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03-22-21 Work Session Agenda and MaterialsCITY COUNCIL KCITY OF WORK SESSION AGENDA ALISPELL March 22, 2021, at 7:00 p.m. This meeting will occur with Council and staff present in Council Chambers with social distancing in place, as well as via video conferencing. The public can participate via videoconferencing. Register to join the video conference at: https://us02web.zoom.us/webinar/register/" sHI3RcoCTOKPj4yzmTMQEg. Public comment can also be provided via email to publiccomment2kalispell.com. A. CALL TO ORDER B. DISCUSSION ITEMS Wastewater Treatment Plant Fermenter Phase 2 Condition Assessment 2. Stormwater Total Maximum Daily Load (TMDL) Action Plan C. PUBLIC COMMENT Persons wishing to address the council are asked to provide public comment via email to publiccomment(cr�,kalispell. com or verbally during the online meeting. Register to join the meeting at: https://us02web.zoom.us/webinar/register/WN sHI3RcoCTOKPj4yzmTMQEg. D. CITY MANAGER, COUNCIL, AND MAYOR REPORTS E. ADJOURNMENT UPCOMING SCHEDULE / FOR YOUR INFORMATION Next Regular Meeting — April 5, 2021, at 7:00 p.m. — Council Chambers Next Work Session — April 12, 2021, at 7:00 p.m. — Council Chambers Watch City Council sessions live on Charter Cable Channel 190 or online at the Meetings on Demand tab at www.kalispell.com. Page 1 of 1 CITY OF k1l 111110146 KALISPELL To: Doug Russell, City Manager From: Susie Turner, P.E., Public Works Director 201 ]"Avenue East, P.O. Box 1997, Kalispell, MT 59903-Phone (406) 758- 7720 www.kalispell.com Re: Wastewater Treatment Plant Fermenter — Phase 2 Condition Assessment Meeting Date: March 22, 2021 Enclosures: Technical Memorandum — Fermenter Conditions Assessment The existing fermenter tank was constructed during the 2007-2009 Phase 1 WWTP Improvements Project. The primary purpose of a fermenter is to produce supernatant (liquid by-product) which contains volatile fatty acids (VFAs) utilized in the treatment process to facilitate phosphorous removal. The fermentation system is a critical component of the treatment process and necessary to achieve low effluent phosphorus concentrations. In July 2020, a condition assessment was performed to ascertain the condition of the structural and mechanical components of the fermenter after over a decade of continuous operation. The condition assessment evaluated the fermenter concrete, concrete coatings, piping, hardware, equipment, launder, ventilation system, and access points. The initial assessment yielded some insight into the condition of structure and equipment. Unfortunately, areas of contaminated concrete were discovered as well as section loss of interior steel components. These identified areas of concern, i.e., internal concrete and steel components, require additional in-depth evaluation. The recommended Phase 2 Assessment will include a deeper look in the concrete and steel components, as outlined in the bullets below. The second assessment will provide a better understanding of the condition of the deteriorated components of the fermenter and aid in the development of the rehabilitation strategy. • Concrete: Inspect, analyze, and evaluate the structural integrity of the contaminated concrete in the fermenter including the walls, floor, and launder. Steel: Inspect, analyze, and evaluate the status of existing metal structure and metal protective coating in the fermenter. Perform thickness readings on metal components to determine extent of section loss. The objective of this work session is to inform City Council of the condition of the fermenter, the Phase 2 Assessment strategies, and the estimated future rehabilitation timelines. Technical Memorandum Date: Friday, November 13, 2020 Project: Fermenter Condition Assessment To: Susie Turner, City of Kalispell Public Works Director Aaron Losing, City of Kalispell WWTP Manager From: Gregory Mieczkowski NACE Level III #9254 Lizzy English Muir NACE Level 1 #78618 Subject: Fermenter Condition Assessment 1. Introduction HDR Engineering, Inc. (HDR) performed a site visit to the Kalispell Advanced Wastewater Treatment Plant (AWWTP) on July 27, 2020 to perform a condition assessment on the Primary Sludge Fermenter. The fermenter was constructed during the 2007 Phase 1 project and the one year warranty inspection revealed that the coatings on the concrete were delaminating. The coatings were removed and completely re -applied after the one year warranty inspection. The fermenter was emptied and cleaned by the City prior to the July 271" site visit to provide HDR with a clean environment in which to inspect and observe the condition. The condition assessment evaluated the fermenter in its entirety, including the concrete, concrete coatings, piping, hardware, equipment, launder, ventilation system, and access points. 2. Record Review Kalispell Advanced Wastewater Treatment Plant Phase 1 Expansion Contract Documents HDR teamed with Morrison Maierle on the design and construction administration for the Kalispell AWWTP Phase 1 Expansion project. The applicable contract documents (As -built drawings and construction photos) were studied prior to the infield assessment to strategize the assessment methodology and to understand the products and materials to expect. 3. Test Methods The test methods described below were used during the condition assessment. Visual and Photographic Inspection Inspections and testing were performed on foot from inside the structure. Confined space entry support was provided by City of Kalispell AWWTP staff, while the HDR Coatings Specialist performed a dry footed inspection on top of the cover and inside the Fermenter basin. The camera used for documentation was equipped with a flash and a neck strap for secure handling. Documentation of the visual observations were also collected with a cellular phone camera. 