and Maintenance • Implement a regular cleaning schedule of the storm drainage system • Implement good housekeeping and spill response methods Best Management Practices A storm drainage system inspection and cleaning program will be developed and implemented to ensure the following goals: 1. All catch basins are cleaned once every five years. 2. Catch basins, storm drain inlets, and other conveyance structures in high pollutant load areas are identified and cleaned before the wet season to remove sediments and debris accumulated during the summer. 3. Catch basin and inlet structure sumps are cleaned before it is 40% full. 4. During routine maintenance and inspection: a. Note the condition of the sewer and identify areas that need repair or maintenance. b. Staff will look for evidence of illegal discharge or illicit connections: i. Is there evidence of spills such as paint, discoloring, etc? ii. Are there any odors associated with the drainage system? iii. Report illicit discharge to supervision. c. Catch basin inspections include documentation of: i. Condition of inlet pipe ii. Amount of sediment in pipe iii. Evaluation of the grout of the inlet pipe iv. Amount of debris in catch basin sump v. Evidence of illicit discharges vi. Condition of the structure vii. Evidence of inflow or infiltration viii. Condition of the inlet grate and its installation ix. Evaluation of curbing around the inlet grate and proper drainage Storm drainage system inspection and cleaning program 1. The City will be divided into areas for inspection and cleaning. 232 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 92 2. The City maintains a current storm utility map of the entire drainage system. As the Map is updated the inspection areas will be updated. 3. Inspection and cleaning will be performed on catch basins, inlet structures, manholes, Municipal structural flow control and water quality facilities, and ditch and pipe systems. 4. Inspection sheets and logged cleaning will be required for the program. 233 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 93 GH-BMP 3: Spill Prevention, Response, and Containment Description of Pollutant Source Spills and leaks, if not properly controlled, can adversely impact the storm drainage system and receiving surface waters. Due to the type of work or the material involved, many activities that occur either at a municipal facility or as a part of municipal field activities have the potential for accidental spills and leaks. In the event of a spill, depending upon the volume and characteristic of the material released, Kalispell has defined spill response as either a Minor Spill Response or a Major Spill Response. The Fire Department has separate procedures. Spill Prevention (City Facility/In-House) 1. If possible, move material handling indoors, under cover, or away from storm drainage systems. 2. Properly label all containers so that the containers are easily identifiable. 3. Berm storage areas so that if a spill or leak occur, the material is contained. 4. Cover outside storage areas either with a permanent structure or with a seasonal one such as a tarp so that rain cannot come into contact with the materials. 5. Check containers often for leaks and spills. Replace container that are leaking, corroded, or otherwise deteriorating with containers in good condition. Collect all spilled liquids and properly dispose of them. 6. Store, contain, and transfer liquid material in such a manner that if the container is ruptured or the contents spilled, they will not discharge, flow or be washed into the storm drainage system, surface waters, or groundwater. 7. Place drip pans or absorbent material beneath all mounted taps and at all potential drip and soil locations during the filling and unloading of containers. Any collected absorbent material should be bagged and properly disposed of in a solid waste container. 8. For field programs, only transport the minimum amount of material needed for the daily activities. 9. Any liquid storage container greater than 15 gallons is required to have secondary containment and may require special storage. 10. Know the location of the spill kits. Replace material as they are used from the kits. Minor Spill Response A Minor Spill Response is defined as one that poses no significant threat to human health or the environment. These spills general involve less than 5 gallons and can usually be cleaned up by the City personnel. Other characteristics of a minor spill include: • The spilled material is easily stopped or controlled at the time of the spill • The spill is localized • The spilled material is not likely to reach surface water or groundwater 234 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 94 • There is little danger to human health • There is little danger of explosion Procedure The following procedures will be used in response to a minor spill: 1. The facility superintendent or senior on-site employee will be notified of the spill. 2. If necessary, the spill will be physically contained to prevent further migration from the facility or project site. 3. The spill will be cleaned up using absorbent material or rags. Absorbent material will be stored at Spill Kit location. 4. Use brooms or a shovel for the general cleanup of dry materials. 5. The contaminated material (spill debris) will be placed in an approved container and disposed of properly. 6. Biohazard spills will be neutralized using the appropriate chemical. Major Spill Response A Major Spill Response is defined as one involving a spill that cannot be safely and or adequately controlled or cleaned up by on-site personnel. Characteristics of a major spill include: • The spill is large enough to spread beyond the immediate area • The spill material entered surface water or ground water (regardless of the size) • The spill requires special training and equipment to cleanup • The spill material is a threat to human health • There is a danger of fire or explosion Procedure The following procedures will be used in response to major spills: 1. All workers shall immediately evacuate the spill site to a safe distance away from the spill. 2. The facility superintendent or senior on-site employee will be notified of the spill and details regarding the spill. 3. The superintendent will contact the Fire Department to notify the Hazardous Response Team. 4. The superintendent will coordinate cleanup with the Hazardous Response Team. 5. City-owned storm system will be plugged in an attempt to isolate private spills. 6. See the biohazard procedure in minor spills. 235 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 95 Table 4-2. Telephone numbers that are to be used to contact the appropriate response personnel or agency in the event of an emergency. Table 4-2 Emergency Telephone Numbers Contact Phone Numbers Fire Department 911 Police Department 911 Sewer On-Call [PHONE REDACTED] 236 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 96 GH-BMP 4: Good Housekeeping Description This BMP applies to all facility and field activities and all City Departments. Use efficient and safe housekeeping practices (storage, use, and cleanup) when handling potentially harmful materials such as fertilizers, pesticides, cleaning solutions, paint products, automotive products, and swimming pool chemicals. Pollution Prevention Approach • Employee education • Product management Best Management Practices 1. Facility site inspections will be performed weekly. The superintendent will specify employees to perform the task and authority to remedy any problems found. 2. Purchase only the amount of material that will be needed for foreseeable use. 3. Be aware of new products that may do the same job with less environmental risk and for less or the equivalent cost. 4. Keep working sites clean and orderly. Remove debris in a timely fashion. Sweep site at least weekly. 5. Clean up spills as outlined in GH-BMP 3: Spill Prevention, Response, and Containment. 6. Use less-toxic chemicals for maintenance when possible. 7. Sweep paved areas regularly to collect loose particles and wipe up spills with rags and other absorbent materials immediately; do not hose down the area to a storm drain. 8. Do not dump any toxic substance or liquid waste on the pavement, the ground, or toward a storm drain. 9. Maintain solid waste containers. Empty on-site solid waste container(s) weekly. Do not over fill the container capacity. 10. Pick up and dispose of debris and trash laying around at the facility. 237 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 97 GH-BMP 5: Street Sweeping Description of Pollutant Source Streets, roads, and highways are significant sources of pollutants in stormwater discharges. Routine street sweeping can collect and contain sediments, metals, organics, and oil and grease wastes. Pollution Prevention Approach • Employee education • Maintain regular sweeping schedule of streets Best Management Practices 1. Kalispell streets are swept on a routine basis. A map of the regular scheduled street sweeping operations is located at the Public Works Office. 2. During spring sweeping operations, streets are swept more often to collect winter sanding material. 3. Routine sweeping practices include: a. Operating sweepers to get optimal debris removal. This includes adjusting sweeper speed, brush alignment, and sweeping pattern. b. If storm drain plugging or high pollutant loading have been found in certain areas, schedule additional sweeping in those areas. c. Schedule sweeping immediately after street repair projects and water and sewer repair project. d. Schedule sweeping immediately after special events like street fairs, art shows and parades. 238 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 98 GH-BMP 6: Leaf Collection Description of Pollutant Source Fall leaves contribute significant sources of pollutants in stormwater discharges. Leaf collection practices remove leaves and debris which can contain nutrients and organics that are transported by stormwater runoff to surface waters. Pollution Prevention Approach • Employee education • Maintain regular sweeping schedule of streets for leaf collection Best Management Practices 1. Kalispell streets are swept on a routine basis in the fall to collect leave. A map of the regular scheduled leaf collection sweeping operations is located at the Public Works Office. 2. During fall leaf sweeping operations, leaves are collected from the street, curb, and gutter using sweepers, loaders, and vacuum trucks. 3. Public Service Announcements are sent to inform Kalispell citizens of the correct leaf collection disposal method and routes. 4. Leaves are collected and deposited at the City compost site. The leaves are composted and used for topsoil, nutrient supplements, and erosion control on City projects. 239 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 99 GH-BMP 7: Surface Water Buffer Management Description of Pollutant Source Direct runoff from City facilities, parks, and landscape areas can contribute significant sources of pollutants in stormwater discharges. Implementing a minimum 20’ native vegetative buffer will minimize pollutants transported by stormwater runoff to surface waters. Natural buffers provide filtration and delineation between City facilities and surface waters. Pollution Prevention Approach • Employee education • Maintain native vegetative buffer between surface waters and City facilities, parks, and landscape areas Best Management Practices 1. Where practicable leave a 20’ natural vegetative buffer between the surface water and park or landscaped area. For streams and rivers, the buffer edge should be delineated from the top of the bank 20’ toward the park or landscape area. 2. The following City areas could utilize the 20’ buffer management a. Lawrence Park b. Begg Park c. Willow Glen Park d. Woodland Park e. Dry Bridge Slough f. City Shop Complex Material Storage Areas 240 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 100 GH-BMP 8: Illicit Discharge Management Description of Pollutant Source Discharges into storm conveyance systems often include wastes and wastewater from non-storm sources. A portion of these dry weather flows are from illicit and/or inappropriate discharges and connections to the storm conveyance systems. Illicit discharges enter the system through either direct connections wastewater piping either mistakenly or deliberately connected to the storm drains) or indirect connections infiltration into the storm sewer from cracked sanitary systems, spills collected by drain outlets, paint or used oil dumped directly into a drain). The results are untreated discharges that contribute high levels of pollutants, including heavy metals, toxins, oil and grease, solvents, nutrients, viruses, and bacteria to receiving water bodies. Pollution Prevention Approach • Employee education • Report, investigate, and eliminate illicit discharge Best Management Practices 1. Illicit discharge education to City staff. a. All new City employees are required to watch a video on stormwater and illicit discharges during orientation b. Illicit discharge training will be included in all other stormwater training. 2. Illicit discharge reporting, investigation, and elimination will follow the Illicit Discharge Investigation and Corrective Action Plan and the Enforcement Response Plan for Stormwater Management. a. The root cause of the discharge will be identified, or the stormwater system will be isolated. b. Report Illicit Discharges: Call Public Works Office (758-7720) and report tot MS4 Manager 241 of 334 ---PAGE BREAK--- Kalispell Municipal Pollution Prevention/ Good Housekeeping Guidance Manual 101 6 Employee Training As a designated MS4 under the MPDES Phase II Stormwater Program, Kalispell is required to develop a pollution prevention/good housekeeping program to control and reduce stormwater pollution generated by municipal operations. The municipality is also required to train employees on how to incorporate pollution prevention/good housekeeping techniques into municipal facility and field operations. Within the MS4, all City employees whose activities can potentially impact surface waters are required to receive training regarding stormwater quality and municipal operation at least once per year. 6.1 Annual Training Annual training will be provided to the following City of Kalispell employees and operators of City owned facilities. 1. Public Works Department 2. Park and Recreational Department 3. Fire Department The Phase II Coordinator is responsible to develop the annual training course and provide the training to the City employees. The training will incorporate City fixed facilities, field operations, good housekeeping measures, and Best Management Practices to be employed by the City to reduce the potential for polluting surface waters as stated in this guidance manual. 242 of 334 ---PAGE BREAK--- Appendix F: Stormwater TMDL Action & Sampling Plan 243 of 334 ---PAGE BREAK--- Stormwater TMDL Action Plan City of Kalispell, Montana Storm Water Management Program Kalispell, MT February 18, 2021 244 of 334 ---PAGE BREAK--- This page intentionally left blank 245 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan i Table of Contents 1 Introduction 3 1.1 Mission 3 1.2 Background 3 1.2.1 Permitting 3 1.2.2 Growth Policy 3 1.3 Purpose 4 2 MS4 Permit TMDL Requirements 4 2.1 Addressing in the SWMP 4 2.2 TMDL-Related Monitoring 4 3 with MS4 Approved WLAs 4 3.1 Pollutants of Concern and WLAs 6 3.1.1 Nutrients (Total Phosphorus, Total Nitrogen, Nitrate + 7 3.1.2 Dissolved Oxygen 7 3.1.3 Sediment 7 3.1.4 Temperature 7 4 Stormwater Action Plan for Addressing 8 4.1 Impairment Priorities and Long-term Strategy 8 4.1.1 Impairment Priorities: Sub-basin Prioritization 8 4.1.2 Long-term Strategy 1. Pollution Prevention & Good Housekeeping (i.e. Municipal Operations) 2. Education & Outreach 3. Construction Site Stormwater Management 4. Water Quality Treatment Applications & Capital Improvement Plan 5. Low Impact Development 6. Stormwater TMDL & Self-Monitoring 4.1.3 Funding 4.1.4 Adaptive Management 4.2 Schedule and Progress Towards Meeting the TMDL 17 4.2.1 Schedule for Action Items 4.2.2 Measuring Progress towards Meeting the TMDL Non-Structural BMPs 246 of 334 ---PAGE BREAK--- ii Structural BMPs 4.2.3 Estimation of Recent Historical Progress towards Meeting the TMDL 5 References 27 Appendix A: TMDL Progress Reporting Appendix B: Treatment Scenarios Appendix C: TMDL Sampling Plan Figures Figure 1. Highest Priority Sub-Basins in City of Kalispell Figure 2. City of Kalispell Stormwater TMDL CIP Strategy Figure 3. Anticipated Schedule of Structural and Non-Structural Action Items Figure 4. 2020 Ashley Creek Estimate of Total Pollutant Reductions Figure 5. 2020 Spring Creek Estimate of Total Pollutant Reductions Figure 6. 2020 Stillwater River Estimate of Total Pollutant Reductions Tables Table 1. Impaired Waterbodies within Kalispell City Limits 5 Table 2. TMDL Loads and MS4 Wasteload Allocations 6 Table 3. Stormwater Outfalls Discharging to Impaired Surface Waters 8 Table 4. DEQ TMDL Reference Pollutants of Concern Percent Removals Table 5. Summary of Pollutants of Concern Removed by Non-Structural BMPs Table 6. 2020 Pollutant Reductions from Non-Structural BMPs by Waterbody Table 7. Example Reduction Progress Evaluation for a Single BMP Table 8. Example Reduction Progress Evaluation for Multiple Scenarios Table 9. Reduction Progress Evaluation for Impaired Waterbodies from Structural BMPs Table 10. Reduction Progress Evaluation for Ashley Creek from Structural BMPs Table 11. Reduction Progress Evaluation for Spring Creek from Structural BMPs Table 12. Reduction Progress Evaluation for Stillwater River from Structural BMPs Table 13. Estimate of Total Pollutant Reductions within the MS4 in 2020 247 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan 3 1 Introduction 1.1 Mission The City of Kalispell (City) seeks to provide long-term stormwater management by administering a drainage and treatment system that protects properties and water quality through the strategic use of limited finances while meeting regulatory requirements. 