HomeMy WebLinkAboutStormwater Auditppp'—_-M�
M Mo ntana Department of
Brian Schweitzer, Governor Y ���O\ ENUIAL OTATUTY Richard H. Opper, Director
P.O. Box 200901 - Helena, MT 59620 -0901 - (406) 444 -2544 - www.deq.mt.gov
December 12, 2011
City of Bozeman
Chris Kukulski, City Manager c/o Debbie Arkell, Director of Public Service
P.O. Box 1230
Bozeman, MT 59771 -1230
Montana State University
Robert V. Lashaway, Associate Vice President Administration and Finance
c/o Jeff Butler, Director — Facility Services
P.O. Box 172760
Bozeman, MT 59717
Montana Department of Transportation
Dwayne Kailey, Chief Operations Officer
c/o Jeffery Ebert, Butte District Administrator
P.O. Box 3068
Butte, MT 59702 -3068
RE: Municipal Separate Storm Sewer System (MS4) Audit
City of Bozeman Permittee; Montana Department of Transportation and Montana
State University- Bozeman Co- Permittees
MPDES Permit #MTR040002
Dear Mr. Kukulski, Mr. Lashaway and Mr. Kailey,
On August 2nd _ 4th, 2011, the Montana Department of Environmental Quality (The
Department) obtained the services of a contractor, Water and Environmental Technologies
(WET), to conduct a MS4 audit of MPDES #MTR040002 Permittees: the City of Bozeman (City);
Montana Department of Transportation (MDT) and Montana State University (MSU) Bozeman.
The goals and benefits of the MS4 audit were to:
Determine compliance status /assistance with appropriate enforcement;
Assist with permit renewal /issuance /SWMP development & implementation;
• Assess pollutants of concern;
Enforcement Division - Permitting & Compliance Division - Planning, Prevention & Assistance Division • Remediation Division
• Provide technical assistance;
• Encourage stronger coordination between permitting authority and co- permittees; and
• Promote better understanding of expectations and permit requirements.
During the audit, permit - related documentation was reviewed, staff were interviewed, field
inspections of receiving waters, outfall locations, and construction /industrial sites were
conducted, and results were summarized into a narrative report.
The audit evaluated compliance of the following MS4 control measures:
• Program Management;
• Public Education and Public Participation;
• Illicit Discharge Detection and Elimination;
• Construction Activities;
• Post - Construction Activities;
• MS4 Maintenance Activities (Pollution Prevention /Good Housekeeping);
• Industrial /Commercial Facilities; and
• Other Permit Conditions.
The program evaluation resulted in eight (8) Commendable Elements, sixteen (16) Program
Deficiencies, twenty -three (23) Recommendations for Improvement, and one (1) Permit
Violation. Overall the City of Bozeman, MDT, and MSU have implemented a large portion of
their Storm Water Management Program (SWMP) and have made a commitment to reducing
pollutants to the Maximum Extent Practicable (MEP). However, the audit team identified
several program deficiencies and recommendations for improvement, with the majority related
to better documentation of activities, and more specific measureable goals to allow regular
evaluation of the SWMP.
The only Permit Violation was in the Illicit Discharge Detection and Elimination program
component. The permittees must compile a comprehensive map of the storm water system
and receiving waters, and it must be reproducible and readily available for use by the public,
city departments, and M54 stakeholders.
Each co- permittee must specifically address all of the violations, program deficiencies, and
recommendations for improvement stated in this report, and submit a plan to ensure all items
are brought into compliance. This plan must be submitted in a separate document from, but
concurrent with, the 2011 Annual Report due from each co- permittee by the March 1, 2012
deadline.
z
The Department thanks you for your cooperation during the audit and appreciates the
commitment you have made to improve storm water quality. Please feel free to contact the
Water Protection Bureau at (406) 444 -6727 with any questions.
