H3. Resolution 5961, ROI for Stormwater Sampling Plan Public HearingKALISPELL
MEMORANDUM
City of Kalispell
Post Office Box 1997 - Kalispell, Montana 59903
Telephone: (406) 758-7701 Fax: (406) 758-7758
To: Doug Russell, City Manager
From: Susie Turner, P.E., Public Works Director
Meeting Date: January 21, 2020
Re: Resolution of Intent for Public Hearing for the "MS4 Sampling Plan for
TMDL-Related Monitoring"
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 (DEQ), 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. 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 MS4 General Permit required the sampling be submitted
to DEQ for approval with the first annual Report. Further, after the sampling plan is approved by
DEQ, the Permittee must provide a mechanism for public review.
In 2017, the City, in conjunction with HDR, developed the "MS4 Sampling Plan for TMDL-
Related Monitoring" to comply with the MS4 General Permit requirements. The plan was submitted
to DEQ for review with the City's 2017 MS4 Annual Report. On December 31, 2019, the City
received notification of approval from DEQ on Kalispell's Sampling Plan and DEQ requested the
City make the plan available to the public for review.
Notification and public hearing processes will begin with the passage of the proposed resolution
that establishes a date for the public hearing.
RECOMMENDATION: It is recommended that Council approve resolution 5961, a resolution
calling for a public hearing on February 3, 2020 for the "MS4 Sampling Plan for TMDL-Related
Monitoring".
ALTERNATIVES: Council can elect to not pass the resolution of intent or propose
modifications as Council may desire.
ATTACHMENTS: Resolution 5961
MS4 Sampling Plan for TMDL-Related Monitoring
RESOLUTION NO. 5961
A RESOLUTION OF INTENT TO PROVIDE FOR PUBLIC REVIEW OF THE MS4
SAMPLING PLAN FOR TMDL-RELATED MONITORING IN ORDER TO COMPLY
WITH THE MS4 GENERAL PERMIT REQUIREMENTS PURSUANT TO FEDERAL AND
STATE LEGAL REQUIREMENTS, SETTING A PUBLIC HEARING AND DIRECTING
THE CITY CLERK TO PROVIDE NOTICE THEREOF.
WHEREAS, based upon its population, the City of Kalispell is required to comply with MCA §
75-5-101 et seq. and ARM §§ 17.30.1101; 17.30.1301 et seq. and 17.30.1401 et seq.
for Storm Water Discharge Associated with Small Municipal Separate Storm Sewer
System (commonly referred to as "MS4 permitting"); and
WHEREAS, in 2017, the City, in conjunction with HDR Engineering, developed the "MS4
Sampling Plan for TMDL-Related Monitoring" to comply with the MS4 General Permit
requirements and submitted to DEQ for review with the City's 2017 MS4 Annual Report;
and
WHEREAS, on December 31, 2019, the City received notification of approval from DEQ on
Kalispell's Sampling Plan and the City is now required to make the plan available to the
public for review in order to provide input on the plan after giving due and proper
notice of said hearing.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF
KALISPELL, AS FOLLOWS:
SECTION 1. That there is hereby set a Public Hearing on the 3rd day of February, 2020, at
7:00 o'clock p.m. in the Council Chambers, City Hall, Kalispell, Montana, to
receive public comment on the City of Kalispell's Sampling Plan as required
by Federal and State law.
SECTION 2. The City Clerk is hereby authorized and directed to make, publish and
distribute notices of said Public Hearing in conformity with State law. The
City Clerk shall further make the Sampling Plan, attached hereto, available to
the public upon the Kalispell City Website and in paper format upon request.
PASSED AND APPROVED BY THE CITY COUNCIL AND SIGNED BY THE MAYOR OF THE
CITY OF KALISPELL, ON THE 21 ST DAY OF JANUARY, 2020.
Mark Johnson
Mayor
ATTEST:
Aimee Brunckhorst, CMC
City Clerk
A?UNTAN: 1
Ih
Prepared by
MS4 Sampling Plan
for TMDL-Related
Monitoring
City of Kalispell, Montana
Storm Water Management Program
January 9, 2018
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City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
Table of Contents
1 Introduction.....................................................................................................................................1
1.1. Background.............................................................................................................................1
1.2. Purpose...................................................................................................................................1
2 Kalispell MS4-Related TMDLs.......................................................................................................1
2.1. TMDL Overview......................................................................................................................1
2.2. TMDL Strategy........................................................................................................................2
3 Monitoring Locations and Strategies..............................................................................................2
3.1. Sites 001 and 001 a: 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 Control..........................................................................................9
4.6. Analysis of Results................................................................................................................9
5 Reporting........................................................................................................................................9
Figure 1. Monitoring Sites 001 and 001a
Figure 2. Monitoring Site 002..................
Figure 3. Monitoring Site 004..................
Figures
Tables
Table 1. Summary of TMDLs with Kalispell MS4 Approved WLAs
Table 2. TMDL-Related Monitoring Sample Locations ...................
Table 3. Self -Monitoring Sample Locations ....................................
Table 4. Analytical Methods............................................................