1 HDR's Coatings Specialist performed the inspection in a systematic and organized manner to provide a comprehensive evaluation of the structure. HDR staff started with the exterior of the basin, then moved to the aluminum stairway and cover, and finally into the fermenter working downwards in elevation. Concrete Soundinq with Hammer Sounding with a hammer is a non-destructive way to evaluate the condition of the concrete. Good concrete makes a ringing sound when struck with a hammer and degraded cracking concrete produces a hollow drum -like sound. 4. Findings On the exterior of the Fermenter the aluminum components were in satisfactory condition. The coating systems and the steel and concrete substrate were found to be in unsatisfactory condition and the coatings performance did not meet the requirements described in the contract documents. Observations verified that the coating systems were not applied or cured in accordance with the specification and the material manufacturer's recommendations. Additionally, the substrate preparation was insufficient leading to delamination of the protective coatings. Overall Condition The visual inspection did discover significant defects, evidence of poor workmanship, and product performance deficiencies. Areas of generalized rusting and pitting on the steel structural support beams were discovered during inspection. Additionally, there was significant deterioration on the concrete inside the basin including concrete spalling due to corroding steel reinforcement. The condition of the individual fermenter components are discussed in the following sections in more detail. 4.1.1 Aluminum Cover and Stairway The aluminum cover on the fermenter (Figure 1) was found to be in good condition. The aluminum stairway (Figure 2) and aluminum handrail was also found to be in good condition. The treads on the stairs are aluminum with non -slip coatings on the top edges. The stair treads are fastened down with stainless steel clips, however the lock nuts in random locations are rusting, including the bolts which are anchored to the galvanized supports. The stairway supports are anchored well to the sidewall of the unit with stainless steel bolts and nuts. An aluminum stairway support angle at the top of the stairs was observed to be corroding (Figure 3). E M Figure 1. Aluminum Cover in Good Condition t � Figure 2. Aluminum Stairway in Good Condition 3 M O, Figure 3. Corroding Stairway Support 4.1.2 Anchor Points and Fasteners The anchor points and fasteners on the aluminum cover were found to be in good condition. 4.1.3 Aluminum Cover Hatches The nine aluminum cover square launder hatches were found to be in good condition. The two aluminum cover flush hatches were found to be in good condition. The aluminum cover supernatant hatch was also found to be in good condition. 4.1.4 Air Intake and Exhaust The 12-inch gravity air intake on the northwest side of the fermenter and the exhaust duct on the southeast side of the fermenter were found to be in good condition. 4.1.5 Drive Mechanism, Drive Assembly, and Associated Piping The fermenter mechanism appeared to be in good condition aside from some delamination in the blue coatings. This should be recoated during any potential fermenter rehabilitation project. The insulation for the 3-EW piping has begun separating and exposing the piping, fittings, and the flanges bolts. The condition of the 3-EW and 4-EW piping is unknown until the insulation is replaced. New insulation should to be rewrapped and banded. 0 4.1.6 Exterior Tank Wall Crazed cracking was observed on the coatings of the exterior concrete tank wall (Figure 4). Adhesion testing was performed on the wall in accordance with ASTM 6677, and the results of the test indicated the adhesion of the coatings were very weak. Figure 4. Crazed Cracking on Exterior Concrete Wall 4.1.7 Scum Box Hatch The diamond plate hatches over the FRP grating were observed to be in good condition. 4.1.8 Scum Wet Well The scum wet well was found to be in good condition overall. The top landing double leaf aluminum hatch was opened by City staff to observe the interior of the wet well (Figure 5). The scum wet well appears to be coated from the bottom of the inlet piping all the way down to the bottom of the wet well. The transducer is non-functional and the City does not wish to replace it. A U. t N .111 MM Figure 5. Scum Wet Well in Good Condition The pipe inside the scum wet well is the overflow pipe according to information provided by the City. The 6-inch or 8-inch pipe on the south elevation of the scum pit is the pipe associated with the scum beach. The coating appears to be a Polybrid 705 and it is beginning to delaminate at the wall/hatch interface on the south elevation. Some crazed cracking was evident on the exterior scum walls. 4.1.9 Bridge Beam and Tank Wall Recess, Fasteners General rusting was observed on these bridge beams, especially in the areas where the beams are recessed and mounted into the tank wall. However, the extent of corrosion will not be definitively determined until the components are abrasively blasted. The aluminum cover will likely need to be removed to perform proper and thorough blasting. Photos of the rusting can be seen in Figure 6 and Figure 7. 