Sincerely,
(S�lb 4n�4—-
Kari Smith, Supervisor
Compliance and Technical Section
Water Protection Bureau
cc: Josh Vincent, Water and Environmental Technologies, PC
Attachment
3
PHASE 11 MS4 AUDIT REPORT
CITY OF BOZEMAN
PERMIT MTR040002
PREPARED FOR:
Department of Environmental Quality
Kari Smith, Supervisor
Compliance and Technical Support Section
Water Protection Bureau
P. O. Box 200901
Helena, MT 59620 -0901
m jt
WATER & SUBMITTED BY:
Water & Environmental Technologies
ENVIRONMENTAL 480 East Park Street, Suite #200
Butte, MT 59701
TECHNOLOGIES 406.782.5220
October 28, 2011
TABLE OF CONTENTS
1.0
INTRODUCTION .............................................................................. ..............................1
1.1
Description of City of Bozeman MS4 ............................................................. ..............................2
1.2
Description of Hydrology and Receiving Waters ........................................... ..............................2
2.0
AUDIT PROCEDURES ...................................................................... ............................... 3
2.1
MS4 Audit Scope— Minimum Control Measures .......................................... ..............................4
2.2
Materials Reviewed for the Audit ................................................................. ..............................4
2.3
Audit Interviews and Participants ................................................................. ..............................5
2.4
Site Visits Conducted During Audit ................................................................ ..............................5
3.0
AUDIT FINDINGS ......................................................... ............................... ............... 5
3.1
Program Management .................................................................................. ..............................6
3.2
Public Education and Outreach/ Public Involvement and Participation ....... ..............................7
3.3
Illicit Discharge Detection and Elimination ................................................... .............................10
3.4
Construction Site Storm Water Runoff Control ............................................ .............................12
3.5
Post - Construction Storm Water Management ............................................ .............................15
3.6
MS4 Maintenance - Pollution Prevention /Good Housekeeping .................. .............................17
3.7
Industrial /Commercial Facilities ................................................................... .............................19
3.8
Site Inspections ............................................................................................. .............................20
3.8.1
Construction Site Field Inspections ............................................................... .............................20
3.8.2
MS4 Maintenance Facility ............................................................................. .............................21
3.8.3
Industrial /Commercial Inspection ................................................................ .............................22
3.8.4
MS4 Outfalls .................................................................................................. .............................22
3.9
Additional Permit Conditions ....................................................................... .............................23
FIGURES
Figure 1. Bozeman MS4 Map
Figure 2. Facility /Outfall Inspection Locations
ATTACHMENTS
A — City of Bozeman (MTR #040002) Documents Reviewed
B — City of Bozeman Audit Schedule
C— Completed Program Evaluation Worksheets
D — Site Visit /Outfall Inspection Forms
E — Completed EPA Form 3560
1.0 INTRODUCTION
As defined, a municipal separate storm sewer system (MS4) is a system of conveyances owned
by a state, city, town or other public entity that discharges to waters of the US, designed or
used to collect or convey storm water, is not a combined sewer, and is not part of a Publicly
Owned Treatment Works. To prevent pollutant discharges to receiving waters of the United
States, operators must obtain a National Pollutant Discharge Elimination System ( NPDES)
permit and develop a storm water management plan. Phase II of the NPDES was issued in 1999
and requires small regulated MS4's in urbanized area to obtain permit coverage for discharging
storm water.
The Montana Department of Environmental Quality (the Department) administers the MPDES
(Montana Pollutant Discharge Elimination System) permitting, compliance and enforcement
program for MS4 general permits under the authority of 75 -5 -402, MCA, of the Montana Water
Quality Act and Section 402 and 303 of the federal Clean Water Act. The City of Bozeman
submitted its initial MS4 permit application in December 2005, and was issued authorization
under MPDES General Permit #MTR040002 on July 17, 2006. The City of Bozeman has two co-
permittees: Montana Department of Transportation (MDT) and Montana State University
(MSU). Permit coverage was reauthorized on February 22, 2010 under MDEQ's January 1, 2010
General Permit for Storm Water Discharge Associated with Small Municipal Separate Storm
Sewer System (MS4), #MTR040000 (General Permit).
This report details results of an audit conducted on the City of Bozeman MS4 program on
August 2nd _ 4th, 2011. The primary purpose of this audit was to review the Storm Water
Management Program (SWMP) to determine whether the permittee is adequately
implementing the program to reduce pollutants in the MS4 to the Maximum Extent Practicable
(MEP). The audit provided an opportunity for the permittee to evaluate and assess their
pollutants of concern and consider ways to reduce impacts. Specific benefits to the MS4
permittees include:
• Determining compliance /assistance with appropriate enforcement;
Stronger coordination and working relationship between permitting authority,
permittee, and co- permittees;
Better understanding of expectations and permit requirements and opportunity to
clarify;
Better understanding by permitting authority of operations, constraints, priorities, etc;
and,
More effective SWMP and improved water quality.
1
The audit was also conducted for MDEQ to meet the Federal Fiscal Year 2011 compliance
monitoring commitment imposed by the US Environmental Protection Agency (EPA).