1.2 Background 1.2.1 Permitting The City operates its storm drainage system under the authorization of the General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4s) (MTR040000). This MS4 General Permit (MS4 Permit) was approved by the Montana Department of Environmental Quality (DEQ) in July of 2006, with subsequent re-approvals in 2010 and January 2017 (DEQ 2016) and is effective from January 1, 2017 through December 31, 2021. The MS4 Permit provides authorization to discharge stormwater to waters of the state under the Montana Pollutant Discharge Elimination System (MPDES). Under this permit, the City is required to develop, document, and maintain a Storm Water Management Plan (SWMP), which includes management practices, control techniques, systems, designs, good standard engineering practices, and other provisions necessary to reduce the discharge of pollutants from the permitted MS4. 1.2.2 Growth Policy The City’s Growth Policy “lays out a framework to guide growth in and around the City for the next 20 years”, including consideration of limited financial resources and the growing population (Kalispell 2017). Stormwater management goals are included in the policy, which demonstrates the importance of the Stormwater Total Maximum Daily Load (TMDL) Action Plan. The policy includes direct references to the MS4 Permit, satisfying those permit requirements, protecting the environment and water quality, and addressing impaired waters The stormwater management goals from the Growth Policy are identified below: GOALS: 1. Ensure adequate stormwater management facilities for all incorporated urban areas. 2. Improve the drainage and stormwater infrastructure in problem areas of the community. 3. Require all new development and redevelopment to have adequate stormwater management facilities for storm event attenuation and water quality treatment. 4. Ensure maintenance and management of existing and new stormwater management facilities are being performed on both public and private properties to maximize their use. 5. Meet all requirements of the permit including effluent limits, stormwater management program, and special conditions for impaired waters and monitoring, recording, and reporting requirements. 248 of 334 ---PAGE BREAK--- 4 1.3 Purpose The purpose of this document, the Stormwater TMDL Action Plan, is to address the requirements in Part III Special Conditions Section B of the MS4 Permit. Part III Special Conditions Section B requires the City to include in the SWMP a section addressing water quality controls for storm discharges to impaired waterbodies that do not meet one or more water quality standards and have an approved TMDL. 2 MS4 Permit TMDL Requirements 2.1 Addressing in the SWMP Per Part III Special Conditions Section B of the MS4 Permit, the permittee’s SWMP must: 1. Identify: a. All outfalls that discharge to impaired waterbodies with an approved MS4 Wasteload Allocation (WLA) b. The impaired waterbodies c. The associated pollutant(s) of impairment 2. Include a section: a. Identifying the measures and best management practices (BMPs) it plans to implement b. Describing the MS4’s impairment priorities and long-term strategy c. Outlining interim milestones a completion schedule for action items) for controlling the discharge of the pollutants of concern and making progress towards meeting the TMDL 3. Incorporate TMDL-Related Monitoring into the TMDL section. Item 1 is required to be submitted with each Annual Report. Item 2 must be submitted with the 4th year Annual Report for approval. The permittee will begin to implement the approved section no later than the start of the 5th permit year. The TMDL section must be annually evaluated based on monitoring results, revisited as needed, and resubmitted with Annual Reports beginning with the 5th year Annual Report. Any revisions to the section require rationale and must be approved by DEQ. 2.2 TMDL-Related Monitoring The permittee must supplement the Self-Monitoring Requirements in Part IV of the MS4 Permit with additional monitoring targeted at further evaluating MS4 loading to impaired waterbodies or at evaluating the effectiveness of BMPs selected for reducing MS4 loading to impaired waterbodies. See Appendix C for more information. 3 with MS4 Approved WLAs The City of Kalispell is within the Flathead – Stillwater Planning Area. Completed by DEQ in 2014, the Flathead – Stillwater Planning Area Nutrient, Sediment, and Temperature and 249 of 334 ---PAGE BREAK--- 5 Water Quality Improvement Plan identifies water quality targets, pollutant sources, and total allowable pollutant loads (2014). In Kalispell, the following waterbodies flow through City limits or receive stormwater discharges from the City’s MS4: • Ashley Creek • Bowser/Little Spring Creek (Unnamed tributary to Spring Creek – aka Kids Creek) • Dry Bridge Slough • Spring Creek • Stillwater River • Stillwater Slough / Muskrat Slough • Whitefish River • An unnamed perennial surface water tributary to Ashley Creek from Foys Lake Of the above, the TMDL identifies four waterbodies as impaired: Ashley Creek, Spring Creek, Stillwater River, and Whitefish River. Table 1 provides a list of impaired waterbodies and their corresponding pollutants of concern within Kalispell City limits. Although the TMDL lists WLAs for the pollutants of concern in these waterbodies, the WLAs are not intended to add concentration or load limits to the MS4 Permit. Table 1. Impaired Waterbodies within Kalispell City Limits Waterbody & Location Description Waterbody ID Impairment Cause(1) Pollutant Category(2) (Middle) Ashley Creek. Smith Lake to Kalispell Airport Road MT76O002_020 Nitrogen (Total) Nutrients Phosphorus (Total) Nutrients Sedimentation/Siltation Sediment Temperature, water Temperature (Lower) Ashley Creek, Kalispell Airport Road to mouth (Flathead River) MT76O002_030 Alteration in stream side or littoral vegetative covers Not Applicable; Non-pollutant a Not Applicable; Non-pollutant Nitrate/Nitrite (Nitrite+Nitrate as N) Nutrients Nitrogen (Total) Nutrients Oxygen, Dissolved Dissolved Oxygen Phosphorus (Total) Nutrients Sedimentation/Siltation Sediment Temperature, water Temperature Spring Creek, Headwaters to mouth (Ashley Creek) MT76O002_040 Nitrate/Nitrite (Nitrite+Nitrate as N) Nutrients Nitrogen (Total) Nutrients Oxygen, Dissolved Dissolved Oxygen Phosphorus (Total) Nutrients Stillwater River, Logan Creek to mouth MT76P001_010 Alteration in streamside or littoral vegetative covers Not Applicable; Non-pollutant Sedimentation/Siltation Sediment Whitefish River, Whitefish Lake to mouth (Stillwater River) MT76P00_010 Temperature, water Temperature (1)Oxygen, Dissolved impacts are associated with nutrients and sediment and not further addressed in this plan. (2)Nutrients are total nitrogen and total phosphorus DEQ 2014 (Table DS-1) 250 of 334 ---PAGE BREAK--- 6 3.1 Pollutants of Concern and WLAs Six pollutants of concern are identified as part of the TMDL and MS4 Permit for the City: • Total Phosphorus • Total Nitrogen • Nitrate + Nitrite • Dissolved Oxygen • Sediment • Temperature Total nitrogen, total phosphorus, and sediment WLAs for the Kalispell MS4 and their percent reductions are identified in Table 2. Table 2. TMDL Loads and MS4 Wasteload Allocations Segment Load (lbs) Percent Reduction WLA Total Nitrogen Middle Ashley Creek 417 30% 292 Lower Ashley Creek 1,472 30% 1,030 Spring Creek 384 30% 269 Stillwater River n/a n/a n/a Whitefish River n/a n/a n/a Total Phosphorus Middle Ashley Creek 26 44% 15 Lower Ashley Creek 97 44% 54 Spring Creek 24 44% 13 Stillwater River n/a n/a n/a Whitefish River n/a n/a n/a Sediment (5,6) Middle Ashley Creek 80,800 62% 30,800 Lower Ashley Creek 244,800 62% 93,000 Spring Creek n/a n/a n/a Stillwater River 86,800 62% 33,000 Whitefish River n/a n/a n/a Temperature Middle Ashley Creek Follow the minimum control measures provided in the MPDES permit authorization for permit MTR04005, or any subsequent permit renewals. Lower Ashley Creek Spring Creek n/a Stillwater River n/a Whitefish River Follow the minimum control measures provided in the MPDES permit authorization for permit MTR04005, or any subsequent permit renewals. These values are not intended to add concentration or load limits to the MS4 Permit; meeting permit BMP and other requirements equates to meeting the total nitrogen and total phosphorus WLAs. WLA = Wasteload Allocation Load and WLA for nutrients are given as growing season, July 1 through September 30. Middle Ashley Creek includes the load for Spring Creek. Lower Ashley Creek includes the loads from Middle Ashley Creek and Spring Creek. Load and WLA for sediment are given as annual limits. The MS4 permit does not include effluent limits, but requires the development and implementation of a stormwater management program (SWMP) to minimize sediment loading to surface waters. Source: DEQ 2014 (Table 5-22, Table 5-23, Table 6-21, and Table 7-2) 251 of 334 ---PAGE BREAK--- 7 3.1.1 Nutrients (Total Phosphorus, Total Nitrogen, Nitrate + Nitrite) Applicable waterbodies: Ashley Creek (middle and lower), Spring Creek Per the TMDL, the MS4 does not continuously discharge nutrients and therefore the WLA is only applicable during the dry summer growing season (July 1 – September 30). Percent reduction allocations were developed, but the WLAs are not intended to add load limits to the permit. The WLAs are met by adhering to the MS4 Permit requirements (DEQ 2014; DEQ 2016). According to the MS4 Permit, the total nitrogen TMDL for Lower Ashley Creek provides a surrogate TMDL and allocations to address the Nitrate + Nitrate impairment and water quality improvements that address excess nitrogen loading will result in a decrease in Nitrate + Nitrite. For these reasons, Nitrate + Nitrite are not addressed further in this Action Plan. 3.1.2 Dissolved Oxygen Applicable waterbodies: Ashley Creek (lower), Spring Creek There are no dissolved oxygen WLAs for the MS4. The MS4 Permit states that water quality improvements that address nutrients (nitrogen and phosphorus) will result in improved DO concentrations. By adhering to MS4 permit requirements, DO will improve. For this reason, DO is not addressed further in this Action Plan. 3.1.3 Sediment Applicable waterbodies: Ashley Creek (middle and lower), Stillwater River Percent reduction allocations were developed, but the WLAs are not intended to add load limits to the permit. The WLAs are met by adhering to the MS4 Permit requirements (DEQ 2014; DEQ 2016). 3.1.4 Temperature Applicable waterbodies: Ashley Creek (middle and lower), Whitefish River There are no temperature WLAs for the MS4. According to the MS4 Permit, “discharge temperatures will be consistent with naturally occurring conditions by the City of Kalispell MS4 adhering to the MS4 Permit requirements” (DEQ 2014; DEQ 2016). However, installed BMPs can be beneficial for temperature impaired waterbodies. For example, infiltration basins, bioretention, and dispersion are preferred BMPs when considering temperature impairments, while extended detention basins and wet detention basins should be avoided (HDR 2017). Temperature is addressed through consideration of BMP selection for new and redevelopment projects within the City as well as for public capital improvement projects. Therefore, it is not further discussed in this Action Plan. 252 of 334 ---PAGE BREAK--- 8 4 Stormwater Action Plan for Addressing The City conducts extensive planning to maintain and operate the MS4. Focusing on removing and reducing pollutants in stormwater through both structural1 and non-structural BMPs2 provides a well-rounded approach to the complex and variable nature of stormwater. Even though the TMDL emphasizes that the MS4 will meet WLAs by adhering to the MS4 Permit requirements, the City strategically incorporates capital projects centered on impaired waterbodies to reduce stormwater pollutants. Combining the structural water quality improvement projects with non-structural BMPs (i.e. street sweeping, public outreach, etc.), provides greater benefits to water quality in the long-term. 4.1 Impairment Priorities and Long-term Strategy 4.1.1 Impairment Priorities: Sub-basin Prioritization Within City limits, there are 78 stormwater outfalls that discharge into surface waters. Outfall ownership varies; some are owned and maintained by the City, others by Montana Department of Transportation, and some are privately owned and maintained. A complete list of the City’s outfalls is presented in Appendix A of the SWMP (Kalispell 2021). Of the stormwater outfalls, 67 discharge to the four impaired waterbodies. Table 3 identifies impaired waterbody outfalls and the number of outfalls per waterbody. Table 3. Stormwater Outfalls Discharging to Impaired Surface Waters Waterbody Waterbody Stormwater Sub-basin Drainage Area (Acres) City Assigned Outfall Code Number of Outfalls that Discharge to Impaired Waterbodies Ashley Creek (middle and lower) 1,214.16 AC1–AC11, AC13–AC21, UT1–UT3 23 Spring Creek 1,130.08 SC1–SC2, SC4, SC6–SC25 23 Stillwater River 1,237.91 SWR1–SWR11, SWR14- SWR17, SWR19-SWR22 19 Whitefish River 14.22 WFR1–WFR2 2 Sum of drainage areas as shown in Appendix A of Kalispell 2021. Excludes closed basins. Outfall codes as shown in Appendix A of Kalispell 2021. In order to progressively reduce stormwater pollutants entering impaired waterbodies, urban sub-basins (subwatersheds), areas that drain to a designated outfall, need to be ranked and prioritized based on which have the largest pollution potential to negatively impact water quality. Once sub-basins with the largest pollution potential are identified, those basins can be targeted for both structural and non-structural BMPs (private and public) to improve stormwater quality leaving the sub-basin. As part of the Illicit Discharge Detection and Elimination (IDDE) program operated by the City (and required by the MS4 Permit), the City uses a desktop assessment to determine which sub- 1 Structural BMPs refer to constructed structures designed to provide water quality treatment. See HDR 2017. 2 Non-structural BMPs refer to actions (i.e. City street sweeping, public programs, etc.) designed to provide water quality benefits. 253 of 334 ---PAGE BREAK--- 9 basins have the greatest pollution potential within the City’s MS4. As described in Appendix C of the SWMP, this prioritization for the IDDE program was developed with the following steps: 1. Delineate sub-basins or drainage areas within the City 2. Compile available mapping and data for each drainage unit (e.g. land use, age, outfalls, infrastructure history) 3. Calculate sub-basin discharge screening factors using GIS analysis a. Screening factors include: i. Past illicit discharge complaints and reports ii. Areas prone to incidents of illegal dumping iii. Age of storm sewer in sub-basin iv. Areas primarily served by onsite sewage disposal systems v. Amount of industrial area draining to outfall vi. Outfall discharges to an impaired water body vii. Size of drainage basin 4. Screen and rank pollution potential at the sub-basin and community level 5. Generate maps to support field investigations Resulting from this assessment is a prioritization list of sub-basins based on the risk for pollution and illicit discharges (See MS4 Annual Report). Based on the 2020 IDDE priority ranking, the following sub-basins were identified as the highest priority based on their normalized Illicit Discharge Potential score (Figure 1. AC6 1. SC1 1. AC11 2. SWR4 3. AC2 3. AC21 3. SC6 3. SC16 3. SWR7 Determination of the location of new structural BMPs and measures to address utilizes the prioritization list. Selection of the type of new structural BMPs and measures to address includes information about the land use, target pollutants, performance capabilities, physical site capabilities, aesthetics, safety, maintenance requirements, and cost (HDR 2017). As each BMP implementation has unique goals and constraints, no single BMP will be selected in all scenarios, but rather prioritized and selected as described above. 