0 FN Figure 6. Bridge Beam With General Rusting p" is Figure 7. Bridge Beam Rusting At Edges T .00 7 4.1.10 Launder The coating in the launder has large blisters that have cracked and the coating has started to peel in various locations. Two pieces of the existing coating in the launder have been archived for further examination of dry film thickness. There are several locations on the 5`6" launder wall that are showing H2S corrosion on the concrete, thereby exposing aggregate. A photo of the exposed aggregate beneath delaminating coatings can be seen in Figure 8. - , r Figure 8. Launder Exposed Aggregate Notable delamination was found in the vicinity of the fermenter launder trough and when the coatings were manually removed a pink/purple staining was uncovered. Further testing will be needed to identify what has caused the staining shown in Figure 9 Fy [ ` w~V•:4�r i a ,97120i.2 2 `{1��L�1L/ �y y,� q�n�j Figure 9. Purple Staining and Discoloration Under Delaminating Coating 0 There are also locations on the launder weir side that are experiencing concrete degradation and vertical cracking is further exposing the aggregate. A pH test was performed on the concrete at the inside of the crack and where the first layer of degraded concrete was chiseled away. Photos of the launder vertical cracking can be seen in Figure 10. Figure 10. Launder and Coating Cracking Concrete sounding by hammer was performed at the 12 o'clock position on the vertical crack in Figure 10 and no hollow sound was witnessed. The vertical crack at the launder wall was chiseled away to depth of approximately 3/4 of an inch where the red pH rainbow indicator showed a pH level between 11 and 13. A photo of the pH examination and depth of the chiseling can be seen in Figure 11. Figure 11. Chiseled Crack pH Coloring In another location, 3/4 of an inch just above the crack was also chiseled. The pH indicator in the chiseled area came up at pH of 13 at a depth of a 1/4 of an inch. Vertical cracks throughout the inner -diameter inside launder wall were contaminated to 3/4 of an inch thickness from H2S gas. On the basin side of the launder inner -diameter wall the coating was applied to 12 inches below the launder down the basin wall. No keyway was present for proper termination of the coatings. Without proper termination, the edge of the coatings have pulled away and is allowing moisture to creep up behind the coating. Cracks were visible on the basin side of the launder and were the same condition as on the inside. The true condition of these areas will be unknown until the coatings are removed and further concrete testing is performed. 4.1.11 Launder Trough The examination of the launder trough found that there is a keyway but the coating is nonetheless peeling away from the substrate. A pink/purple staining was also observed in the area and shown in Figure 9. A photo of the launder trough and the significant delamination of the coatings can be seen in Figure 12. 10 W. I Figure 12. Delaminating Coating on Launder Trough 4.1.12 Skimmer and Counterweight The City performed a temporary skimmer repair during the fermenter inspection. Additional repairs shall be performed during the rehab outage. The counterweights are rusted but still well fastened, they shall be taken apart and individually coated and reinstalled during the rehabilitation period. 4.1.13 Supported Piping: 6-SC, 6-PS, 4-EW and Supports The six-inch SC pipe is stainless steel and dielectrically isolated from beach scum. It has stainless steel hardware fastened to the interior wall. The 6-PS and 4-EW piping are also stainless steel and properly isolated from the pipe supports and the influent well beams and influent well. Figure 13 shows the 6-PS, 4-EW, supports, influent beam and influent well. 4.1.14 Influent Well I -Beam and Pipe Support General rusting was observed on the influent well beams at 6 o'clock and 12 o'clock. These locations correspond to the southernmost and northernmost ends, respectively, of the beams as they abut the concrete wall where they are mounted. Figure 13 shows how the influent beams support the influent well as well as the 6-PS penetration into the influent well. 11 Figure 13. 6-PS, 4-EW, Influent Beam, Influent Well 4.1.15 Center Torque Tube The main square tubing of the center torque tube is in good condition with the exception of the bolts at the flanged ends that connect the upper and lower segments of the tubing. The nuts and bolts have experienced significant corrosion with the lack of proper isolation of dissimilar metals and must be replaced. Figure 14. Torque Tube Flanges with Corroded Nuts and Bolts 12 4.1.16 Scum Trough The scum trough was found to be in good condition. 4.1.17 4-foot Wide Scum Beach The scum beach support was found to be in good condition. The scum beach is carbon steel and is well fastened to the wall. 4.1.18 Scum Blade The scum blade had a torn corner (Figure 15) that will require replacement. Figure 15. Torn Scum Blade and End of Skimmer Counterweight Arm 4.1.19 Scum Weir and Baffle The scum weir and baffle components are FRP and include brackets with stainless steel hardware. These will be removed, "saved", and then re -installed after concrete rehabilitation is complete. 4.1.20 Concrete Walls Exposed aggregate (Figure 15 and Figure 16) and concrete spalling (Figure 17) due to corroded rebar was observed on the interior of the fermenter. 13 FN Figure 16. Exposed Aggregate on Interior Concrete Fermenter Floor Figure 17. Exposed Aggregate on Interior Concrete Fermenter Floor 14 W a Figure 18. Vertical Spalling from Corroding Rebar At 11 o'clock on the basin side wall an area rusting from corroding rebar through the concrete was observed. Exposed aggregate also was observed in this area approximately 10 feet off the floor. Furthermore, no cracking was observed on the concrete floor but the exposed aggregate was evident as well as the spacing between the floor and the plow blade with squeegees. The squeegees are designed to scrape along the floor with contact at all times. In many locations the squeegees have no contact with the floor. 4.1.21 Plow Blade and Trusses The plow rake arm is carbon steel and was observed to be in good condition. The trusses of the plow blade were also in good condition. 15 4.1.22 Tide Flex Valves The tide flex valves were observed to be in sufficient condition but should be replaced at the time of the fermenter rehabilitation. 4.1.23 Hopper Scraper and Truss The hopper scraper and truss were submerged in water and were not accessible for visual assessment. 