1.1 DESCRIPTION OF CITY OF BOZEMAN MS4
The City of Bozeman MS4 consists of a series of pipes, catch basins, ditches, ponds, and other
infrastructure and serves a population of approximately 38,000 citizens in Gallatin County,
Montana, as described in its 2010 Annual Report. The MS4 regulated area is defined as the city
limits. A map showing the Bozeman MS4 city limits and MS4 area was created by the audit
team and is included as Figure 1. Co- permittee MDT's MS4 consists of a system of roads,
ditches, and culverts located throughout the MS4 boundary, as well as a maintenance facility
located in the city limits. Co- permittee MSU's MS4 consists of a series of pipes, catch basins,
and associated infrastructure serving the campus of Montana State University.
The City of Bozeman has an unknown number of outfalls to area receiving waters. They have
identified one major outfall into Bozeman Creek, which has had previous sampling and dry
weather screening conducted. The City currently conducts semi - annual monitoring on two
outfalls to satisfy conditions of the permit:
001A — Residential Outfall: Westridge and Overbrook St; Latitude = 45 °39'20.5 "N
Longitude = - 111 °2'33 "W
002A — Commercial Outfall: Tamarack Street; Latitude = 45 °41'18.96 "N Longitude = -
11173.84 "W
MDT and MSU are not required to monitor outfalls at this time.
1.2 DESCRIPTION OF HYDROLOGY AND RECEIVING WATERS
The City of Bozeman MS4 is located in the Gallatin River watershed (4th Code HUC 10020008)
Authorized receiving waters according to their respective permittee are shown below:
Spring Creek (City of Bozeman);
Bozeman /Sourdough Creek (City of Bozeman & MDT);
Bridger Creek (City of Bozeman);
East Gallatin River (City of Bozeman & MDT);
Farmer's Canal (City of Bozeman & MSU);
Bear Creek (City of Bozeman);
Baxter Creek (City of Bozeman & MDT);
Maynard Border Ditch (City of Bozeman & MSU);
Mandeville Creek (City of Bozeman & MSU);
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Middle Creek Ditch (City of Bozeman & MSU);
West Gallatin Canal (MSU); and
Unnamed Ditch —West End MSU Boundary (MSU).
According to the MDEQ Clean Water Act Information Center ( CWAIC), the following receiving
waters are listed on the Montana 303(d) list for multiple impairments:
Bear Creek;
Bridger Creek;
Bozeman (Sourdough) Creek; and
East Gallatin River.
Currently there is no waste load allocation assigned to the MS4 as TMDLs are not yet
completed; however, the CWAIC lists probable causes for impairments as high density
municipal operations, residential districts, septage disposal, channelization, and yard
maintenance, which represent typical impacts from an MS4.
The City of Bozeman MS4 is located in an intermontane valley bottom region with a mix of
urban development, rural residential and commercial development, and agricultural land.
Several tributary receiving waters and irrigation ditches flow through the MS4 boundary from
south to north and discharge into the East Gallatin River, which flows from southeast to
northwest through the northern portion of the MS4. The Gallatin River flows from south to
north near the west boundary of the MS4.
2.0 AUDITPROCEDURES
The City of Bozeman and its co- permittees (MDT and MSU) were provided notification of the
program review and copies of all audit interview forms a minimum of 20 -days prior to the
scheduled audit. The MS4 audit was completed according to the January 2007 EPA Document
MS4 Program Evaluation Guidance (EPA- 833 -R -07 -003). Program evaluation worksheets from
this document were completed on the following topics:
• Program Management;
• Public Education and Public Participation;
Illicit Discharge Detection and Elimination;
Construction Activities;
Post- Construction Activities;
• MS4 Maintenance Activities (Pollution Prevention /Good Housekeeping); and
Industrial /Commercial Facilities.
3
Due to slight differences between federal and state requirements, additional questions were
developed to address additional requirements in the Department's January 1, 2010 General
Permit for Storm Water Discharge Associated with Small Municipal Separate Storm Sewer
System (MS4), MTR040000 (General Permit). The audit was conducted by asking questions
from each compliance area to all participants.
2.1 MS4 AUDIT SCOPE- MINIMUM CONTROL MEASURES
The EPA MS4 Program Evaluation Guidance document (EPA- 833 -R -07 -003) was written to cover
program evaluation of both Phase I and Phase II MS4 programs; as a result, MS4 control
measures are presented in a slightly different format than the Department's General Permit for
Storm Water Discharge Associated with Small Municipal Separate Storm Sewer System (MS4),
MTR040000. Specifically, the following differences should be noted:
Program Management and Industrial /Commercial Facilities control measures are not
specifically included in the Montana General Permit;
Public Education and Public Participation control measures are separate topics in the
Montana General Permit but are combined in the EPA document; and
The EPA document control measure topic named MS4 Maintenance is labeled as
Pollution Prevention /Good Housekeeping in the Montana General Permit; however,
both cover the same information and requirements.