254 of 334 ---PAGE BREAK--- 10 Figure 1. Highest Priority Sub-Basins in City of Kalispell 255 of 334 ---PAGE BREAK--- 11 4.1.2 Long-term Strategy The long-term strategy of the City to address impaired waterbodies and their associated includes prioritizing pollutant reduction BMPs within sub-basins with the greatest potential to protect water quality, employing structural and non-structural approaches, and utilizing public water quality projects while maintaining private water quality development requirements. Using an adaptive approach, BMP performance will be evaluated through stormwater sample collection and analysis. The results will be used to make informed decisions on best practices locally. By continuing to make incremental progress, the City continues to prevent and remove stormwater pollutants from entering local waterbodies and ultimately meet TMDL goals. Since stormwater pollution is variable, it is important to have a varied approach to pollutant reduction. Pollutants in stormwater are targeted primarily by using BMPs identified in the TMDL (DEQ 2014) and its cited references, the MS4 Permit (DEQ 2016), and the SWMP (Kalispell 2021). The City will employ or continue to employ structural and non-structural BMPs within the following categories: 1. Pollution Prevention & Good Housekeeping (i.e. Municipal Operations) 2. Education & Outreach 3. Construction Site Stormwater Management 4. Water Quality Treatment Applications & Capital Improvement Projects 5. Low Impact Development 6. Stormwater TMDL & Self-Monitoring 1. Pollution Prevention & Good Housekeeping (i.e. Municipal Operations) Long-Term Strategy Utilize operation-based programs and initiatives, such as street sweeping and infrastructure cleaning, targeting pollutants of concern for the MS4’s impaired waterbodies. These activities provide pollutant reduction through economical and sustainable administrative and operational activities. BMPs - Treatment Unit & Infrastructure Maintenance Water quality treatment units, catch basins, storm drain inlets, and other conveyance structures are cleaned regularly to remove sediment and debris. Each year, the cubic yards of sediment and debris removed from infrastructure is collected and used to calculate an estimate of yearly tons of sand/sediment removed from the MS4 and prevented from reaching local waterbodies. - Street Sweeping Kalispell streets are swept on a routine basis. During spring sweeping operations, streets are swept more often to collect winter sanding material. Routine sweeping practices include:  Operating sweepers to get optimal debris removal  Additional sweeping if a storm drain is plugged or high pollutant loading has been found in certain area  Sweeping immediately after street, water, and sewer repair projects 256 of 334 ---PAGE BREAK--- 12  Sweeping after special events such as street fairs, art shows, and parades Each year, the cubic yards of sweepings are collected and used to calculate an estimate of yearly tons of sand/sediment removed from the MS4 and prevented from reaching waterbodies. - Leaf Collection Kalispell streets are swept and cleaned on a routine basis in the fall to collect leaves. During fall leaf collection operations, leaves are removed from streets, curbs, and gutters using sweepers, loaders, and vacuum trucks. Public service announcements are advertised through social media outlets to inform Kalispell citizens of the correct leaf collection and disposal method and routes. The leaves are collected and deposited at the City compost yard. Each year, the cubic yards of leaves are collected and used to calculate an estimate of yearly tons of leaves removed from the MS4 and prevented from reaching waterbodies. 2. Education & Outreach Long-Term Strategy Implement education-based programs and initiatives, such as targeted community outreach, focused on pollutants of concern for the MS4’s impaired waterbodies. Targeted outreach reduces pollutants of concern by focusing on those within the MS4 who are most likely to influence pollutant loading. BMPs - Community Activities & Education Various non-structural measures are employed to reduce pollutants entering local waterbodies. Programs designed for residents (i.e. Flathead Rain Garden Initiative) provide education and on-site assistance with stormwater pollution and best management techniques. The City also provides information on best practice awareness to businesses that commonly contribute to stormwater pollution via handouts, field visits, and emails. 3. Construction Site Stormwater Management Long-Term Strategy To prevent additional pollutants from reaching waterbodies, continue to maintain the City’s construction site stormwater management program. The Construction Stormwater Permit program provides oversight and enforcement mechanisms on all construction sites greater than 1,000 square feet or five cubic yards of disturbance. BMPs - Permit Review Construction Stormwater Permit submissions are reviewed for completeness and adequacy. Review provides an opportunity for guidance and education and can reduce compliance issues. - Site Inspections 257 of 334 ---PAGE BREAK--- 13 Construction sites are inspected to ensure compliance and reduce impacts to water quality. Inspections also provide opportunities to inform contractors on appropriate stormwater management controls and why they are needed to protect local waterbodies. - Training Programs The City helps support local construction stormwater training programs and classes. Training provides contractors with the knowledge and background necessary to effectively control pollutants on construction sites. 4. Water Quality Treatment Applications & Capital Improvement Plan Long-Term Strategy On both public and private projects, utilize industry standard treatment technologies, such as mechanical separation (80% TSS removal under certain conditions), to mitigate urban pollutant impacts. Treatment technology provides effective, maintainable, and economical treatment systems near stormwater discharge points for the MS4’s large, urban drainage areas currently lacking treatment before discharge. Public Projects: Continue to utilize the Capital Improvement Plan (CIP) to plan and construct projects that address water quality as well as those that focus on infrastructure, flooding, and/or other issues not directly related to water quality. Incorporating stormwater projects into capital planning allows these projects to be adequately budgeted for and included in scheduling. Occurring annually, the planning process allows for public comment, requires approval by the City Council, and is incorporated into the fiscal year’s operating budget. Often spanning several years from the CIP approval, the process includes preliminary engineering, developing an engineered design, bidding out the project, and construction. The five-year CIP is outlined in the SWMP (Section 4 Program Performance-Table 1) (Kalispell 2021). Private Projects: Maintain requirements for privately-owned new and redevelopment projects to provide water quality treatment. Continue post-construction program oversite for sustainable operation and maintenance of the private treatment applications. BMPs - Stormwater TMDL CIPs Utilize the steps below for strategizing stormwater TMDL-related CIPs (Figure 1. Assessment: Using the sub-basin prioritization method, determine priority sub- basins for treatment (generally large, mostly untreated stormwater sub-basins discharging into impaired waterbodies). 2. Plan and Construct CIP: Identify funding for projects to provide water quality treatment to the prioritized sub-basin(s) and schedule in the CIP. 3. Monitor: Monitor stormwater via the sampling plan to gain information on BMP performance in demonstration/representative sub-basins. 4. Adaptive Management: Evaluate, revise as needed, and repeat. CIPs must consider budget constraints to ensure expenditures are equal to funds available from the utility assessment. Additionally, it is important to consider other 258 of 334 ---PAGE BREAK--- 14 planned projects. Combining stormwater projects with other City initiatives, such as road reconstructions, reduces costs. - City-Owned Structural Treatment Structural BMPs owned by the City are inspected and maintained on regular schedules (see Pollution Prevention & Good Housekeeping section). Inspections, maintenance, and debris removed from water quality treatment structures are tracked with an asset management program. - Privately-Owned Structural Treatment City of Kalispell’s Standards for Design and Construction: Privately-owned new and re- development projects that have 10,000 square feet or more of developed area are obligated to comply with the requirements in the City of Kalispell’s Standards for Design and Construction (Kalispell 2020b), including providing water quality treatment. The Standards provide a regulatory mechanism to address post-construction runoff from new development and re-development, implementation of structural and non-structural practices to minimize water quality impacts, including low impact development practices where practicable, and ensure long-term operation and maintenance of structural practices. The Standards have adopted in their entirety, except where amended, the Montana Post-Construction Storm Water BMP Design Guidance Manual (HDR 2017). Stormwater Maintenance Permit Program: The program permits post-construction water quality treatment devices and requires yearly inspections and a five-year renewal that is submitted by a professional engineer certifying that the structure is being maintained and operating as designed. 259 of 334 ---PAGE BREAK--- 15 Figure 2. City of Kalispell Stormwater TMDL CIP Strategy 5. Low Impact Development Long-Term Strategy Assess the potential on public and private projects to reduce pollutants using low impact development (LID) and green stormwater infrastructure, such as bio-retention swales and dispersion (100% TSS removal). These projects allow the MS4 to increase stormwater treatment efficiencies in larger urban watersheds and treat stormwater in smaller urban watersheds not suitable for larger projects. Continue to evaluate ways to reduce barriers to implementation. BMPs - Low Impact Development Barrier Review 260 of 334 ---PAGE BREAK--- 16 Utilize the LID barrier review of City codes and policies to encourage implementation and improve inconsistencies between policies. Determine barriers to City implementation and review options for reasonable solutions. 6. Stormwater TMDL & Self-Monitoring Long-Term Strategy Collect and analyze water quality and in-stream monitoring data to understand BMP effectiveness. Utilize adaptive management to plan future investments, education-based initiatives, and infrastructure operations. BMPs - MS4 Sampling Plan for TMDL-Related Monitoring The MS4 Sampling Plan identifies monitoring locations, strategies, and requirements for sampling (i.e. sampling parameters, analytical methods, and quality assurance) (Appendix The City performs stormwater monitoring for the following purposes (Kalispell 2018): • Fulfill requirements of the MS4 Permit, requiring TMDL-Related Monitoring • Evaluate progress towards meeting the stormwater goals in the TMDL • The City has selected TMDL-related monitoring Option 2; requiring tracking and evaluating the effectiveness of BMPs selected for reducing MS4 loading to impaired waterbodies (DEQ 2104) • The City has selected self-monitoring Option 2 (see Part IV of the MS4 Permit) (DEQ 2014) 4.1.3 Funding Funding to support the stormwater program and planned actions is a challenging constraint that is common to many programs. Sources of funding may include stormwater water quality district fees, development fees, general funds, and/or allocations from transportation or wastewater funds as part of specific projects. In 2017, with City Council approval, the City increased the Storm Sewer Maintenance District Assessment. For five years after the approval, property owners in the City will have an assessment increase totaling 72%; 55% of which is in response to MS4 Permit requirements. The Storm Water Facility Plan Update also includes a Financial Plan section (Kalispell 2008). As noted in the plan, the City will need to continue analysis and monitoring of capital funding and financing and perform a comprehensive rate analysis to provide the City with the information necessary to determine future rate adjustments. The analysis may show that elements of the Stormwater TMDL Action Plan may drive additional funding needs. Other sources of funding, such as state and federal grants, may be sought to enhance the stormwater management program. State Grants - Montana Renewable Resource Grant and Loan Program 261 of 334 ---PAGE BREAK--- 17 o Funds projects for the conservation, management, development and preservation of Montana's renewable resources - Clean Water or Drinking Water State Revolving Fund (SRF) o Can fund capital projects Federal Grants - Federal Emergency Management Agency o Examples: flood mitigation assistance and hazard mitigation grants - Department of Commerce o Examples: local technical assistance - Department of Housing and Community Development o Examples: community development block grant - Environmental Protection Agency o Examples: environmental justice small grants, science to achieve results, pollution prevention, source reduction assistance, and urban small waters grant 4.1.4 Adaptive Management Adaptive management involves a recurring evaluation of whether actions are effective in achieving the goals of the plan and modifying those actions as new information provides additional insights. Findings may drive changes to the Stormwater Sampling Plan and/or the Action Plan. To apply adaptative management, the following will be utilized: Goal: Reduce stormwater pollutants entering impaired waterbodies. 1. Implement MS4 Sampling Plan 2. Analyze results 3. Review progress towards meeting the 4. Adapt plans and BMPs based on results 5. Repeat The MS4 Permit requires the TMDL section to be annually evaluated based on monitoring results, revised as needed, and resubmitted with Annual Reports. Additionally, rationale must be provided for changes and revisions must be approved by DEQ. Since the City has no control over DEQ’s review and approvals, and the changes are anticipated to generally be minor, revisions will be implemented at the beginning of each year and continued unless DEQ provides notification otherwise. 4.2 Schedule and Progress Towards Meeting the TMDL 4.2.1 Schedule for Action Items Action items include both structural and non-structural BMPs designed to minimize the discharge of pollutants of concern (Figure Non-structural BMPs are often a part of routine municipal operations or are a programmatic MS4 Permit component. These BMPs are utilized throughout the year as City staff complete tasks and as public programs are administered. City built, owned, and maintained structural BMPs are completed through the CIP process and are 262 of 334 ---PAGE BREAK--- 18 therefore scheduled. The figure below provides the anticipated schedule for City stormwater CIPs which are updated annually based on funds and scheduling needs. Figure 3. Anticipated Schedule of Structural and Non-Structural Action Items (FY = fiscal year) 4.2.2 Measuring Progress towards Meeting the TMDL The MS4 Permit requires demonstration of progress towards satisfying the TMDL. The City has flexibility in defining how to demonstrate progress. Although Table 2 includes numerical percent reductions and wasteload allocations (WLAs), these values are not intended to add concentration or load limits to the MS4 Permit. Complying with the MS4 Permit equates to meeting the TMDL WLAs. Specifically, the TMDL states: “Though the numeric WLAs represent a reasonable estimate of the growing season loading after implementation of stormwater permit requirements, the WLAs are not intended to add concentration or load limits to the permit. Consistent with EPA guidance (U.S. Environmental Protection Agency, 2002), DEQ assumes the WLA will be met by adhering to the permit requirements and reducing either the total nitrogen and total phosphorus concentrations and/or the discharge volumes, Treatment Sylvan Drive Project Treatment Wyoming Street Project Treatment 1st Ave West Project Treatment 8th Ave W & 11th Street W Project Treatment Meridian Facility Project 2016 FY21 FY22 FY24 FY23 Continual BMPs Municipal Operations Education & Outreach Construction Site Stormwater Management Water Quality Treatment & CIPs Low Impact Development Stormwater TMDL & Self-Monitoring 263 of 334 ---PAGE BREAK--- 19 with the percent reduction values of 30 and 44 percent representing permit implementation goals. As identified in the permit, monitoring data should continue to be evaluated to assess BMP performance and help determine whether and where additional BMP implementation may be necessary. Additional work may be needed in the future to better identify the total nitrogen and total phosphorus sources and BMPs already in place within the system. Also, a stormwater runoff model (such as SWMM) would help to better estimate the load and impact from the MS4.” (DEQ 2014). Additionally, any effort to calculate loads and percent reductions for comparison with and WLAs should be accomplished via the same methodology and/or models used to develop the loads and percent reductions (DEQ 2014). The percent reductions for total nitrogen, total phosphorus, and sediment in the TMDL were based on average percent reduction values for a suite of BMPs provided in the TMDL (Table The TMDL based the sediment reduction value on a 2011 resource with an average sediment reduction of 62 percent (Geo Geosyntec Consultants, Inc. et al. 2011). Literature values for total nitrogen, total phosphorus, and sediment reduction are provided in Table 4, they include the literature values reported in the TMDL and additional values for installed BMPs in the City’s MS4. Table 4. DEQ TMDL Reference Pollutants of Concern Percent Removals Structural BMP Annual Percent Removal Total Nitrogen Total Phosphorus Sediment Biofiltration Swale 40% 38% 92%(3) Bioretention 64%(2) 55%(2) 75%(4) Composite n/a n/a 79%(4) Detention Basin n/a n/a 64%(4) Dry Basin (no extended detention) 5%(2) 15%(2) n/a Extended Detention Dry Basin 24%(2) 20%(2) n/a Extended Detention Stormwater Wetland 25%(1) 50%(1) n/a Extended Detention Wet Pond 30%(1) 50%(1) n/a Grass Strip n/a n/a 57%(4) Grass Swale n/a n/a 16%(4) Hydrodynamic Separator 5%(3) 18%(3) 54%(3) Infiltration Basin 21%(3) 47%(3) 80%(3) LID n/a n/a 42%(4) Media Filter n/a n/a 84%(4) Porous Pavement n/a n/a 72%(4) Retention Pond n/a n/a 75%(4) Sand Filter 30%(1) 60%(1) n/a Vegetated Filter Strip 30%(2) 60%(2) n/a Wetland Basin n/a n/a 55%(4) Wetland Basin/Retention Pond n/a n/a 69%(4) Wetland Channel n/a n/a 23%(4) AVERAGE 27% 41% 62% et al. 2008 Center for Watershed Protection 2007 International Stormwater BMP Database 2020 Geosyntec 2016 264 of 334 ---PAGE BREAK--- 20 Non-Structural BMPs The City implements multiple non-structural BMPs intended to reduce pollutants of concern in the MS4 discharges. As described in Section 4.1.2, these BMPs are varied. The pollutant reduction of some non-structural BMPs is difficult to measure, while others easily provide direct measures. For example, measuring the pollutant reduction from a public education program is very difficult to quantify. In contrast, infrastructure maintenance, street sweeping, and leaf collection are trackable and provide data on the reduction of pollutants of concern. The total mass of solids removed from treatment unit maintenance, infrastructure maintenance, street sweeping, and leaf collection is recorded yearly in tons of solids. Total nitrogen and total phosphorus removals are estimated from the tons of sediment and leaves collected (Table 5, See Table A-1 in Appendix A for breakdown by BMP type). Table 5. Summary of Pollutants of Concern Removed by Non-Structural BMPs Year Reduction in Total Nitrogen (tons) Reduction in Total Phosphorus (tons) Reduction in Sediment (tons) 2017 30.2 4.6 1303.2 2018 38.5 5.5 1456.5 2019 27.6 4.1 1102.4 2020 73.9 11.8 3440.1 Cumulative Reductions 170.2 26.1 7302.2 Assuming that the activities (maintenance, street sweeping, leaf collection) are performed at an equal rate throughout the City, the pollutant reductions per waterbody can be estimated by determining the percent of each watershed of the City (Table Since these non-structural BMPs remove pollutants prior to discharge, the reductions should be updated annually based on performance. The historic watershed of closed basins and the eventual discharge point of unimpaired waters were included to evaluate total non-structural BMP pollutant reductions. Table 6. 