4.1.24 Supernatant Wetwell The supernatant wetwell (Figure 16) was found to be in poor condition with significant corrosion. w 1 M Figure 19. Supernatant Wetwell in Poor Condition 5. Recommendations This initial assessment of the fermenter yielded some insight into the condition of system, but also lead to more questions. There are a number of testing procedures that can be performed to better understand the extent of the contaminated concrete as well as the loss of structural integrity in the structural steel. While many of the smaller nuts and bolts are easily identified and replaced, the concrete and larger steel components may have underlying issues that need to be explored. The following is a list of recommended tests and methods that HDR would like to discuss with the City to develop the plan for the follow-up condition assessment. • Surface penetrating radar unit will indicate if the rebar has good depth of cover. • Extract cores from the concrete, at a depth to be determined, to see how the following constituents vary with depth: 16 o pH - as pH decreases the rate of concrete deterioration increases and concrete becomes more porous, o Carbonation - CO2 in the presence of moisture can form carbonic acid which attacks the concrete and reduces the alkalinity, o Chlorides - chlorides can weaken and permeate through concrete and therefore increases the risk of reinforcement corrosion, o Compressive strength - will indicate how much strength has been lost and to what depth in the core, o Iron Content - the iron concentration in the fermenter liquid is very high which promotes bacterial growth which leads to corrosive environment. • Energy Dispersive Spectroscopy - EDS which is a qualitative elemental analysis that will indicate what inorganic substances are present. • Thickness readings on the structural steel beams flanges and webs to determine extent of section loss. HDR has the capabilities to perform the tests listed or to collect the necessary samples to send to an appropriate lab. However, a separate contractor will need to be retained to take the concrete cores to then be sent to a lab for analysis. We appreciate the opportunity to work with you and look forward to a discussion to determine next steps. Regards, Lizzy English Muir, PE Greg Mieczkowski HDR NACE 1 Coatings HDR NACE III Coatings Inspector Inspector and Project Engineer 17 CITY OF KALISPELL MEMORANDUM To: Doug Russell, City Manager From: Susie Turner, P.E., Public Works Director Re: Stormwater TMDL Action Plan Meeting Date: March 22, 2021 Enclosures: Report — Stormwater TMDL Action Plan (Final Draft) BACKGROUND: The City of Kalispell is permitted by the Montana Department of Environmental Quality (DEQ) under the General Permit for Stormwater Discharges Associated with Small Municipal Separate Storm Sewer Systems (Small MS4s). The purpose of the permit is to protect local water quality by reducing and preventing urban stormwater pollutants from entering the storm system and local water bodies. The 5-year permit (2017-2021) requires the City to develop and maintain a stormwater program. Within the permit, there are yearly programmatic requirements. In permit year four (2020), the City was required to develop a section of the Stormwater Management Plan that addresses applicable total maximum daily loads (TMDLs). The permit required that the TMDL section include: • Identification of measures and best management practices (BMPs) the permittee plans to implement • Description of the MS4's impairment priorities and long-term strategy • An outline of interim milestones for controlling the discharge of the pollutants of concern and making progress towards meeting the TMDL. The purpose of the Stormwater TMDL Action Plan is to maintain compliance with the MS4 permit. The plan contains background information, details on TMDLs with MS4 approved wasteload allocations, and a plan for addressing TMDLs. The objective of this work session is to present an overview of the MS4 permit regulations and the contents of the Stormwater TMDL Action Plan, as well as provide a review of the various methods and practices the City utilizes to reduce and prevent stormwater pollution to meet the TMDL. 201 1"Avenue E Phone (406)758-7720 Po Box 1997 Public Works Department Fax (406)758-7831 Kalispell, MT 59903 1 1 www.kalispell.com Sto rmwate r T M D L Action Plan City of Kalispell, Montana Stormwater Management Program Kalispell, MT February 18, 2021 This page intentionally left blank City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan 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 TMDLs in the SWMP.......................................................................4 2.2 TMDL-Related Monitoring..................................................................................4 3 TMDLs with MS4 Approved WLAs........................................................4 3.1 Pollutants of Concern and WLAs....................................................................... 6 3.1.1 Nutrients (Total Phosphorus, Total Nitrogen, Nitrate + Nitrite) ............................... 7 3.1.2 Dissolved Oxygen................................................................................................. 7 3.1.3 Sediment.............................................................................................................. 7 3.1.4 Temperature......................................................................................................... 7 4 Stormwater Action Plan for Addressing TMDLs.....................................