The City of Bozeman audit was completed following the EPA guidance document. For specific
areas where the Montana General Permit differs from EPA guidance, additional questions and
information were requested to satisfy all portions of the Montana General Permit. For control
measure topics that were covered in the EPA guidance document but not included in the
Montana General Permit, the audit findings simply summarize these topics and make
recommendations, as necessary. No violations will be issued or compliance activities required
unless the requirements are specifically cited in the Montana General Permit (MTR040000).
Additional permit requirements in the Montana General Permit that were not included in a
control measure summary will be covered under the topic of Additional Permit Conditions
(Section 3.9).
2.2 MATERIALS REVIEWED FOR THE AUDIT
Prior to conducting the on -site portion of the audit, a thorough records review was conducted
of all MS4 permit - related information present in the MDEQ files. These data included permit
applications, annual reports, correspondence, and any enforcement actions. In addition, the
City of Bozeman, MDT, and MSU provided additional documents during and after the DEQ audit
proceedings in support of specific program component reviews. A document list of all
information reviewed as part of the audit is included in Attachment A.
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2.3 AUDIT INTERVIEWS AND PARTICIPANTS
WET personnel conducted a detailed audit of the City of Bozeman MS4 permit on August 2nd
through 4th, 2011. The audit included interviews with multiple permittee and co- permittee
staff. The audit participants included representatives from the City of Bozeman and co-
permittees, MSU and MDT, along with members of the Gallatin Local Water Quality District.
A list of MS4 audit participants were as follows:
1. Debbie Arkell, City of Bozeman- Director of Public Service;
2. Dustin Johnson, City of Bozeman - Project Engineer;
3. John VanDelinder, City of Bozeman - Street Superintendent;
4. Dan Stevenson, MSU - Office of Facilities, Services Manager;
5. EJ Hook, MSU - Office of Facilities Services, Environmental Services Manager;
6. Dave Hill, MDT, Phase 2 NPDES Permitting Coordinator;
7. Moriah Thunstrom, MDT, Field Services Engineer;
8. Alan English, Gallatin Local Water Quality District;
9. Tammy Crone, Gallatin Local Water Quality District;
10. C. Ray Stock, MDT -Field Maintenance Bureau Chief; and
11. Mark Peterson, MDT -Field Maintenance Superintendent.
2.4 SITE VISITS CONDUCTED DURING AUDIT
Site visits were performed at the following locations during the audit:
• MS4 Outfall Locations: 001A (Commercial /Industrial) and 002A (Residential);
• MSU Stadium Expansion — Construction Site;
• City of Bozeman WWTP — Construction Site and Industrial Facility;
• City of Bozeman Landfill — Industrial Facility; and
• MDT Maintenance Facility — Maintenance Facility.
Figure 2 shows the locations of the site inspections. Site visit Details of the site visits are
include in the audit findings Section 3.8.
3.0 AUDIT FINDINGS
The audit findings are summarized by MS4 control measure. A brief description of each control
measure is included, as well as a summary that highlights the major activities that the
permittees are conducting as part of their MS4 program. An evaluation of each area resulted in
program activities being classified into four categories, Permit Violations, Program Deficiencies,
Recommendations for Improvement, and Commendable Elements. The multi -day evaluation of
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Bozeman's MS4 program and field inspections spanned three days; an audit schedule is
included in Attachment B. Completed copies of all Program Evaluation Worksheets are included
in Attachment C, and completed copies of all site visit /outfall inspection forms are included in
Attachment D. EPA form 3560 for the City of Bozeman #MTR040002 has been compiled and is
included in Attachment E.
3.1 PROGRAM MANAGEMENT
Effective Program Management is essential to help with the development, implementation,
administration, and assessment of a SWMP. Each control measure should have a clear
management process that defines and facilitates activities by the permittees, co- permittees,
partnering agencies /organizations, and other stakeholders. Another important aspect of a
successful Program Management component is to ensure that there are measurable goals and
standards by which program effectiveness can be evaluated. The entire MS4 program, as a
whole, should be regularly assessed and modified to increase its effectiveness.
