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Home My WebLink About09-24-21 Correspondence - DEQ - Violation Letter DEQMontana Deportment of Environmental Ounlitt September 20, 2021 VIOLATION LETTER The Honorable Cyndy Andrus City of Bozeman PO Box 1230 Bozeman, MT 59771 RE: Inspection Report — Municipal Separate Storm Sewer System (MS4) Inspection: City of Bozeman and Montana State University,Montana Pollutant Discharge Elimination System(MPDES)Permit Authorization $IMTR040002:City of Bozeman and Montana State University MS4 Dear Mayor Cyndy Andrus: The Montana Department of Environmental Quality (DEQ) conducted an inspection of the City of Bozeman and Montana State University, MPDES Permit Authorization MTR040002: City of Bozeman and Montana State University MS4, on June 15—18, 2021. Please review the enclosed inspection report and supplemental documents for detailed information about the inspection. The enclosed inspection report details the results of the inspection of the City of Bozeman and Montana State University MS4 program completed by Montana DEQ.The report is divided into each part of the General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems(General Permit) reviewed. A brief summary of the City of the Bozeman and Montana State University of Montana's efforts to fulfill the requirements defined in the General Permit are provided. Following each summary, additional sections are included which highlight commendable efforts, outline areas for improvement and recommendations, and identify violation(s). Based on the information reviewed and the inspection process, Montana DEQ identified findings in five sections of the General Permit reviewed. The findings are representative of a Storm Water Management Program (SWMP)that is in violation of the Montana Water Quality. Please refer to the conclusion of the inspection report for corrective actions and due dates. Corrective actions addressing the following violation are required to be completed in order to return the City of Bozeman and Montana State University MS4 back to compliance with the requirements of the General Permit: • Failure to develop and implement an adequate Storm Water Management Program (SWMP) is a violation of 75-5-605(1)(b) Montana Code Annotated, 17.30.1342(1) of the Administrative Rules of Montana, and Part II of the General Permit. Montana DEQ is requiring written responses explaining the corrective actions completed by the specified dates in the Conclusion of the inspection report. The written responses can be submitted electronically through your FACTS account. If you do not have a FACTS account, please contact Gina Self with the MPDES Data Management Team at (406) 444-5388 or Gself@mt.gov. Alternatively, the written responses can be mailed to: Montana Department of Environmental Quality, MPDES Data Management Team, PO Box 200901, Helena, MT 59620- 0901, Attn: Christopher Romankiewicz. Refer to the conclusion of the inspection report for required corrective actions and due dates. Greg Gianforte, Governor I Chris Dorrington, Director I P O. Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 wvvw deq mt gov City of Bozeman-City of Bozeman MS4 Page 2 of 2 MTR040002 September 20, 2021 This letter is intended to inform the City of Bozeman and Montana State University of violations of the Montana Water Quality Act so appropriate steps can be taken to return to compliance. If the City of Bozeman and Montana State University cannot meet the defined timeframes to complete corrective actions or if the information presented in this inspection report is inaccurate, please contact me upon receipt of this report. Montana DEQ will take into consideration any documentation that indicates the violations did not occur, or that they occurred differently than described herein. Per Section 75-5-516(2) MCA, this letter will result in the loss of your eligibility for a 25% reduction in your annual fee. If there are any questions, you would like to review and discuss the inspection report, or require compliance assistance, please contact me at (406) 475-2138. Sincerely, C 6 Christopher Romankiewicz Lead Compliance Inspector Compliance, Training, and Technical Assistance Water Quality Division Montana Department of Environmental Quality cromankiewicz@mt.gov Enclosures: 3560, Inspection Report, Photo Reports COB and MSU, Attachments A& B cc:Megan Sterl,Montana State University,Engineering and Utility Manager,Plew Building,611,and Grant,P,O.Box 172760, Bozeman,MT 59717 Adam Oliver,Storm Water Program Coordinator,City of Bozeman,PO Box 1230,Bozeman,MT 59771 El Hook,Director,Facilities Services,Montana State University, Plew Building,61b and Grant,P.O.Box 172760, Bozeman,MT 59717 FACTS Greg Gianforte, Governor I Chris Dorrington, Director I P O.Box 200901 1 Helena, MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov r MPDES 3560 Compliance Inspection Report I)I; Section A: Facility and Contact Information MPDES#/Programmatic ID: MTR040002 MPDES Permit Type: MS4 Facility/Project Name:City of Bozeman MS4 Address/Location: City of Bozeman Latitude and Longitude:45.67716,-111.03626 Facility Site Contact(Permittee): Jeff Mihelich,City Manager Mailing Address: PO Box 1230 City,State,Zip Code: Bozeman,MT 59771 Phone/Email:(406)582-2300/jmihelich@bozeman.net SIC Code:9511-Air,Water,and Solid Waste Management Section B: Compliance Inspection Information Compliance Monitoring Activity Name:City of Bozeman MS4 Program:NPDES-Base Program (Limits, Compliance Monitoring Type: Evaluation Reporting,Schedule), NPDES-Storm Water-MS4 MPDES#/Programmatic ID: MTR040002 Complaince Monitoring Date(s): Compliance Monitoring Reason: Compliance Monitoring Agency Type/Name: Actual Start:06/15/2021 Core Program State/MT DEQ Actual End:06/18/2021 Compliance Monitoring Details: Compliance Monitoring Information: Did EPA Assist? No Number of Days Conducting 4 Activity? State,Federal,or Joint Inspection? State Number of Hours Conducting the 18 Activity? Purpose of the Other Party? State Compliance Monitoring Action Not Immediately Corrected Outcome? Which Party was the Lead? I State I Compliance Monitoring Code? Unsatisfactory Government Contacts:Christopher Romankiewicz I Written Response Due Date:3/1/2022 Section C: Compliance Inspection Outcome MPDES 4/Programmatic ID:MTR040002 Violations Identified:Yes Violation Code:BOM17- Failure to Develop Any or Adequate SWMP Single Event Violation Date:06/15/2021 Section D:Signatory Name and Signature of Inspector Date 9/13/2021 Name and Signature of Inspector Date Click or tap to enter a date. Name and Signature of QA Inspector/Manager Date 9/17/2021 City of Bozeman Montana State University General Permit for Storm Water Discharges Associated with Municipal Separate Storm Sewer Systems (MS4) MPDES Permit Authorization MTR040002 Inspection Report Montana Department of Environmental Quality Water Protection Bureau June 2021 City of Bozeman/Montana State University MS4 Page 2 of 39 MTR040002 September 20, 2021 Table of Contents 1.0 Introduction.................................................................................................................. 3 1.1 City of Bozeman/Montana State University MS4 Overview 2.0 Inspection Overview.................................................................................................... 7 3.0 Inspection Results ........................................................................................................ 9 3.1.1 Part ILA SWMP.............................................................................................................. 9 3.1.2 Commendable Efforts 3.1.3 Areas for Improvement and Recommendations 3.1.4 Violations 3.2.1 Part II.A.1 Public Education Program....................................................................9....14 Public Education and Outreach and Public Involvement and Participation 3.2.2 Commendable Efforts 3.2.3 Areas for Improvement and Recommendations 3.2.4 Violations 3.3.1 Part II.A.3 Illicit Discharge Detection and Elimination— IDDE................................. 18 3.3.2 Commendable Efforts 3.3.3 Areas for Improvement and Recommendations 3.3.4 Violations 3.4.1 Part II.A.4 Construction Site Storm Water Management.......................................... 20 3.4.2 Commendable Efforts 3.4.3 Areas for Improvement and Recommendations 3.4.4 Violations 3.5.1 Part II.A.5 Post Construction Storm Water Management in Newand Redevelopment.............................................................................................. 24 3.5.2 Commendable Efforts 3.5.3 Areas for Improvement and Recommendations 3.S.4 Violations 3.6.1 Pollution Prevention and Good Housekeeping for Permittee Operations............. 28 3.6.2 Commendable Efforts 3.6.3 Commendable Efforts 3.6.4 Commendable Efforts 3.7.1 Part 11.13 Training............................................................................................................ 30 3.6.2 Commendable Efforts 3.6.3 Areas for Improvement and Recommendations 3.6.4 Violations 3.8.1 Part II.0 Sharing Responsibility..................................................................................... 33 3.7.2 Commendable Efforts 3.7.3 Areas for Improvement and Recommendations 3.7.4 Violations 3.9.1 Part III Special Conditions and Part IV Monitoring, Recording, and ReportingRequirements................................................................................................ 34 3.9.2 Commendable Efforts 3.9.3 Areas for Improvement and Recommendations 3.9A Violations 3.10 Field Visits........................................................................................................................ 36 4.0 Conclusion......................................................................................................................... 39 4.1 Corrective Actions Attachments • A—Uocuments Reviewed and Inspection Agenda • B—Letter Providing Notification of Inspection City of Bozeman/Montana State University MS4 Page 3 of 39 MTR040002 September 20, 2021 1.0 Introduction The Montana Department of Environmental Quality (DEQ) conducted an inspection of the City of Bozeman and Montana State University Storm Water Management Program (SWMP) for the Municipal Separate Storm Sewer System (MS4) on June 15 to 18, 2021.The purpose of the inspection was to determine compliance with the General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (General Permit). Montana DEQ's goal is to ensure the City of Bozeman and Montana State University are developing and implementing a SWMP to protect water quality through the implementation of Best Management Practices (BMPs) to the maximum extent practicable (MEP). Montana DEQ completed review of Parts II, III, and IV of the General Permit. These requirements of the General Permit were selected because of the current timeframe of the permit cycle. The selected requirements are further defined in section 2.0 Inspection Overview. The inspection was completed in fulfillment of Montana DEQ's obligations under the federally delegated program and Performance Partnership Agreement (PPA)with the U.S. Environmental Protection Agency (U.S. EPA). 1.1 City of Bozeman/ Montana State University MS4 Overview City of Bozeman -COB The City of Bozeman (COB) urbanized area is 19.15 square miles (12,256 acres) and serves a population of approximately 50,000 people (US Census 2019). Land use in the urbanized area consists of residential, commercial, light industrial, and agricultural. COB is defined as a traditional MS4 under the General Permit. COB is a government body that is governed by locally elected officials. The primary responsibilities of COB personnel are the administration and management of day-to-day operations, which include administration of laws, supplying goods and services, and offering representation of local interests by involving citizens, identifying specific local needs, and determining how these needs can be met. The organizational structure of the COB includes elected officials, boards, committees, commissions, councils, and departments. Boards, committees, and councils include: • Audit Committee • Beautification Advisory Board • Building Division Board of Appeals • Board of Ethics • Bozeman Area Bicycle Advisory Board • Bozeman Climate Partners Working Group • Bozeman Downtown Business Improvement District Board • Bozeman Historic Preservation Advisory Board • Cemetery Advisory Board • City Planning Board • City-County Board of Health • Community Affordable Housing Advisory Board • Criminal Justice Coordinating Council • Design Review Board Development Review Committee • Downtown Area Urban Renewal District Board • Economic Development Council • Fire Code Board of Appeals • Gallatin County Mental Health Local Advisory Council City of Bozeman/Montana State University MS4 Page 4 of 39 MTR040002 September 20, 2021 • Gallatin Local Water Quality District Board of Directors • Impact Fee Advisory Committee • Inter-Neighborhood Council • Library Board of Trustees • Midtown Urban Renewal Board • Northeast Urban Renewal Board • Parking Commission • Pedestrian and Traffic Safety Committee • Police Commission • Prospera Revolving Loan Fund • Recreation and Parks Advisory Board • Streamline Advisory Board • Trails, Open Space, and Parks Committee • Transportation Coordinating Committee • Tree Advisory Board • Zoning Commission COB Departments and Services include: • Building • Cemetery • City Attorney • City Clerk • City Commission • City Manager • Code Compliance • Economic Development • Engineering, including floodplain • Finance • Fire • Forestry • Garbage — Recycling • GIS— Mapping • Historic Preservation • Human Resources • Information Technology • Library • Municipal Court • Parking • Parks • Planning • Police • Pools • Recreation • Storm Water City of Bozeman/Montana State University MS4 Page 5 of 39 MTR040002 September 20, 2021 • Streets • Wastewater Treatment • Water Conservation • Water and Sewer • Water Treatment The responsibility for coordinating, educating, and reporting for compliance with the General Permit is held by the Storm Water Management Program (SWMP) Coordinator.The SWMP Coordinator is part of the Storm Water Division. The Storm Water Division includes the following positions: • Storm Water Program Coordinator • Storm Water Program Specialist • Storm Water Program Manager • Storm Water Program Technicians (2) Montana State University- MSU Montana State University (MSU) urbanized area is 2.78 square miles (1,780 acres) and serves a population of approximately 17,000 people. MSU is located within the COB urbanized area. MSU is a public institution providing education to students and offers support activities to facilitate the educational experience. Land use in the urbanized area consists of sporting fields, green space, parking lots, student housing, buildings for administration, maintenance, food services,and the different colleges. Activities that occur within the urbanized area are student activities and projects, community activities, sporting events, and support services. As a public institution, MSU is considered a non- traditional MS4. MSU is host to councils, committees, boards, and task forces. These include: • Association of Shared Governance Leaders • Budget Council • Campus Sustainability Advisory Committee • Facilities Advisory Committee • Inter-Units Benefits Committee • MSU Benefits Committee Reports • Outreach and Engagement Council • Parking Appeals • Parking and Transportation Advisory Committee • Personnel Advisory Board • President's Commission on the Status of University Women • Recreational Sports and Fitness Advisory Board • Space Management Committee • Tobacco Free Task Force • University Council • University Facilities Planning Board • University Facilities Planning Board-Public Arts • University Marketing Committee City of Bozeman/Montana State University MS4 Page 6 of 39 MTR040002 September 20,2021 The responsibility for coordinating, educating, and reporting for compliance with the General Permit is held by the Storm Water Management Program (SWMP) Coordinator. MSU's SWMP Coordinator is part of Facilities Services. Facilities Services is part of University Services. University Services includes the following departments: • Campus Planning, Design, and Construction • Engineering and Utilities • Facilities Services • Safety and Risk Management • Budget and Accounting Facilities Services helps support the MSU community by offering the following services: • Work Control • Campus Stores • Car Rentals for Campus • Skilled Trades o Carpenters, Electricians, Painters, Plumbers, Laborers, Locksmiths, Grounds Staff,and Custodians COB and MSU—MS4 COB and MSU are co-permittees under the General Permit. The co-permittee status allows the COB and MSU to share responsibilities and work collaboratively to develop and implement the SWMP. The COB does serve as the primary permittee with MSU providing information to COB for reporting. Additionally, MSU is a rate payer under the established utility fee for the COB; therefore, COB provides specific services to MSU.The SWMP and Annual Reports include information for each entity and are submitted as one report for the MS4. The 2020 MS4 annual report, COB Infrastructure Viewer, the Clean Water Act Information Center (CWAIC), and the National Hydrography Dataset (NHD) identify waterbodies the COB and MSU discharges into, identified impairments,Assessment Unit Identification numbers, and status of completed Total Maximum Daily Loads (TMDLs) as follows: • East Gallatin River o MT41HO03_010 ■ Total Nitrogen—TMDL Completed ■ Total Phosphorous—TMDLCompleted • Sourdough Creek (Bozeman Creek) o MT41HO03_040 ■ Total Nitrogen—TMDL Completed ■ E.Coli—TMDL Completed ■ Sedimentation/Siltation—TMDL Completed ■ Alteration in Stream-side or littoral vegetative covers 'l Chloruphyll-a City of Bozeman/Montana State University MS4 Page 7 of 39 MTR040002 September 20, 2021 • Mandeville Creek o MT41HO03_021 ■ Total Nitrogen —TMDL Completed ■ Total Phosphorous—TMDL Completed • Bridger Creek o MT41HO03_110 ■ Nitrate—TMDL Completed • Rocky Creek o MT41HO03_080 ■ No identified or listed impairments The following waterbodies flow through the urbanized area of the MS4 and do not have Assessment Unit Identification numbers, and/or identified or listed impairments: • Aajker Creek • Mathew Bird Creek • Figgins Creek • Flat Creek • Nash Spring Creek • East Fork Catron Creek • West Fork Catron Creek • Cattail Creek • Baxter Creek • Mill Ditch • Story Ditch • Middle Creek Ditch • West Gallatin Canal • Maynard Border Ditch • Farmers Canal Please note: this list of waterbodies is not intended to be a comprehensive list of all state waters flowing through the 2010 U.S. Census designated urbanized area for the MS4. Additional state waters may be present throughout the 2010 U.S. Census designated urbanized area that have not been included in the most recent versions of the sources identified above. 