H. Public Hearing - MS4 Sampling Plan_W10ft1**
CITY OF City of Kalispell
ALISPELL post Office Box 1997 -Kalispell, Montana 59903
Telephone: (406) 758-7701 Fax: (406) 758-7758
MEMORANDUM
To: Doug Russell, City Manager
From: Susie Turner, P.E., Public Works Director
Meeting Date: February 3, 2020
Re: 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.
Self -monitoring data is compiled and evaluated each year in a report and sent to DEQ with the
required Annual Report. The 2019 monitoring results are attached. TMDL monitoring data will be
included with the 4t' Annual Report in a requited TMDL section.
As part of the consideration for the "MS4 Sampling Plan for TMDL-Related Monitoring", a public
hearing was set to encourage public interaction and receive comments. The Plan was advertised
via local newspaper, social media, and on the City website. Thus far, the City has not received
any comments.
ATTACHMENTS:
MS4 Sampling Plan for TMDL-Related Monitoring
2019 Monitoring Results
A?UNTAN: 1
Ih
Prepared by
MS4 Sampling Plan
for TMDL-Related
Monitoring
City of Kalispell, Montana
Storm Water Management Program
January 9, 2018
This page intentionally left blank
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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MPDES Permit # MTR04005
Evaluation of Stormwater Quality Monitoring 2019 Sample Results
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 IV of the MS4 General Permit
requires semi-annual monitoring (self -monitoring).
The City has selected self -monitoring Option 2 (see Part IV of the MS4 General Permit).
Stormwater grab samples were collected semi-annually from four stormwater discharge
locations within the City of Kalispell. Four discharge sample locations were chosen to represent
stormwater runoff (1) from a primarily commercial/industrial area, (1) from a primarily
residential area, (1) from a large drainage area combining both commercial and residential
areas, and (1) upstream, outside the MS4 boundary to evaluate water quality entering the MS4
(Table 1).
Drainage
Name Watershed Receiving Waterbody Location Area
(Acre)
001
SWR-4
Stillwater
48°11'40.14"N
266
Semi-
Total Suspended
p
River
114°17'55.76"W
annual
Solids
■
Chemical Oxygen
Stillwater
48°12'26.98"N
Semi-
Demand
002
SWR-7
River
114°18'49.81"W
100
annual
■
Total Phosphorus
■
Total Nitrogen
■
pH
003A
AC -A
Ashley
48°11'43.49"N
NA
Semi-
Copper
pp
Creek
114°22'23.71"W
annual
0
Lead
■
Zinc
Ashley
48°11'10.01"N
Semi-
Estimated Flow
004
AC-11
Creek
114°19'17.46"W
294
annual
■
Oil and Grease
Methods
Sample Collection
Grab samples were collected once in the spring (4/9/19) and once in the fall (9/9/19) of 2019.
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. Table 2 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.
Sample Analysis
Due to new sample locations being designated in 2017, statistical analyses are not appropriate
because of the low number of samples. The City of Kalispell is required to calculate the long-
term median concentration of all known monitoring results at an individual location of each
parameter in Table 1 Par N.A. of the MS4 General Permit issued by MDEQ.
To compare individual parameters across locations, bar charts were created to visually
represent observed sample values of 2019 in comparison 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 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.
2
Table 2. Parameters and standard analytical methods
Total Suspended
SM 2450 D•
va
Solids
Total Phosphorus
E365.1
0.01
Nitrogen — Kjeldahl,
i
total
E351.2
0.2
Nitrate & Nitrite,
E353.2
totals
E300A
0.01
Chemical Oxygen
E410.1
1
Demand
E410.4
Total Recoverable
E200.8
0.01
Copper
Total Recoverable
E200.8
0.001
Lead
Total Recoverable
E200.7
0.01
Zinc
E200.8
Oil and Grease
E1664A
1
Estimated Flow
NA
NA
Dissolved Oxygen SM 4500-OG 0.1
2 2
1 L plastic None
1 L glass (2) H2SO4 to pH<2
Cool to 4°C
NA NA
NA NA
Temperature NA 0.1°C NA NA
Analyze
immediately2
28
3
Analyze onsite
3
Analyze onsite
3
Analyze onsite
pH E150.1 0.1 unit NA NA Analyze onsite3
'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.