Program Management Summary:
A SWMP has been developed and formally adopted by the City of Bozeman (including MSU) and
MDT. The Gallatin Local Water Quality District (GLWQD) addresses many public education and
public participation MS4 requirements on behalf of the City. The City also works with the
Greater Gallatin Watershed Council (GGWC) on water quality issues. All permittees have staff
identified that are responsible for MS4 management, although the City and MSU do not have
full -time staff currently assigned and MS4 activities are not specifically included in their job
responsibilities. MDT has recently hired an MS4 Coordinator to work with District
Environmental Engineering Specialists. An organization chart is in place for all permittees. Co-
permittees do not communicate in an organized manner on storm water issues, but there
appears to be adequate communication and a positive working relationship between entities
when storm water needs arise.
Permit Violations: None
Program Deficiencies:
The City should have formal agreements with any outside entity that is responsible for
implementing components of the SWMP. As a result, the City of Bozeman needs to
implement a formal Memorandum of Understanding (MOU) with MSU and the GLWQD.
The MOU's should not only define the roles and responsibilities for implementing SWMP
tasks, but also include measurable goals and assessment strategies.
11
Recommendations for Improvement:
A formal MS4 umbrella group consisting of the City of Bozeman, MSU, MDT, and the
GLWQD members is recommended. An umbrella group encourages regular
communication between permittees and stakeholders and provides a forum where
storm water issues can be discussed and addressed.
MSU's MS4 representatives are relatively new to their respective positions; as a result,
efforts to increase knowledge of MS4 permit requirements through training
opportunities would be beneficial.
• Stronger connection between TMDL impairments and activities identified in the SWMP
should be developed. Once final TMDLs are completed for applicable stream segments
within the MS4, a formal evaluation is recommended to develop and implement
potential load reduction strategies for pollutants related to the MS4.
• The 2005 SWMP developed by the City should be updated, with a stronger focus on
improved documentation and measurability of goals.
Based on feedback from the Department on previous MS4 program reviews, MDT is in
the process of revising its MS4 program to more specifically address the issues of the
City of Bozeman and other permitted MS4's. MDT is encouraged to complete this
revision as soon as possible.
Commendable Elements:
The level of cooperation and communication between City of Bozeman, MSU, MDT, and
the GLWQD is commendable. Entities regularly work together to address storm water
needs and maintenance activities. The City has teamed with the GLWQD, a local entity
with experience in water quality issues, to address public education and public
involvement activities. The GLWQD has also completed a restoration prioritization plan,
has completed riparian enhancement projects (Mandeville Creek), and has completed
ground water monitoring within the MS4.
Participants: Debbie Arkell (COB), Dustin Johnson (COB), Dave Hill (MDT), Moriah Thunstrom
(MDT), Dan Stevenson (MSU), EJ Hook (MSU), Alan English ( GCWQD), and Tammy Crone
( GCWQD).
3.2 PUBLIC EDUCATION AND OUTREACH PUBLIC INVOLVEMENT AND PARTICIPATION
The Public Education control measure should provide information to the intended audiences
regarding storm water. Although each permittee will have its own set of goals, the ultimate
outcome is to elicit a change in behavior that will benefit water quality. The Public Participation
control measure should encourage and allow volunteer assistance on storm water projects and
public input on policy decisions and storm water activities in the MS4. Successful Public
Education and Public Involvement programs should include specific message development and
7
packaging, target audiences, distribution mechanisms, evaluation methods, and public
participation activities. It is common for multiple permittees and co- permittees to combine
resources on public education and public involvement measures, as activities often accomplish
common goals and cover the same geographic region. Public Education and Outreach and
Public Involvement /Participation efforts must meet the requirements of Sections II.6.1 and
Section II.6.2 of the Montana General Permit.
Public Education and Outreach /Public Involvement and Participation Summary:
The City addresses Public Education and Outreach and Public Involvement and Participation in
its original SWMP. The City has developed some specific /detailed storm water messages
related to MPDES permitting, pet waste, and household hazardous waste. MDT has also
developed both general and specific storm water messages through its public education
program. Public education is geared towards groups that show an interest. MDT directs their
public education materials to the general public and then focuses on target behaviors (Pet
Waste, IDDE, Household Hazardous Waste). MSU's target audience is the campus residents and
adjacent neighbors with litter reduction as their focus. The City and MDT both use their
websites and local offices as distribution mechanisms, while MSU uses orientation week. Public
education materials are distributed during Catapalooza, a three day festival which welcomes
new and returning students to MSU. MSU conducts six (6) training sessions to educate the
maintenance staff on Pesticides, Herbicides, and Fertilizers. MDT has developed a special
website related to storm water and the MS4 program: www.montanams4.com. The City also
distributes materials during presentations at the county fair and to other interested groups.
Regarding public participation and involvement, the GLWQD has a volunteer monitoring
program for area streams, MDT has its Adopt -A- Highway cleanup program, and MSU has
addressed surface water protection on the campus by increasing the riparian buffer
surrounding Mandeville Creek. MSU also conducts a Campus Cleanup that promotes
awareness of good housekeeping.