2020 Pollutant Reductions from Non-Structural BMPs by Waterbody Watershed Percentage of Total Watershed Reduction in Total Nitrogen (tons) Reduction in Total Phosphorus (tons) Reduction in Sediment (tons) Ashley Creek 29% 21.4 3.4 994 Spring Creek 24% 17.4 2.8 811 Stillwater River 46% 34.1 5.5 1587 Whitefish River 1% 1.0 0.2 48 Structural BMPs The City plans, constructs, and maintains structural water quality BMPs intended to reduce pollutants of concern in MS4 discharges through the CIP process. Additionally, the City requires privately owned new and redevelopment projects to include water quality treatment. Privately owned structural BMPs are managed through the Stormwater Maintenance Permit Program which requires annual inspections and regular maintenance. Although the City does not directly 265 of 334 ---PAGE BREAK--- 21 maintain these systems, the reductions from the privately owned BMPs should be accounted for in evaluating the progress towards meeting the Kalispell MS4 The total nitrogen, total phosphorus, and sediment percent removals for each specified BMP identified in Table 4 should be used in the accounting of progress since the TMDL used baseline reductions of zero percent (DEQ 2014). Since flow to each BMP is variable depending on the storm event, the BMP sub-basin area as a proportion of the total waterbody drainage area can be used as a substitute to determine the proportion of the total drainage flow and load treated by each BMP. This can be used to weight the loading from each outfall. This information provides a basis for calculation of the overall percent reduction of the total nitrogen, total phosphorus, and sediment based on the sub-basin area and the estimated reduction efficiency of the new BMP. This is considered a comparable method for evaluating progress toward the TMDL. An example of this analysis can be seen below. Table 7 provides the example parameters for a BMP and the following bullets identify how the total nitrogen, total phosphorus, and sediment reductions would be calculated for the impaired waterbody drainage basin. Table 7. Example Reduction Progress Evaluation for a Single BMP BMP Treatment BMP Drainage Area (acres) Waterbody Drainage Area (acres) BMP Reduction in Total Nitrogen Load BMP Reduction in Total Phosphorus Load BMP Reduction in Sediment Load Bioretention 10 1,000 64% 55% 75% • Total nitrogen reduction in drainage basin: (10 acres/1,000 acres) * 64% = 0.64% • Total phosphorus reduction in drainage basin: (10 acres/1,000 acres) * 55% = 0.55% • Sediment reduction in drainage basin: (10 acres/1,000 acres) * 75% = 0.75% Calculating the percent reduction becomes more complicated when one large basin is treated at the outfall but within the basin, there are sub-basins with treatments. Some runoff in the basin may only go through the treatment at the outfall while other runoff may go through sub-basin treatments and then outfall treatment. Table 8 provides examples for BMP reductions for total nitrogen, total phosphorus, and sediment calculations for an impaired waterbody drainage basin with different levels and locations of treatment. Appendix B provides graphics illustrating the treatment paths for the example reduction calculations. 266 of 334 ---PAGE BREAK--- 22 Table 8. Example Reduction Progress Evaluation for Multiple Scenarios Basin BMP Drainage Area (acres) BMP Treatment Type BMP Reduction in Total Nitrogen BMP Reduction in Total Phosphorus BMP Reduction in Sediment Outfall Example Outfall 1,000 Bioretention 64% 55% 75% Net 1,000 n/a 64% 55% 75% Sub-basin Treatment without Outfall Treatment Example Sub-basin A 200 Bioretention 64% 55% 75% Outfall 1,000 None 0% 0% 0% Net 1,000 n/a 13% 11% 15% Sub-basin Treatment with Outfall Treatment Example Sub-basin A 200 Bioretention 64% 55% 75% Outfall 1,000 Hydrodynamic Separator 5% 18% 54% Net 1,000 n/a 17% 27% 61% Sub-basin within a Sub-basin Treatment with Outfall Treatment Example Sub-basin B1 200 Bioretention 64% 55% 75% Sub-basin B 400 Sand Filter 30% 60% 90% Outfall 1,000 Hydrodynamic Separator 5% 18% 54% Net 1,000 n/a 25% 41% 71% Two Sub-basin within a Sub-basin Treatment with Outfall Treatment Example Sub-basin A1 100 Bioretention 64% 55% 75% Sub-basin A 200 Sand Filter 30% 60% 90% Sub-basin B1 200 Bioretention 64% 55% 75% Sub-basin B 400 Sand Filter 30% 60% 90% Outfall 1,000 Hydrodynamic Separator 5% 18% 54% Net 1,000 n/a 35% 53% 80% The same methodology used by the TMDL for evaluating and accounting progress (and described at the beginning of Section 4.2.2) was used to assess stormwater quality improvements from projects in the last decade. The BMPs that have been installed in the City’s MS4 to date are identified in Appendix A. These tables identify whether the BMPs are private or public, the discharge waterbody, and the estimated percent reduction in total nitrogen, total phosphorus, and sediment that should be expected based on the identified BMPs. A summary of the reduction in total nitrogen, total phosphorus, and sediment for the MS4 based on private and public BMPs was estimated based on recent historical data (Table This analysis shows the City has made total nitrogen, total phosphorus, and sediment reductions ranging between 3 to 14 percent. In addition to the cumulative reduction in total nitrogen, total phosphorus, and sediment for the entirety of the watershed, Tables 10, 11, and 12 include the cumulative reductions for each watershed individually. 267 of 334 ---PAGE BREAK--- 23 Table 9. Reduction Progress Evaluation for Impaired Waterbodies from Structural BMPs Year Cumulative Number of BMPs BMP Drainage Area (acres) Cumulative Total Nitrogen Reduction Cumulative Total Phosphorus Reduction Cumulative Total Sediment Reduction Pre-2016 4 93 0.1% 0.3% 1.0% 2016 17 560 1.2% 3.3% 7.3% 2017 28 601 1.3% 3.5% 7.9% 2018 41 724 1.8% 4.5% 9.8% 2019 51 811 2.1% 5.1% 11.0% 2020 61 1047 2.6% 6.6% 14.2% Goal TBD 3,281.65 30.0% 44.0% 62.0% *These calculations are based on the assumption that each sub-basin with an installed structural BMP is treated by the single BMP and does not include cumulative effects similar to those identified in Table 8. The cumulative effects of treatment by multiple BMPs will continue to be identified and evaluated by the City in subsequent years of analysis. Table 10. Reduction Progress Evaluation for Ashley Creek from Structural BMPs Year Cumulative Number of BMPs Cumulative Drainage Area (acres) Cumulative Total Nitrogen Reduction Cumulative Total Phosphorus Reduction Cumulative Total Sediment Reduction Pre-2016 2 65 0.2% 0.8% 2.5% 2016 3 131 1.2% 3.0% 6.2% 2017 6 139 1.3% 3.2% 6.6% 2018 11 161 1.4% 3.5% 7.4% 2019 14 203 1.7% 4.1% 9.3% 2020 16 226 1.8% 4.4% 10.1% Table 11. Reduction Progress Evaluation for Spring Creek from Structural BMPs Year Cumulative Number of BMPs Cumulative Drainage Area (acres) Cumulative Total Nitrogen Reduction Cumulative Total Phosphorus Reduction Cumulative Total Sediment Reduction Pre-2016 1 22 0.1% 0.4% 1.1% 2016 5 30 0.1% 0.5% 1.4% 2017 6 30 0.1% 0.5% 1.4% 2018 9 32 0.2% 0.5% 1.5% 2019 11 41 0.2% 0.7% 2.0% 2020 14 129 0.6% 2.0% 6.1% Table 12. Reduction Progress Evaluation for Stillwater River from Structural BMPs Year Cumulative Number of BMPs Cumulative Drainage Area (acres) Cumulative Total Nitrogen Reduction Cumulative Total Phosphorus Reduction Cumulative Total Sediment Reduction Pre-2016 1 5 0.0% 0.0% 0.1% 2016 8 398 1.8% 4.8% 11.0% 2017 14 428 1.9% 5.2% 11.8% 2018 19 480 2.4% 6.2% 13.6% 2019 23 516 2.7% 7.0% 14.9% 2020 29 641 3.7% 9.3% 19.1% 268 of 334 ---PAGE BREAK--- 24 Approximately 55 to 65 percent of these reductions were from the installation of private BMPs. Although the City permits these private installations and City engineers review the design of these BMPs to ensure they meet City requirements and standards, the City does not plan, fund, or install these BMPs. However, if growth and development in the City is expected to remain constant, it can be assumed that construction and installation of privately maintained BMPs and the resulting reduction in total nitrogen, total phosphorus, and sediment will continue at a similar rate. This will allow flexibility in the City’s planning and will reduce the capital expenditures required by the City for installation of structural BMPs. 4.2.3 Estimation of Recent Historical Progress towards Meeting the TMDL An estimate of the MS4’s reduction of pollutants of concern from both structural and non- structural BMPs can be made with a few assumptions. The TMDL includes an estimated load entering the waterbodies without BMPs implemented. By using this load, the pollutant reduction load of structural BMPs can be calculated from their associated reduction percentages. The estimated load reductions of structural BMPs can then be combined with the current year’s non- structural BMPs’ pollutant removal loads to determine the year’s cumulative impact. When pollutant reductions of structural and non-structural BMPs are combined, the cumulative reductions surpass the MS4’s WLA (Table 13). When compared, the effectiveness of non- structural BMPs in pollutant removal is evident. However, it should be noted that pollutant reduction for structural BMPs will always be lower since it is a percentage reduction of the estimated load, and therefore cannot exceed the original load estimated by the TMDL. Table 13. Estimate of Total Pollutant Reductions within the MS4 in 2020 Total Nitrogen Reduction (lbs) Total Phosphorus Reduction (lbs) Total Sediment Reduction (lbs) Non-structural 147,850 23,666 6,880,100 Structural 49 8 47,084 TOTAL 147,899 23,674 6,927,184 WLA 1,591 82 156,800 Non-structural BMPs continue to be important in pollutant reduction when watersheds are looked at separately. Figures 4, 5, and 6 show the amount of pollutants removed by both structural and non-structural BMPs within each watershed compared to the WLA. 269 of 334 ---PAGE BREAK--- 25 Figure 4. 2020 Ashley Creek Estimate of Total Pollutant Reductions Figure 5. 2020 Spring Creek Estimate of Total Pollutant Reductions 1 10 100 1,000 10,000 100,000 1,000,000 10,000,000 Total Nitrogen Reduction (lbs) Total Phosphorus Reduction (lbs) Total Sediment Reduction (lbs) Pollutant Removed (lbs) (log scale) Ashley Creek Non-structural Structural WLA 1 10 100 1,000 10,000 100,000 1,000,000 10,000,000 Total Nitrogen Reduction (lbs) Total Phosphorus Reduction (lbs) Total Sediment Reduction (lbs) Pollutant Removed (lbs) (log scale) Spring Creek Non-structural Structural WLA 270 of 334 ---PAGE BREAK--- 26 Figure 6. 2020 Stillwater River Estimate of Total Pollutant Reductions Understanding where within the MS4 pollutant reductions are occurring and through what mechanisms is important. As development continues, additional structural BMPs will be incorporated, increasing their importance in overall pollutant reductions. With continued growth, the service area of the City expands, stretching existing resources potentially making it difficult to keep pace with non-structural BMPs. Fortunately, the City’s multi-faceted approach provides some leniency to keep pollutant reductions high while growth continues. 1 10 100 1,000 10,000 100,000 1,000,000 10,000,000 Total Nitrogen Reduction (lbs) Total Phosphorus Reduction (lbs) Total Sediment Reduction (lbs) Pollutant Removed (lbs) (log scale) Stillwater River Non-structural Structural WLA 271 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan 27 5 References Center for Watershed Protection. 2007. National Pollutant Removal Performance Database: Version 3. Ellicott City, MD. DEQ 2012. Water Quality Planning Bureau Field Procedures Manual for Water Quality Assessment Monitoring. Helena, MT. DEQ 2014. Final - Flathead – Stillwater Planning Area Nutrient, Sediment, and Temperature and Water Quality Improvement Plan. Document Number C11-TMDL-02aF. Helena, MT. DEQ 2016. General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4s). Permit Number MTR040000. Montana Department of Environmental Quality. Authorization to Discharge under the Montana Pollutant Discharge Elimination System (MPDES). Helena, MT. EPA 1983. Nationwide Urban Runoff Program. Accessed December 2020. {Urban Storm Water Preliminary Data Summary (epa.gov)}. Geo Geosyntec Consultants, Inc. and Wright Water Engineers, Inc. 2011. International Stormwater Best Management Practices Database Pollutant Category Summary: Solids (TSS, TDS, and Turbidity). www.bmpdatabase.org. HDR 2017. Montana Post-Construction Storm Water BMP Design Guidance Manual. September 2017. K Collins, and T. Schueler. 2008. Technical Memorandum: The Runoff Reduction Method. Ellicott City, MD: Center for Watershed Protection and the Chesapeake Stormwater Network. Kalispell, City of. 2008. City of Kalispell. Stormwater Facility Plan Update March 28, 2008. Prepared by HDR Engineering, Inc. and Morrison Maierle, Inc. Kalispell, MT. Kalispell, City of. 2017. City of Kalispell, Growth Policy, Plan-It 2035. Prepared by Kalispell City Planning Board. Adopted by Kalispell City Council, Resolution #5821A. Kalispell, MT. Kalispell, City of. 2018. MS4 Sampling Plan for TMDL-Related Monitoring. (Appendix F: Stormwater TMDL Action & Sampling Plan). City of Kalispell, Montana. Storm Water Management Program. January 9, 2018. Kalispell, City of. 2021. Stormwater Management Program. Permit Years: 2017-2021. Updated: 3/1/2021. Kalispell, MT. Kalispell, City of. 2020b. Standards for Design and Construction. January 21, 2020. PNAS 2018. Patterns of plant carbon, nitrogen, and phosphorus concentration in relation to productivity in terrestrial ecosystems. PNAS April 17, 2018 115 (16) 4033-4038. 272 of 334 ---PAGE BREAK--- 28 WERF 2017. International Stormwater BMP Database: 2016 Summary Statistics. 1COh%20BMP%20Database%202016%20Summary%20Stats.pdf}. 273 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan A TMDL Progress Reporting 274 of 334 ---PAGE BREAK--- Table A-1. Pollutants of Concern Removed by Non-Structural BMPs by Year Year Non-Structural BMP Reduction in Total Nitrogen (tons) Reduction in Total Phosphorus (tons) Reduction in Sediment (tons) 2017 Treatment Unit Maintenance1 0.5 0.1 22.6 Infrastructure Maintenance1 0.7 0.1 35.6 Street Sweeping1 25 4.2 1,245 Leaf Collection2 4.1 0.3 n/a 2018 Treatment Unit Maintenance1 0.9 0.2 45.0 Infrastructure Maintenance1 1.0 0.2 49.5 Street Sweeping1 27 4.5 1,362 Leaf Collection2 9.3 0.7 n/a 2019 Treatment Unit Maintenance1 0.8 0.1 38.6 Infrastructure Maintenance1 3.0 0.5 151.8 Street Sweeping1 18 3.0 912 Leaf Collection2 5.6 0.4 n/a 2020 Treatment Unit Maintenance1 1.2 0.2 59.55 Infrastructure Maintenance1 2 0.4 115.5 Street Sweeping1 65 10.9 3,265 Leaf Collection2 5.1 0.4 n/a 1Total nitrogen and phosphorus estimated from tons of sediment and nutrient ratio of N 50:1 g/g and P 300 g/g (EPA 1983). 2Total nitrogen and phosphorus estimated from tons of leaves collected and nutrient stoichiometry of N 14 mg/g and P 1 mg/g (PNAS 2018). The total tons of leaves removed by the MS4 for the reported years is as follows: 2017 – 292 tons, 2018 – 667 tons, 2019 – 399 tons, 2020 – 366 tons Table A-2. Pre-2016 Completed Private and Public Stormwater Quality Improvement Projects Year Completed Name Type and Private or Public1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 2009 Super One Foods Proprietary Private - HDS 5.2 Stillwater River 5% 18% 54% 2012 South Meadows Drainage Improvements Proprietary Private - HDS 36.36 Ashley Creek 5% 18% 54% 2013 Willows Stormwater Improvements Proprietary Private - HDS 28.8 Ashley Creek 5% 18% 54% 2013 Kalispell Center Mall Proprietary Private - HDS 22.45 Spring Creek 5% 18% 54% 1Propriertary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 275 of 334 ---PAGE BREAK--- Table A-3. 2016 Completed Private and Public Stormwater Quality Improvement Projects Name Private or Public Type1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 Sylvan Drive Public Proprietary 265 Stillwater River 5% 18% 54% Spring Creek Alley Stormwater Public Structure Sump 0.05 Spring Creek 0% 0% 0% Spring Prairie Four Private Infiltration Basin 56.53 Closed Basin (Stillwater) 21% 47% 80% Gardner Retention Private Infiltration Basin 66.26 Closed Basin (Lower Ashley) 21% 47% 80% Owl View Townhomes Private Infiltration Basin 0.46 Closed Basin (Stillwater) 21% 47% 80% Glacier View Professional Center Private Proprietary 0.567 Closed Basin (Stillwater) 5% 18% 54% Herberger's Expansion Private Proprietary Spring Creek 5% 18% 54% Hampton Inn Private Proprietary 6.75 Spring Creek 5% 18% 54% McDonald's Private Proprietary 0.92 Spring Creek 5% 18% 54% Forest Service Building Private Proprietary & Wet Detention Basin 0.39 Stillwater River 30% 50% 64% J2 Office Warehouse Private Proprietary 0.21 Stillwater River 5% 18% 54% KRH Northwest Family Medicine Private lnfiltration Basin 0.61 Closed Basin (Whitefish) 21% 47% 80% Sunnyview Phase I I I Private Proprietary & lnfiltration Basin 69.15 Closed Basin (Stillwater) 21% 47% 80% 1Propriertary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 276 of 334 ---PAGE BREAK--- Table A-4. 