2.0 Inspection Overview The inspection focused on the following parts of the General Permit: • Part II.A—Storm Water Management Program (SWMP) • Part II.A.1—Public Education and Outreach • Part II.A.2—Public Involvement and Participation • Part II.A.3— Illicit Discharge Detection and Elimination (IDDE) • Part II.A.4—Construction Site Storm Water Management • Part II.A.5—Post Construction Storm Water Management in New and Redevelopment • Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations City of Bozeman/Montana State University MS4 Page 8 of 39 MTR040002 September 20, 2021 • Part 11.6—Training • Part ILC—Sharing Responsibility • Part III—Special Conditions o Parts A and B • Part IV—Monitoring, Recording, and Reporting Requirements o Parts A and B Montana DEQ reviewed documents submitted by COB and MSU and documents available on the websites for COB and MSU in preparation for the inspection. A detailed list is provided in Attachment A. Montana DEQ provided notification of the inspection to the COB and MSU in a letter dated May 11, 2021, (Attachment B) and requested additional information be submitted to Montana DEQ before the inspection. A list of the required information is included in Attachment A and B. COB submitted information to Montana DEQ on June 4, 2021. MSU submitted information to Montana DEQ on June 7, 2021. Montana DEQ provided an inspection agenda via email (Attachment A) on June 7, 2021. The inspection was completed on June 15 to 18, 2021.The following personnel were in attendance: • Christopher Romankiewicz, Montana DEQ Lead Compliance Inspector • Don Danesi, Montana DEQ Compliance Inspector • Daniel Congdon, Montana DEQ Compliance Inspector • Adam Oliver, COB Interim Storm Water Program Coordinator, Storm Water Project Manager • Frank Greenhill, COB Storm Water Program Specialist • Lance Lehigh, COB Engineer III* • EJ Hook, MSU, Director, Facilities Services • Megan Sterl, MSU, Engineering and Utility Manager* *These personnel were not in attendance throughout the entire inspection. The inspection included two sections: 1.)discussion and records review of COB and MSU SWMP for the General Permit and 2.) field visits to review drainage areas, including outfalls, and monitoring locations. The results of the inspection completed by Montana DEQ for the MS4 are provided in this inspection report. The report is divided into each part of the General Permit reviewed. Each section of the inspection report provides a brief summary of the SWMP for the MS4 and discusses efforts of the MS4 to fulfill the requirements defined in the General Permit. Following the summaries, additional sections are included which highlight commendable efforts, outline areas for improvement and recommendations, and identify violations. For areas requiring corrective actions, please refer to the conclusion of this inspection report. The inspection report uses the following references when referring the COB: • MS4 —City of Bozeman and Montana State University • COB—City of Bozeman • MSU —Montana State University City of Bozeman/Montana State University MS4 Page 9 of 39 MTR040002 September 20, 2021 3.0 Inspection Results: COB and MSU SWMP and Field Visits 3.1.1 Part II.A SWMP The February 24, 2021, SWMP includes nine (9) sections. SWMP Sections 1.) Program Administration 2.) Capital Project Program 3.) Public Education Program a. Public Education and Outreach b. Public Involvement and Participation 4.) Illicit Discharge Detection and Elimination Program S.) Construction Site Storm Water Management Program 6.) Post-Construction Program 7.) Good Housekeeping Program 8.) Sampling and Evaluation Program 9.) Storm Water Management Plan Updates Section 1.0, Program Administration,of the SWMP provides the following information: • Introduction o Overview of SWMP, which includes COB and MSU, Best Management Practices(BMPs), and defines goals • Background Information o Provides a description of the MS4 ■ Population ■ Land Use ■ Geographic Characteristics ■ Waterbodies ■ Pollutants of Concern from Storm Water ■ Description of Relationship between COB and MSU as co-permittees • City Program Framework o History of SWMP o Description of Utility Fee and COB Programs involved in Managing Utility Fee o Description of Budget Allocations • University Program Framework o Provides a list of Construction Projects o Defines number of hours committed to SWMP for 2020 o Defines Current Staff and MSU's SWMT, including roles and responsibilities for MCMs o Funding • Storm Water Management Team o Organizational Chart for the SWMT for COB o Outlines roles and responsibilities of the SWMT for the COB, includes MCMs o Defines mechanisms for communication for the COB • MS4 Coordination o Outlines the SWMP elements the COB and MSU work collaboratively together on City of Bozeman/Montana State University MS4 Page 10 of 39 MTR040002 September 20, 2021 • Collaborative Organizations o List of Organizations the MS4 works collaboratively with outside of the MS4 • Additional Regulatory Responsibilities o Lists additional MPDES Permit Authorizations applicable to the MS4 • Annual Report • Public Comments o Provides a list of comments collected by the COB Section 2.0, Capital Project Program, of the SWMP provides the following information: • Introduction o Defines the goals of the MS4 Capital Project Program • Total Maximum Daily Load Action Plan o Defines waterbodies with TMDLs, pollutants, and BMPs • Planned Projects o Describes the COB Capital Improvement Plan o Identifies Planned Projects, Goals, and Budgets • Ongoing or Completed Projects o Lists projects COB is working on or has completed • Pollutant Reduction Totals o Calculations of Pollutant Load Reductions from Ongoing Efforts • Performance Measures o Report Card and Grading for Efforts to Protect and Improve Water Quality Sections 3 to 7 of the SWMP address the six minimum control measures (MCM) defined the General Permit. Each MCM section includes subsections that describe efforts to fulfill requirements within the General Permit. Additional supporting information is provided within each section that supports the efforts by each entity to fulfill the requirements under each part of the General Permit. Section 8 of the SWMP provides discussion and results of monitoring completed by the MS4. Section 9 of the SWMP outlines annual updates to the SWMP. Annual updates are included in each section of the SWMP. Note: review and discussion of information provided for MCMs 1 to 6(sections 3 to 7 as outlined above), training, sharing responsibility, special conditions, monitoring, recording, and reporting is provided in other sections of this inspection report. An organizational chart is included within the SWMP. Communication mechanisms for the MS4 include scheduled monthly meetings, emails, and phone calls. Communication mechanisms for COB include weekly meetings with the SWMT, additional meetings with storm water matter experts that are scheduled and impromptu, with additional communications occurring via email and phone calls.The COB also utilizes a variety of software programs to facilitate business process, which provides for additional communication. Communication mechanisms for MSU include periodic meetings, emails, and phone calls. MSU also utilizes a work order software program, which provides additional communication. City of Bozeman/Montana State University MS4 Page 11 of 39 MTR040002 September 20, 2021 3.1.2 Commendable Efforts Montana DEQ identified the following actions to be commendable efforts in Part ILA of the General Permit. MS4 a.) Capital Project Program—Section 2 of the SWMP outlines the MS4's Capital Project Program, which includes: • Total Maximum Daily Load Action Plan o MS4 prioritizes program efforts on reducing storm water impacts in local waterways that have TMDLs o Efforts are focused on addressing pollutants identified in TMDLs; MS4 uses Best Management Practices outlined in MCMs to address pollutants • Planned Projects o MS4 utilizes five-year Capital Improvement Plan (CIP) to outline future projects that the MS4 will complete; identified projects within the CIP specifically address water quality impacts within local waterways that have TMDLs • Ongoing or Completed Projects o MS4 tracks progress on projects outlined in CIP • Pollutant Reduction Totals o MS4 tracks the effectiveness of completed projects and implementation, operation, and maintenance of Best Management Practices (BMPs) to calculate pollutant load reductions to the local waterways that have TMDLs • Performance Measures o MS4 uses performance measures to evaluate the program strategies implemented to protect and improve water quality and manage overall municipal operations The information contained within Section 2 of the SWMP details the MS4's goals to improve existing infrastructure and protect water quality.The MS4 has developed strategies that provide a targeted approach to addressing waterbodies that are impaired and have TMDLs. The strategies, planned projects, and ongoing or completed projects address each MCM and provide a comprehensive approach to protecting water quality within the MS4 while fulfilling General Permit requirements. Additionally, the incorporation of the pollutant reduction program and utilizing performance measures allows the MS4 to evaluate overall program effectiveness.The combination of these resources allows the MS4 to incorporate storm water management throughout municipal operations, utilize resources efficiently and effectively,and demonstrate a commitment to protecting water quality. COB b.) Fulfillment of Program Objectives—COB continues to fulfill program objectives despite position vacancies. COB identifies five positions that makeup the SWMT within the Storm Water Division. Three of the five positions, including the Storm Water Program Coordinator, were vacant at the time of the inspection.The Storm Water Program Specialist and Storm Water Project Manager continue to fulfill permit responsibilities for each minimum control measure while taking on permit responsibilities of the vacant positions. c.) Development and Implementation of a Rate Model—COB developed and implemented a rate model that provides funding allocations for deferred maintenance, operations and maintenance, City of Bozeman/Montana State University MS4 Page 12 of 39 MTR040002 September 20, 2021 and storm water enhancements to the MS4. The rate model was first adopted by COB in 2012. The initial adoption allowed for the COB to map, inventory, and complete an assessment of infrastructure within the MS4.The rate model was reviewed and updated in 2014 with the COB implementing the full Storm Water Utility in 2015. The rate model is reviewed and updated periodically as new development occurs within the urbanized area. The rate model and subsequent management allows for the COB to allocate resources, provide justification, evaluate effectiveness, and request approvals from elected officials and commissions and councils when required.The incorporation of the rate model into business process allows for a comprehensive program management and future planning while engaging the public and elected officials. Note:MSU is a rate payer under the current rate model and therefore is provided services by COB. d.) Program Management Software—COB incorporates a variety of software programs to help facilitate business process and demonstrate compliance with the requirements within the General Permit.The software programs include ePlans,SmartSheet, City Works, Navil.ine, and Esri products. Each software program is utilized by different divisions and/or departments within the COB. The incorporation of these software programs facilitates business process, improves communication internally and externally, allows for automated tracking, and improves annual reporting. 3.1.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Part ILA of the General Permit: MS4 a.) Review, update, and formalize the Memorandum of Understanding (MOU)—A draft, unsigned, MOU was provided that identifies the two entities (COB and MSU) and the tentative agreement between the two entities. Under the draft agreement COB agrees to: • Provide a single contact • Request permission for access on MSU property • Facilitate and document meetings • Update MSU's storm water service fee • Provide SWMP technical assistance • Deliver an updated copy of the SWMP to MSU MSU agrees to: • Provide a single contact • Participate in regular meetings • Complete activities listed in the SWMP • Deliver information, review, and approve the SWMP annually • Provide parking and access to COB vehicles and equipment The draft agreement provides the basic elements for the MS4 to work collaboratively; however, it is unclear which entity is fulfilling the obligations under each MCM to demonstrate compliance with the General Permit. Due to the co-permittee status of COB and MSU, the MOU should identify the MCM and the MCM components each entity is responsible for under the General Permit. Identifying the individual roles and responsibilities will help establish clear cummunications, use resources effectively, improve repur ling,and aid ill uverdll pennit compliance. City of Bozeman/Montana State University MS4 Page 13 of 39 MTR040002 September 20, 2021 COB a.) Organizational Chart—review and update the organizational chart to include Parks and Recreation, Before the inspection, COB took over the responsibility of managing the parks and open spaces within the urbanized area for the COB. Parks and Recreation should be added to organizational chart to provide education, improve communication, and address pollutant generating activities from operations with Parks and Open Space. In addition, Standard Operating Guidelines or Procedures will need to be developed and implemented for parks facilities and activities. The Standard Operating Guidelines or Procedures will need to be completed per MCM 6 of the General Permit. MSU a.) Roles and Responsibilities of University Services—review the roles and responsibilities of each department and section in University Services. Assess the ability of each department and section to contribute to the SWMT/SWMP. Specifically, but not limited to, Campus Planning, Design and Construction, Engineering and Utilities, Facilities Services, and Safety and Risk Management. During the inspection, it was determined the SWMP is the responsibility of the Facility Services Director.The evaluation of the services being provided by other departments and sections within University Services will help identify appropriate SWMT members, improve business process, utilize available resources, increase awareness about the SWMP, and aid in fulfilling reporting requirements, Provide updates to the organizational chart in annual reports. b.) Work Order System—assess the capabilities of the work order system to track and document communications and help fulfill requirements, including reporting, for each MCM. During the CEI, it was determined Facility Services uses a work order system for tracking projects and activities; however, it was determined the work order system is not being consistently used. The use of the work order system will help improve business process, utilize available resources, improve communications,and aid in fulfilling reporting requirements. 