Permit Violations: None
Program Deficiencies:
Although public education and public involvement activities are being conducted, a
more organized approach by all permittees and co- permittees in the implementation of
these control measures per Section II.6.1 and II.B.2 of the Montana General Permit
should be developed. Co- permittees should improve its Public Education and Public
Involvement plans with the roles and responsibilities assigned and measurable goals
defined. Storm water messages need to a specifically address the storm water
EN
challenges unique to the community, and target audiences should be expanded to
include entities such as industrial and commercial business and agricultural groups. The
SWMP needs to document public education and involvement activities, and regularly
evaluate these activities for potential improvements. Different activities should be
considered that will help engage the public to be more active and informed on storm
water issues. Documentation of tasks such as tracking attendance at events, volumes of
education materials distributed, and number and location of outreach /participation
events is encouraged. The City should improve the accessibility and usability of its
website by making storm water information easier to find, and making more
information available to the public. One option for this would be for permittees to
better promote and use MDT's www.montanams4.com website. The City and MDT
should have their SWMP's available publicly for review.
The General Permit requires that permittees identify how the success of this minimum
control measure will be evaluated, including how the measurable goals for each of the
BMPs were selected. All permittees need to improve their measurability and evaluation
techniques to determine the effectiveness of selected BMPs.
Recommendations for Improvement:
Co- permittees could work more closely on public education and involvement activities.
Coordination of efforts will result in cost savings for each permittee and a more unified
message to the citizens of Bozeman.
• The City should have its SWMP available publicly for review.
• A strong recommendation for public involvement is to engage MSU students in storm
water activities through internships or volunteer activities. Storm water activities could
include: 1) identification and stenciling of drop inlets, 2) storm sewer system mapping,
3) observation or studies of runoff patterns and water quality during rainfall events, and
4) preliminary design or recommendations for needed storm water controls. These
activities will help engage a large target audience in the MS4 (MSU campus), and will
benefit all co- permittees with increased public education and involvement.
Additionally, engaging students can typically be accomplished for minimal capital
expenditures, or through school projects and graduate studies. These types of activities
will improve knowledge of the MS4 system and lead to more informed management
decisions regarding SWMP implementation.
Commendable Elements:
• MDT's www.montanams4.com website educates the public on the MS4 program
statewide. It also helps the permittees communicate and gather ideas from each other
on MS4 programs and ideas. MDT has a large array of storm water materials with a
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wide variety of messages and formats (website links, brochures, notepads, trash bags,
bookmarks, and magnets).
Participants: Dustin Johnson (COB), Dave Hill (MDT), Moriah Thunstrom (MDT), EJ Hook (MSU),
Alan English (GCWQD), and Tammy Crone (GCWQD).
3.3 ILLICIT DISCHARGE DETECTION AND ELIMINATION
An Illicit Discharge Detection and Elimination (IDDE) program must consist of an effective
means to prohibit illicit discharges from entering the MS4, and must meet the requirements of
Section 11.6.3 of the Montana General Permit. IDDE programs must have established legal
authority through an ordinance, resolution, or other means in order to ensure proper
enforcement capability. Other important components to an IDDE program are: the
development of MS4 maps showing infrastructure, outfalls; and receiving waters; dry weather
field screening of outfalls for the presence of illicit discharges; investigation of potential illicit
discharges; spill prevention and response; public awareness and reporting; management of
hazardous wastes; and training /education of employees.
Illicit Discharge Detection and Elimination Summary:
Storm Water Ordinance 1763 adopted by the City of Bozeman in 2010 establishes legal
authority to prohibit illicit discharges to the MS4. The ordinance defines discharge prohibitions,
requires construction activity and drainage plan submittals and defines the review process,
identifies BMP requirements, and contains multiple enforcement mechanisms. MDT and MSU
do not have established legal authority to prohibit illicit discharges, although MDT does have
the ability to revoke Right of Way (ROW) approach and encroachment permits, if significant
issues are identified.
The City and MDT do not have complete maps of their MS4 including storm water
infrastructure, outfalls, and receiving waters. There are %- section grid maps of the city that
contain some storm water infrastructure information. Dry- weather screening is not conducted
on a scheduled basis, but is completed in response to a complaint. Approximately ninety -
percent (90 %) of the major outfalls are checked annually by Public Works personnel. MDT
maintenance staff makes regularly scheduled maintenance checks of all infrastructure and
report incidents of illicit discharges or illegal dumping. Screening areas are prioritized to
address flood control /runoff issues. The City uses its general public works telephone to field
citizen calls and complaints, but no tracking system is in place. MSU refers all illicit discharge
problems to personnel responsible for spill response. MDT has IDDE specific information
available via brochure and on their website.