'The City analyzes estimated flow, dissolved oxygen, temperature, and pH, onsite.
3
Results
Sample Comparison and Median Concentration
Table 3 is a summary of the 2019 sample parameter comparisons with 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 (6 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.
Zinc was greater for all stormwater sampling locations collected in the spring (zinc was not
detected at AC-A/003A, the in -stream sample).
Total phosphorus (TP), pH, chemical oxygen demand (COD), total nitrogen (TN), copper, and
lead were greater in the spring for all locations except for AC-A/003A (TP, COD, TN, copper,
lead) and AC-11/004 (pH).
Total suspended solids (TSS) was greater in the spring for all locations except AC-A/003A where
it was equivalent for both sampling events.
Oil and grease values were greater in spring at both locations discharging to the Stillwater River
(SWR-4/001, SWR-7/002), not detected in spring and fall at AC-A/003A, and greater in fall at AC-
11/004.
Flow was greater in fall for all locations.
In the spring, observed parameter values somewhat to notably elevated include TSS, oil/grease,
and COD at SWR-4/001 and TSS and COD at SWR-7/002.
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SWR-4 SWR-4
4/9/19 9/9/19
SWR-7 SWR-7 AC -A AC -A
4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
AC-11 AC-11
4/9/19 9/9/19
Figure 1. Observed (2019) and median (2017-2019) TSS (total suspended solids) concentrations
by location. Horizontal red lines represent median concentrations.
OBSERVED & MEDIAN COD
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9/9/19
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9/9/19 4/9/19 9/9/19 4/9/19
LOCATION
Figure 2. Observed (2019)
and median (2017-2019)
COD (chemical oxygen demand)
concentrations by location. Horizontal red
lines represent median concentrations.
AC-11
9/9/19
11
OBSERVED & MEDIAN TP
0.5
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0.4
0.35
0.3
ono
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0.2
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0
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4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
Figure 3. Observed (2019) and median (2017-2019) TP (total phosphorus) concentrations by
location. Horizontal red lines represent median concentrations.
OBSSERVED & MEDIAN TN
3
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SWR-4 SWR-4 SWR-7 SWR-7 AC -A AC -A AC-11 AC-11
4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
Figure 4. Observed (2019) and median (2017-2019) TN (total nitrogen) concentrations by
location. Horizontal red lines represent median concentrations.
7
9
8.8
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8.2
x
8
a 7.8
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OBSERVED & MEDIAN PH
SWR-4 SWR-4 SWR-7 SWR-7 AC -A AC -A AC-11 AC-11
4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
Figure 5. Observed (2019) and median (2017-2019) pH values by location. Horizontal red lines
represent median concentrations.
OBSERVED & MEDIAN OIL & GREASE
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SWR-7 SWR-7 AC -A AC -A
4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
AC-11 AC-11
4/9/19 9/9/19
Figure 6. Observed (2019) and median (2017-2019) oil and grease concentrations by location.
Horizontal red lines represent median concentrations.
U.,
OBSERVED & MEDIAN COPPER
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4/9/19
9/9/19
4/9/19 9/9/19 4/9/19 9/9/19 4/9/19 9/9/19
LOCATION
Figure 7. Observed (2019) and median (2017-2019) copper concentrations by location.
Horizontal red lines represent median concentrations.
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OBSERVED & MEDIAN LEAD
I
SWR-4
9/9/19
■
■
SWR-7
SWR-7 AC -A
4/9/19
9/9/19 4/9/19
LOCATION
AC -A AC-11 AC-11
9/9/19 4/9/19 9/9/19
Figure 8. Observed (2019) and median (2017-2019) lead concentrations by location. Horizontal
red lines represent median concentrations.
PEI
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OBSERVED & MEDIAN ZINC
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SWR-4 SWR-7 SWR-7
9/9/19 4/9/19 9/9/19
AC -A AC -A
4/9/19 9/9/19
IXGIGYAIIs] ►I
AC-11 AC-11
4/9/19 9/9/19
Figure 9. Observed (2019) and median (2017-2019) 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 have elevated values in spring and lower values in fall.
The parameter values at the in -stream location (AC-A/003), generally, do not fluctuate as much
as the stormwater samples.