3.1.4 Violations Montana DEQ identified the following violation for the information reviewed for Part ILA of the General Permit: failure to develop and implement an adequate SWMP per Part II.A of the General Permit. The following findings were identified with the information reviewed: MS4 a.) Organizational Chart—the MS4 has not formalized a complete organizational chart that accurately represents the members of the SWMT and the position(s) responsible for implementing each minimurn measure for the MS4. The February 24, 2021, SWMP provides an organizational chart that identifies the SWMP Support Divisions, SWMP Team, and SWMP Subject Matter Experts. The information provided in the organizational chart is limited to COB; MSU is not listed or identified as part of the SWMP Team for the MS4. During the inspection process, MSU provided an organizational chart for University Services; however, the organizational chart does not identify which position(s) are responsible for implementing each MCM, including the COB. The organizational chart must identify the SWMT, including primary SWMP Coordinator, and the positions that are responsible for implementing each control measure per Part II.A of the General Permit.The organizational chart was required to be developed within 60 days of the effective date of the General Permit per Part II.A. City of Bozeman/Montana State University MS4 Page 14 of 39 MTR040002 September 20, 2021 3.2.1 Public Education and Outreach and Public Involvement and Participation Section 3.0 of the February 24, 2021, SWMP describes the Public Education Program. The MS4 combines MCM 1—Public Education and Outreach and MCM 2—Public Involvement and Participation to create the Public Education Program for the MS4. Section 3.0 of the SWMP contains the following sections: • Introduction o Overview of goals and strategies to implement Public Education Program within the MS4 • Education Protocol o Defines the educational strategy to reach the general public and target groups identified in the SWMP. The educational strategies include: ■ Passive Engagement ■ Active Engagement • Key Audiences o Lists key target audiences that MS4 intends to focus educational efforts ■ Key target audience information includes targeted audience, activity, rationale, engagement type, and initiatives • Ongoing Initiatives o Lists initiatives implemented but still ongoing by the MS4 ■ Initiatives include Adopt a Storm Drain Program, Educational Storm Water Video Summary, Dog Waste Campaign, Vehicle Decal Wrap, Website, Construction Training, Project WET Curriculum, Post-Construction Storm Water Program, Carpet Cleaning Targeted Outreach, and Lawn Care Targeted Outreach o Information provided for each initiative is year implemented and current activities, task, task outcome, goal, goal outcome, and notes • Future and Deferred Initiatives o Lists future initiatives for the MS4 to implement ■ Future initiatives include education video series, adopt a rain garden,and CATS program The Storm Water Division for the COB maintains a website that provides information about storm water and the SWMP. Information on the COB's website includes: • Learn About Storm Water • Submit a Public Comment • Apply for a Construction Permit • Adopt a Storm Drain • Report Pollution • Design a Storm Water Feature • Maintain a Storm Water Facility • Learn About My Utility Bill • Navigate a System Map Contact the Division City of Bozeman/Montana State University MS4 Page 15 of 39 MTR040002 September 20, 2021 Each of the above items provided on COB's website includes an explanation of the listed item, supporting information and additional items that pertain to the SMWP. For instance, a copy of the up- to-date SWMP, COB Storm Water Design Standards,Annual Reports, Best Management Practices for Construction Sites, permitting information, infrastructure mapping, and detailed information about the storm water utility fee. Additional information includes news, events, and photos. COB collects and compiles comments from the general public on an annual basis.A summary of the comments is provided in the corresponding annual report. MSU provides a webpage under Facilities Services. The webpage includes basic information about co- permitting with the COB, development of the SWMP, and fun facts about storm water. The webpage provides a link the COB's webpage. 3.2.2 Commendable Efforts Montana DEQ identified the following actions to be commendable efforts for Parts II.A.1 and II.A.2 of the General Permit. COB a.) Webpage—COB's webpage provides the minimum required information, plus additional information to provide education and outreach opportunities to key target audiences, stakeholders, and the general public. For instance, COB provides a detailed explanation of the utility fee and examples of the work being completed with the collected utility fees. Using the webpage in this format allows the COB to communicate with key target audiences, stakeholders, and the general public to provide education, maintain transparency about municipal work, and provides a mechanism for gaining support of future projects and activities that benefit water quality. Finally, the webpage provides an opportunity for the general public to participate in the SWMP by providing comments on the SWMP and updates on new or ongoing initiatives. b.) Identification of Key Target Audiences and Rationale—COB developed a list of key target audiences and educational strategies that help demonstrate compliance with other MCMs. For instance, COB identifies the construction industry as a key target audience. The educational strategy is providing training. The General Permit has requirements for the construction industry in MCM 4. Building a training curriculum that educates a key target audience with additional General Permit requirements allows the COB to utilize resources effectively and efficiently, while building a comprehensive SWMP. c.) Tracking of Ongoing Initiatives and Performance Measures—COB develops a performance measure for each of the ongoing initiatives. For instance, COB tracks the number of tons of dog waste collected at the waste stations.The performance measure demonstrates the success of the educational strategy for the key target audience, while at the same time allowing the COB to assess whether the educational strategy is working to protect water quality. d.) Outreach and Educational Campaign Materials—COB utilizes a variety of fliers, pamphlets, and signage to help meet education and outreach goals.The fliers and pamphlets are included in mailings, available on the website, and at COB offices. The flyers and pamphlets have simple graphics that show the activity generating storm water pollution and have easy to understand messaging about what each member of the general public can do to help protect water quality. Signage is provided on vehicles and at public locations. By targeting general public with information that is specific to an activity and keeping the messaging simple, the general public is able to see how their actions can have an impact on water quality. Further, posting signage on City of Bozeman/Montana State University MS4 Page 16 of 39 MTR040002 September 20, 2021 vehicles and in public spaces provide an opportunity for the public to see how the work completed by the COB benefits water quality. MSU a.) Nutrient Study in Mandeville Creek—MSU developed a study that identified contributing sources of nutrients to Mandeville Creek, which is impaired. The study concluded that mowing and turf care activities completed by the Facilities Services were contributing sources of nutrients. MSU changed mowing and fertilization practices that included providing a buffer between the turf management areas along Mandeville Creek. The end result was reduction in pollutant loading to Mandeville Creek. Evaluating pollutant sources and changing existing practices allowed MSU to utilize resources effectively and efficiently while protecting water quality. 3.2.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Parts II.A.1 and II.A.2 of the General Permit: MS4 a.) Key Target Audiences and Initiatives— review the current list of key target audiences and ongoing initiatives. Update the list to include new or additional key target audiences if the outlined goals are achieved for the existing key target audience. For instance,the Carpet Cleaning Targeted Outreach initiative met the goal of eliminating illicit discharges in 2019.The success of this education strategy should be used to expand the list of key target audiences and further address other impacts to water quality from activities occurring within the MS4. COB a.) Key Target Audiences and Performance Measures—review current key target audiences and update to include community events that address community clean-up and hazardous chemical collection events. Presently, the COB hosts or sponsors a variety of community clean-up events with local organizations. Additionally, the COB sponsors a hazardous chemical collection event at the landfill. The community clean-up and hazardous chemical collection events offer the COB an opportunity to increase SWMP awareness and take credit for additional efforts to protect water quality within the urbanized area. Further, the COB can use data collected from the events to provide a performance metric in annual reporting. For instance, total number pounds of trash collected from community clean-up events and total number of gallons of chemicals collected during the hazardous chemical collection event. MSU a.) Outreach Formats and Distribution Channels—Identify outreach formats and distribution channels for key target audiences. During the inspection, it was identified that MSU provides a variety of educational opportunities to students outside of the classroom. For instance, MSU provides educational signs throughout campus that highlight projects intended to benefit water quality. The educational signs are not included in the SWMP as an outreach mechanism. Further, it was identified that MSU utilizes a variety of low impact development techniques and green infrastructure design in new construction and re-development. These efforts by MSU are ongoing and should be used as a foundation to develop a comprehensive outreach and education strategy(s) to key target audiences and the general public. City of Bozeman/Montana State University MS4 Page 17 of 39 MTR040002 September 20, 2021 b.) Key Target Audience and Performance Measures— review current campus activities/events to identify activities/events that are sponsored by MSU that benefit water quality. During the inspection, it was determined MSU hosts campus clean-up days. These events offer MSU an opportunity to increase awareness about the SWMP, provide an avenue for public engagement, and protect water quality. Further, MSU can collect data for annual reporting. For instance, MSU can provide total number of pounds of trash collected for each event. 3.2.4 Violations Montana DEQ identified the following violation for the information reviewed for Parts II.A.1 and II.A.2 of the General Permit: failure to develop and implement an adequate SWMP per Parts II.A.1 and II.A.2 of the General Permit. The following findings were identified with the information reviewed: MSU a.) Key Target Audiences— MSU has not developed a list of key target audiences specific to MSU. Presently, the SWMP identifies key target audiences and initiatives specific to COB and the associated urbanized area.The urbanized area of MSU is a separate from COB and hosts different types of activities that contribute to storm water pollution. Despite future initiatives identifying the CATs program as means to incorporate MSU students, the incorporation of MSU students into the program has not started. The list of key target audiences was to be developed by the end of the first permit year per Part II.A.1.a.i of the General Permit. b.) Website, Outreach Messages, Outreach Formats, and Distribution Channels—MSU has not developed a website that includes the minimum information defined in Part II.A.La.ii, b.1, and 6 of the General Permit. MSU has a website, which provides very basic information about co- permitting with the COB, development of the SWMP, and fun facts about storm water.The webpage provides a link the COB's webpage. Despite MSU being a co-permittee with COB, MSU has a different urbanized area, audiences, and activities that contribute to storm water pollution. The website should provide specific information regarding MSU's SMWP and ongoing activities. Additionally,the website should provide access to outreach materials, outreach event information, and a means for the campus audience to comment on the SWMP. The website was required to be developed by the end of the first permit year. A website was required to be developed per Part II.A.1.a.ii of the General Permit. Outreach messages, outreach formats,and distribution channels were required to be completed per Parts II.A.1.b.i and II.A.1.6 of the General Permit. (Vote: the website is required, at a minimum, to include a copy of the General Permit, outreach materials, event information, SWMP with documents and updates, annual reports, and an effective mechanism for continued public input. c.) Key Target Audience Involvement in SWMP Development and Implementation —MSU has not identified, implemented, and documented approaches for involving key target audiences in the development and implementation of the SMWP, Further, MSU does not provide a website that offers the opportunity for soliciting input from key target audiences, other stakeholders, and the general public.The identification and documentation of approaches for involving key target audiences was required to be completed by the end of the first permit year per Part II.A.2.a.i of the General Permit. The implementation of the approaches for involving key target audiences was required to be completed during the second, third, fourth, and fifth permit years per Part II.A.2.a.ii of the General Permit. The development and advertisement of the website was required to be completed by the end of first permit year per Part II.A.2.b.i of the General Permit. City of Bozeman/Montana State University MS4 Page 18 of 39 MTR040002 September 20, 2021 3.3.1 Part II.A.3 Illicit Discharge Detection and Elimination— IDDE The MS4's storm water infrastructure includes inlets, piping, culverts, ditches, open channels, detention ponds, retention ponds, infiltration facilities, green infrastructure, and low impact development techniques. The MS4 has a total of 463 outfalls. Part 4 of SWMP includes the following information: • Introduction o Describes the goals of the MS4's IDDE Program • Regulatory Framework o Provides the regulatory framework for the program for the MS4 o COB has an established ordinance in Bozeman Municipal Code prohibiting illicit discharges into the MS4 • Illicit Discharge Detection and Corrective Action Plan o Defines the procedure how the COB will address reported illicit discharges • Enforcement Response Plan o Defines the enforcement authority under Bozeman Municipal Code o Defines the informal, formal, and judicial response procedures • Includes information about SWMT roles and responsibilities • Event Tracking o Outlines the IDDE events for each year of the permit o Provides a map of IDDE event locations • Non-Storm Water Discharge Evaluation o Provides the Evaluation of Non-Storm Water Discharges • Outfall Reconnaissance Inventory (ORI) * Provides a list of waterbodies, the number of outfalls, number of outfalls inspected, TMDL, Impairments, and MS4 Waste Load Allocation o Provides a map of Storm Water Outfalls o Provides Outfall Reconnaissance Inventory (ORI) plan for inspection, including high- priority outfalls ■ Results of high priority outfall inspections o Includes a map identifying the high-priority outfalls • Storm Sewer Infrastructure Totals o Lists the infrastructure totals for the MS4 • Information include infrastructure for COB, MSU, Montana Department of Transportation,and Private, Null, or Other 3.3.2 Commendable Efforts Montana DEQ identified the following actions to be commendable efforts in fulfillment of Part II.A.3 of the General Permit: COB a.) Inventory of Storm Water Sewer Infrastructure—COB provides an online map of the urbanized area, waterbodies, and storm water infrastructure, including outfalls, inlets, manholes, curb chases,outlet structure, treatment units, and gravity mains. The map is updated annually, The map is accessible to the general public and stakeholders. The map is comprehensive and offers an interactive tool to help inform,educate, and encourage engagement with the general public and stakeholders. Note: the online map includes the infrastructure operated by MSU. City of Bozeman/Montana State University MS4 Page 19 of 39 MTR040002 September 20, 2021 b.) IDDE Investigations—COB is responding to IDDE complaints within 24 hours or less of the complaint being filed with the city. The General Permit requires an investigation to be completed within seven days. The shortened timeframe being adhered to by the city will help minimize the discharge of pollutants. c.) Mapping of IDDE Complaints/Investigations—COB is mapping IDDE complaints/investigations to assist with tracking and help identify areas of the urbanized area that may be subject to illicit discharges. Mapping of illicit discharges will help identify areas and/or activities that may contribute to illicit discharges within the urbanized area. COB can use this information to identify/assess high priority outfalls, target specific audiences for education and outreach, implement the illicit discharge investigation and corrective action plan, and implement the ERP. d.) Spill Response Vehicle—COB operates and maintains a spill response vehicle, The vehicle is called on-site to coordinate and clean-up spills.The vehicle is managed by the Street Division. A committed spill response vehicle allows the COB to quickly respond to spills and follow a consistent process to minimize impacts to water quality. 