10
The City and MDT have written spill response plans for individual facilities and departments.
For larger spills, the City calls the County for a Hazmat team. MSU does not have a written spill
response plan. All permittees have household hazardous waste (HHW) programs in place. The
City conducts some training at individual facilities with annual refreshers. MDT has annual
HAZWOPER training of some employees and has local training conducted by the District
Environmental Engineer.
Permit Violations:
Although some information is available, a significant shortfall with the Bozeman MS4 is
in regards to mapping. The City maintains file copies of subdivision and SID drawings,
and other city infrastructure is available on %- section grid maps. Storm water
infrastructure is not available in a single usable database or mapping program such as
GIS. The permittees need one comprehensive map of the storm water system including
the pipe network, outfalls, receiving waters, catch basins, and manholes with
information on the size and condition of each control. This map should be available in
an electronic format that can be used by all departments and MS4 stakeholders, and it
should be reproducible and readily available to the public.
Program Deficiencies:
Although the City has met several of the IDDE requirements as identified in the 2005
SWMP (such as establishing legal authority and enforcement procedures), permittees
need a more detailed written plan and procedure for IDDE that meets all criteria listed
in Section II.B.3 of the Montana General Permit. Documentation must be maintained on
all facets of IDDE activities and should identify BMPs, measurable goals, and responsible
parties.
MDT should ensure that its MOU with the City of Billings specifically states that MDT
may use the City's storm water Ordinance to meet its IDDE requirements.
The General Permit requires that permittees identify how the success of this minimum
control measure will be evaluated, including how the measurable goals for each of the
BMPs were selected. All permittees need to improve their measurability and evaluation
techniques to determine the effectiveness of selected BMPs.
Recommendations for Improvement:
During a tour of the MS4 outfalls, significant baseflow was noted in the residential
outfall 001A. The City should investigate and identify the source of baseflow (ground
water inflow or other). The presence of unidentified baseflow could indicate the
presence of illicit discharges into the MS4, or hinder attempts to identify them.
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• The permittees need to better document all the storm water activities within the MS4
boundary, what actions are taken, and inspection frequency. These activities include
dry weather screening, maintenance activities, spill response, public input and
complaints, and training frequency and topics.
• The permittees need to provide more specific storm water training to internal staff and
departments related to IDDE, and training attendance should be mandatory with
attendance and topics documented. Increasing the awareness of all permittee staff
allows for broader participation and an increased level of compliance regarding storm
water issues.
MSU should have a written spill response plan in place, or clearly educate employees
and students of the procedures used by outside entities.
In its Ordinance, the City has identified a list of discharges that shall not be considered
illicit discharges. Please note that depending on the type and volume of discharge,
some activities may require permit coverage under other MPDES permit types. The City
must evaluate these discharges and identify permit requirements, if necessary.
Both permittees must have procedures in place that ensure the Montana DEQ
Enforcement division is notified of all identified illicit discharges or dumping activities.
Commendable Elements:
• All permittees have comprehensive HHW programs in place that encourage the proper
disposal of wastes.
• The City has conducted water quality monitoring, in addition to their required outfalls
001A and 002A, near a major downtown outfall that discharges to Bozeman Creek to
establish baseline storm water conditions. These data collection activities are valuable
in determining the impact of storm water discharges, and can be used to conduct
follow -up monitoring to identify the sources of contaminants in the discharge.
Participants: Dustin Johnson (COB), Dave Hill (MDT), Moriah Thunstrom (MDT), EJ Hook (MSU),
and Tammy Crone (GCWQD).
3.4 CONSTRUCTION SITE STORM WATER RUNOFF CONTROL
Permittees must, implement a Construction Site Storm Water Runoff Control program that
requires erosion and sediment controls on construction sites disturbing at least 1 -acre. This
program requires adequate legal authority through an ordinance or resolution to ensure proper
enforcement. This control measure also requires plan review procedures, construction
requirements and BMP selection, a construction site inventory, site inspections, enforcement
procedures, and staff training and education. Construction Site Storm Water Runoff efforts
must meet the requirements of Section II.6.4 of the Montana General Permit.