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..............................................................................................11 1. Pollution Prevention & Good Housekeeping (i.e. Municipal Operations)..................11 2. Education & Outreach.............................................................................................12 3. Construction Site Stormwater Management............................................................12 4. Water Quality Treatment Applications & Capital Improvement Plan.........................13 5. Low Impact Development........................................................................................15 6. Stormwater TMDL & Self-Monitoring.......................................................................16 4.1.3 Funding................................................................................................................16 4.1.4 Adaptive Management.........................................................................................17 4.2 Schedule and Progress Towards Meeting the TMDL....................................... 17 4.2.1 Schedule for Action Items....................................................................................17 4.2.2 Measuring Progress towards Meeting the TMDL.................................................18 Non -Structural BMPs......................................................................................................20 StructuralBMPs.............................................................................................................20 4.2.3 Estimation of Recent Historical Progress towards Meeting the TMDL..................24 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...........................................................10 Figure 2. City of Kalispell Stormwater TMDL CIP Strategy........................................................15 Figure 3. Anticipated Schedule of Structural and Non -Structural Action Items ..........................18 Figure 4. 2020 Ashley Creek Estimate of Total Pollutant Reductions........................................25 Figure 5. 2020 Spring Creek Estimate of Total Pollutant Reductions........................................25 Figure 6. 2020 Stillwater River Estimate of Total Pollutant Reductions.....................................26 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................................19 Table 5. Summary of Pollutants of Concern Removed by Non -Structural BMPs.......................20 Table 6. 2020 Pollutant Reductions from Non -Structural BMPs by Waterbody ..........................20 Table 7. Example Reduction Progress Evaluation for a Single BMP.........................................21 Table 8. Example Reduction Progress Evaluation for Multiple Scenarios..................................22 Table 9. Reduction Progress Evaluation for Impaired Waterbodies from Structural BMPs ........23 Table 10. Reduction Progress Evaluation for Ashley Creek from Structural BMPs....................23 Table 11. Reduction Progress Evaluation for Spring Creek from Structural BMPs ....................23 Table 12. Reduction Progress Evaluation for Stillwater River from Structural BMPs .................23 Table 13. Estimate of Total Pollutant Reductions within the MS4 in 2020.................................24 City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan 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 (TMDLs). 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. 3 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 TMDLs 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 (i.e., 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 4t" year Annual Report for approval. The permittee will begin to implement the approved section no later than the start of the 5t" permit year. The TMDL section must be annually evaluated based on monitoring results, revisited as needed, and resubmitted with Annual Reports beginning with the 5t" 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 TMDLs 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 TMDLs and 0 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 Waterbody ID Impairment Cause(1) Pollutant Category(2) Description (Middle) Ashley Creek, Smith Lake to Kalispell Airport Road MT760002_020 Nitrogen Total Nutrients Phosphorus Total Nutrients Sedimentation/Siltation Sediment Temperature, water Temperature Alteration in stream side or littoral vegetative covers Not Applicable; Non -pollutant Chlorophyll a Not Applicable; Non -pollutant Nitrate/Nitrite Nitrite+Nitrate as N Nutrients (Lower) Ashley Creek, Nitrogen Total Nutrients Kalispell Airport Road to MT760002_030 Oxygen, Dissolved Dissolved Oxygen mouth (Flathead River) Phosphorus Total Nutrients Sedimentation/Siltation Sediment Temperature, water Temperature Spring Creek, Headwaters to mouth (Ashley Creek) MT760002 040 — Nitrate/Nitrite Nitrite+Nitrate as N Nutrients Nitrogen Total Nutrients Oxygen, Dissolved Dissolved Oxygen Phosphor s Total Nutrients Stillwater River, Logan Creek to mouth MT76PO01_010 Alteration in streamside or littoral ve etative covers Not Applicable; Non -pollutant Sedimentation/Siltation Sediment Whitefish River, Whitefish Lake to mouth MT76P00_010 Temperature, water Temperature Stillwater River (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 5 3.1 Pollutants of Concern and WI -As 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 WI -As for the Kalispell MS4 and their percent reductions are identified in Table 2. Table 2. TMDL Loads and MS4 Wasteload Allocations Segment Load Ibs Percent Reduction 1 WLA 1 Total Nit oclen 2 Middle Ashley Creek 3 417 30% 292 Lower Ashley Creek 4 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 2 Middle Ashley Creek 3 26 44% 15 Lower Ashley Creek 4 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. (1) 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 WI -As. WLA = Wasteload Allocation (2) Load and WLA for nutrients are given as growing season, July 1 through September 30. (3) Middle Ashley Creek includes the load for Spring Creek. (4) Lower Ashley Creek includes the loads from Middle Ashley Creek and Spring Creek. (5) Load and WLA for sediment are given as annual limits. (6) 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 A 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 WI -As are not intended to add load limits to the permit. The WI -As 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 WI -As 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 WI -As are not intended to add load limits to the permit. The WI -As 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 WI -As 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. 