3.3.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Part II.A.3 of the General Permit: MS4 a.) Non-Storm Water Discharge Evaluation—review and update the list provided in the SWMP to address Non-Storm Water Discharges and Occasional Incidental Non-Storm Water Discharges. Presently, the MS4 provides one list for both types of discharges; it is not clear how the MS4 determines the difference between the two types of listed discharges in the General Permit. The General Permit requires an assessment of each type of discharge on an annual basis. Updates are to be completed annually and include new sources of non-storm water and occasional incidental non-storm water discharges that are identified during illicit discharge investigations and dry weather screenings. Update the SWMP to address any changes in identification during the evaluation process and document local controls or conditions placed on these discharges. Note: the discharge of chlorinated water is a regulated activity under the Montana Water Quality Act. This applies specifically to the discharge of chlorinated water from municipal operations, water line flushing, and/or swimming pools. These types of discharges are subject to permitting under the General Permit for Disinfected Water and Hydrostatic Testing. Review municipal operations, including but not limited to public swimming pools,fire hydrant pressure testing, hydrant flushing, and water line testing and ensure these discharges are being properly managed by not discharging to the storm sewer system and/or appropriate permit coverage is in place. b.) Dry Weather Inspections of All Outfalls—continue to complete inspections of all outfalls during dry weather using the outfall screening protocol developed by the Center for Watershed Protection or equivalent.COB developed an Outfall Reconnaissance Inventory(ORI) based on the criteria provided in the Center for Watershed Protection. As of February 23, 2021, the MS4 had inspected a total of 221 out of 463. All outfalls are required to be inspected by the end of the fifth year of the General Permit. 3.3.4 Violations Montana DEQ identified the following violation for the information reviewed for Part II.A.3 of the General Permit: failure to develop and implement an adequate SWMP per Part II.A.3 of the General City of Bozeman/Montana State University MS4 Page 20 of 39 MTR040002 September 20, 2021 Permit. The following findings were identified with the information reviewed: MS4 a.) Cooperative Agreement—the M54 has not formalized a cooperative agreement between the COB and MSU. A draft Memorandum of Understanding (MOU)was provided during the inspection process; however, the MOU is a draft and does not specify investigation and enforcement responsibilities. Review of the Enforcement Response Plan (ERP) and Illicit Discharge Investigation and Corrective Action Plan also concluded the investigation and enforcement responsibilities are not specified between COB and MSU.The Cooperative Agreement is required to specify investigation and enforcement responsibilities and be incorporated into ERP and Illicit Discharge Investigation and Corrective Action Plan. The Cooperative Agreement was required to be completed by the end of the second permit year per Part II.A.3.d.iii of the General Permit. Note:MSU is still required to maintain documents of IDDE events even if the neighboring MS4 conducts the investigation (Part II.A.3.f.iv), MSU a.) Adoption of an Ordinance or Other Regulatory Mechanism to Prohibit Illicit Discharges- MSU has not formalized regulatory mechanisms to prohibit illicit discharges. During the inspection, it was determined MSU adheres to the ordinance defined in Bozeman Municipal Code; however, MSU does not have a formal written policy regarding illicit discharges. Further, it is unclear how MSU would work with COB in the event an illicit discharge was detected within the urbanized area of MSU.The adoption of an ordinance or other regulatory mechanism to prohibit illicit discharges was to be completed by the end of the second permit year per Part II.A.3.d.ii of the General Permit. 3.4.1 Part II.A.4 Construction Site Storm Water Management The February 24, 2021, SWMP provides the following information for the MS4's Construction Site Storm Water Management Program: • Introduction o Defines goals and objectives of the Construction Site Storm Water Management MCM • Regulatory Framework o Defines the regulations that provide the COB with regulatory authority for construction projects ■ Bozeman Municipal Code ■ Montana Code Annotated ■ Administrative Rules of Montana • Construction Site Permitting o Defines the permitting programs for the COB ■ Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity • Applicable to sites that disturb one or more acres • Construction Storm Water Permit • Applicable to sites that are less than one acre of disturbance ■ Construction Storm Water Permit • Applicable to single-family residential projects City of Bozeman/Montana State University MS4 Page 21 of 39 MTR040002 September 20, 2021 • Enforcement Response Plan o Outlines protocol for inspections and enforcement o Defines Inspection Type o Describes the Compliance Determination Authority of the COB Lists and Describes the Enforcement Response Options o Lists and Describes the Enforcement Action Options • Additional ERP Information • Site Prioritization Process o Describes the Criteria used to Determine Inspection Frequency of Permitted Projects • Construction Site Inventory o Provides an Inventory of Construction Site Permits and Inspections o Identifies High-Priority Construction Sites ■ Provides Description ■ Lists Inspection Dates • Performance Tracking o Describes the Method COB Evaluates the Effectiveness of the Construction Program o Lists Outcomes of the Evaluation and Provides Recommendations for Improvements • Future Opportunities o Lists Opportunity to Improve Program • Program Documents o Lists Documents Associated with Each Permit Issued by the COB At the time of the inspection, COB was limiting inspections to projects that are determined to be high- priority. High-priority sites are located within the Bozeman Creek watershed. The emphasis on high- priority sites is due to staffing shortages and workload. MSU completes inspections at all projects within the urbanized area of MSU 3.4.2 Commendable Efforts Montana DEQ identified the following actions to be commendable efforts in fulfillment of Part II.A.4 of the General Permit: COB a.) Construction Permitting Program —COB requires owners/operators of construction sites to submit Storm Water Pollution Prevention Plans (SWPPPs) before receiving a Building Permit of Infrastructure Notice to Proceed. The COB requires one of three permits for construction activities within the urbanized area of the COB, which include: a. Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity b. Sites Less than One (1)Acre c. Single-Family Residential Projects The requirement to obtain permit coverage from the COB for projects that are less than the minimum threshold acreage of disturbance defined the General Permit for Storm Water Discharges Associated with Construction Activity is above the minimum requirements defined in the General Permit. The COB's construction permitting program creates a consistent and fair City of Bozeman/Montana State University M54 Page 22 of 39 MTR040002 September 20, 2021 process for construction activities and will help ensure discharges of pollutants from construction projects are minimized. b.) Pre-Construction Meetings—COB completes pre-construction meetings with parties proposing to build within the urbanized area. During the pre-construction meetings, the project is reviewed with reminders being provided of the requirements to obtain the applicable permit coverage based on the construction activity. The pre-construction meetings allow COB to provide information about permitting requirements and helps ensures appropriate permits are acquired before construction activities commence. c.) Best Management Practice (BMP) Manual for Construction Sites—COB has developed a manual for construction sites that provides examples of BMPs for use during construction activities. The BMP manual serves as an educational tool for construction industry professionals. The BMPs provided in the manual are applicable to all projects that qualify under one of the three permits the COB issues for construction activities. The BMP manual provides design specifications for temporary BMPs. The BMP manual aids in the review process of permits, help ensure proper BMP installation on public and private projects, provides for consistent compliance determinations during inspections, and minimizes the discharge of pollutants. d.) Performance Tracking—COB completes a construction site compliance inspection audit in the fall to evaluate compliance with Bozeman Municipal Code and the General Permit for Storm Water Discharges Associated with Construction Activity. The COB uses established criteria to grade each construction site/project into a category.The categories are used to compile the data and provide a score for the overall program. After scoring, the COB provides a discussion on observations and proposes new strategies to improve compliance. Completing an annual audit of construction site compliance allows the COB to evaluate program effectiveness, assess goals and objectives, implement new strategies, and improve compliance and reporting. 3.4.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Part II.A.4 of the General Permit: COB a.) Inspection Frequency Protocol—evaluate and revise the High Priority Construction Site criteria to address inspection frequency following precipitation events. Currently,the criteria include completing inspections after a .25" rain event. Consider completing inspections before precipitation events to ensure BMPs are installed and maintained to protect water quality. Completing inspections following storm events is reactive and may miss opportunities to proactively protect water quality.Additionally, high priority inspections are limited to the Bozeman Creek watershed, which is listed as impaired for sediment and is part of the TMDL Action Plan. Completing inspections before precipitation events in the Bozeman Creek watershed will contribute to the TMDL Action Plan goals and objectives. b.) Storm Water Management Plan Review Checklist(SWPPP Checklist)—review and update the storm water management plan review checklist to include the requirements described in the Non-Numeric Technology Based Effluent Limits of the most current Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity. The current checklist being used by the COB does not specifically address these requirements.The inspection checklist currently being used by the COB incorporates these requirements in section 6.0 Technology Based Effluent Limits. The items presented in the inspection checklist can be incorporated into the Storm Water Management Plan Review Checklist. By incorporating the City of Bozeman/Montana State University MS4 Page 23 of 39 MTR040002 September 20, 2021 items from the inspection checklist into the Storm Water Management Plan Review Checklist, the COB will help establish a consistent SWPPP review and inspection process that ensures compliance with local requirements and the requirements of the General Permit for Storm Water Discharges Associated with Construction Activity. MSU a.) Adopt Standardized Temporary Best Management Practice (BMP) Specifications—the adoption of standardized temporary BMP specifications and requiring construction activities to utilize these specifications will help ensure the requirements described in the Non-Numeric Technology-Based Effluent Limits of the most current Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity are addressed. Additionally, the adoption of standardized temporary BMP specifications will help expedite the review process of permits for projects, help ensure proper BMP installation, provide for consistent compliance determinations during inspections, and minimize the discharge of pollutants to the MS4. Note: MSU can utilize the COB's Best Management Practice Manual for Construction Sites and the associated specifications. 3.4.4 Violations Montana DEQ identified the following violation for the information reviewed for Part II.A.4 of the General Permit: failure to develop and implement an adequate SWMP per Part II.A.4 of the General Permit. The following findings were identified with the information reviewed: MSU a.) Regulatory Mechanism—MSU has not adopted formal policies or other mechanisms that require construction storm water controls on permittee-owned/operated projects.The policy or other mechanism should include the requirement to submit SWPPPs for review and include a provision explaining inspections will be conducted by MSU. An authority summary, written policy, and written procedures were required to be completed by the end of the third permit year and submitted with the 2019 annual report per Part II.A.4.a.ii of the General Permit. Note: Establishing contractual requirements and formalizing policies and procedures towards construction projects will help meet these requirements. b.) Enforcement Response Plan (ERP) —MSU has not developed an ERP. The ERP provided in the SWMP is specific to COB's construction site storm water management program. During the inspection, MSU indicated that it would use the COB's ERP; however, it is unclear if MSU is capable of using Bozeman Municipal Code as a means to pursue enforcement. MSU is required to develop an ERP by the end of the third permit year per Part II.A.4.a.iii of the General Permit. c.) Storm Water Management Plan Review Checklist—MSU has not developed and implemented a construction storm water management plan review checklist that documents, at a minimum, the requirements described in the Non-Numeric Technology Based Effluent Limits of the most current Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity. During the inspection, it was determined that MSU was operating under the premise that COB was completing review of SWPPPs utilizing a checklist. Upon review of the information provided during the inspection process, it was concluded that COB is not completing review of the SWPPPs. Also, it was noted in the meeting summaries between MSU and COB that updated forms were provided to MSU for use. MSU is not using any forms provided by COB. MSU is required to develop and implement a construction storm water management plan review City of Bozeman/Montana State University MS4 Page 24 of 39 MTR040002 September 20, 2021 checklist per Part II.A.4.b.iii of the General Permit. This requirement was to be completed by the end of the first permit year. Note: the most current Non-Numeric Technology Based Effluent Limits can be found in Part 2.1 Technology-Based Effluent Limitations and Parts 3.3 and 3.10 of the January 1, 2018, General Permit for Storm Water Discharges Associated with Construction Activity. d.) Inspection Form or Checklist—MSU has not developed and implemented an inspection form or checklist to ensure consistent and thorough regulated project inspections that includes, at a minimum, the Non-Numeric Technology Based Effluent Limits of the most current Montana DEQ General Permit for Storm Water Discharges Associated with Construction Activity. At the time of the inspection, it was determined permittees are submitting inspection records to the SWMP Coordinator for review; the SWMP Coordinator would follow to verify inspection records and require corrective actions, if necessary.The inspection process was informal and completed by email. Also, it was noted in the meeting summaries between MSU and COB that updated forms were provided to MSU for use. MSU is not using any forms provided by COB.The inspection form or checklist was required to be developed and implemented by the end of the first permit year per Part II.A.4.c.ii of the General Permit. e.) Inspection Frequency Determination Protocol—MSU has not developed and implemented an inspection frequency determination protocol. An inspection frequency determination protocol is required to be implemented per Part II.A.4.c.v of the General Permit. The inspection frequency determination protocol was required to be developed by the end of the first permit year. Note: MSU can develop a similar criterion as COB and establish the inspection frequency determination protocol for projects that discharge to Mandeville Creek and/or Bozeman Creek. 