Appendices
Appendix A —Supplemental Figures
3
4
5
2
5
6
8
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
1 Introduction
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 TMDLs. 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 111.13 of the MS4
General Permit, requiring a sampling plan for TMDL-Related Monitoring.
2 Kalispell MS4-Related TMDLs
M . 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
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
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 TMDLs 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 TMDLs with Kalispell MS4 Approved WLAs
Waterbody
Whitefish River X
Stillwater River X _
Spring Creek X X X
Ashley Creek' X X X X
TN is a surrogate TMDL for Nitrate+Nitrite
' 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 TMDLs. 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 (i.e., 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 001 a: Hydrodynamic Separator Effectiveness
Evaluation
The City installed a Downstream Defender® hydrodynamic separator in August 2016 near the
intersection of Sylvan Drive and Sylvan Court (see Figure 1). This area drains to the Stillwater River,
which has an MS4 WLA for sediment. The City will conduct monitoring immediately upstream and
downstream 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 N.A. in the MS4 General
Permit.
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
The results of this evaluation will be used to assist the City in making informed decisions about
whether to install a Downstream Defender° hydrodynamic separator, or equivalent device, in other
locations.
� LLV LIY V//
l
i
Figure 1. Monitoring Sites 001 and 001a
�.�. 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 2). 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.
January 9, 2018 3
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
LEGEND
Monitoring Location
Receiving Waterbody
Figure 2. Monitoring Site 002
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 11t" Street West (see Figure 3). 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.
January 9, 2018 4
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
a
L
O Storm Manhole
• Monitoring Location
Storm Main
------- Open Channel or Ditch
Receiving Waterbody
Figure 3. Monitoring Site 004
Table 2. TMDL-Related Monitoring Sample Locations
001 SWR-4 Stillwater
48°11'40.14"N Grab 4 Sediment
River
114°17'55.76"W
Stillwater
48°11'40.70"N
001a SWR-4
River
Grab 4 Sediment
114°17'57.38"W
002 SWR-7 Stillwater
48°12'26.98"N Grab' 4 Sediment
River
114'18'49.81"W
004 AC-11 Ashley 48'11'10.01"N Grab' 4 TP, TN, DO, Sediment,
Creek 114°19'17.46"W Temperature
' 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.
January 9, 2018 5
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
Table 3. Self -Monitoring Sample Locations
Name Watershed Receiving Locatio
Waterbody
Stillwater
48°11'40.14"N
001 SWR-4
River
114°17'55.76"W
00 SWR-7
Stillwater
48°12'26.98"N
River
114'18'49.81"W
003-A AC -A Ashley 48°11'43.49"N
Creek 114°22'23.71 "W
004 AC-11 Ashley 48'11'10.01"N
Creek 114°19'17.46"W
Grab Semi-annual'
■ Total Suspended Solids
■ Chemical Oxygen Demand
Grab Semi-annual' - Total Phosphorus
■ Total Nitrogen
■ pH
■ Copper
Grab Semi-annual' - Lead
■ Zinc
■ Estimated Flow
■ Oil and Grease
Grab Semi-annual'
' One sample must be collected between January 1It and June 30th of each permitted calendar year and the other
sample between July 15t and December 315c
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, 001 a, and 003' throughout the
duration of this plan. The grab sample method is suitable for site's 001 and 001 a 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 Downstream 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,
' 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
https://radar.weather.gov/ridge/radar.php?rid=msx&product=NOR&overlav=l 1101111 &loop=no
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
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 downstream -most 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.
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.
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.
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
Table 4. Analytical Methods
Total Suspended
SM 2540 D
1
Solids
Total Phosphorus
E365.1
0.01
Nitrogen — Kjeldahl,
E351.2
0.2
total'
Nitrate & Nitrite,
E353.2
0.01
total'
E300A
1 L plastic3
None
Chemical Oxygen
E410.1
1
Demand
E410.4
Total Recoverable
E200.8
0.01
Copper2
Total Recoverable
E200.8
0.001
Lead2
Total Recoverable
E200.7
0.01
Zinc2
E200.8
Oil and Grease2
E1664A
1
1 L glass (2)
H2SO4 to pH<2
Cool to 4°C
Estimated Flow2
N/A
N/A
N/A
N/A
Dissolved Oxygen
SM 4500-OG
0.1
N/A
N/A
Temperature
N/A
0.1°C
N/A
N/A
Analyze
immediately3
28
Analyze
onsite4
Analyze
onsite4
Analyze
onsite4
PH E150.1 0.1 unit N/A N/A Analyze
onsite
' 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 1 L 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 1 st and June 30th and a minimum of one sample will
be collected at each site between July 1 st and December 31 st of each year. The City will attempt to
January 9, 2018 8
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
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 gauge s4, 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.
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 001 a is to compare influent and effluent data for the
Downstream 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.
mim
Percent Change= C'cce *100 Equation 1
C; = 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/cqi-bin/droman/precip monitor.cgi?state=MSO&rawsflaq=3
January 9, 2018
City of Kalispell I Storm Water Management Program
MS4 Sampling Plan for TMDL-Related Monitoring
Appendix A. Supplemental Figures
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