7 4 Stormwater Action Plan for Addressing TMDLs The City conducts extensive planning to maintain and operate the MS4. Focusing on removing and reducing pollutants in stormwater through both structural' 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. 0 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 Stormwater City Assigned Outfall Code Number of Outfalls Waterbody Sub -basin Drainage Area (2) that Discharge to Acres 1 Impaired Waterbodies Ashley Creek 1,214.16 AC1 —AC 11, AC13—AC21, 23 middle and lower UT1—UT3 Spring Creek 1,130.08 SC1—SC2, SC4, SC6—SC25 23 Stillwater River 1,237.91 SWR1—SWR11, SWR14- 19 SWR17, SWR19-SWR22 Whitefish River 14.22 WFR1—WFR2 2 (1) Sum of drainage areas as shown in Appendix A of Kalispell 2021. Excludes closed basins. 2 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- ' 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. 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): 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 TMDLs utilizes the prioritization list. Selection of the type of new structural BMPs and measures to address TMDLs 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. 9 a i Drainage Basin �J AC6 0 SC1 ® AC11j 0 SWR4 0 AC2 AC21 0 SC6 0 SC16 �� SWP N 0 005 1 2 Miles ESri, HERE I Figure 1. Highest Priority Sub -Basins in City of Kalispell 10 4.1.2 Long-term Strategy The long-term strategy of the City to address impaired waterbodies and their associated TMDLs 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 Housekeepinq (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 11 ■ 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 12 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. 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 2): 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 13 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. 14 Monitor and e►raluate via Stormwater Sampling Plan 0010 Identify sub -basins Evaluate and requiring treatment repeat to further TIVIDL goals Require privately owned new and re -development meet standards for Construct CIP treatment Plan CIP 1f" Figure 2. City of Kalispell Stormwater TMDL CIP Strategy f-ow 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 15 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. 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 C). 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 16 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 TMDLs 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 TMD' 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 3). 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 17 therefore scheduled. The figure below provides the anticipated schedule for City stormwater CIPs which are updated annually based on funds and scheduling needs. Municipal Operations = 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, 18 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 TMDLs and WI -As 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 4). 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 M S4. Table 4. DEQ TMDL Reference Pollutants of Concern Percent Removals Structural BMP Annual Percent Removal Total Nitrogen Total Phos horus 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 1 27% 41 % 1 62% (1) Hirschman et al. 2008 (2) Center for Watershed Protection 2007 (3) International Stormwater BMP Database 2020 4 Geos ntec 2016 19 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 Total Nitrogen Removed (tons) Total Phosphorus Removed tons Sediment Removed (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 Removals 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 6). 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 Pollutants Removed by Non -Structural BMPs per Waterbody Total Nitrogen Total Sediment Watershed Percentage of Removed Phosphorus Removed Total Watershed (tons) Removed (tons) 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 I• • maintain these systems, the reductions from the privately owned BMPs should be accounted for in evaluating the progress towards meeting the Kalispell MS4 TMDLs. 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 BMP Reduction BMP Reduction BMP BMP Drainage stare Area Drainage Area Reduction in in Total in Sediment Treatment Area (acres) (acres) Total Nitrogen Phosphorus Load Load 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. 21 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 Exam le 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 Al 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 1 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 9). 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. 22 Table 9. Reduction Progress Evaluation for Impaired Waterbodies from Structural BMPs Cumulative BMP Cumulative Total Cumulative Total Cumulative Total Number of Drainage Nitrogen Phosphorus Sediment Year BMPs Area Reduction Reduction Reduction acres 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 1 61 1 1047 1 2.6% 1 6.6% 14.2% Goal I TBD 1 4891 1 30.0% 1 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 Cumulative Cumulative Cumulative Number Cumulative Cumulative Total Total Total Year Drainage Area Nitrogen of BMPs Phosphorus Sediment (acres) Reduction Reduction 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 Cumulative Cumulative Cumulative Number Cumulative Cumulative Total Total Total Year Drainage Area Nitrogen of BMPs (acres) Reduction Phosphorus Sediment Reduction 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 Cumulative Cumulative Cumulative Number Cumulative Cumulative Total Total Total Year Drainage Area Nitrogen of BMPs Phosphorus Sediment (acres) Reduction Reduction 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 % 23 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 Ibs Total Phosphorus Reduction Ibs Total Sediment Reduction Ibs Non-structural 147,850 23,666 6,880,100 Structural 49 8 47,084 TOTAL 147,899 23,674 6,927,184 WLA 1,030 54 156,800 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. Ashley Creek 10,000,000 1,000,000 100,000 o 10,000 E U N Cn 0 1,000 c� 0 100 d 10 1 Total Nitrogen Reduction (Ibs) Total Phosphorus Reduction Total Sediment Reduction (Ibs) (Ibs) ■ Non-structural ■ Structural —WLA 10,000,000 1,000,000 100,000 o 10,000 E U N Cn 0 1,000 c� 0 100 d 10 Figure 4. 