3.5.1 Part II.A.S Post-Construction Storm Water Management in New and Redevelopment The February 24, 2021, SWMP provides the following information for the MS4's Post-Construction Storm Water Management in New and Redevelopment: • Introduction o Defines the goals for the Post-Construction Storm Water Management in New and Redevelopment o Lists the sections contained in the Post-Construction Storm Water Management in New and Redevelopment section of the SWMP • Regulatory Framework and Applicable Documents o Defines the requirements for projects that disturb over an acre, including the types of BM Ps o Lists the regulatory documents and other sources for information about post-construction BMPs • Development Review o Defines the types of projects subject to review and describes the two approaches to post- construction BMPs • On-site approach ■ Off-site approach o Describes the review process COB utilizes for projects that meet the requirements for post- construction BMPs City of Bozeman/Montana State University MS4 Page 25 of 39 MTR040002 September 20, 2021 • Structural BMP Inventory o Categorizes BMPs by ownership ■ Public ■ Private • Open Space/ Parkland ■ Unknown o Categorizes the types of structural BMPs ■ Surface Water Detention ■ Underground Detention ■ Surface Retention ■ Underground Retention o Provides a series of tables that lists the total number of each type of BMP identified for each permit year o Identifies High Priority Structural BMPs ■ Defines criteria to determine high priority structural BMPs ■ Provides a table with totals identified each permit year • Inspection Program o Describes the inspection program o Defines inspection types ■ Typical ■ High Priority o Defines the maintenance priority level criteria used following inspections o Provides a table of the total number of inspections completed each permit year • High Priority Structural BMPs o Lists and describes high priority structural BMPs • Enforcement Response Plan (ERP) o Defines the components to the COB's ERP ■ Design ■ Installation ■ Operation and Maintenance • No formal policy developed at time of inspection • Performance Tracking o Describes the annual Structural BMP Compliance Audit completed by the COB • Defines criteria ■ Describes categories ■ Summarizes results of the audit • Ongoing and Future Initiatives o Lists proposed projects and activities to be assessed and/or completed by the COB At the time of the inspection, COB was in the process of updating the Engineering Standards and the Storm Water Facilities Plan.The documents have been contracted out to consulting/engineering firms and are expected to be complete by the end of 2021. COB is completing inspections of high-priority BMPs located within the urbanized area of MSU. COB provides the inspection report to the SWMP Coordinator at MSU; the SWMP Coordinator creates a work City of Bozeman/Montana State University MS4 Page 26 of 39 MTR040002 September 20, 2021 order or assigns a task to the grounds management team to address any issues identified in the inspection report provided by the COB. 3.5.2 Commendable Efforts Montana DEQ identified the following any action by the MS4 to be commendable efforts in fulfillment of Part II.A.S of the General Permit: COB a.) Review Process—the COB is developing a comprehensive review process that incorporates different divisions and sections within the COB organizational structure. The review process addresses planning, development, construction, and maintenance of post-construction BMPs. The review process provides the COB the opportunity to host conversations at each step of the development process while establishing multiple check points after design approval to ensure the BMPs are installed correctly and have a long-term maintenance plan. The development and implementation of a comprehensive review process allows the COB to increase awareness of the SWMP, establish clear requirements, improve business process and communication, and improve tracking and reporting. 3.S.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Part II.A.5 of the General Permit: MS4 a.) Incorporation of Requirements into Plans, Policies, and Ordinances to Utilize LID Concepts— Continue to assess approaches for incorporating LID concepts into plans, policies, and ordinances. COB staff met in 2020 to discuss the Center for Watershed Protection Code and Ordinance Worksheet and other areas for updates in the COB Design Standards. MSU was not included in the discussion. Further, coordination meetings between COB and MSU did not highlight discussion about LID Concepts. The COB and MSU should consider working together to identify current design standards for new and redevelopment within each entity's urbanized area and develop one formalized plan, policy, and/or ordinance for the entire urbanized area. The combination of resources will help develop consistent requirements throughout the urbanized area. COB a.) Review, update, and finalize Post Construction Documents—COB is in the process of updating the Engineering Design Standards and the Storm Water Facility Plan. Updating these documents will allow the COB to incorporate General Permit water quality requirements, integrating post- construction design manual requirements, update and standardize forms, and provide recommendations for program management and improvement. The documents are scheduled to be updated by the end of 2021. b.) Development and Implementation of an Electronic Plan Submittal Portal—COB is developing a portal for submittal of development applications.The development and implementation of this tool will allow for developers, builders, and contractors to submit plans and specifications electronically, expediate business process, improve communications both internally and externally, and improve tracking and reporting. City of Bozeman/Montana State University MS4 Page 27 of 39 MTR040002 September 20, 2021 MSU a.) Corrective Actions—develop a formal mechanism for tracking corrective actions completed on high priority BMPs and provide the information to the COB for reporting.The tracking of complete d corrective actions will improve annual reporting and communications within MSU and between the COB and MSU. An example of a formal mechanism for tracking would be the use of the work order tracking system. 3.5.4 Violations Montana DEQ identified the following violation for the information reviewed for Part II.A.5 of the General Permit: failure to develop and implement an adequate SWMP per Part II.A.5 of the General Permit. The following finding was identified with the information reviewed: MS4 a.) Enforcement Response Plan (ERP) —the MS4 has not developed a complete ERP to ensure compliance with the installation, operation, and maintenance requirements on regulated projects, including private property. The ERP provided in the SWMP does not address formal and judicial responses for those facilities that do not properly operate and maintain facilities. At the time of the inspection, the COB was in the process of updating Engineering Standards and the Storm Water Facilities Plan.The documents are proposed to be updated in 2021 and presented to the City Commission for decision-making. The finalization of these documents will help complete the ERP.The ERP was to be developed by the end of the fourth permit year per Part II.A.5.a.iii of the General Permit. COB a.) Inspection of all High-Priority Privately Owned BMPs—the COB has not implemented an inspection program to either: o Conduct inspections of high-priority post-construction storm water management controls at least annually; or o To require self-inspection and reporting at least annually The COB has identified privately owned high-priority BMPs; however, inspections of the identified BMPs are not consistently occurring on an annual basis. The SWMP lists the high priority BMPs and identifies the issues with inspection process and the associated BMP, which is largely based on ownership and access issues. Presently, the COB is completing the inspections where and when possible but does not possess another regulatory mechanism to require owners to complete the inspections and submit reports to the COB. An inspection program was required to be developed by the end of the second permit year per Part II.A.5.c.vii of the General Permit. Inspections are required to be completed during the third, fourth, and fifth permit years per Part II.A.5.c.ix of the General Permit. MSU a.) Formalize Post-Construction Policy(s) — MSU has not developed a formal policy that requires post construction BMPs on permittee owned/operated projects. During the inspection, it was determined that MSU requires the design of projects to meet the minimum requirements of the COB and utilize LEED Project Design elements; however, there was no formalized document provided that outlined these requirements. The establishment of a formalized policy was required to be completed by the fourth permit year per Parts II.A.5.a and II.A.5.b of the General Permit. Please note: MSU requires construction projects be designed to meet LEED requirements,- LEED has established requirements for water efficiency, however, it is unclear whether the City of Bozeman/Montana State University MS4 Page 28 of 39 MTR040002 September 20, 2021 standards in LEED will meet the post-construction site storm water management requirements in Part II.A.5.b.iii of the General Permit. Montana DEQ acknowledges the requirements of LEED as a baseline for post-construction design standards; however, additional standards may have to be incorporated to fulfill the requirements of the General Permit. 3.6.1 Part II.A.6 Pollution Prevention and General Housekeeping for Permittee Operations Section 7.0 of the February 24, 2021, includes the following information about the Pollution Prevention /General Housekeeping for Permittee Operations: • Introduction o Defines goals and objectives for the MCM • Infrastructure Operations o Defines the operations,goal, season, and operational area for infrastructure ■ COB and MSU each maintain infrastructure within their own urbanized area with the exception of hydrodynamic separators located within the urbanized area of MSU o Defines performance measures for each of the following items: ■ Inlets and Manholes ■ Storm Sewer Cleaned ■ Infrastructure Repairs ■ Storm Sewer Inspection Information above is taken from the Operations Dashboard and Section 4.8 of the SWMP. • Facility Storm Water Pollution Prevention Program o Defines the facility minimum standards/goals for pollution prevention o Defines inspection protocol for facilities o Lists facilities subject to program requirements ■ Facility ID, Facility Name, Facility Classification, Initial Inspection, Facility SWPPP Development Date, Facility SWPPP Update Date(s) • Activity Storm Water Pollution Prevention Program o Defines activity minimum standards/goals for pollution prevention o Defines inspection protocol for activities o Lists activities subject to program requirements ■ Activity ID, Activity Name, Division, Responsible Entity, Location, Inspection Year, and Activity SWPPP Development Training requirements for MCM 6 are addressed under Part 3.7.1 of this inspection report. 3.6.2 Commendable Efforts Montana DEQ identified the following actions by the MS4 to be commendable efforts in fulfillment of Part II.A.6 of the General Permit: COB a.) Maintenance Districts—the COB has developed five maintenance districts throughout the urbanized area of the MS4. The intention of each maintenance district is breakdown the urbanized area into smaller areas and assign and track routine maintenance activities City of Bozeman/Montana State University MS4 Page 29 of 39 MTR040002 September 20, 2021 throughout each district on an annual basis. Specifically, cleaning out publicly owned inlets and pipe.The goal is to clean 20%of all publicly owned inlets and pipes on an annual basis with a 100%of inlets and pipes to be cleaned once every five-years.The COB assigns and tracks the cleaning of the infrastructure using the Operations Dashboard. Since 2018, COB has cleaned on average 20%each year. Establishing the maintenance districts within the urbanized area allows the COB to plan, complete, and track routine maintenance. Incorporating routine maintenance as part of SWMP allows for the COB to utilize existing efforts and take credit for routine municipal operations.The tracking of the routine maintenance gives the COB performance metrics for reporting and demonstrates a commitment to minimizing the discharge of pollutants. Note:MSU performs the majority of maintenance on infrastructure within the urbanized area of MSU. MSU a.) Maintenance Activities—MSU completes maintenance on inlets and pipe within the urbanized area. Maintenance includes cleaning the inlets and pipes. Since 2018, MSU averages cleaning 67%of inlets on an annual basis. The 67%average is a above the 20%goal set by the MS4. Incorporating routine maintenance into the SWMP allows MSU use resources effectively and efficiently, demonstrates a commitment to protect water quality, and improves reporting. 3.6.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendations to ensure compliance and improve program performance with Part II.A.6 of the General Permit: COB a.) Inventory of Permittee Owned Facilities and Activities—update the current inventory of permittee owned facilities to include the parks, trails, and open spaces acquired by the COB through the creation of the Parks and Trails District. Create a list of potential contaminants from each facility/activity. Identify and list the responsible party(s) responsible for pollution prevention at each facility and activity. Update the map to include these facilities and activities. Finally, develop and implement Standard Operating Procedures (SOPs)or a Facility SWPPP for these facilities and activities. Activities to evaluate include mowing, fertilization, trail maintenance, irrigation maintenance, and construction maintenance. b.) Evaluate Storm Water Pollution Controls in Facility SWPPPs—evaluate the current storm water pollution controls and implement new or additional storm water pollution controls to minimize the discharge of containments at the following facilities: i. City Maintenance Shop (East Tamarack and North Rouse)—the equipment wash area does not have an oil/water separator and is not connected to the sanitary sewer collection system. The equipment wash area is used to wash heavy equipment and trucks. The wash area discharges to a drain that infiltrates into the ground. City engineering standards require connection to the sanitary sewer collection system and an oil/water separator for other types of facilities and operations located within the urbanized area.Additionally, there is no secondary containment in the wash area, which allows excess wash water to flow towards the storm drain inlet on the northside of the property. ii. Snow Storage Site (Haggarty Lane)—the snow storage site is used as a stockpile area for snow removal operations from the downtown area of the COB. Run-off from the stockpile area flows northeast to a natural drainage that connects to state surface waters. There is a small depression that collects initial run-off; however, the majority of City of Bozeman/Montana State University MS4 Page 30 of 39 MTR040002 September 20, 2021 run-off discharges without treatment.The slope that conveys the run-off into the drainage has erosion gully formation. The snow contains oil and grease,trash, and sediment. MSU a.) Inventory of Permittee Owned Facilities and Activities—evaluate and update the current list of facilities and activities provided in the SWMP for MSU. Examples include but are not limited to Bobcat Stadium and Brick Breeden Field House and the subsequent events that occur at each location. b.) Standard Operating Procedures—develop and implement Standard Operating Procedures (SOPS)or Facility SWPPPs for the facilities and SOPS or Activity SWPPPs for the activities listed in the February 24, 2021, SWMP. Update and include SOPS, Facility SWPPPs, and/or Activity SWPPPs identified in item a.). Note: MSU has not developed any SOPS, Facility SWPPPS, and/or Activity SWPPPs for the items listed in the February 24, 2021, SWMP. SOPs, Facility SWPPPs, and/or Activity SWPPPs are to be completed by the end of the fifth permit year. 3.6.4 Violations Montana DEQ did not identify any violations for information reviewed for Part II.A.6 of the General Permit. Montana DEQ recommends the MS4 review the information presented in this section and make updates or changes accordingly to the SWMP. 3.7.1 Part 11.6 Training Section 7.5 of the February 24, 2021, SWMP lists the following categories of trainings: • Comprehensive Training • Awareness Training o Activity SWPPP(ASWPPP) and Facility SWPPP (FWWPPP) • Construction Site Program Management Training • Post Construction Program Management Training Each category provides a list of trainings attended by the SWMT for the COB, the SWMP Coordinator for MSU, and personnel for the MS4. Trainings provided for personnel within the MS4 are completed virtually or online and are tracked using software. The SWMT for the COB has completed the following comprehensive trainings: • 2017: Montana Water Environment Association Conference, Bellevue StormCon Conference, Phase 1 Leadership Training, Hazardous Waste Training • 2018: International Erosion Control Conference, Montana Stormwater Conference, Denver StormCon Conference • 2019: BMP 101 Introduction to Stormwater Management, BMP 201 Certified SWPPP Administrator/Preparer,WQM 130 Stormwater Management for Industrial Operations, 2019: Weekly meeting, bimonthly meeting, WEF-Tech Chicago, WQM 130 Stormwater Management for Industrial Operations • 2020: Virtual Designing Successful Stormwater Facilities with Maintenance and Enforcement in Mind, Virtual National Stormwater Symposium Stormwater Digital Conference,Virtual Storrwater Rate Study with FCS Group, Virtual StormCon Conference,Virtual Stormwater Pond Problems Webcast City of Bozeman/Montana