The elevated TSS and oil and grease at SWR-4/001 on 4/13/18 appear to strongly co -vary, while
the elevated TP at AC-11/004 on 4/13/18 does not strongly co -vary with any other parameters.
Standardized parameters in 2019 did not see as large of fluctuations as 2018.
10
SWR-4 - RESIDENTIAL 30%, COMMERCIAL 70%
tTSS (mg/L) fpH DTP (mg/L) —M—COD (mg/L) —*—TN (mg/L)
tCopper (mg/L) t Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) t Flow (GPM)
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6/13/2017 11/22/2017 4/13/2018 11/2/2018 4/9/2019 9/9/2019
Figure 10. Standardized parameter values over time at SWR-4/001.
SWR-7 - COMMERICAL/INDUSTRIAL
tTSS (mg/L) f pH —DTP (mg/L) —M—COD (mg/L) —*—TN (mg/L)
Copper (mg/L) Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) Flow (GPM)
4
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6/13/2017 11/22/2017 4/13/2018 11/2/2018 4/9/2019 9/9/2019
Figure 11. Standardized parameter values over time at SWR-7/002.
11
tTSS (mg/L)
Copper (mg/L)
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fpH -*—TP (mg/L) COD (mg/L) —Mt—TN (mg/L)
Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) --*---Flow (GPM)
-2
6/13/2017 11/22/2017 4/13/2018 11/2/2018 4/9/2019 9/9/2019
Figure 12. Standardized parameter values over time at AC-A/003 (2017-2018) and AC-
A/003A (2019).
tTSS (mg/L)
tCopper (mg/L)
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fpH —DTP (mg/L) --*(--COD (mg/L) —Mt—TN (mg/L)
t Lead (mg/L) Zinc (mg/L) Oil & Grease (mg/L) --*---Flow (GPM)
6/13/2017 11/22/2017 4/13/2018 11/2/2018 4/9/2019 9/9/2019
Figure 13. Standardized parameter values over time at AC-11/004.
12
Discussion: Trends, Outliers, and BMPs
The following analysis reviews the 2019 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
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 April 2019. The winter leading up to this sample collection had
numerous snow events, which lead to frequent sanding and salt application.
Fall samples were collected in September 2019. Prior to sample collection, the summer was
generally cool with some small rain showers. The September event began with heavy rainfall in
the very early morning. Samples were collected at the beginning of the workday.
Spring samples generally had higher concentrations of all parameters. This same pattern was
observed in the 2017 and 2018 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
001-SWR-4 is characterized as mixed residential (30%) and commercial (70%) and location 002-
SWR-7 is characterized as commercial/industrial.
Mixed Residential (30%) and Commercial (70%) Location
Sample location 001-SWR-4 drains about 266 acres and had elevated total suspended
solids, oil/grease, and chemical oxygen demand in the spring samples in 2018 and 2019.
However, the 2019 samples all had lower pollutant concentrations per season than
2018.
In 2018, due to the elevated TSS and oil and grease, the surrounding storm system was
inspected and cleaned. This sample location is downstream 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 been contributing 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 due to the amount of debris found when they were cleaned,
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
At sample location 002-SWR-7, the median of every parameter, except TP and TN, was
higher than other locations in both 2018 and 2019. The drainage area of 002-SWR-7 is
approximately 100 acres and is comprised mostly of commercial/industrial land use
13
including highway managed by Montana Department of Transportation. Activities 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 001-SWR-4. 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 2020 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 003A-AC-A is characterized as being in -
stream and outside the MS4 boundary and 004-AC-11 is characterized as residential.
In -Stream Outside MS4 Boundary Location
Sample location 003A-AC-A 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 004-AC-11 is approximately 300 acres, comprised mostly of
residential land use.
Sample location 004-AC-11 results showed moderate levels of total suspended
sediment, chemical oxygen demand, total phosphorus, and total nitrogen. In 2018, total
phosphorus was significantly elevated in the spring sample but was comparable to other
sites in 2019. 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 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.
Identified Pollutants
Several pollutants were identified as elevated through this evaluation. As such, this section
provides a schedule and rationale of BMPs planned to improve the water quality of the
stormwater discharges.