2017 Completed Private and Public Stormwater Quality Improvement Projects Name Private or Public Type1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 4th Avenue E Water Replacement Public N/A N/A Ashley and Stillwater 0% 0% 0% Begg Park Dog Park Public Infiltration Basin 1.69 Ashley Creek 21% 47% 80% MDT Maintenance Facility – City Maintained Public Proprietary 1.6 Stillwater River 5% 18% 54% Southside Estates Private Proprietary 5.8 Ashley Creek 5% 18% 54% Glacier Village Greens Phase 21 Private lnfiltration Basin 2.75 Closed Basin (Whitefish) 21% 47% 80% RDO Private Bioretention 0.37 Ashley Creek 64% 55% 75% Pinnacle Chiropractic Private lnfiltration Basin 0.28 Closed Basin (Spring Creek) 21% 47% 80% Owl View Landing Private lnfiltration Basin & Proprietary 3.923 Closed Basin (Stillwater) 21% 47% 80% Emmanuel Lutheran West Campus Private Proprietary 4.74 Stillwater River 5% 18% 54% Kalispell Ford Private lnfiltration Basin 10 Closed Basin (Stillwater) 21% 47% 80% Women's & Children's Private Proprietary 3.58 Closed Basin (Stillwater) 5% 18% 54% MDT Maintenance Facility Private Proprietary 6.2 Stillwater River 5% 18% 54% 1Propriertary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 277 of 334 ---PAGE BREAK--- Table A-5. 2018 Completed Private and Public Stormwater Quality Improvement Projects Name Private or Public Type1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 Glacier Rail Park Public Proprietary & Infiltration Basin 47.724 Closed Basin 21% 47% 80% Sherry Lane and Ramsgate Dr. Public Storm Improvements & Flood Reduction N/A Spring Creek 0% 0% 0% The Vision Clinic Private Proprietary 0.75 Spring Creek 5% 18% 54% Peterson Elementary Private lnfiltration Basin 0.12 Closed Basin (Lower Ashley) 21% 47% 80% J2 Office Products Private Proprietary 0.79 Stillwater River 5% 18% 54% Glacier Rail Park Private lnfiltration Basin 44.07 Closed Basin (Stillwater) 21% 47% 80% PTA Private Infiltration Basin 0.798 Closed Basin (Lower Ashley) 21% 47% 80% First American Title Private Proprietary 0.74 Stillwater River 5% 18% 54% Husky Street Apartments Private Biofiltration Swale 0.83 Spring Creek 40% 38% 92% Green Nissan/Hyundai Private Proprietary 6.2 Closed Basin (Lower Ashley) 5% 18% 54% Rankin Elementary Private Proprietary 11.62 Ashley Creek 5% 18% 54% Lofts at Ashley Private Proprietary 3.7 Ashley Creek 5% 18% 54% Treeline Subdivision Private Proprietary 5.603 Stillwater River 5% 18% 54% 1Propriertary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 278 of 334 ---PAGE BREAK--- Table A-6. 2019 Completed Private and Public Stormwater Quality Improvement Projects Name Private or Public Type1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 Sylvan Drive Conveyance and Detention Improvements Public Extended Detention Basin N/A (refurbish) Stillwater River 24% 20% 64% Shop Complex Pavement Restoration Public Proprietary 26.82 Ashley Creek 5% 18% 54% Linderman School Public Proprietary 3.49 Ashley Creek 5% 18% 54% Faith Covenant Presbyterian Public Proprietary 2.92 Ashley Creek 5% 18% 54% Brightview Subdivision Private lnfiltration Basin 32.16 Stillwater River 21% 47% 80% Oral Surgery Private lnfiltration Basin 0.588 Closed Basin (Stillwater) 21% 47% 80% Edge Apartments Private Biofiltration Swale 0.42 Spring Creek 40% 38% 92% Basecamp RV Private Biofiltration Swale 9.24 Ashley Creek 40% 38% 92% Glacier Eye Clinic Private lnfiltration Basin 3.42 Stillwater River 21% 47% 80% Meadows Edge Phase 1A Private Proprietary 8.424 Spring Creek 5% 18% 54% 1Proprietary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 279 of 334 ---PAGE BREAK--- Table A-7. 2020 Completed Private and Public Stormwater Quality Improvement Projects Name Private or Public Type1 Drainage Treatment Area (acres) Discharge Location BMP Total Nitrogen Percent Removal2 BMP Total Phosphorus Percent Removal2 BMP Sediment Percent Removal3 Fresh Life Public Proprietary 1.8 Ashley Creek 5% 18% 54% Smith’s Grocery Private Proprietary 4.37 Stillwater River 5% 18% 54% Southside Estates Phase 2 Private Proprietary 20.5 Ashley Creek 5% 18% 54% Glenwood Apartments Private Proprietary 5.58 Spring Creek 5% 18% 54% Jaxon Ridge Private Proprietary 3.896 Dry Bridge Slough 5% 18% 54% Peterson Acre Private Infiltration Basin 1 Closed Basin (Stillwater) 21% 47% 80% Kalispell North Town Center Private Infiltration Basin 102 Closed Basin (Stillwater) 21% 47% 80% Westview Phase 4 Private Proprietary 13.0001 Closed Basin (Stillwater) 5% 18% 54% Cottage Gardens Private Proprietary 11.7 Spring Creek 5% 18% 54% Meadow’s Edge Private Proprietary 71.27 Spring Creek 5% 18% 54% Owl View Landing Private Proprietary 0.988 Closed Basin (Stillwater) 5% 18% 54% 1Proprietary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 3Average percent removal based on Section 6.5.5.2 DEQ 2014, treatment specific percent removal based on WERF 2017 Referenced percent removals summarized in Table 4 280 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan B Treatment Scenarios Corresponding to nitrogen removal and scenarios in Table 8 281 of 334 ---PAGE BREAK--- 282 of 334 Total Basin = 1,000 ac BR Bioretention = 64% removal 1,000 ac 1,000 ac - 1,000 ac x 64% = 360 ac 360 ac 1,000 ac basin with bioretention treatment at the effluent end. 64% Reduction Total Basin = 1,000 ac BR Sub-basin A 200 ac 200 ac 72 ac 200 ac -200 ac x 64% = 72 ac 872 ac Bioretention = 64% removal 872 ac 1000 ac - 200 ac + 72 ac =872 ac 1,000 ac basin with 200 ac sub-basin. Sub-basin has bioretention treatment at the effluent. 13% Reduction ---PAGE BREAK--- 283 of 334 Total Basin = 1,000 ac Sub-basin A 200 ac 200 ac 72 ac 200 ac - 200 ac x 64% = 72 ac 872 ac Bioretention = 64% removal Hydrodynamic separator = 5% removal 828 ac 872 ac - 872 ac x 5% = 828 ac H 1000 ac - 200 ac + 72 ac = 872 ac BR 1,000 ac basin with 200 ac sub-basin. Sub-basin has bioretention treatment at the effluent. Entire basin has hydrodynamic separator treatment at the effluent. 17% Reduction Total Basin = 1,000 ac BR F Sub-basin B1 200 ac Sub-basin B 400 ac 200 ac 72 ac 272 ac 190 ac 400 ac - 200 ac + 72 ac = 272 200 ac - 200 ac x 64% = 72 ac 272 ac - 272 ac x 30% = 190 ac 790 ac Bioretention = 64% removal Hydrodynamic separator = 5% removal 751 ac 790 ac - 790 ac x 5% = 751 ac H 1000 ac - 400 ac + 190 ac = 790 ac Filter = 30% removal 1,000 ac basin with 400 ac sub-basin with filter at the effluent. Sub-basin also has a 200 acre sub-basin with bioretention treatment at the effluent. Entire basin has hydrodynamic separator treatment at the effluent. 25% Reduction ---PAGE BREAK--- 284 of 334 Total Basin = 1,000 ac BR F F BR Sub-basin B1 200 ac Sub-basin B 400 ac Sub-basin A1 100 ac Sub-basin A 200 ac 200 ac 72 ac 272 ac 100 ac 36 ac 136 ac 190 ac 95 ac 400 ac - 200 ac + 72 ac = 272 200 ac - 200 ac x 64% = 72 ac 272 ac - 272 ac x 30% = 190 ac 100 ac - 100 ac x 64% = 36 ac 200 ac - 100 ac + 36 ac = 136 ac 136 ac - 136 ac x 30% = 95 ac 685 ac Bioretention = 64% removal Bioretention = 64% removal Filter = 30% removal Hydrodynamic separator = 5% removal 651 ac 685 ac - 685 ac x 5% = 651 ac H 1000 ac - 400 ac - 200 ac + 190 ac + 95 ac = 685 ac Filter = 30% removal 1,000 ac basin with two sub-basins, A & B. Sub-basin A is 200 acres with a filter at the effluent. Sub-basin A also has a 100 acre sub-basin with bioretention at the effluent. Sub-basin B is 400 acres with a filter at the outlet. Sub-basin B also has a 200 acre sub-basin with bio-retention at the effluent. The entire basin also has a hydrodynamic separator at the effluent. 35% Reduction ---PAGE BREAK--- C TMDL Sampling Plan 285 of 334 ---PAGE BREAK--- MS4 Sampling Plan for TMDL-Related Monitoring City of Kalispell, Montana Storm Water Management Program January 9, 2018 Prepared by 286 of 334 ---PAGE BREAK--- This page intentionally left blank 287 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 i Table of Contents 1 Introduction 1 1.1. Background 1 1.2. Purpose 1 2 Kalispell MS4-Related 1 2.1. TMDL Overview 1 2.2. TMDL Strategy 2 3 Monitoring Locations and Strategies 2 3.1. Sites 001 and 001a: Hydrodynamic Separator Effectiveness Evaluation 2 3.2. Site 002: Assess Future BMP Performance in Commercial/ Industrial Area 3 3.3. Site 004: Assess Future BMP Performance in Residential Area 4 4 Monitoring Requirements 6 4.1. Field Sampling Methods 6 4.2. Sampling Parameters and Analytical Methods 7 4.3. Sample Handling and Documentation 7 4.4. Storm Events and Sample Frequency 8 4.5. Quality Assurance/Quality 9 4.6. Analysis of Results 9 5 Reporting 9 Figures Figure 1. Monitoring Sites 001 and 001a 3 Figure 2. Monitoring Site 002 4 Figure 3. Monitoring Site 004 5 Tables Table 1. Summary of with Kalispell MS4 Approved WLAs 2 Table 2. TMDL-Related Monitoring Sample Locations 5 Table 3. Self-Monitoring Sample Locations 6 Table 4. Analytical Methods 8 Appendices Appendix A – Supplemental Figures 288 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 1 1 Introduction 1.1. Background The City of Kalispell (City) operates its storm drainage system under the authorization of the Montana Pollution Discharge Elimination System (MPDES) General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4s), hereafter referred to as the MS4 General Permit. The current MS4 General Permit, issued by the Montana Department of Environmental Quality (MDEQ), is effective from January 1, 2017 through December 31, 2021. In accordance with Part III of the MS4 General Permit, the City is required to develop a sampling plan for total maximum daily load (TMDL) related monitoring, due with the first year’s annual report; and a TMDL section in its Storm Water Management Program (SWMP), due with the fourth year’s annual report. The results from the TMDL-related monitoring will be used in conjunction with the TMDL section of the SWMP to address applicable Similarly, Part IV of the MS4 General Permit requires semi-annual monitoring (self-monitoring) that may be satisfied entirely or in part by the TMDL-related monitoring required under Part III. 1.2. Purpose The purpose of this sampling plan is to describe the City’s TMDL-related monitoring program for the 2017 through 2021 permit term. More specific details relating to the purpose of this plan are as follows:  The City has selected TMDL-related monitoring Option 2; therefore, this plan will be implemented to track and evaluate effectiveness of BMPs selected for reducing MS4 loading to impaired waterbodies.  In accordance with the MS4 General Permit requirements, this plan will ultimately become a part of the TMDL section of the City’s SWMP (which will be submitted with the fourth year’s annual report in 2020).  The City has selected self-monitoring Option 2 (see Part IV of the MS4 General Permit). The monitoring locations identified in this plan will also be used to fulfill the self-monitoring requirements. Additional discussion on the City’s plan for self-monitoring is provided in Section 8 of the City’s SWMP.  This document, when implemented, will fulfill the requirements of Part III.B of the MS4 General Permit, requiring a sampling plan for TMDL-Related Monitoring. 2 Kalispell MS4-Related 2.1. TMDL Overview There are six named or perennial surface waters that receive stormwater discharges from the City’s MS4 outfalls. These receiving waters are as follows:  Whitefish River  Stillwater River  Ashley Creek 289 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 2  Spring Creek  Bowser/Little Spring Creek- Aka Kids Creek-Classified as an unnamed perennial  Unnamed perennial surface water tributary to Ashley Creek from Foys Lake The Whitefish River, Stillwater River, Spring Creek, and Ashley Creek are classified as impaired surface waters of the state and each has an approved pollutant TMDL with waste load allocation (WLA). Table 1 summarizes the impaired waterbodies with within the Kalispell MS4 boundary and the associated pollutant of impairment. Figure A.1 (Appendix A) provides a map of the City’s outfalls and associated receiving waterbodies. Table 1. Summary of with Kalispell MS4 Approved WLAs Waterbody Pollutants of Impairment Total Phosphorus Total Nitrogen1 Dissolved Oxygen Sediment Temperature Whitefish River X Stillwater River X Spring Creek X X X Ashley Creek2 X X X X X 1 TN is a surrogate TMDL for Nitrate+Nitrite 2 Middle and Lower Segments 2.2. TMDL Strategy Part III.B of the MS4 General Permit specifies that the City shall develop and implement a section of their SWMP to address More specifically, the City must include in its SWMP a section identifying the measures and BMPs it plans to implement, describing the City’s impairment priorities and long term strategy, and outlining interim milestones a completion schedule for action items) for controlling the discharge of the pollutants of concern and making progress towards meeting the TMDL. The City has yet to develop this section of the SWMP; however, the City has selected its monitoring locations in watersheds where they are currently planning to implement BMPs aimed at reducing pollutants of impairment for its receiving waterbodies. Additional discussion of target pollutants and impairment priorities will be provided within the TMDL section of the SWMP when it is submitted. 3 Monitoring Locations and Strategies 3.1. Sites 001 and 001a: Hydrodynamic Separator Effectiveness Evaluation The City installed a Defender® hydrodynamic separator in August 2016 near the intersection of Sylvan Drive and Sylvan Court (see Figure This area drains to the Stillwater River, which has an MS4 WLA for sediment. The City will conduct monitoring immediately upstream and of the hydrodynamic separator in order to evaluate its effectiveness at removing sediment from MS4 wet weather discharges. Additional parameters will also be analyzed in accordance with Table 1. Small MS4 Monitoring Requirements, of Part IV.A. in the MS4 General Permit. 290 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 3 The results of this evaluation will be used to assist the City in making informed decisions about whether to install a Defender® hydrodynamic separator, or equivalent device, in other locations. Figure 1. Monitoring Sites 001 and 001a 3.2. Site 002: Assess Future BMP Performance in Commercial/ Industrial Area Kalispell MS4 drainage area SWR-7 drains to the Stillwater River, which has an MS4 WLA for sediment. A monitoring location is located near the outfall of this watershed on Wyoming Street (see Figure The drainage area is approximately 100 acres, comprised mostly of commercial/industrial land use. The City is planning to implement future BMPs within this drainage area in an effort to reduce the MS4’s discharge of sediment to the Stillwater River. The monitoring results from samples collected before the BMPs are implemented within the drainage area (baseline samples) will establish the existing conditions. Future monitoring results will be compared to the baseline samples as BMP(s) are added within the drainage basin. The City plans to use the monitoring data results from this site to assess the BMP effectiveness in this immediate watershed (drainage area SWR-7) and develop a plan for installing BMPs in other commercial/industrial areas. 291 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 4 Figure 2. Monitoring Site 002 3.3. Site 004: Assess Future BMP Performance in Residential Area Kalispell MS4 drainage area AC-11 drains to Ashley Creek, which has an MS4 WLA for phosphorus, nitrogen, dissolved oxygen, sediment, and temperature. A monitoring location is located near the outfall of this watershed on 11th Street West (see Figure The drainage area is approximately 300 acres, comprised mostly of residential land use. The City is planning to implement future BMPs within this drainage area in an effort to reduce the MS4’s discharge of pollutants to Ashley Creek. The monitoring results from baseline samples collected within the drainage area will establish the existing conditions. Monitoring results will be compared to the baseline data as BMP(s) are added within the drainage basin. The City plans to use the results of the monitoring data at this site to assess BMP effectiveness in this immediate watershed (drainage area AC-11) and plan future BMPs in other residential areas. A summary of all TMDL-related monitoring locations is provided in Table 2. For reference, Table 3 provides a summary of all self-monitoring locations where sampling will be conducted in accordance with Part IV of the MS4 General Permit. Comparison of Table 2 and Table 3 reveals that three of the self-monitoring locations will also be used for TMDL-related monitoring. This allows the City to be more efficient with collection of samples and analysis of monitoring data each year. 292 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 5 Figure 3. Monitoring Site 004 Table 2. TMDL-Related Monitoring Sample Locations Name Watershed Receiving Waterbody Location Sample Collection Method Number of Samples (Annually) Sample Parameter(s) (MS4 Listed Impairments) 001 SWR-4 Stillwater River 48°11’40.14”N 114°17’55.76”W Grab 4 Sediment 001a SWR-4 Stillwater River 48°11’40.70”N 114°17’57.38”W Grab 4 Sediment 002 SWR-7 Stillwater River 48°12’26.98”N 114°18’49.81”W Grab1 4 Sediment 004 AC-11 Ashley Creek 48°11’10.01”N 114°19’17.46”W Grab1 4 TP, TN, DO, Sediment, Temperature 1 A composite sample is the preferred sample collection method for this site; however, experience collecting grab samples at this site will help the City develop a better understanding of site conditions resulting in a more effective implementation plan and design for collecting composite samples in the future. The City will consider development of a composite sample collection and analysis plan for this site in the coming years. 