State University MS4 Page 31 of 39 MTR040002 September 20, 2021 The SWMP Coordinator for MSU completed the following Comprehensive Storm Water Training: • 2018: Montana Storm Water Conference Awareness training is provided to personnel within the MS4 and include Facility SWPPP(FSWPPP) and Activity SWPPPP (ASWPPP)training. The trainings are provided a minimum of once every three years. Those personnel that fulfill requirements under the Multi-Sector General Permit for Storm Water Discharges Associated with Industrial Activity complete the training on annual basis. New hires for the COB are provided training within 90-days of hire.The trainings include: Awareness: • Storm Water in Bozeman Video • Rain Check Video Series o Intro o Housekeeping o Vehicle Fueling o Spill Control o Fueling o Vehicle Maintenance o Vehicle Washing o Materials Management o Waste Management o Facility Maintenance o Landscaping Activity SWPPP (ASWPPP): • Water Main Breaks • Sanitary Sewer Overflows • Trenching and Excavation • Sidewalk and Curb Construction • Curb Cutting • Traction Sand Application • Solid Waste Collection • Arena Construction • Parks Mowing • Tree Planting Facility SWPPP(FSWPPP): • MSU Shops Facility • City Shops Complex • Vehicle Maintenance Facility • Laurel Glen Operations Facility • East Gallatin Storage Area • Closed Landfill • Snow Storage Area • MSU Material Storage Area • Water Treatment Plant • Water Reclamation Facility City of Bozeman/Montana State University MS4 Page 32 of 39 MTR040002 September 20,2021 • Public Parking Garage and Lots • MSU Parking Garage and Lots • Bozeman Public Safety Building • Fire Stations#1-3 • Parks and Recreation Note: Personnel at MSU that are required to receive training under the FSWPPP and ASWPPP have not been provided the training as the SOPS,ASWPPP, and FSWPPP were not developed at the time of the inspection. The SWMT for the COB completed the following trainings for the Construction Site Management Program requirement: • 2017: BMP 101 Introduction to Stormwater Management Training, BMP 201 SWPPP Administrator Training, BMP 202 SWPPP Preparer Training, BMP 101 Introduction to Stormwater Management Training, BMP 102 Field Academy, BMP 201 SWPPP Administrator Training, BMP 202 SWPPP Preparer Training, BMP 301 Compliance Evaluation Inspection Training • 2018: International Erosion Control Association Conference, BMP 101 Introduction to Stormwater Management Training, 201/202 SWPPP Administrator and Preparer Training, BMP 100 Construction Dewatering Training, 102 BMP Field Academy • 2019: BMP 101 Introduction to Stormwater Management, BMP 201 Certified SWPPP Administrator/Preparer • 2020: Virtual BMP 301 Conducting Stormwater Compliance Evaluation Inspections, Virtual C1241 Qualified Compliance Inspector of Stormwater—Montana The SWMP Coordinator for MSU completed the following training for the Construction Site Management Program requirement: • 2017: BMP 301 Compliance Evaluation Inspection Training The SWMT for the COB completed the following trainings for the Post-Construction Program requirements: • 2017: Montana Water Environment Association Conference, Bellevue StormCon Conference • 2018: Montana Stormwater Conference (May 1-3), Denver StormCon Conference • 2020: The Benefits of Third-Party Performance Verification:A Better Understanding of NJDEP and WADOE TAPE Webinar, Virtual StormCon Conference, Virtual Stormwater Pond Problems Webcast, Virtual Designing Successful Stormwater Facilities with Maintenance and Enforcement in Mind, Virtual ADS/Bay Saver BMP Design and Maintenance Workshop,Virtual StormCon Conference City of Bozeman/Montana State University MS4 Page 33 of 39 MTR040002 September 20, 2021 The SWMP Coordinator for MSU did not complete trainings for the Post-Construction Program. 3.7.2 Commendable Efforts Montana DEQ identified the following action to be commendable efforts in fulfillment of Part II.B of the General Permit: a.) Tracking of Training—the MS4 centralized all training modules for awareness into an online training management system. COB initiated the use of the online training management system. MSU is currently participating in the online training management system.The MS4 uses the online training management system during the onboarding process for new employees and for existing employees to ensure all employees receive the appropriate training within required timeframes. Centralizing the training program into an online management system allows the MS4 to train employees, track total number of employees trained, ensures employees receive appropriate training within required timeframes, facilitates accurate reporting, and helps raise awareness about the SWMP. 3.7.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendation to ensure compliance and improve program performance with Part II.B of the General Permit: MS4 a.) Training Frequency and Training Curriculum —review the required minimum training frequency and training requirements specified in Part 11.13 of the General Permit. Ensure appropriate staff and members of the SWMT for both COB and MSU responsible for implementing minimum control measures receive the appropriate training within required timeframes. This is applicable to the Construction Site Management Program and Post-Construction Program training programs. The trainings are to include inspection protocol and the implementation of the ERP upon development.This requirement is applicable to all new hires and/or new SWMT members that become part of the SWMT based on the evaluation of existing personnel. 3.7.4 Violations Montana DEQ did not identify any violations for information reviewed for Part II.0 of the General Permit. Montana DEQ recommends the MS4 review the information presented in this section and make updates or changes accordingly to the SWMP. 3.8.1 Part II.0 Sharing Responsibility The COB and MSU applied as a co-permittee under the January 1, 2017, General Permit. Montana DEQ issued an authorization letter to the MS4 on January 31, 2017. At the time of the inspection, the MS4 is sharing responsibilities with each other as traditional and non-traditional MS4s. The COB serves as the primary permittee administering and managing the majority of the requirements within the General Permit, including providing services within the urbanized area of MSU. MSU completes independent activities in fulfilment of General Permit requirements and provides supplemental information to the COB for reporting. Both entities routinely coordinate to share information about ongoing efforts and projects. City of Bozeman/Montana State University MS4 Page 34 of 39 MTR040002 September 20, 2021 3.8.2 Commendable Efforts Montana DEQ did not identify any commendable efforts for the information reviewed for Part II.0 of the General Permit. Montana DEQ recommends the MS4 review the information presented in this section and make updates or changes accordingly to the SWMP. 3.8.3 Areas for Improvement and Recommendations Montana DEQ is providing the following recommendation to ensure compliance and improve program performance with Part ILC of the General Permit: a.) Written Agreements—develop and implement a written agreement or finalize the memorandum of understanding (MOU) between the two entities.The written agreement or MOU should outline, at a minimum, which entity is responsible for each MCM and MCM component. Establishing a written agreement or finalizing the MOU will help define responsibilities, improve program performance, establish better communication, and improve reporting. Provide updates in annual reports. Please note: Review Part 11.A3.d.iii of the General Permit. Specifically, the formalization of the cooperative agreements to implement the IDDE program described in Part H.A.3 of the General Permit. This requirement is in addition to Part 11.0 of the General Permit. 3.8.4 Violations Montana DEQ did not identify any violations for information reviewed for Part ILC of the General Permit. Montana DEQ recommends the MS4 review the information presented in this section and make updates or changes accordingly to the SWMP. 3.9.1 Part III Special Conditions, Part IV Monitoring, Recording, and Reporting Requirements Section 8 of the February 24, 2021, SMWP consists of the following: • Introduction o Outlines goals and objectives of the SWMP Monitoring • Targeted Waterways o Lists the waterbodies and impairments with TMDLs that flow through the urbanized area of the MS4 ■ Bozeman Creek ■ Mandeville Creek • Regulatory Requirements o Describes the regulatory requirements, including monitoring parameters, defined in the General Permit • Urban Runoff Monitoring o Lists and describes the four monitoring sites selected by the MS4 ■ Includes location, monitoring parameters,frequency of analysis, methodology, and analytical procedures • Sampling locations include two residential and two commercial/light industrial o Includes table with summary of monitoring results from sampling performed o Provides an evaluation of the analytical results with a scoring City of Bozeman/Montana State University MS4 Page 35 of 39 MTR040002 September 20, 2021 • In-stream Wet Weather Monitoring o Describes the additional in-stream monitoring program ■ Includes location, monitoring parameters, frequency of analysis, methodology, and analytical procedures • Includes two (2) locations on Bozeman Creek and two (2) locations on Mandeville Creek. Each Creek has one (1) station upstream and one (1) downstream of the MS4 boundary o Includes table with summary of monitoring results from sampling performed o Provides an evaluation of the analytical results with a scoring • Sediment Reduction Monitoring o Describes the sediment reduction program established by the MS4 to address the wasteload allocation in the MDL for Bozeman Creek and sets a self-imposed wasteload allocation for Mandeville Creek o Lists and describes the monitoring locations, methods, analysis, and location o Provides a summary and an evaluation of the results through a scoring process • Long-Term Trend Monitoring o Provides a description of the long-term monitoring plan, which utilizes a macroinvertebrate study o Defines the sites, methods, analysis, and evaluation procedures, including scoring • Evaluation o Describes the process used to comprehensively evaluate the collected monitoring data from each monitoring program ■ Process is completed by compiling the scores generated from each monitoring program o Provides a report card score for the overall effectiveness of the SWMP for the MS4 • Discussion o Provides an evaluation of the outcome of the scores 3.9.2 Commendable Efforts Montana DEQ identified the following items to be commendable efforts for the information reviewed for Part III and IV of the General Permit: MS4 a.) Development and Implementation of a Comprehensive Sampling and Evaluation Program—the MS4 has developed and implemented a comprehensive sampling and evaluation plan that exceeds the minimum requirements defined the General Permit.The sampling and analysis program is comprised of four sperate monitoring programs.These programs include monitoring urban runoff, wet weather, sediment reduction, and long-term monitoring. The MS4 implemented the sampling and analysis plan on the waterbodies that are listed as impaired and have TMDLs.The MS4 uses the analytical results to provide a score for the MS4's efforts to protect water quality. Despite the MS4 calculating a failing grade for 2018, 2019, and 2020, the design of the sampling and analysis plan allows the MS4 to objectively evaluate program effectiveness. Through this process, the MS4 can assess efforts and make systematic changes to the SWMP. Further, the focused efforts of the MS4 within the waterbodies that have impairments and TMDLs will allow the MS4 to develop, refine, and implement effective City of Bozeman/Montana State University MS4 Page 36 of 39 MTR040002 September 20, 2021 strategies that utilize the requirements of each MCM to protect water quality throughout the urbanized area. 3.9.3 Areas for Improvement and Recommendations Montana DEQ did not identify any areas for improvement or recommendations for Parts III and IV of the General Permit. 3.9.4 Violations Montana DEQ did not identify any violations for the information reviewed for Part III and Part IV of the General Permit. 3.10 Field Visits The following areas for COB were evaluated during the field visit: • Alison Subdivision—High Priority Construction Site • Westridge Mechanical Separator • Urban Upstream 01 Sampling Location • Infiltration Gallery • RES-01—Inlet Sampling Location @ S. Bozeman and E. Garfield • Downstream Sampling 01 • IND_01—Industrial Sampling Site at end of Commercial Dr • High Priority Outfall (Overgrown Site) • Mandeville Creek • City Shop • Snow Removal Dump Area The following areas for MSU were evaluated during the field visit: • University Shop and Groundskeeping Facility • Bobcat Stadium Construction Site • Roskie Parking Lot Detention Pond • Headwaters Complex—Green Infrastructure and LID • Settling basin near new residence building • Mandeville Creek Outfalls at North end of Campus The following information provides a brief description of the photos included in the photo report associated with the inspection report. Please refer to the photo report for additional information. COB Field Visit 1.) Alison Subdivision (MTR108735)— High Priority Construction Site a. Photos 1-11 b. Issues identified during evaluation include off site tracking/inadequate track pad BMP's, inadequate maintenance of silt fence, and ineffective erosion prevention for water diverted from settling pond. City of Bozeman/Montana State University MS4 Page 37 of 39 MTR040002 September 20, 2021 2.) Westridge Continuous Deflection Separator(CDS)— a. Photos 12-14 b. No issues were noted at this location. 3.) Urban Upstream Sampling 001 — a. Photos 15-16 b. No issues were noted at this location. 4.) Mason and Tracy Infiltration Gallery— a. Photos 17-20 b. The issue identified during evaluation was accumulation of sediment and organic matter at inlet structures of the infiltration gallery. 5.) RES_01—Sampling Location — a. Photos 21-22 b. No issues were noted at this location. 6.) DWS-01—Sampling Location— a. Photo 23 b. No issues were noted at this location. 7.) IND_01 — Industrial Sampling Location— a. Photo 24 b. No issues were noted at this location 8.) High Priority Outfall (Overgrown Site)— a. Photo 25 b. The issue noted at this location was large trees and shrubs growing in the basin preventing observation and maintenance of this facility. Uncontrolled vegetative growth also reduces the effectiveness of the facility by reducing its capacity to accept large volumes of stormwater. 9.) Mandeville Creek Outfall - a. Photo 26 b. The issue noted at this location was ponding water due to grading that prevented stormwater from being conveyed away from the site. 10.)City Shop— a. Photos 27-38 b. Issues noted during the evaluation include oil and gas spills that appeared to not have been cleaned up, tracking of oil throughout the facility in places where stormwater events will wash these substances into storm outlets, accumulation of organic debris and concrete washout at stormwater outlet. 11.)Snow Removal Dump Area— a. Photos 39-40 b. Issues noted during the evaluation include lack of BMPs to prevent sediment and deicer laden snowmelt from running into the adjacent creek drainage and erosion head-cutting caused by runoff without adequate conveyance structure City of Bozeman/Montana State University MS4 Page 38 of 39 MTR040002 September 20, 2021 MSU Field Visit 1.) Facilities and Groundskeeping Shops a. Photos 1-18 b. Issues noted during the evaluation include a broken-down garbage truck leaking multiple types of fluid and directly adjacent to a storm inlet, leaking grease from a dumpster(photos 5-6), accumulation of grass clippings near where mowers are stored, leaking hydraulic fluid from snow removal equipment in area adjacent to stormwater inlet (photos 9-10), and multiple storm inlets in gravel parking areas that had been filled in by gravel. 2.) Bobcat Stadium Construction Site a. Photos 19-27 b. Issues noted during the evaluation include concrete washout throughout the site was not properly contained, fuels stored without secondary containment, and porta-toilets not staked. 3.) Roskie Parking Lot Detention Pond a. Photos 28-30 b. No issues noted here. A mowing strategy has been implemented here and other areas on campus in response to a study showing that leaving an un-mowed buffer around water ways reduces fertilizer runoff into the creeks. 4.) Headwaters Complex a. Photos 31-34 b. No issues noted. 5.) Parking Lot Swale and Settling Basin at North end of Campus a. 37-38 b. The issue noted here was that the settling basin had not been vegetated after construction and bare soil still remained. 6.) Mandeville Creek Outfalls at North end of Campus a. Photos 39-40 b. No issues were noted in this location. City of Bozeman/Montana State University MS4 Page 39 of 39 MTR040002 September 20, 2021 4.0 Conclusion This report details the results of the inspection completed by Montana DEQ of the MS4's SWMP.The report provides an overview of the MS4, inspection process, and inspection results. The inspection results are divided into each part of the General Permit reviewed and field visits. For each section of the General Permit reviewed a brief summary is provided of the MS4's efforts to fulfill the requirements of the General Permit. Following each summary, additional sections are included that highlight Commendable Efforts, Areas for Improvement and Recommendations, and Violations. For field visits, a summary is provided of observations with additional information being provided in the Photo Report. 