14
Chemical Oxygen Demand (COD)
Potential Sources
Natural:
• Leaves and woody debris
• Dead plants and animals
Industrial:
• Oils and grease from transportation
and industrial/commercial site
activities
• Benzene from gasoline
• Synthetic detergents
Residential:
• Grass clippings and leaves
• Animal waste
• Failing septic systems
• Animal manure
• Pesticides
• Herbicides
• Wood preservatives
• Synthetic organic industrial
chemicals
• Sugar -containing substances (milk,
molasses, juice, vegetables, energy
drinks, etc.)
Management Measures and BMPs
Table 4 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 4. COD Evaluation
1 Public Education Program
2015-Current
Implement Pollution Prevention
Good Housekeeping Guidance
Manual for Kalispell Municipal
Operations.
2015-Current
Fallen Leaves
Provide training to City
Organic material Landscaping employees.
i.e. leaves, grass
clippings Pre -Winter 6 Street Sweeping Program
2015-Current
Maintenance
Leaf Collection Program
2015-Current
Storm Drainage System
2015-Current
Inspection and Cleaning
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.
15
Total Suspended Solids (TSS)
Potential Sources
Natural:
• Erosion
Industrial:
• Land development
• Roadway material deterioration
• Road salt and sand
Residential:
• Land development
• Road salt and sand
• Road paint
• Industrial/commercial site activities
• Gravel parking areas
• Road paint
• Roadway material deterioration
Management Measures and BMPs
Table 5 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.
16
Table 5. TSS Evaluation
Irlimimurn
x.
Potential Sources
Reasons
Measure
BMP
Implemented
Ordinance 1831: Stormwater
Regulations. Requires Construction
2015-
Stormwater Permits for all land
Current
4
disturbance within City limits.
Subdivision Development
Provide training for builders,
2015-
engineers, and developers.
Current
Residential House
2015-
Construction
Public Education Program
Current
Construction
Site Runoff
Municipal Operations
1
Public Education Program 2010
g
2010-
Update to include commercial
Commercial
education.
Current
Implement Pollution Prevention
Development
Good Housekeeping Guidance
6
Manual for Kalispell Municipal
Current
Operations.
Provide training to City employees.
Implement Pollution Prevention
Good Housekeeping Guidance
Manual for Kalispell Municipal
Current
Operations.
Sand on Roads
Winter condition road
6
Provide training to City employees.
sanding
Street Sweeping
2015-
Current
Storm Drainage System Inspection &
2015-
Cleaning
Current
Generation of solid 1
Public Education Program
2015-
material from industrial
Current
Industrial and and commercial site
Illicit Discharge, Detection, and
2015-
Commercial activities 3
Elimination Program
Current
Sites
Dirt/gravel driveways
Redevelopment standards
2015-
5
implemented through Kalispell
and parking areas
Design and Construction Standards
Current
Yard Waste Management 1
Public Education Program
2018-
Current
Residential Native Landscaping
Better Car and Equipment 6
Residential Curbside Pickup Services
p
2013-
Current
Washing
Commercial Yard Waste Management 1
Public Education Program
Landscaping
Current
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.
17
Oil and Grease
Potential Sources
Natural:
■ Petroleum
Industrial:
■ Automotive oils
Residential:
■ Automotive oils
■ Cooking oils
Management Measures and BMPs
Table 6 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 6. Oil and Grease
Evaluation
*Mi..
•.
Measure Implemented
Public Education Program 2007-Current
1 Public Education Program
Industrial Site
Common industrial and
2010 Update to include 2010-Current
Activities
commercial site activities
commercial education
Illicit Discharge, Detection,
3 2008-Current
and Elimination Program
Restaurants
Common restaurant activities
1 Public Education Program 2013-Current
Residential
Car Maintenance
1 Public Education Program 2018-Current
Mobile Cleaning
Common mobile cleaning
Business
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.
18
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 9). 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
19
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.
c
APPENDIX B. Correlation Matrix
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0
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o QS O o O O O O
CD
0
co ti ti o
co O o o O O O o 4
O
oot, 0 s 1, 00'0 00'o 0000s o
Figure 131. Correlation matrix of water quality variables. Correlations (r) are represented on the
lower left, histograms on the diagonal, and x-y plots on the upper right. 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
21