293 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 6 Table 3. Self-Monitoring Sample Locations Name Watershed Receiving Waterbody Location Sample Collection Method Frequency Sample Parameter(s) 001 SWR-4 Stillwater River 48°11’40.14”N 114°17’55.76”W Grab Semi-annual1  Total Suspended Solids  Chemical Oxygen Demand  Total Phosphorus  Total Nitrogen  pH  Copper  Lead  Zinc  Estimated Flow  Oil and Grease 002 SWR-7 Stillwater River 48°12’26.98”N 114°18’49.81”W Grab Semi-annual1 003-A AC-A Ashley Creek 48°11’43.49”N 114°22’23.71”W Grab Semi-annual1 004 AC-11 Ashley Creek 48°11’10.01”N 114°19’17.46”W Grab Semi-annual1 1 One sample must be collected between January 1st and June 30th of each permitted calendar year and the other sample between July 1st and December 31st. 4 Monitoring Requirements Quality Assurance/Quality Control (QA/QC) is critical for accurate sampling. This section provides details of sampling methods, laboratory analytical methods, and QA/QC procedures to be used in sampling. 4.1. Field Sampling Methods The City will use manual sample collection techniques to conduct monitoring activities at each site in the immediate future. In the coming years, automated samplers will likely be used to collect composite samples at sites 002 and 004. Each of these methods are discussed below. 4.1.1 Manual Sample Collection Manual grab techniques will be used to collect samples at 001, 001a, and 0031 throughout the duration of this plan. The grab sample method is suitable for site’s 001 and 001a because samples will be collected within minutes of each other and since the hydraulic residence time that stormwater is in the BMP is only a few minutes, this approach will provide an accurate comparison of influent and effluent water quality for the Defender® hydrodynamic separator. A grab sample at site 003 will be used to evaluate the quality of water in Ashley Creek upstream of Kalispell’s MS4. Manual grab techniques will also be used to collect samples at sites 002 and 004 in the immediate future; however, the City is considering the use of automated samplers to collect composite samples at these sites in the coming years (see Section 4.1.2). The samples will be collected by field personnel during rainfall events. Rainfall events will be monitored by weather surveillance radar so that field personnel can determine when to be present in the watershed during active events to obtain manual samples.2 Samples will be collected in clean, 1 Site 003 is a self-monitoring site and will not be part of the TMDL-related monitoring. 2 Radar is available via the Nation Weather Service webpage 294 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 7 labeled bottles provided by the laboratory. If necessary, an extension pole, rope or other apparatus can be used to aid the field crew in safe sample collection, especially during high flow conditions. 4.1.2 Automated Sample Collection If applicable, automated sampling devices will be used to collect composite samples; that is, small constant volume samples that are collected throughout a runoff event (as opposed to a manual grab sample, which only represents one point in time during an event). The City owns two ISCO 6712 automated sample devices which will likely be used to collect composite samples at site’s 002 and 004 in the future. The primary monitoring objective at site’s 002 and 004 is to assess the impact of future BMPs implemented upstream using sample data collected near the point in a local watershed. Composite sampling is preferred for these locations because it would provide an event mean concentration of the pollutants from the runoff event; however, as noted above, additional experience and understanding of site conditions is needed to effectively and accurately collect and analyze composite samples. If automated sampling is implemented, the City expects that flow-weighted sampling would be used by collecting multiple aliquots (small samples) over the duration of the storm in one bottle which will be shipped to the Montana Environmental Laboratory for analysis following the storm event. 4.1.3 Sampling Equipment Decontamination Decontaminated sample collection bottles and lids will be provided by the laboratory. 4.2. Sampling Parameters and Analytical Methods The water quality samples collected will be analyzed for the MS4 listed pollutants of impairment in the specific receiving waterbody as well as the parameters listed in Table 1 of Part IV.A in the MS4 General Permit (Small MS4 Monitoring Requirements). Table 4 shows the parameters and standard analytical methods to be used. All data should meet the precision, recovery, and accuracy requirements specified in the laboratory method used. The laboratory used for this study will maintain internal quality assurance/quality control procedures as documented in their laboratory quality assurance manual. The laboratory will use a combination of blanks, laboratory control spikes, surrogates, and duplicates to evaluate the analytical results. 4.3. Sample Handling and Documentation Automatic samplers will be serviced immediately following a storm event. Chain of custody forms will accompany all samples. A Field Log will be kept for each sampling site with the details of the date, time, personnel, and purpose of visit, weather, and conditions observed, samples collected and actions performed. 295 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 8 Table 4. Analytical Methods Parameter Analytical Method Reporting Limit (mg/L) Sample Container Preservative Holding Time (days) Total Suspended Solids SM 2540 D 1 1 L plastic3 None3 Analyze immediately3 Total Phosphorus E365.1 0.01 Nitrogen – Kjeldahl, total1 E351.2 0.2 Nitrate & Nitrite, total1 E353.2 E300A 0.01 Chemical Oxygen Demand2 E410.1 E410.4 1 Total Recoverable Copper2 E200.8 0.01 Total Recoverable Lead2 E200.8 0.001 Total Recoverable Zinc2 E200.7 E200.8 0.01 Oil and Grease2 E1664A 1 1 L glass H2SO4 to pH<2 Cool to 4°C 28 Estimated Flow2 N/A N/A N/A N/A Analyze onsite4 Dissolved Oxygen SM 4500-OG 0.1 N/A N/A Analyze onsite4 Temperature N/A 0.1°C N/A N/A Analyze onsite4 pH2 E150.1 0.1 unit N/A N/A Analyze onsite4 1 Total Nitrogen is calculated from Nitrogen – Kjeldahl, total and Nitrate & Nitrite, total. 2 These parameters will only be analyzed semi-annually, in accordance with the City’s self-monitoring plan. 3 Samples will be immediately delivered to the Montana Environmental Lab in Kalispell. The lab staff will separate the 1L samples so that each parameter can be analyzed. Preservatives will be added by the lab staff, if necessary. 4 The City analyze for estimated flow, dissolved oxygen, temperature, and pH, onsite. 4.4. Storm Events and Sample Frequency Sampling will be attempted for measurable runoff events (that is a rainfall events that produce any volume of runoff flowing past/through the monitoring location that will allow a sample to be collected). In accordance with Part IV.a.6.a. of the MS4 General Permit, a minimum of one sample will be collected at each site between January 1st and June 30th and a minimum of one sample will be collected at each site between July 1st and December 31st of each year. The City will attempt to 296 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring January 9, 2018 9 collect four samples annually for MS4 listed impairments at each site (see Table 2).3 Four annual samples will provide greater assurance that data is representative. Precipitation will be monitored using a combination of on-site or web-based rain gauges4, and the radar managed by the National Oceanic and Atmospheric Administration’s Nation Weather Service. This data may be used to delineate storm characteristics, if necessary (timing, duration, intensity, and relative total rainfall). 4.5. Quality Assurance/Quality Control Samples will be analyzed using the designated EPA Method or Standard Method as defined in Table 4. Chain-of-custody procedures will be followed for samples sent to the laboratory. 4.6. Analysis of Results All sample results will be compiled into a spreadsheet containing the results for each parameter at every sample site. The analysis method will vary depending on the sample collection method and site objectives, which are described in the subsequent sections. 4.6.1 Sample Collection at Sites 001 and 001a The objective at sample site’s 001 and 001a is to compare influent and effluent data for the Defender® hydrodynamic separator. BMP effectiveness will be quantified by calculating the percent change in pollutant concentration between the two sample sites, using Equation 1. The calculated percent change for each sample collected will be presented on a graph (sample date vs. percent change) to assess the long-term performance of the BMP. Percent Change= Ci-Ce Ci *100 Equation 1 Where: Ci = Influent concentration (mg/L) Ce = Effluent concentration (mg/L) 4.6.2 Sample Collection at Sites 002 and 004 A graph will be generated showing sample date (time) vs. concentration, for each parameter. These graphics will show the trend in water quality data over the period of time which samples are being collected. A downward trend will indicate that BMPs implemented upstream are effective, while a stagnant or upward trend would indicate the BMPs implemented upstream are not effective at reducing pollutants. A separate analysis of each parameter can be used to help understand the effectiveness of BMPs for a variety of parameters considered. 5 Reporting The results from TMDL-related monitoring will be presented and discussed in each year’s MS4 annual report. The discussion will focus on the evaluation of the effectiveness of BMPs being implemented to address pollutants of impairment within each local watershed as well as changes in water quality over time. 3 Only two of the four annual samples will be analyzed for the full suite of self-monitoring parameters (listed in Table 1. Small MS4 Monitoring Requirements, of Part IV.A. in the MS4 General Permit). 4 The following websites provide historic rainfall data for the City of Kalispell: http://w2.weather.gov/climate/index.php?wfo=mso; http://mesowest.utah.edu/cgi-bin/droman/precip_monitor.cgi?state=MSO&rawsflag=3 297 of 334 ---PAGE BREAK--- City of Kalispell I Storm Water Management Program MS4 Sampling Plan for TMDL-Related Monitoring Appendix A. Supplemental Figures 298 of 334 ---PAGE BREAK--- Source: Esri, DigitalGlobe, GeoEye, Geographics, CNES/Airbus DS, USDA, USGS, AEX, Getmapping, Aerogrid, IGN, IGP, swisstopo, and the GIS User Community PATH: G:\PROJECTS\KALISPELL\KALISPELL MS4\MAP_DOCS\FIGURE 1 - RECEIVING WATERBODIES MAP.MXD - USER: MPETERSO - DATE: 12/29/2017 MS4 RECEIVING WATERBODIES MAP FIGURE A.1 CITY OF KALISPELL, MT MS4 SAMPLING PLAN FOR TMDL-RELATED MONITORING (CLIENT LOGO) 0 4,000 Feet O DATA SOURCE: ESRI, City of Kalispell LEGEND Outfall Storm Main Kalispell Receiving Waterbody City Limits Approximate Drainage Basin* Ashley Creek Little Spring Creek Spring Creek Stillwater River Unnamed Perennial Whitefish River Areas which Generally Drain to an Infiltration Basin *Note: Drainage basin delineations are approximate and only consider areas within the city limits. These delineations are intended to generally depict which waterbodies portions of the MS4 drains to. Stillwater River Stillwater River Whitefish River Spring Creek Ashley Creek Little Spring Creek Unnamed Perennial Ashley Creek Flathead River 299 of 334 ---PAGE BREAK--- !H !H !H !H !H Source: Esri, DigitalGlobe, GeoEye, Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community PATH: S:\PW DATA\DEPARTMENTS\STORMWATER\PHASE II STORMWATER PERMIT\STORMWATER MANAGEMENT PROGRAM\STORM SAMPLING\EDITABLE DOCUMENTS\FIGURE 2 - MONITORING LOCATIONS MAP UPDATE.MXD - USER: CLEWIS - DATE: 1/9/2020 MS4 TMDL AND SELF-MONITORING LOCATIONS FIGURE A.2 CITY OF KALISPELL, MT MS4 SAMPLING PLAN FOR TMDL-RELATED MONITORING 0 4,000 Feet O DATA SOURCE: ESRI, City of Kalispell LEGEND !H Monitoring Location Outfall Storm Main Kalispell Receiving Waterbody City Limits Approximate Drainage Basin* Ashley Creek Little Spring Creek Spring Creek Stillwater River Unnamed Perennial Whitefish River Areas which Generally Drain to an Infiltration Basin *Note: Drainage basin delineations are approximate and only consider areas within the city limits. These delineations are intended to generally depict which waterbodies portions of the MS4 drains to. Stillwater River Stillwater River Whitefish River Spring Creek Ashley Creek Little Spring Creek Unnamed Perennial Ashley Creek Flathead River Source: Esri, DigitalGlobe, GeoEye, Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 0 300 Feet WOODLAND AVE SYLVAN DR SYLVAN CT O Flathead River Site 003-A - Self-Monitoring Location Site 004 - TMDL & Self-Monitoring Location Site 002 - TMDL & Self-Monitoring Location Site 001a - TMDL Monitoring Location Site 001 - TMDL & Self- Monitoring Location 300 of 334 ---PAGE BREAK--- Appendix G: 2020 Sample Results 301 of 334 ---PAGE BREAK--- 2020 SAMPLE RESULTS EVALUATION OF STORMWATER QUALITY MONITORING MPDES Permit #MTR04005 302 of 334 ---PAGE BREAK--- 1 Contents Introduction 2 Methods 3 Sample Collection 3 Sample Parameters and Analytical Methods 3 Sample Analysis 4 Self-Monitoring: Results and Discussion 5 Results 5 Sample Comparison and Median Concentration 5 Standardized Parameter Concentrations by Location 12 Discussion: Trends, Outliers, and BMPs 14 Sampling Conditions 15 Stillwater River 15 Ashley Creek 16 Identified Pollutants 17 TMDL-Related Monitoring: Results and Discussion 22 Results 22 Stillwater River 22 Ashley Creek 25 Discussion: Adaptive Management 28 Stillwater River 28 Ashley Creek 29 APPENDIX A. Monitoring Parameters 30 Total Suspended Solids (TSS) 30 Chemical Oxygen Demand (COD) 30 Total Phosphorus (TP) 30 Total Nitrogen (TN) 30 pH 30 Heavy Metals: Total Copper (Cu), Lead (Pb), Zinc (Zn) 30 Oil and Grease (O&G) 31 APPENDIX B. Correlation Matrix 32 303 of 334 ---PAGE BREAK--- 2 Introduction The City of Kalispell operates its storm drainage system under the authorization of the Montana Pollution Discharge Elimination System (MPDES) General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4s). The current MS4 General Permit, issued by the Montana Department of Environmental Quality (MDEQ), is effective from January 1, 2017 through December 31, 2021. Part III of the MS4 General Permit requires total maximum daily load (TMDL) related monitoring. The City has selected TMDL-related monitoring Option 2 to track and evaluate effectiveness of BMPs selected for reducing MS4 loading to impaired waterbodies. Similarly, Part IV of the MS4 General Permit requires semi-annual monitoring (self-monitoring) that may be satisfied entirely or in part by the TMDL-related monitoring required under Part III. The City has selected self-monitoring Option 2 (see Part IV of the MS4 General Permit). Stormwater grab samples are collected four times a year for TMDL-related monitoring and two times a year for self-monitoring. Note: three of the five sample locations are the same between the different sampling protocols. Annually, a total of 18 individual site samples are collected sites for TMDL and self-monitoring X 2x/year) + (4 sites for only TMDL monitoring 2x/year)). Self-monitoring is completed at four stormwater discharge locations within the City of Kalispell. The sample locations were chosen to represent stormwater runoff from a primarily commercial/industrial area, from a primarily residential area, from a large drainage area combining both commercial and residential areas, and upstream, outside the MS4 boundary to evaluate water quality entering the MS4 (Table Table 1. Self-Monitoring Sample Locations Name Watershed Receiving Waterbody Location Drainage Area (Acres) Frequency Sample Parameter(s) 001 SWR-4 Stillwater River 48°11’40.14”N 114°17’55.76”W 268 Semi- annual1  Total Suspended Solids  Chemical Oxygen Demand  Total Phosphorus  Total Nitrogen  pH  Copper  Lead  Zinc  Estimated Flow  Oil and Grease 002 SWR-7 Stillwater River 48°12’26.98”N 114°18’49.81”W 96 Semi- annual1 003A AC-A Ashley Creek 48°11’43.49”N 114°22’23.71”W NA Semi- annual1 004 AC-11 Ashley Creek 48°11’10.01”N 114°19’17.46”W 291 Semi- annual1 1 One sample must be collected between January 1st and June 30th of each permitted calendar year and the other sample between July 1st and December 31st. 304 of 334 ---PAGE BREAK--- 3 TMDL-related monitoring overlaps with self-monitoring locations at 3 sites (SWR-4/001, SWR- 7/002, AC-11/004). AC-A/003A (in-stream, outside MS4 boundary) is not included in TMDL- related monitoring. One additional site is included only in TMDL-related monitoring, SWR- 4/001a. Monitoring locations were selected to evaluate best management practice (BMP) effectiveness (Table Sites 001a and 001 are upstream and respectively of an installed water quality treatment practice. Sites 002 and 004 are drainage basins that have planned water quality treatment practices. For more details regarding TMDL-related monitoring locations, see the “Kalispell MS4 Sampling Plan for TMDL Related Monitoring”. Table 1. TMDL-Related Monitoring Sample Locations Name Watershed Receiving Waterbody Location Drainage Area (Acres) Number of Samples (Annually) Sample Parameter(s) (MS4 Listed Impairments) 001 SWR-4 Stillwater River 48°11’40.14”N 114°17’55.76”W 268 4 Sediment 001a SWR-4 Stillwater River 48°11’40.70”N 114°17’57.38”W 268 4 Sediment 002 SWR-7 Stillwater River 48°12’26.98”N 114°18’49.81”W 96 4 Sediment 004 AC-11 Ashley Creek 48°11’10.01”N 114°19’17.46”W 291 4 TP, TN, DO, Sediment, Temperature Methods Sample Collection Grab samples for self- and TMDL-related monitoring were collected once in the spring (5/12/20) and once in the fall (10/12/20) of 2020. Additionally, only TMDL-related monitoring samples were collected 6/8/20 and 10/21/20. Field personnel collected samples during rainfall events that produced a measurable volume of runoff flowing past/through the monitoring locations that allowed a sample to be collected. Clean, labeled bottles provided by the laboratory, on an extension pole, were used to obtain stormwater samples. Field logs were used to document the date, time, location, personnel, weather, conditions observed, samples collected, estimated duration of the storm event, and total rainfall of the storm event. Sample Parameters and Analytical Methods Stormwater samples were analyzed for the parameters listed in Table 1 and Table 2. Table 3 shows the parameters and the standard analytical methods used. Montana Environmental Labs processed all the samples and uses a combination of blanks, laboratory control spikes, surrogates, and duplicates to evaluate analytical results. Chain of custody forms accompanied all samples. 