4.1 Corrective Actions Summary Based on the information reviewed and interviews completed, Montana DEQ has identified violations in sections 3.1.4, 3.2.4, 3.3.4, 3.4.4, 3.5.4, and 3.7.4 of this inspection report. In order to return to compliance, Montana DEQ is requiring the following information be submitted: I. A written response addressing each finding presented with the violation identified in the following sections of this inspection report: 3.1.4, 3.2.4, 3.3.4, 3.4.4, and 3.5.4. Submit the written responses by March 1, 2022. II. A written response addressing each Area for Improvement and Recommendation in the following sections of this inspection report: 3.1.3, 3.2.3, 3.3.3, 3.3.4, 3.5.3, 3.6.3, 3.7.3, and 3.8.3. Submit the written responses by March 1, 2022. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 1 Photo 1: Photo 2: III 1 Ipl r C 11i1 ' /A II •� N I.K Site #1-Allison Subdivision (MTR108735) Site 41 - Allison Subdivision (MTR108735). Required Signage Present. Photo 3: Photo 4: tea - -_ - �K:.ti - -•+ wM_ -- 4 f 4 Site#1 - Offsite Tracking at Northeastern Entrance/Exit. Site #1 -Track pad at Western Entrance/Exit. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 2 Photo 5: Photo 6: 40 „�'*"•ram"*. #..> LF 2021-06-16 - '� •ray ` . '�. , -`..' ,�...vl•: Site#1 -Silt fence along Eastern Border of subdivision. Site#1 -Close up of silt fence along Eastern border showing gap between bottom of silt fence and ground. Photo 7: Photo 8: s I oft qPM 7. 6. . 0 _. Site#1 -Settling pond receiving water from dewatering Site#1 - Outflow from settling pond in previous photo wells. Outflow from pond entered ditch that runs South to flowing into ditch running to the North. North and enter creek at the Eastern border of the subdivision. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facilit /Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 3 Photo 9: Photo 10: r ITt) r ��' Sri � Al-•I - ^. 1, _ 1 I. Site#1 - End of ditch fed by settling pond. Show flow out Site #1 - Post Contruction BMP—Pond in NE corner of the end of ditch and toward point of discharge into Middle subdivision. Creek Ditch. Flow is largely going around rip rap. Photo 11: Photo 12: ,gam • '` jum i• r Site#1- Post Construction BMP—Second pond SW of first Site#2—West Ridge Continuous Deflection Separator pond. (CDS)—Showing inlet and covers over the unit. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 4 Photo 13: Photo 14: 4 r. 1 a a 1; •' 1 , P s ss Site #2—Inside CDS unit—showing some accumulation of Site#2—Small pond that CDS outlet discharges to.This garbage and other debris. pond flows to another pond (flows out culvert pictured above right) and then into adjacent water way (Middle Creek Ditch). Photo 1S: Photo 16: AL r; or 7 a. �.1 A: . I45.K5686, K823,48684f, M 1 Site#3—Upstream 001 Sampling location—South side of E Site#3—Bozeman Creek near where samples are Kagy Blvd - Bridge over Bozeman Creek. Confluence of collected for Upstream 001. Bozeman Creek and Spring creek is just South of this bridge. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather:Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 5 Photo 17: Photo 18: 9'_Vbi?re Standing at the Intersection of Beautification and Innovation. cr+.rs y..t_orw � =:..ter:..."..."'� srw..r.ar.anw. • -. • • 4 Site#4—Mason and Tracy Infiltration Gallery—Sign Site#4—Curb cut and beehive inlet for infiltration gallery— explaining how the infiltration gallery works and why it is showing buildup of sediment and debris. important. Photo 19: Photo 20: 1 mi Site#4—Infiltration gallery from across the street— Site#4—Signage for picking up dog waste and dog waste showing overall of the structure and curb cut inlets. bags—across the street from infiltration gallery along walking path and adjacent to community garden plot. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 6 Photo 21: Photo 22: 1 _ 'y°T Site#5—Residential 001—Sampling location at the Site #5—Emblem next to storm inlet reads " No Dumping intersection of S Bozeman and E Garfield. —Drains to Bozeman Creek." Photo 23: Photo 24: M Site#6—DWS 01 —Sampling location on Bozeman Creek, Site#7—IND-01—Sampling location for monitoring North of 1-90. Picture shows stream flow gauge and potential industrial discharge to stormwater. Arrow added equipment for monitoring. Samples are collected at this to show storm inlet location. location for aquatic invertebrate analysis. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 7 Photo 25: Photo 26: RAW tr gill Site#8—Overgrown Outfall Basin—Located along trail Site #9—High Priority Outfall to Mandeville Creek—Outfall system NW of where Commercial Dr. dead ends. Actual located on North side of W. Villard St.,just East of N 9''St. outfall somewhere in the direction of the arrow. Grading of ditch at this outfall causes pooling. Photo 27: Photo 28: 1 Site # 10—City of Bozeman Shop-Arrow indicates Site # 10—CDS Unit location of inlet and adjacent CDS unit. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 8 Photo 29: Photo 30: f I f. Site# 10—Refueling location at city shop. Note multiple Site # 10—Same fueling location as last photo. This photo spills around the fuel tank. shows tracking and direction of flow to either an outfall or dry well. Photo 31: Photo 32: all r ' 1� S MMA- 4. fS Site # 10—Oil spills in large equipment parking area. Site # 10—Close up of oil spill in large equipment parking Arrow shows direction of flow toward dry well inlet. area. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance, Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 _Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 9 Photo 33: Photo 34: ANNPL 1 I S. 1S Site# 10—Equipment wash area that drains to dry well Site # 10—Dumpster adjacent to covered parking/mechanic shop area.Arrows indicates location of trench drain and drywell that trench drain flows to. Photo 35: Photo 36: DATUM - Y 14 1 7S Site # 10—Dry well location referenced in previous Site# 10—Sloped drainage area in front of covered pictures parking/mechanic shop building. Arrow indicates outfall location Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 10 Photo 37: Photo 38: Y Site # 10—Outfall at end of sloped drainage area from Site# 10—Close of inlet showing what appears to be previous photo concrete washout and grass clippings Photo 39: Photo 40: y i :. Site #11—Snow Management Facility—Parking lot where Site#11—Blue arrows indicate direction of snow melt snow is piled. Headcutting was observed where blue flow toward creek bottom. There is a seasonal spring fed arrow runs to the left and down toward creek bottom. creek that runs through the area where melting snow flows off of parking lot. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance, Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 1 Photo 1: Photo 2: DATUM f . or 77,1 pow 4VP OWN M a a s Site 41—MSU Facilities Shop Area Site #1 —Close up of leaking fluid from garbage truck adjacent to stormwater inlet. Picture shows garbage truck waiting for repair. Leaking fluids can be seen under truck, adjacent to stormwater Photo 3: Photo 4: DIRECTION S 1 1 ti SS f. SS Site#1 —Red arrow indicates plastic hose draining Site#1—Red arrow indicates location of stormwater inlet. condensate which pools and flows toward stormwater Blue arrow indicates direction of flow based on inlet. Blue arrow indicates direction of flow. topography. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 2 Photo 5: Photo 6: DIRECTION ARE, \ _ - f Site#1 —Dumpster leaking oil. Blue arrows show potential Site#1—Close up of oil leak at dumpster. Oil appears to stormwater flow direction that could carry oil to storm be coming from grease pump for piston on garbage lid. inlet. Red arrow indicates storm inlet. Photo 7: Photo 8: i G Site#1—Grass clippings accumulated on ground outside Site #1—Sand and gravel for road traction stored under of groundskeeping shop. awning. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 3 Photo 9: Photo 10: - 7 l � � 0 2021-06-17 Site#1—Maintenance attachment storage area overall Site#1—Close up of equipment leaking hydraulic fluid. view. Arrow indicates stormwater inlet adjacent to storage area. Photo 11: Photo 12: �, 09 ti n�c t. +. Site #1—Storm inlet on West side of shop facility in Site#1 —A second storm inlet in gravelled area. gravelled area. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County:Gallatin Page 4 Photo 13: Photo 14: 1 Site#1—Close up of previous inlet showing that gravel has Site#1 —A third stormwater inlet surrounded by, and filled in the storm inlet. filled in with,gravel. Photo 15: Photo 16: GROWTH pROOUC�'S� NlGfuosru Ugro�..n�,.... !I!1411,I�� Site#1—Empty fertilizer barrels stored between building. Site #1—Close up of fertilizer label on barrels. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 5 Photo 17: Photo 18: DIRECTION 45.66371 N ACCURACY 39 ft DIRECTION 45.66362"N ACCURACY 31 ft Mir 4da 2021-06-11 a , Site #1 — Fueling operation at MSU shop and grounds Site #1 —Another picture of fueling operation looking facility. North. Red arrow indicates location of stormwater inlets downgradient from fueling operation. Photo 19: Photo 20: r 44- 2021-06-17 2021-06-11 as s Site#2 —Bobcat Stadium Construction Site—Picture Site#2 —A second concrete washout at Bobcat stadium shows concrete washout station with overflowing showing washout water and concrete residue outside of concrete. washout container. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance, Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather:Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 6 Photo 21: Photo 22: e• ai Site#2—Concrete washout residue on ground from curb Site#2— Uncontained concrete washout. form and concrete cutting machinery. Photo 23: Photo 24: 2021-06-17 -� -)J- `� .• �- ;, •etii,>�: - -� �ter. Site#2—Uncontained concrete washout. Site#2—Concrete washout that appears to have been dumped from concrete mixer. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 7 Photo 25: Photo 26: , 1 r i low y Site#2—Concrete forms and fuel storage. No secondary Site #2—Porta-toilets that do not appear to be staked. containment observed for fuels. Photo 27: Photo 28: � � I K G \ M Site #2 — Backside of porta-toilets from previous picture Site #3—Detention pond at the Roskie Parking lot. with pooling moisture on ground. Detention pond discharges to Mandeville Creek. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training, and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: Whone County: Gallatin Page 8 Photo 29: Photo 30: Site#3—Blue arrow indicates overflow point from Site#3—A vegetated Swale on campus to the East of detention pond in previous picture and blue line indicates Yellowstone building. location of Mandeville creek from the point that it exits culvert. Photo 31: Photo 32: M .. Site #4—Vegetated Swale to catch and infiltrate roof Site #4—Informational sign about rain gardens in the runoff water from the Gallatin building. Headwaters Complex. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather: Sunny, low 80's Facility/Permittee: City of Bozeman MS4 Photographer: DC and DD Location: Bozeman, MT Camera: iPhone County: Gallatin Page 9 Photo 33: Photo 34: Site#4—A second informational sign about native Site #4—A third sign about sustainable development in landscaping in the Headwaters Complex. the Headwaters Complex. Photo 35: Photo 36: 2021-06-17 Site#5—Condenser Units on the West side of the Miller Site #5—A second shot of condensate water outside of building with condensate water running to stormwater the Miller building. inlet. Signature: Date: Click or tap to enter a date. Montana Department of Environmental Quality—Compliance,Training,and Technical Assistance Photo Form Permit Number: MTR040002 Weather:Sunny, low 80's Facilit /Permittee: City of Bozeman M54 Photographer: DC and DD Location: Bozeman, MT Camera: Phone County:Gallatin Page 10 Photo 37: Photo 38: i I 9111 y Site#6—Large Stormwater Swale between two large Site#6— New detention basin outside of new residence parking lots at the North end of Campus. hall at the North end of campus. Photo 39: Photo 40: Site#7—Outfall from detention pond at Wally Byam Park. Site 47—Outfall from parking lot south of new residence Outfall goes into Mandeville Creek. hall going to Mandeville Creek. Signature: Date: Click or tap to enter a date. City of Bozeman/Montana State University Page 1 of 6 MTR040002 Attachment A Attachment A— Documents Reviewed and Inspection Agenda Documents Reviewed for the Inspection • Authorization for Reapplication under the General Permit for Storm Water Discharges Associated with Small Municipal Separate Storm Sewer Systems (MS4) • Form MS4 Reapp • City of Bozeman and Montana State University Storm Water Management Plan • Form MS4-AR and Supplemental Information for Calendar Years 2017, 2018, 2019, and 2020 Montana DEQ requested the following information be submitted by June 4, 2021.The information was requested in a May 11, 2021, letter. Submitted information was reviewed before the inspection. • Part ILA—Storm Water Management Program o Formalized Mechanisms of Communication—Meeting Agendas, Notes and/or Summaries,for all meetings completed with the Storm Water Management Team for 2020 ■ City of Bozeman and Montana State University o Current Organizational Chart for Montana State University or how they fit into Bozeman's Organizational Chart (Part 1.5 of the SWMP —Section 1.0 Page 10) • Part II.A.3—Illicit Discharge Detection and Elimination (IDDE) c, Part II.A.3.d.ii—Adopt Ordinance or Other Regulatory Mechanism to Prohibit Illicit Discharges ■ Montana State University—provide a copy of regulatory mechanism to prohibit illicit discharges and summary of legal authority. c, Part II.A.3.d.iii—Provide a copy of formalized cooperative agreements between City of Bozeman and Montana State University to implement the IDDE prograrn. ■ City of Bozeman and Montana State University o Part II.A.3.d.iv—IDDE enforcement response plan (ERP) through ordinance, formal policies, or memoranda of understanding with neighboring MS4 ■ Montana State University o Part II.A.3.e.i and e.iii—Copies of all dry weather screening field sheets and/or reports completed of outfalls for 2020 including high priority outfalls screened in 2020. ■ City of Bozeman and Montana State University o Part II.A.3.f.iii and f.iv—Documentation of All Investigations Conducted and Corrective Actions Completed for 2020 ■ City of Bozeman and Montana State University • Part II.A.4—Construction Site Storm Water Management o Part II.A.4.a.ii—Formal Policies or Other Mechanisms to Require Construction Storm Water Controls ■ Montana State University—provide a copy of the authority summary,written policy, and written procedures. o Part II.A.4.a.iii—Formal ERP to ensure compliance with the construction storm water management regulatory mechanisms on regulated projects including private property. ■ Montana State University o Part II.A.4.b.ii and b.iii—Copies of Completed Storm Water Management Plan Review City of Bozeman/ Montana State University Page 2 of 6 M TR040002 Attachment A Checklists ■ City of Bozeman • Provide copies for 10 projects completed in 2020. • Requested copies are limited to review completed on projects equal to or over one acre of disturbance. ■ Montana State University • Provide copies for all reviews completed in 2020(3) o Part II.A.4.c.iii—Copies of Completed Construction Site Storm Water Management Inspection Checklists ■ City of Bozeman • Provide copies of 10 projects for 2020. • Requested copies are limited to inspections completed on projects equal to or over one acre of disturbance, ■ Montana State University • Provide copies of completed inspections in 2020 (5) o Part II.A.4,c.iv—Copy of up-to-date "Regulated Project Inventory" containing all permits and approvals received or applied for frorn State or Federal regulatory agencies. ■ City of Bozeman —provide regulatory project inventory for projects equal to or over one acre of disturbance for 2020. ■ Montana State University— provide regulatory project inventory for all projects for 2020. • Part II.A.S—Post Construction Site Storm Water Management in New and Redevelopment o Part II.A.S.b,i and b.ii—Copy of Plan Review Checklist and copies of all completed Plan Review Checklists ■ City of Bozeman—copies for projects reviewed in 2020. ■ Montana State University—copies for projects reviewed in 2020. o Part II.A.S.b.iii—Formal ERP Documentation supporting the implementation of requirements that all regulated projects comply with the run-off reduction requirement. ■ City of Bozeman and Montana State University o Part II.A.S.c.i and c,ii—Copy of Inspection Form or Checklist and copies of all completed Post Construction Storm Water Management Control Inspection Forms ■ City of Bozeman—copies for all inspections completed in 2020. ■ Montana State University—copies for all inspections completed in 2020. o Part II.A.S.c.viii—Copies of all inspections completed of permittee-owned