2020 Ashley Creek Estimate of Total Pollutant Reductions Spring Creek Total Nitrogen Reduction (Ibs) Total Phosphorus Reduction Total Sediment Reduction (Ibs) (Ibs) ■ Non-structural ■ Structural — WLA Figure 5. 2020 Spring Creek Estimate of Total Pollutant Reductions 25 Stillwater River 10,000,000 1,000,000 Cn 100,000 m o 10,000 E U N Cn 0 1,000 c� 0 100 d 10 1 Total Nitrogen Reduction (Ibs) Total Phosphorus Reduction Total Sediment Reduction (Ibs) (Ibs) ■ Non-structural ■ Structural — WLA 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. 009 City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan 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. WQPBWQM-020. Helena, MT. DEQ 2014. Final - Flathead — Stillwater Planning Area Nutrient, Sediment, and Temperature TMDLs 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. Hirschman, D., 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. 27 WERF 2017. International Stormwater BMP Database: 2016 Summary Statistics. {https://www.bmpdatabase.org/Docs/03-SW- 1 COh%20BM P%20Database%202016%20Summary%20Stats.pdf�. City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan TMDL Progress Reporting 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 Treatment Unit Maintenance' 0.5 0.1 22.6 Infrastructure Maintenance' 0.7 0.1 35.6 2017 Street Sweeping' 25 4.2 1,245 Leaf Collection 4.1 0.3 n/a Treatment Unit Maintenance' 0.9 0.2 45.0 Infrastructure Maintenance' 1.0 0.2 49.5 2018 Street Swee in ' 27 4.5 1,362 Leaf Collection 9.3 0.7 n/a Treatment Unit Maintenance' 0.8 0.1 38.6 Infrastructure Maintenance' 3.0 0.5 151.8 2019 Street Sweeping' 18 3.0 912 Leaf Collection 5.6 0.4 n/a Treatment Unit Maintenance' 1.2 0.2 59.55 Infrastructure Maintenance' 2 0.4 115.5 2020 Street Sweeping' 65 10.9 3,265 Leaf Collection z 5.1 0.4 n/a 'Total 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 Type and Drainage Discharge BMP Total BMP Total BMP Year Name Private or Treatment Location Nitrogen Phosphorus Sediment Completed Public' Area Percent Percent Percent acres Remova12 Remova12 Removal' Super One Proprietary Stillwater 2009 Foods Private - 5.2 River 5% 18% 54% HDS South Proprietary 2012 Meadows Pr ivate - 36.36 Ashley o 5 /0 0 18 /0 0 54 /o Drainage HDS Creek Improvements Willows Proprietary Ashley 2013 Stormwater Private - 28.8 Creek o 5 /0 0 18 /0 0 54 /o Improvements HDS Kalispell Proprietary Spring 2013 Center Mall Private - 22.45 Creek o 5 /0 0 18 /0 0 54 /o HDS 'Propriertary 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 Table A-3. 2016 Completed Private and Public Stormwater Quality Improvement Projects Private Type' Drainage Discharge BMP BMP Total BMP or Treatment Location Total Phosphorus Sediment Name Public Area Nitrogen Percent Percent (acres) Percent Removal2 Removal' Removal2 Sylvan Drive Public Proprietary 265 Stillwater 5% 18% 54% 2 River Spring Creek Structure Alley Public Sump 0.05 Spring Creek 0% 0% 0% Stormwater Spring Prairie Private Infiltration 56 Closed Basin o 21 /0 0 47 /0 0 80 /o Four Basin .53 (Stillwater) Gardner Infiltration Closed Basin Retention Private Basin 66.26 (Lower 21% 47% 80% Ashley) Owl View Private Infiltration 046 Closed Basin 47% 80% Townhomes Basin . Stillwater)21% Glacier View Closed Basin Professional Private Proprietary 0.567 (Stillwater) 5% 18% 54% Center Herberger's Private Proprietary Spring Creek 5% 18% 54% Expansion Hampton Inn Private Proprietary 6.75 Spring Creek 5% 18% 54% McDonald's Private Proprietary 0.92 Spring Creek 5% 18% 54% Proprietary & Forest Service Private Wet 0.39 Stillwater 30% 50% 64% Building Detention River Basin J2 Office Private Proprietary 0.21 Stillwater 5% 18% 54% Warehouse River KRH Northwest Private Infiltration 061 Closed Basin 47% 80% FamilyMedicine Basin . (Whitefish)21% Sunnyview Proprietary & Closed Basin Phase I I I Private Infiltration 69.15 (Stillwater) o 21% 0 47 /0 0 80 /o Basin 'Propriertary 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 Table A-4. 2017 Completed Private and Public Stormwater Quality Improvement Projects Private Type' Drainage Discharge BMP BMP Total BMP or Treatment Location Total Phosphorus Sediment Name Public Area Nitrogen Percent Percent (acres) Percent Removal2 Removal' Removal2 41h Avenue E Water Public N/A N/A Ashley and o 0 /0 0 0 /0 0 0 /o Replacement Stillwater Begg Park Dog Public Infiltration 1.69 Ashley Creek 21% 47% 80% Park Basin MDT Maintenance Public Proprietary 1.6 Stillwater 5% 18% 54% Facility — City River Maintained Southside Private Proprietary 5.8 Ashley Creek 5% 18% 54% Estates 2 Glacier Village Infiltration Closed Basin Greens Phase Private Basin 2.75 (Whitefish) 21% 47% 80% 21 RDO Private Bioretention 0.37 Ashley Creek 64% 55% 75% Pinnacle Infiltration Closed Basin Chiropractic Private Basin 0.28 (Spring 21% 47% 80% Creek Owl View Infiltration Closed Basin Landing Private Basin & 3.923 (Stillwater) 21% 47% 80% Proprietary Emmanuel Proprietary Stillwater Lutheran West Private (2) 4.74 River 5% 18% 0 54% Campus Kalispell Ford Private Infiltration 10 Closed Basin 21% 47% 80% Basin (Stillwater) Women's & Private Proprietary 3.58 Closed Basin 5% 18% 54% Children's Stillwater MDT Proprietary Stillwater Maintenance Private (2) 6.2 River750% 18/0 054 /o0 Facility 'Propriertary 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 Table A-5. 