305 of 334 ---PAGE BREAK--- 4 Table 3. Parameters and standard analytical methods Parameter Analytical Method Reporting Limit (mg/L) Sample Container Preservative Holding Time (days) Total Suspended Solids SM 2450 D 1 1 L plastic 2 None 2 Analyze immediately 2 Total Phosphorus E365.1 0.01 Nitrogen – Kjeldahl, total 1 E351.2 0.2 Nitrate & Nitrite, total 1 E353.2 E300A 0.01 Chemical Oxygen Demand E410.1 E410.4 1 Total Recoverable Copper E200.8 0.01 Total Recoverable Lead E200.8 0.001 Total Recoverable Zinc E200.7 E200.8 0.01 Oil and Grease E1664A 1 1 L glass H2SO4 to pH<2 Cool to 4°C 28 Estimated Flow NA NA NA NA Analyze onsite 3 Dissolved Oxygen SM 4500- OG 0.1 NA NA Analyze onsite 3 Temperature NA 0.1°C NA NA Analyze onsite 3 pH E150.1 0.1 unit NA NA Analyze onsite 3 1 Total Nitrogen is calculated from Nitrogen – Kjeldahl, total and Nitrate & Nitrite, total. 2 Samples will be immediately delivered to the Montana Environmental Lab in Kalispell. The lab staff will separate the 1L samples so that each parameter can be analyzed. Preservatives will be added by the lab staff, if necessary. 3 The City analyzes estimated flow, dissolved oxygen, temperature, and pH, onsite. Sample Analysis Due to new sample locations being designated in 2017 and TMDL-related sampling beginning in 2018, statistical analyses are not appropriate because of the low number of samples. For self- monitoring, the City of Kalispell is required to calculate the long-term median concentration of all known monitoring results at an individual location for each parameter in Table 1 per Part IV.A. of the MS4 General Permit issued by MDEQ. 306 of 334 ---PAGE BREAK--- 5 To compare individual parameters across locations, bar charts were created representing observed sample values from 2020 compared to the long-term median. To compare parameters at one location, parameter values were standardized and graphed over time by location. The MS4 General Permit requires self-monitoring results to be used to evaluate measures taken to improve the quality of stormwater discharges. This includes an evaluation of the results relative to the long-term median, comparisons between monitoring locations, discussion of trends and outliers compared to the long-term median, discussion of pH values outside the range of 6.0 to 9.0, and a schedule and rationale for BMPs planned to improve water quality of stormwater discharges based on monitoring results. The “Kalispell MS4 Sampling Plan for TMDL Related Monitoring” outlines the analysis of TMDL- related monitoring samples results. Analysis is designed to evaluate BMP effectiveness. The Plan states that the discussion of results will focus on the evaluation of the effectiveness of BMPs being implemented to address pollutants of impairment within each local watershed as well as changes in water quality over time. Self-Monitoring: Results and Discussion Results Sample Comparison and Median Concentration Table 4 is a summary of the 2020 sample parameter comparisons to the long-term median concentrations for each. Long-term median concentrations are calculated from all known monitoring results for each parameter at a monitoring location. Please note, as monitoring locations were new in 2017, median concentrations have been calculated only with samples taken since 2017 (8 total samples per site). Figures 1-9 depict observed and median parameter concentrations by site location. Many of the sites had higher recorded parameter values in spring than fall. Observed parameter values somewhat to notably elevated include total phosphorus in the spring at SWR-7/002 and oil and grease in the fall at SWR-4/001. Heavy Metals Zinc and copper were greater for all stormwater sampling locations collected in the spring (not detected at AC-A/003A, the in-stream sample). Lead was greater in in spring at SWR-7/002, greater in fall for SWR-4/001 and AC-11/004, and not detected at AC-A/003A. Nutrients Nutrients (total phosphorus (TP) and total nitrogen (TN)) were greater in the spring for all locations except AC-A/003A. At AC-A/003A, TP was equivalent in both samples and TN was greater in the fall. Sediment, Chemical Oxygen Demand, pH, & Oil and Grease Total suspended solids (TSS) was greater in the spring for all locations. Chemical oxygen demand (COD) was greater in the spring for all locations except for AC-A/003A. 307 of 334 ---PAGE BREAK--- 6 pH was greater in fall for all locations. Oil and grease values were greater in spring at SWR-7/002, not detected in spring and fall at AC- A/003A, and greater in fall at SWR-4/002 and AC-11/004. 308 of 334 ---PAGE BREAK--- 7 Table 4. 2020 Parameter Comparison ND=Not detected at the reporting limit 309 of 334 ---PAGE BREAK--- 8 Figure 1. Observed (2020) and median (2017-2020) TSS (total suspended solids) concentrations by location. Horizontal red lines represent median concentrations. Figure 2. Observed (2020) and median (2017-2020) COD (chemical oxygen demand) concentrations by location. Horizontal red lines represent median concentrations. 0 50 100 150 200 250 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 TSS (mg/L) LOCATION OBSERVED & MEDIAN TSS 0 50 100 150 200 250 300 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 COD (mg/L) LOCATION OBSERVED & MEDIAN COD 310 of 334 ---PAGE BREAK--- 9 Figure 3. Observed (2020) and median (2017-2020) TP (total phosphorus) concentrations by location. Horizontal red lines represent median concentrations. Y-axis is on a log scale. Figure 4. Observed (2020) and median (2017-2020) TN (total nitrogen) concentrations by location. Horizontal red lines represent median concentrations. 0.01 0.1 1 10 100 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 TP (mg/L) - Log Scale LOCATION OBSERVED & MEDIAN TP 0 0.5 1 1.5 2 2.5 3 3.5 4 4.5 5 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 TN (mg/L) LOCATION OBSSERVED & MEDIAN TN 311 of 334 ---PAGE BREAK--- 10 Figure 5. Observed (2020) and median (2017-2020) pH values by location. Horizontal red lines represent median concentrations. Figure 6. Observed (2020) and median (2017-2020) oil and grease concentrations by location. Horizontal red lines represent median concentrations. 7.6 7.8 8 8.2 8.4 8.6 8.8 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 pH LOCATION OBSERVED & MEDIAN PH 0 1 2 3 4 5 6 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 OIL & GREASE (mg/L) LOCATION OBSERVED & MEDIAN OIL & GREASE 312 of 334 ---PAGE BREAK--- 11 Figure 7. Observed (2020) and median (2017-2020) copper concentrations by location. Horizontal red lines represent median concentrations. Figure 8. Observed (2020) and median (2017-2020) lead concentrations by location. Horizontal red lines represent median concentrations. 0 0.005 0.01 0.015 0.02 0.025 0.03 0.035 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 COPPER (mg/L) LOCATION OBSERVED & MEDIAN COPPER 0 0.001 0.002 0.003 0.004 0.005 0.006 0.007 0.008 0.009 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 LEAD (mg/L) LOCATION OBSERVED & MEDIAN LEAD 313 of 334 ---PAGE BREAK--- 12 Figure 9. Observed (2020) and median (2017-2020) zinc concentrations by location. Horizontal red lines represent median concentrations. Standardized Parameter Concentrations by Location Figures 10-13 compare sample parameters at one site over time. Parameters have been standardized to make the variables comparable. At most locations, many parameters co-vary together. Stormwater sample locations (SWR- 4/001, SWR-7/002, AC-11/004) appear to generally have elevated values in spring and lower values in fall. The parameter values at the in-stream location (AC-A/003), typically, do not fluctuate as much as the stormwater samples. The elevated TSS and oil and grease at SWR-4/001 in April 2018 appear to strongly co-vary, while the elevated TP at AC-11/004 in April 2018 and at SWR-7/002 in May 2020 does not strongly co-vary with any other parameters. Standardized parameters in 2019 did not see as large of fluctuations as 2018. In 2020, fluctuations of the standardized parameters were generally small, however a few parameters were elevated during spring sampling. 0 0.05 0.1 0.15 0.2 0.25 SWR-4 5/12/20 SWR-4 10/12/20 SWR-7 5/12/20 SWR-7 10/12/20 AC-A 5/12/20 AC-A 10/12/20 AC-11 5/12/20 AC-11 10/12/20 ZINC (mg/L) LOCATION OBSERVED & MEDIAN ZINC 314 of 334 ---PAGE BREAK--- 13 Figure 10. Standardized parameter values over time at SWR-4/001. Figure 11. Standardized parameter values over time at SWR-7/002. -2 -1 0 1 2 3 4 5 JUN - 17 N O V- 17 A P R- 18 N OV- 18 A P R- 19 S E P - 19 M A Y - 20 O C T - 20 NORMALIZED PARAMETER VALUES SWR-4 - RESIDENTIAL 30%, COMMERCIAL 70% TSS (mg/L) pH TP (mg/L) COD (mg/L) TN (mg/L) Copper (mg/L) Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) Flow (GPM) -3 -2 -1 0 1 2 3 4 5 JUN - 17 N O V- 17 A P R- 18 N OV- 18 A P R- 19 S E P - 19 M A Y - 20 OC T - 20 NORMALIZED PARAMETER VALUES SWR-7 - COMMERICAL/INDUSTRIAL TSS (mg/L) pH TP (mg/L) COD (mg/L) TN (mg/L) Copper (mg/L) Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) Flow (GPM) 315 of 334 ---PAGE BREAK--- 14 Figure 12. Standardized parameter values over time at AC-A/003 (2017-2018) and AC-A/003A (2019-Present). Figure 13. Standardized parameter values over time at AC-11/004. Discussion: Trends, Outliers, and BMPs The following analysis reviews the 2020 parameter trends and outliers compared to the calculated long-term median and examines results outside a pH range of 6.0 to 9.0 standard -2 -1 0 1 2 3 4 JUN - 17 N O V- 17 A P R- 18 N OV- 18 A P R- 19 S E P - 19 M A Y - 20 OC T - 20 NORMALIZED PARAMETER VALUES AC-A - IN-STREAM TSS (mg/L) pH TP (mg/L) COD (mg/L) TN (mg/L) Copper (mg/L) Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) Flow (GPM) -3 -2 -1 0 1 2 3 JUN - 17 N O V- 17 A P R- 18 N OV- 18 A P R- 19 S E P - 19 M A Y - 20 OC T - 20 NORMALIZED PARAMETER VALUES AC-11 - RESIDENTIAL TSS (mg/L) pH TP (mg/L) COD (mg/L) TN (mg/L) Copper (mg/L) Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) Flow (GPM) 316 of 334 ---PAGE BREAK--- 15 units. Additionally, explained is a schedule and rationale for BMPs planned to improve the water quality of stormwater discharges based on monitoring results. Sampling Conditions Spring samples were collected in May 2020. The winter leading up to this sample collection was mild, which lead to infrequent sanding and salt application. The parameter concentrations in the spring 2020 samples were generally lower than pervious year’s spring samples. Fall samples were collected in October 2020. Prior to sample collection, the summer was dry with very few rain events. The October event began with steady rain during the night which then let up in the morning. Periodic, short rain events continued through midday. Samples were collected near the beginning of the workday once the rain began again. Spring samples generally had higher concentrations of all parameters. This same pattern was observed in the 2017 – 2019 sample results. This may be indicative of winter loading of contaminants. Additional measures to try to reduce spring runoff may be beneficial. Future sampling will help clarify trends and what BMPs will be most beneficial to minimize pollutant discharge. Stillwater River Two locations drain into the Stillwater River, which is listed as impaired for sediment. Location SWR-4/001 is characterized as mixed residential (30%) and commercial (70%) and location SWR- 7/002 is characterized as commercial/industrial. Mixed Residential (30%) and Commercial (70%) Location Sample location SWR-4/001 drains about 266 acres and typically has elevated total suspended solids and chemical oxygen demand in the spring. However, the 2020 samples had lower pollutant concentrations than the notable highs seen in spring 2018. In 2018, due to the elevated TSS and oil and grease, the surrounding storm system was inspected and cleaned. This sample location is from two mechanical treatment units. Both treatment units were cleaned along with upstream manholes and sumps (if needed). A roll of Ram-Nek/manhole mastic was found in a manhole sump upstream and was removed. This could have contributed to higher oil and grease and COD readings in spring 2018. The cleaning schedule of the two treatment units was updated to twice a year in 2018 and the biannual schedule has been maintained. After the wide-scale cleaning in 2018, TSS, oil and grease, and COD levels dropped during the next sampling event and have continued to stay below the spring 2018 levels. Commercial/Industrial Location The drainage area of SWR-7/002 is approximately 100 acres and is comprised mostly of commercial/industrial land use including highway managed by Montana Department of Transportation. At sample location SWR-7/002, from 2018 – 2020, the median of most parameters (excluding TP, TN, lead, and pH) was higher than other locations. Activities 317 of 334 ---PAGE BREAK--- 16 in industrial areas and highways, including material handling and storage, equipment maintenance and cleaning, and others, are often exposed to weather and may introduce pollutants into stormwater. Total suspended solids and chemical oxygen demand readings were elevated, though not as high as SWR-4/001. In spring 2020, TP was notably high. All parameters will be monitored to try and further understand sources. Future sampling may help clarify trends and outliers at this location and what management practices will provide a reduction of the pollutant loads. The City’s Capital Improvement Program has a stormwater quality treatment facility planned for fiscal year 2021 to try to reduce the MS4’s discharge of sediment to the Stillwater River. Samples collected prior to implementation may provide information on BMP effectiveness in a commercial/industrial location and help plan future BMPs in other commercial/industrial areas. Ashley Creek Two locations drain into Ashley Creek, which is listed as impaired for phosphorus, nitrogen, dissolved oxygen, sediment, and temperature. Location AC-A/003A is characterized as being in- stream and outside the MS4 boundary and AC-11/004 is characterized as residential. In-Stream Outside MS4 Boundary Location Sample location AC-A/003A did not have notable trends or outliers in monitoring results compared to the calculated long-term median. The in-stream sample results provide background readings of the pollutants in-stream during comparable rain events. Residential Location The drainage area of AC-11/004 is approximately 300 acres, comprised mostly of residential land use. Sample location AC-11/004 results showed moderate levels of total suspended sediment, chemical oxygen demand, and total phosphorus. In 2018, total phosphorus was significantly elevated in the spring sample but was comparable to other sites in future samples. In 2017 and 2020, total nitrogen was elevated in spring. Future sampling may help clarify trends and outliers at this location and what management practices will provide a reduction of the pollutant loads. The City’s Capital Improvement Program has a stormwater quality treatment facility planned for fiscal year 2023 to try to reduce the MS4’s discharge of pollutants to Ashley Creek. Samples collected prior to implementation may provide information on BMP effectiveness in a residential location and help plan future BMPs in other residential areas. 318 of 334 ---PAGE BREAK--- 17 Identified Pollutants Several pollutants were identified as elevated through this evaluation (TP and oil and grease). As such, this section provides a schedule and rationale of BMPs planned to improve the water quality of the stormwater discharges from various pollutants. Chemical Oxygen Demand (COD) Potential Sources Natural: • Leaves and woody debris • Dead plants and animals • Animal manure Industrial: • Oils and grease from transportation and industrial/commercial site activities • Benzene from gasoline • detergents • Pesticides • Herbicides • Wood preservatives • organic industrial chemicals Residential: • Grass clippings and leaves • Animal waste • Failing septic systems • Sugar-containing substances (milk, molasses, juice, vegetables, energy drinks, etc.) Management Measures and BMPs Table 5 outlines the potential sources, reasons, and management measures the City has or will implement for the MPDES MS4 permit. Dry weather screening will continue to be utilized to aid in identifying sources of chemical oxygen demand. Additionally, two locations have a planned stormwater quality treatment facility in the City’s Capital Improvement Program. Table 5. COD Evaluation Potential Sources Reasons *Minimum Measure BMP Date(s) Implemented Organic material i.e. leaves, grass clippings Fallen Leaves Landscaping Pre-Winter Maintenance 1 Public Education Program 2015-Current 6 Implement Pollution Prevention Good Housekeeping Guidance Manual for Kalispell Municipal Operations. Provide training to City employees. 