high priority post-construction storm water management controls,findings, and resulting compliance actions. ■ City of Bozeman and Montana State University o Part II.A.S.c.ix—Copies of all inspections completed of all high priority privately-owned post construction storm water management controls. ■ City of Bozeman —copies of all inspections completed in 2020. • Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations c> Part II.A.6.a.i—Copy of Inventory of Permittee Owned/Operated Facilities and Activities ■ City of Bozeman and Montana State University o Part II.A.6.a.ii—Updated Map Identifying Locations of All Facilities and Activities ■ City of Bozeman and Montana State University o Part II.A.6.a.iii—Copies of Inspections and Communications Completed in conjunction City of Bozeman/Montana State University Page 3 of 6 MTR040002 Attachment A with the development of Standard Operating Procedures (SOPS) ■ City of Bozeman and Montana State University o Part II.A.6.a.iv—Copies of training curriculum and sign in sheets completed in conjunction with the development of each SOP. ■ City of Bozeman and Montana State University Part II.A.6.a.v—Copies of records for trainings completed in 2019 and 2020. ■ City of Bozeman and Montana State University • Part 11.6—Training: o Copy of the curriculum and/or information covered during all trainings conducted in permit year 2017. ■ City of Bozeman and Montana State University o Copy of the curriculum and/or information covered during all trainings conducted in permit year 2020. ■ City of Bozeman and Montana State University o Sign in sheets for all personnel that attended trainings, including new hires between January 1, 2017, to present date. ■ City of Bozeman and Montana State University • Part II.0—Sharing Responsibility o Copy of Written Agreements between the City of Bozeman and Montana State University for implementation of any Minimum Control Measure (MCM) • Part III—Special Conditions and Part IV—Monitoring, Recording,and Reporting Requirements o Copies of Bench Sheets, Chain of Custody Forms, and Laboratory Analytical Reports for all monitoring completed in 2020. ■ City of Bozeman Inspection Agenda Montana DEQ provided an inspection agenda on June 7, 2021, by email. Montana DEQ provided the following agenda: Tuesday.June 15, 2021 City of Bozeman and Montana State University 8:00—8:30: Inspection Kickoff: Welcome Overview and Goals of the Inspection, Initial Q&A, Inspection Schedule Requested Staff: • City of Bozeman:Storm Water Program Manager, Storm Water Project Manager, Water Quality Specialist, Storm Water Program Technician • Montana State University:Director, Facilities Services Optional: • City of Bozeman: City Manager, Assistant City Manager, Public Works Director • Montana State University: Engineering and Utility Manager 8:30— 10:00: Part II.A Storm Water Management Program (SWMP)/ Part 11.6 Training/ Part II.0 Sharing Responsibility Requested Staff: • City of Bozeman:Storm Water Program Manager, Storm Water Project Manager, Water Quality Specialist Storm Water Program Technician • Montana State University: Director, Facilities Services City of Bozeman/Montana State University Page 4 of 6 MTR040002 Attachment A 10:00— 10:30 Break 10:30— 12:00: Part II.A.3 Illicit Discharge Detection and Elimination(IDDE) Requested Staff: • City of Bozeman:Storm Water Program Manager, Storm Water Project Manager, Water Quality Specialist, Storm Water Program Technician • Montana State University:Director, Facilities Services Optional: • City of Bozeman:Storm Operations Superintendent,Assistant Storm Operations Superintendent, Storm Water Operations Foreman,Storm Water Operator 12:00— 1:00 Lunch City of Bozeman 1:00—2:30: Part II.A.1 Public Education and Outreach and Part II.A.2 Public Involvement and Participation Requested Staff:Stone Water Program Manager, Storm Water Project Manager, Water Quality Specialist, Storm Water Program Technician Optional: Economic Development:Neighborhoods and Communication 2:30—3:00: Break 3:00—4:30: Part II.A.4 Construction Site Management Requested Staff:Storm Water Program Manager,Storm Water Project Manager,Storm Water Program Technician 4:30—5:00:Closing—Day 1 Recap/Day 2 Overview/Q&A Requested Staff:Storm Water Program Manager, Storm Water Project Manager, Storm Water Program Technician Wednesday,June 16, 2021 City of Bozeman 8:00—8:30: Day 2—Overview, Follow-Up Day 1,Q&A Requested Staff.Storm Water Program Manager, Stone Water Project Manager, Storm Water Program Technician 8:30—10:00: Part II.A.5 Post-Construction Site Storm Water Management in New and Redevelopment Requested Staff:Storm Water Program Manager, Storm Water Project Manager, Storm Water Program Technician Optional: City Engineer, Development Review Manager, Development Review Engineer 10:00—10:30: Break 10:30—12:00: Part II.A.6 Pollution Prevention/Good Housekeeping for Permittee Operations City of Bozeman/Montana State University Page 5 of 6 MTR040002 Attachment A Requested Staff:Storm Water Program Manager, Storm Water Project Manager,Storm Water Program Technician Optional:Assistant City Manager, Storm Operations Superintendent, Assistant Storm Operations Superintendent, Storm Water Operations Foreman, Storm Water Operator, Solid Waste, Water Conservation, Water Reclamation Facility, Street Operations Superintendent, Street Operations Assistant Superintendent, Street Sweeping Crew 12:00—1:00: Lunch 1:00—2:00: Part III Special Conditions/ Part IV Monitoring, Recording and Reporting Requirements Requested Staff:Storm Water Program Manager, Storm Water Project Manager,Storm Water Program Technician 2:00—5:00: Field Visits—TBD Thursday,June 17, 2021 Montana State University 8:00—8:30:Welcome: Overview, Follow-Up Day 1 and 2,Q&A Requested Staff:Engineering and Utility Manager, Director, Facilities Services 8:30—9:30: Part II.A.1 Public Education and Outreach and Part II.A.2 Public Involvement and Participation Requested Staff.- Director, Facilities Services 9:30—9:45: Break 9:45 to 10:45: Part II.A.4 Construction Site Management Requested Staff.• Director, Facilities Services 10:45—11:45: Part II.A.5 Post-Construction Site Storm Water Management in New and Redevelopment Requested Staff. Director, Facilities Services 11:45—12:45: Lunch 12:45—1:45: Part II.A.6 Pollution Prevention /Good Housekeeping for Permittee Operations Requested Staff: Director, Facilities Services 1:45—2:45: Part III Special Conditions/Part IV Monitoring, Recording and Reporting Requirements Requested Staff.-Director, Facilities Services 2:45—3:00: Break 3:00—4:30: Field Visits—TBD Requested Staff. Director, Facilities Services City of Bozeman/ Montana State University Page 6 of 6 MTR040002 Attachment A 4:30—5:00:Closing—Day 3 Recap/ Day 4 Overview/Q&A Requested Staff. Engineering and Utility Manager, Director, Facilities Services Friday,June 18,2021 City of Bozeman and Montana State University 8:00—12:00:Inspection Follow-Up/Inspection Wrap-Up: Inspection Summary, Conclusion, Preliminary Findings, Discussion of Inspection Reporting Process,Q&A (Timeframe will be confirmed during inspection) Requested Staff: • City of Bozeman:Storm Water Program Manager, Storm Water Project Manager, Water Quality Specialist, Storm Water Program Technician • Montana State University:Director, Facilities Services Optional: • City of Bozeman: City Manager, Assistant City Manager, Public Works Director • Montana State University:Engineering and Utility Manager ATTACHMENT B DE QAM�- of Fnvlronmental Quality May 11, 2021 The Honorable Cyndy Andrus City of Bozeman PO Box 1230 Bozeman, MT 59771 RE:Small Municipal Separate Storm Sewer System(MS4) Inspection:City of Bozeman and Montana State University, Montana Pollutant Discharge Elimination System (MPDES) Permit Authorization MTR040002: City of Bozeman Small MS4 Dear Mayor Cyndy Andrus: The Department of Environmental Quality(DEQ) is providing notification for a planned inspection of the City of Bozeman and Montana State University MS4 Programs. Montana DEQ is scheduling the inspection for June 15-18,2021. The inspection will be completed with representatives of Montana DEQ and members of the Storm Water Management Team for the City of Bozeman and Montana State University. Information to be reviewed during the inspection will include the following sections of the General Permit for Storm Water Discharges Associated with Small Municipal Storm Sewer Systems (General Permit): • Part ILA—Storm Water Management Program • Part II.A.1—Public Education and Outreach • Part II.A.2—Public Involvement and Participation • Part II.A.3—Illicit Discharge Detection and Elimination • Part II.A.4—Construction Site Storm Water Management • Part II.A.5—Post Construction Storm Water Management in New and Redevelopment • Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations • Part I1.B—Training • Part ILC—Sharing Responsibility • Part III—Special Conditions o Parts A and B • Part IV—Monitoring, Recording, and Reporting Requirements o Parts A and B Information Requested To facilitate the inspection, Montana DEQ is requesting the following information be submitted from each respective party by June 4, 2021: • Part ILA—Storm Water Management Program o Formalized Mechanisms of Communication—Meeting Agendas, Notes and/or Summaries, for all meetings completed with the Storm Water Management Team for 2020 ■ City of Bozeman and Montana State University o Current Organizational Chart for Montana State University or how they fit into Bozeman's Organizational Chart(Part 1.5 of the SWMP—Section 1.0 Page 10) Greg Gianforte,Governot I Chris Dorrington,Director I P.O.Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 vmv.deq.mt.gov City of Bozeman-City of Bozeman Small MS4 Page 2 of 4 MTR040002 May 11, 2021 • Part II.A.3— Illicit Discharge Detection and Elimination (IDDE) o Part II.A.3.d.ii—Adopt Ordinance or Other Regulatory Mechanism to Prohibit Illicit Discharges ■ Montana State University—provide a copy of regulatory mechanism to prohibit illicit discharges and summary of legal authority. o Part II.A.3.d.iii—Provide a copy of formalized cooperative agreements between City of Bozeman and Montana State University to implement the IDDE program. ■ City of Bozeman and Montana State University o Part II.A.3.d.iv—IDDE enforcement response plan (ERP) through ordinance, formal policies, or memoranda of understanding with neighboring MS4 ■ Montana State University Part II.A.3.e.i and e.iii—Copies of all dry weather screening field sheets and/or reports completed of outfalls for 2020 including high priority outfalls screened in 2020. ■ City of Bozeman and Montana State University Part II.A.3.f.iii and f.iv—Documentation of All Investigations Conducted and Corrective Actions Completed for 2020 ■ City of Bozeman and Montana State University • Part II.A.4—Construction Site Storm Water Management o Part II.A.4.a.ii—Formal Policies or Other Mechanisms to Require Construction Storm Water Controls ■ Montana State University—provide a copy of the authority summary,written policy, and written procedures. o Part II.A.4.a.iii—Formal ERP to ensure compliance with the construction storm water management regulatory mechanisms on regulated projects including private property. ■ Montana State University o Part II.A.4.b.ii and b.iii—Copies of Completed Storm Water Management Plan Review Checklists ■ City of Bozeman • Provide copies for 10 projects completed in 2020. • Requested copies are limited to review completed on projects equal to or over one acre of disturbance. ■ Montana State University • Provide copies for all reviews completed in 2020 (3) o Part II.A.4.c.iii—Copies of Completed Construction Site Storm Water Management Inspection Checklists ■ City of Bozeman • Provide copies of 10 projects for 2020. • Requested copies are limited to inspections completed on projects equal to or over one acre of disturbance. ■ Montana State University • Provide copies of completed inspections in 2020(5) o Part II.A.4.c.iv—Copy of up-to-date "Regulated Project Inventory"containing all pert-nits and approvals received or applied for from State or Federal regulatory agencies. • City of Bozeman—provide regulatory project inventory for projects equal to or over one acre of disturbance for 2020. Greg Glanforte.Governor I Chris Dorrington, Director I P.O.Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov City of Bozeman-City of Bozeman Small M54 Page 3 of 4 MTR040002 May 11, 2021 • Montana State University—provide regulatory project inventory for all projects for 2020. • Part II.A.5—Post Construction Site Storm Water Management in New and Redevelopment o Part II.A.5.b.i and b.ii—Copy of Plan Review Checklist and copies of all completed Plan Review Checklists ■ City of Bozeman—copies for projects reviewed in 2020. ■ Montana State University—copies for projects reviewed in 2020. o Part II.A.5.b.iii—Formal ERP Documentation supporting the implementation of requirements that all regulated projects comply with the run-off reduction requirement. ■ City of Bozeman and Montana State University o Part II.A.5.6 and c.ii—Copy of Inspection Form or Checklist and copies of all completed Post Construction Storm Water Management Control Inspection Forms ■ City of Bozeman —copies for all inspections completed in 2020. ■ Montana State University—copies for all inspections completed in 2020. o Part II.A.5.c.viii—Copies of all inspections completed of permittee-owned high priority post- construction storm water management controls, findings,and resulting compliance actions. ■ City of Bozeman and Montana State University o Part II.A.5.c.ix—Copies of all inspections completed of all high priority privately-owned post construction storm water management controls. • City of Bozernan—copies of all inspections completed in 2020. • Part II.A.6—Pollution Prevention/Good Housekeeping for Permittee Operations o Part II.A.6.a.i—Copy of Inventory of Permittee Owned/Operated Facilities and Activities ■ City of Bozeman and Montana State University o Part II.A.6.a.ii—Updated Map Identifying Locations of All Facilities and Activities ■ City of Bozeman and Montana State University o Part II.A.6.a.iii—Copies of Inspections and Communications Completed in conjunction with the development of Standard Operating Procedures(SOPS) ■ City of Bozeman and Montana State University o Part II.A.6.a.iv—Copies of training curriculum and sign in sheets completed in conjunction with the development of each SOP. ■ City of Bozeman and Montana State University o Part II.A.6.a.v—Copies of records for trainings completed in 2019 and 2020. • City of Bozeman and Montana State University • Part 11.6—Training: o Copy of the curriculum and/or information covered during all trainings conducted in permit year 2017. ■ City of Bozernan and Montana State University o Copy of the curriculum and/or information covered during all trainings conducted in permit year 2020. ■ City of Bozeman and Montana State University o Sign in sheets for all personnel that attended trainings, including new hires between January 1, 2017, to present date. ■ City of Bozeman and Montana State University • Part II.0—Sharing Responsibility o Copy of Written Agreements between the City of Bozeman and Montana State University for implementation of any Minimum Control Measure(MCM) Greg Gianforte,Governor I Chris Dorrington,Director I P.O.Box 200901 1 Helena,MT 59620.0901 1(406)444-2544 1 www.deq.mt.gov City of Bozeman-City of Bozeman Small MS4 Page 4 of 4 MTR040002 May 11, 2021 • Part III—Special Conditions and Part IV—Monitoring, Recording, and Reporting Requirements o Copies of Bench Sheets, Chain of Custody Forms, and Laboratory Analytical Reports for all monitoring completed in 2020. • City of Bozeman Documentation outlined in the section titled Information Requested can be mailed to: Montana Department of Environmental Quality, Water Protection Bureau, 220 West Lamme, Suite 1B, Bozeman, MT 59715, Attn: Christopher Romankiewicz. Alternatively, the documentation can be submitted electronically through the City of Bozeman's FACTS account. If you have questions regarding your FACTS account, please contact Gina Self with the MPDES Data Management Team at(406)444-5388 or Gself@mt.gov. If the requested information is not available, please provide a written explanation detailing why the information is not available by June 4, 2021. Montana DEQ will confirm the inspection date, provide an inspection schedule, and identify appropriate staff one week before the date of the scheduled inspection. Notification will be provided by email. Montana DEQ looks forward to meeting with your staff and discussing the efforts of the City of Bozeman Small MS4 to protect water quality through the MS4 Program. If you have any questions, please feel free to contact me at the information listed below. I appreciate you and your staff's time and consideration. Sincerely, C Christopher Romankiewicz Lead Compliance Inspector Compliance, Training, and Technical Assistance Water Quality Division Montana Department of Environmental Quality cromankiewicz@mt.Pov cc:Kayla Mehrens,Storm Water Program Coordinator,City of Bozeman,via email:kmehrens@bozeman.net EJ Hook, Director,Facilities Services,Montana State University,via email:edward.hookl@montana.edu FACTS Greg Gianforte,Governor I Chris Dorrington,Director I P.O. Box 200901 1 Helena,MT 59620-0901 1(406)444-2544 1 www.deq.mt.gov