2018 Completed Private and Public Stormwater Quality Improvement Projects Private Type' Drainage Discharge BMP BMP Total BMP or Treatment Location Total Phosphorus Sediment Name Public Area Nitrogen Percent Percent (acres) Percent Removal2 Removal' Removal2 Glacier Rail Proprietary & Park Public Infiltration 47.724 Closed Basin 21% 47% 80% Basin Sherry Lane Storm and Ramsgate Public Improvements N/A Spring Creek 0% 0% 0% Dr. & Flood Reduction The Vision Private Proprietary 0.75 Spring Creek 5% 18% 54% Clinic Peterson Infiltration Closed Basin Elementary Private Basin 0.12 (Lower 21% 47% 80% Ashley) J2 Office Private Proprietary 0.79 Stillwater 5% 18% 54% Products River Glacier Rail Private Infiltration 44 Closed Basin 47% 80% Park Basin .07 (Stillwater)21% Infiltration Closed Basin PTA Private Basin 0.798 (Lower 21% 47% 80% Ashley) First American Private Proprietary 0.74 Stillwater 5% 18% 54% Title River Husky Street Private Biofiltration 0.83 Spring Creek 40% 38% 92% Apartments Swale Green Closed Basin Nissan/Hyundai Private Proprietary 6.2 (Lower 5% 18% 54% Ashley) Rankin Private Proprietary 11.62 Ashley Creek 5% 18% 54% Elementary Lofts at Ashley Private Proprietary 3.7 Ashley Creek 5% 18% 54% Treeline Private Proprietary 5.603 Stillwater 5% 18% 54% Subdivision River 'Propriertary means manufactured control measure or devices with a company branded treatment process. 2Percent removal based on Table 5-21 DEQ 2014 'Average 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 Table A-6. 2019 Completed Private and Public Stormwater Quality Improvement Projects Private Type' Drainage Discharge BMP BMP Total BMP or Treatment Location Total Phosphorus Sediment Name Public Area Nitrogen Percent Percent (acres) Percent Removal2 Removal' Removal2 Sylvan Drive Extended Conveyance Public Detention N/A Stillwater 24% 20% 64% and Detention Basin (refurbish) River Improvements Shop Complex Proprietary Pavement Public (2) 26.82 Ashley Creek o 5% 0 18 /0 0 54 /o Restoration Linderman Public Proprietary 3.49 Ashley Creek 5% 18% 54% School Faith Covenant Public Proprietary 2.92 Ashley Creek 5% 18% 54% Presbyterian Brightview Private Infiltration 3216 Stillwater o 21 /0 0 47 /0 0 80 /o Subdivision Basin . River Oral Surgery Private Infiltration 0.588 Closed Basin 21% 47% 80% Basin (Stillwater) Edge Private Biofiltration 0.42 Spring Creek 40% 38% 92% Apartments Swale Basecamp RV Private Biofiltration 9.24 Ashley Creek 40% 38% 92% Swale Glacier Eye Private Infiltration 3.42 Stillwater 21 % 47% 80% Clinic Basin River Meadows Edge Private Proprietary 8.424 Spring Creek 5% 18% 54% Phase 1A 'Proprietary 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 Table A-7. 2020 Completed Private and Public Stormwater Quality Improvement Projects Private Type' Drainage Discharge BMP BMP Total BMP or Treatment Location Total Phosphorus Sediment Name Public Area Nitrogen Percent Percent (acres) Percent Removal2 Removal' Removal2 Fresh Life Public Proprietary 1.8 Ashley Creek 5% 18% 54% Smith's Grocery Private Proprietary 4.37 Stillwater 5% 18% 54% 4 River Southside Private Proprietary 20.5 Ashley Creek 5% 18% 54% Estates Phase 2 2 Glenwood Private Proprietary 5.58 Spring Creek 5% 18% 54% Apartments Jaxon Ridge Private Proprietary 3.896 Dry Bridge 5% 18% 54% Slough Peterson Acre Private Infiltration 1 Closed Basin 21% 47% 80% Basin (Stillwater) Kalispell North Private Infiltration 102 Closed Basin o 21/0 0 47 /0 0 80 /o Town Center Basin (Stillwater) Westview Private Proprietary 13.0001 Closed Basin 5% 18% 54% Phase 4 Stillwater 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 Private Proprietary 0.988 Closed Basin 5% 18% 54% LandingStillwater 'Proprietary 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 City of Kalispell I Storm Water Management Program Stormwater TMDL Action Plan Treatment Scenarios Corresponding to nitrogen removal and scenarios in Table 8 Total t Total Basin - 1,000 ac 1,000 ac basin with 200 ac sub -basin. Sub -basin has bioretention treatment at the effluent. 13% Reduction Sub -basin A 200 ac BR y l � 72 ac J — Bioretention = 64% removal 8j2 a� 200 ac -200 ac x 64% = 72 ac ab 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. Total Basin = 1,000 ac Entire basin has hydrodynamic separator treatment at the effluent. 17% Reduction Sub -basin A Al 200 ac y ` 72 ac J - Bioretention = 64% removal r 8j2 0, 200 ac - 200 ac x 640 = 72 ac 1000 ac - 200 ac + 77c,=872ac Hydrodynamic separator = 5% removal 872 ac - 872 ac x 5% = 828 ac Total Basin = 1,000 ac Sub -basin B1 200 ac Bioretention = 64% removal Sub -basin B 200 ac - 200 ac x 64% = 72 ac 400 ac °a 400 ac - 200 ac + 72 ac = 272 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 BR,,72q aC 190 ac 1000 ac - 400 ac + 190 ac = 790 ac Filter = 30% removal 272 ac - 272 ac x 30% = 190 ac A #d e Hydrodynamic separator = 5% removal SJ 01 790 ac - 790 ac x 5% = 751 ac 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 Total Basin = 1,000 ac Sub -basin B 400 ac Sub -basin A •.l� 200 ac Sub -basin Al P 100 ac 1 a BR +,_36 ac> Sub -basin B1 200 ac Bioretention = 64% removal 0 200 ac - 200 ac x 64% = 72 ac a 400 ac - 200 ac + 72 ac = 272 BR -* Filter = 30% removal 22 --� _, 2j2ac 272 ac - 272 ac x 30% = 190 ac 136 ac 190 ac — 6,9,6 l 95 ac J ac Bioretention = 64% removal 100ac-100acx64%E36 200 ac - 100 ac = 136 ac Filter = 30% removal 136ac- 136ac x30%=95ac 1000 ac - 400 ac - 200 ac + 190 ac + 95 ac = 685 ac Hydrodynamic separator = 5% removal 685 ac - 685 ac x 5% = 651 ac TMDL Sampling Plan 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 LEGEND Outfall Storm Main Kalispell Receiving Waterbo( . 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. 0 Feet 4,000 DATA SOURCE: ESRI, City of Kalispell .. r.. 1 1 1 1 1 j 1 1 FN 77 G:IPROJECTSIKALI SPELLIKALI SPELL MS4IMAP DOCSIFK URE I -RECENING WATERBOOIES MAP.MXO - USER: MPETERSO - DAM 10291201; \ LEGEND Monitoring Location Outfall Storm Main e — Kalispell Receiving Waterbody v 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. 0 Feet 4,000 DATA SOURCE: ESRI, City of Kalispell Site 002 - TMDL & Self -Monitoring Lc � 11� ?3 I� ................... PATH: S:IPW OATAIOEPARTMENTS%STORMWATER%PHASE 11 STORM WATER PERMITSTORMWATER MANAGEMENT PROGRAMISTORM SAMPLING%EOITABLE OOCUMENTSTIGURE 2 - MONITORING LOCATIONS MAP UPOAMMXO - USER: CLEW I S - OATS: 11912020