2015-Current Street Sweeping Program 2015-Current Leaf Collection Program 2015-Current Storm Drainage System Inspection and Cleaning 2015-Current Residential Curbside Pickup Services 2013-Current * Minimum Measures 1) Public education and outreach on stormwater impacts; 2) Public involvement/participation; 3) Illicit discharge detection and elimination; 4) Construction site stormwater runoff control; 5) Post-construction stormwater management in new development and redevelopment; and, 6) Pollution prevention and good housekeeping for municipal operations. 319 of 334 ---PAGE BREAK--- 18 Total Suspended Solids (TSS) Potential Sources Natural: • Erosion Industrial: • Land development • Roadway material deterioration • Road salt and sand • Road paint • Industrial/commercial site activities • Gravel parking areas Residential: • Land development • Road salt and sand • Road paint • Roadway material deterioration Management Measures and BMPs Table 6 outlines the potential sources, reasons, and management measures the City has implemented or will implement for the MPDES MS4 General Permit. Additionally, two locations have a planned stormwater quality treatment facility in the City’s Capital Improvement Program. 320 of 334 ---PAGE BREAK--- 19 Table 6. TSS Evaluation Potential Sources Reasons *Minimum Measure BMP Date(s) Implemented Construction Site Runoff Subdivision Development Residential House Construction Municipal Operations Commercial Development 4 Ordinance 1831: Stormwater Regulations. Requires Construction Stormwater Permits for all land disturbance within City limits. 2015- Current Provide training for builders, engineers, and developers. 2015- Current 1 Public Education Program 2015- Current Public Education Program 2010 Update to include commercial education. 2010- Current 6 Implement Pollution Prevention Good Housekeeping Guidance Manual for Kalispell Municipal Operations. Provide training to City employees. 2015- Current Sand on Roads Winter condition road sanding 6 Implement Pollution Prevention Good Housekeeping Guidance Manual for Kalispell Municipal Operations. Provide training to City employees. 2015- Current Street Sweeping 2015- Current Storm Drainage System Inspection & Cleaning 2015- Current Industrial and Commercial Sites Generation of solid material from industrial and commercial site activities Dirt/gravel driveways and parking areas 1 Public Education Program 2015- Current 3 Illicit Discharge, Detection, and Elimination Program 2015- Current 5 Redevelopment standards implemented through Kalispell Design and Construction Standards 2015- Current Residential Yard Waste Management Native Landscaping Better Car and Equipment Washing 1 Public Education Program 2018- Current 6 Residential Curbside Pickup Services 2013- Current Commercial Landscaping Yard Waste Management 1 Public Education Program 2018- Current * Minimum Measures 1) Public education and outreach on stormwater impacts; 2) Public involvement/participation; 3) Illicit discharge detection and elimination; 4) Construction site stormwater runoff control; 5) Post-construction stormwater management in new development and redevelopment; and, 6) Pollution prevention and good housekeeping for municipal operations. 321 of 334 ---PAGE BREAK--- 20 Oil and Grease Potential Sources Natural:  Petroleum Industrial:  Automotive oils Residential:  Automotive oils  Cooking oils Management Measures and BMPs Table 7 outlines the potential sources, reasons, and management measures the City has implemented or will implement for the MPDES MS General Permit. Additionally, two locations have a planned stormwater quality treatment facility in the City’s Capital Improvement Program. Table 7. Oil and Grease Evaluation Potential Sources Reasons *Minimum Measure BMP Date(s) Implemented Industrial Site Activities Common industrial and commercial site activities 1 Public Education Program 2007-Current Public Education Program 2010 Update to include commercial education 2010-Current 3 Illicit Discharge, Detection, and Elimination Program 2008-Current Restaurants Common restaurant activities 1 Public Education Program 2013-Current Residential Car Maintenance 1 Public Education Program 2018-Current Mobile Cleaning Business Common mobile cleaning activities (i.e. pressure washing) 1 Public Education Program 2018-Current Gas Stations Common gas station activities 1 Public Education Program 2018-Current * Minimum Measures 1) Public education and outreach on stormwater impacts; 2) Public involvement/participation; 3) Illicit discharge detection and elimination; 4) Construction site stormwater runoff control; 5) Post-construction stormwater management in new development and redevelopment; and, 6) Pollution prevention and good housekeeping for municipal operations. 322 of 334 ---PAGE BREAK--- 21 Total Phosphorous Potential Sources Natural:  Soil and rocks  Plant and leaf litter Industrial:  Fertilizers  Wastewater Treatment Plant discharges  Livestock and farm animals  Commercial cleaning preparations  Road salt Residential:  Fertilizers  Failing septic systems  Pet waste  Disturbed land areas  Road salt  Plant and leaf litter Management Measures and BMPs Table 8 outlines the potential sources, reasons, and management measures the City has implemented or will implement for the MPDES MS General Permit. Additionally, two locations have a planned stormwater quality treatment facility in the City’s Capital Improvement Program. Table 8. Total Phosphorous Evaluation Potential Sources Reasons *Minimum Measure BMP Date(s) Implemented Fertilizer Fall fertilizing of residential yards and commercial landscape area Fertilization storage, handling, and application 1 Public Education Program 2007-Current Organic material i.e. leaves, grass clippings Fallen leaves Landscaping Pre-Winter Maintenance Yard Waste Management 6 Street Sweeping Program 2011-Current Leaf Collection Program 2011-Current Storm Drainage System Inspection and Cleaning 2012-Current Review and update City Operational and Maintenance Activities as necessary. Provide training to City employees. 2007-Current Residential Curbside Pickup Services 2013-Current Litter and animal waste Pet waste 1 Public Education Program 2007-Current * Minimum Measures 1) Public education and outreach on stormwater impacts; 2) Public involvement/participation; 3) Illicit discharge detection and elimination; 4) Construction site stormwater runoff control; 5) Post-construction stormwater management in new development and redevelopment; and, 6) Pollution prevention and good housekeeping for municipal operations. 323 of 334 ---PAGE BREAK--- 22 TMDL-Related Monitoring: Results and Discussion Results Stillwater River SWR-7/001 and 001a At SWR-7/001 and 001a, the objective is to compare influent and effluent data for the Defender® hydrodynamic separator (installed August 2016). These sites ultimately drain to the Stillwater River, which is listed as impaired for sediment. Therefore, TSS is the pollutant of focus for TMDL-related monitoring. Sample sites are immediately upstream (001a) and (001) of the hydrodynamic separator in order to evaluate its effectiveness at removing sediment from MS4 wet weather discharges. BMP effectiveness was quantified by calculating percent change in pollutant concentration between influent (pre-treatment) and effluent (post-treatment). Figure 14 displays percent change from grab samples on each sample date. Only two rain events (11/17/19, 10/12/20) have had a positive percent change where effluent had lower TSS than influent. All other samples had greater TSS post-treatment than pre-treatment. Figure 14. Percent change in TSS concentration between influent and effluent Figure 15 displays the same sampling dates but visually depicts actual TSS concentrations pre- treatment (SWR-4/001a) and post-treatment (SWR-4/001). Many of the samples collected on the same data had similar TSS concentrations. -37 -18 -35 -9 -26 -6 -2 85 -14 -35 2 -9 -45 -25 -5 15 35 55 75 95 Percent Change 324 of 334 ---PAGE BREAK--- 23 When looking at sample date 11/17/19 in both Figures 14 and 15, there was an 85% reduction in TSS post-treatment however, while the percent change was large the actual TSS concentrations were quite low compared to other sample dates. Figure 15. TSS concentration pre-treatment (SWR-4/001a) and post-treatment (SWR-4/001) Figure 16 shows generally small increases in TSS concentrations post-treatment for most rain events. The data points are mostly above the solid line which shows that the effluent concentrations are greater than the influent concentrations. If the data was plotted along the line (1 to this would indicate no difference between influent and effluent TSS concentrations. 0 200 400 [PHONE REDACTED] 1200 1400 1600 1800 2000 TSS (mg/L) SWR-4/001 SWR-4/001a 325 of 334 ---PAGE BREAK--- 24 Figure 16. Scatterplot of observed influent and effluent TSS concentrations (log transformed) SWR-4/002 SWR-4/002 also drains to the Stillwater River (impaired for sediment) and therefore, TSS is the pollutant of focus for TMDL-related monitoring. The City plans to install future BMPs within this mostly commercial/industrial drainage area to reduce the MS4’s discharge of sediment to the Stillwater River. Monitoring results from samples collected before the BMPs are implemented within the drainage area (baseline samples) are to establish existing conditions. Future monitoring results will be compared to the baseline samples as BMP(s) are added within the drainage basin. Figure 17 shows baseline TSS concentration at SWR-4/002. 0 1 2 3 4 5 6 7 8 0 1 2 3 4 5 6 7 8 Log Effluent TSS (mg/L) Log Influent TSS (mg/L) 326 of 334 ---PAGE BREAK--- 25 Figure 17. TSS concentration at SWR-7/002 over time Ashley Creek AC-11/004 AC-11/004 drains to Ashley Creek which is impaired for phosphorus, nitrogen, dissolved oxygen, sediment, and temperature. The City plans to install future BMPs within this mostly residential drainage area to reduce the MS4’s discharge of pollutants to Ashley Creek. Monitoring results from samples collected before the BMPs are implemented within the drainage area (baseline samples) are to establish existing conditions. Future monitoring results will be compared to the baseline samples as BMP(s) are added within the drainage basin. Figures 18 - 22 show baseline TSS, TP, TN, DO, and temperature readings respectively at AC- 11/004. 0 100 200 300 400 500 600 700 TSS (mg/L) SWR-7/002 - TSS 327 of 334 ---PAGE BREAK--- 26 Figure 18. TSS concentration at AC-11/004 over time Figure 19. TP concentration at AC-11/004 over time 0 50 100 150 200 250 300 350 TSS (mg/L) AC-11/004 - TSS 0 1 2 3 4 5 6 7 8 TP (mg/L) AC-11/004 - TP 328 of 334 ---PAGE BREAK--- 27 Figure 20. TN concentration at AC-11/004 over time Figure 21. DO concentration at AC-11/004 over time 0 2 4 6 8 10 12 14 16 18 TN (mg/L) AC-11/004 - TN 0 1 2 3 4 5 6 7 8 9 10 DO (mg/L) AC-11/004 - DO 329 of 334 ---PAGE BREAK--- 28 Figure 22. Temperature concentration at AC-11/004 over time Discussion: Adaptive Management Stillwater River SWR-7/001 and 001a Samples collected before and after treatment at SWR-7 are not consistently showing reduced TSS after treatment. This finding may have to do with several factors. Hydrodynamic separators are typically not best at removing very fine sediments. However, the MS4 Permit requires TSS to be sampled and TSS does not take into account sediment size. For example, we have evidence that the hydrodynamic separators are removing a significant amount of sediment and debris from regular maintenance activities. In 2020, ~44 tons of sediment were removed from the hydrodynamic separators effectively preventing the material from reaching the Stillwater River in this drainage basin alone. Stormwater flows from the hydrodynamic separators into a detention basin. Although the detention basin was not designed for water quality treatment, it may be providing additional water quality benefits. To better understand the impacts of the entire stormwater system, an additional sample location at the end of the detention basin could be considered. SWR-4/002 Further evaluation and discussion will be provided once the City installs additional BMPs within this drainage basin. 0 2 4 6 8 10 12 14 16 18 Temperature AC-11/004 - Temperature 330 of 334 ---PAGE BREAK--- 29 Ashley Creek AC-11/004 Further evaluation and discussion will be provided once the City installs additional BMPs within this drainage basin. 331 of 334 ---PAGE BREAK--- 30 APPENDIX A. Monitoring Parameters The parameters required to be monitored can contribute to stormwater pollution. The following is a description of the potential sources of stormwater runoff contamination. Total Suspended Solids (TSS) TSS is a common stormwater pollutant and can be generated from construction sites, bare spots in lawns and gardens, wastewater from washing/trucks on driveways and parking lots, dirt roads and driveways, and sanding roads during winter conditions. Chemical Oxygen Demand (COD) Organic material such as leaves, grass, oils, grease, and litter become deposited in urban areas and become part of stormwater runoff flows. A COD test can be used to quantify the amount of organics in water. COD is a measure of the capacity of water to consume oxygen during the decomposition of organic matter and the oxidation of inorganic chemicals such as Ammonia and nitrite. High COD concentrations lower dissolved oxygen concentration, progressively deteriorating conditions for fish and other aquatic life. Also, the absence of dissolved oxygen could result in the growth of microorganisms that produce by-products which cause foul odors in the water. Total Phosphorus (TP) Nutrients such as phosphorus are common constituents of nonpoint source runoff. The introduction of nutrients into receiving waters stimulates the growth of algae and other aquatic plants causing algal blooms and creating turbid conditions. Total phosphorus enters runoff from sources such as fertilizers, pesticides, grass clippings/leaves left on streets and sidewalks, detergents and washing fluids, animal waste, and seepage from septic tanks. Automobile lubricant emissions, food products, and various household cleaners, paints, fabrics and carpets contain phosphates which can also be transported by runoff. Total Nitrogen (TN) Plant nutrients, such as nitrogen, are common constituents of nonpoint source runoff. The introduction of nutrients into receiving waters stimulates the growth of algae and other aquatic plants causing algal blooms and creating turbid conditions. Total nitrogen enters runoff from sources such as fertilizers, grass clippings and leaves left on streets and sidewalks, detergents and washing fluids, animal wastes, and seepage from septic tanks. pH Most discharge flow types are neutral, having a pH value around 7, although groundwater concentrations can be somewhat variable. pH is a reasonably good indicator for liquid wastes from industries, which can have very high or low pH (ranging from 3 to 12). The pH of residential wash water tends to be rather basic (pH of 8 or Although pH data is often inconclusive by itself, it can identify problem outfalls that merit follow-up investigations using indicators that are more effective. Heavy Metals: Total Copper (Cu), Lead (Pb), Zinc (Zn) Metal pollutants can be generated from the operation and maintenance of motor vehicles, the degradation of highway material, and industrial/commercial site activities. Heavy metals in 332 of 334 ---PAGE BREAK--- 31 water can cause bioaccumulation in animal tissues, affect reproduction rates and life spans of aquatic species, and ultimately affect recreational and commercial fisheries. Transportation- related sources of Zn include diesel fuel, crankcase and lubrication oils, grease, and decorative and protective coatings. Copper in stormwater runoff can be generated from wear on brake pads, roofing and gutter runoff, and copper-based fungicides/fertilizers used for controlling algae, fungi, and mildew. Metal finishers, electroplaters, and semiconductor manufacturers may use copper-containing materials in their manufacturing processes. Vehicle services (engine repair and service, fueling, vehicle body repair, replacement of fluids, recycling, cleaning, and outdoor equipment storage and parking through dripping engines) can generate toxic hydrocarbons and other organic compounds, oils and greases, nutrients, phosphates, heavy metals, paints and other contaminants. Radiator repair and flushing operations are the most likely source of copper- containing waste streams. The principal source of lead in highway and street stormwater runoff as well as soils in urban areas and near highways during the time of the NURP studies i.e., about 1980, was the use of lead as an additive in gasoline. Other sources of lead in stormwater runoff include yellow and white road marking paints used on parking lots, streets, buildings, building cavity dust and other demolition waste from buildings and structures, and vehicular sources including leaded petrol (auto exhaust), auto paint (which can still contain 10% lead), lead-acid batteries, lubricating oil and grease, and bearing wear. Oil and Grease (O&G) Oil and grease pollutants can be generated from leaks and spills of oil and gas, used oil dumping, and commercial and industrial activities. These organic pollutants cannot be easily decomposed through biological action and may persist for long periods. 333 of 334 ---PAGE BREAK--- 32 APPENDIX B. Correlation Matrix Figure B1. Correlation matrix of water quality variables. Correlations are represented on the lower left, histograms on the diagonal, and x-y plots on the upper right. For normality, variables have been log transformed. TSS = total suspended solids, COD = chemical oxygen demand, TP = total phosphorus, TN = total nitrogen, Cu = total copper, Pb = total lead, Zn = total zinc, OG = oil and grease 334 of 334