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Construction Site Storm Water Runoff Control Summary:
Storm Water Ordinance 1763 adopted by the City of Bozeman in 2010 establishes legal
authority to require storm water Best Management Practices (BMPs) at construction sites
within the MS4. Ordinance 1763 defines construction activity requirements, a comprehensive
drainage plan submittal and review process, identifies BMP requirements, and contains
multiple enforcement mechanisms. Permit application forms are required both for sites
greater than 1 -acre and less than 1 -acre. Developments greater than 1 -acre are also required
to submit executed copies of the State's NO1, SWPPP, and NOT forms. Ordinance 1763 also
incorporates by reference storm water development requirements in the City's Storm Water
Master Plan, Unified Development Ordinance (UDO), and Design Standards.
Contractors are given technical guidance including a brochure and a checklist of different types
of BMPs. A database is used to track construction projects. Site. inspections are conducted 1)
after a rain event, 2) if there are issues with the site, and /or 3) once the site is occupied. Each
construction site is required to have at least two (2) inspections, which compare the design plan
to on -site installations, although some inspections are conducted by the building department
and are not specific to storm water. Inspections are not currently tracked in a database. BMP
operation and maintenance (0 & M) is included in guidance documents.
The engineering department conducts erosion and sediment control plan reviews and requires
DEQ issued MPDES permits for sites greater than 1 -acre. Storm water management plans are
also required for sites less than 1 -acre. Various meetings and checklists are used during the
plan review process to address all development requirements. Standard conditions of approval
include requirements for the submittal of a Storm Water Droinage/Treotment Grading Plan and
Maintenance Plan, and a Storm Water Management Permit.
MDT requires BMPs with detailed design review for all projects regardless of size. MDT has a
variety of mechanisms to enforce proper storm water management at construction sites,
including stop work orders, withholding payment, and self- reporting policies. All construction
projects are tracked in a database. Project managers are required to turn in a BMP inspection
sheet routinely on the 1St and 15`h of the month. A library of technical guidance materials
including operation and maintenance information is available on the MDT website. MDT has
significant information available on construction BMP's and permanent erosion and sediment
control measures. Plan reviews are conducted routinely during construction. A letter of
confirmation that a MPDES permit has been issued is required. Inspections are conducted as
per permit specification (every 2 -weeks or after a storm event of %- inch /24- hours); inspections
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are not tracked in a database. Improperly maintained BMPs are the most common compliance
issue. Construction BMP training is conducted annually.
MSU assigns the responsibility for storm water BMPs to the Project Manager of construction
projects on campus, and to hired contractors with contractual conditions included to ensure
compliance. The status of construction projects of all sizes is tracked using a campus -wide
database, which is updated monthly; however, inspections are not tracked in a database. Sites
with close proximity to surface water are given priority. The most common compliance issue is
improperly maintained BMPs.
Permit Violations: None
Program Deficiencies:
Permittees need to improve project database tracking including project details,
inspections, and compliance issues.
• The City should require confirmation that the NOI /SWPPP package has been submitted
and a permit issued by MDEQ, by requiring that a copy of the Department confirmation
letter be submitted.
• MSU currently does not have an inspection program specific to its MS4. MSU must
implement a program that meets all requirements of Section II.6.4 of the Montana
General Permit, or specifically delegate these responsibilities in its MOU with the City.
• The General Permit requires that permittees identify how the success of this minimum
control measure will be evaluated, including how the measurable goals for each of the
BMPs were selected. All permittees need to improve their measurability and evaluation
techniques to determine the effectiveness of selected BMPs.
Recommendations for Improvement:
• The permittees need to provide more specific storm water training to internal staff and
departments related to construction site storm water control, and training attendance
should be mandatory with attendance and topics documented. Increasing the
awareness of all permittee staff allows for broader participation and an increased level
of compliance regarding storm water issues.
• The City of Bozeman needs to improve outreach and education of area contractors on
storm water issues including the proper use, installation and maintenance of BMPs.
• The City should consider assigning additional staff to assist with storm water
inspections, or train inspectors from other departments to perform storm water
inspections.
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Commendable Elements:
The City and MDT require storm water management plans for sites less than 1 -acre in
size, which exceeds the Montana General Permit requirement.
Participants: Dustin Johnson (COB), Dave Hill (MDT), Moriah Thunstrom (MDT), and EJ Hook
(MSU).
3.5 POST- CONSTRUCTION STORM WATER MANAGEMENT
The SWMP must include Post - Construction Storm Water control measures to address storm
water management from new development and redevelopment projects for sites that disturb
at least one acre, and meet the requirements listed in Section II.B.5 of the Montana General
Permit. This program requires adequate legal authority through an ordinance or resolution to
ensure proper enforcement. This control measure also requires plan review procedures to
ensure that developments include appropriate BMPs, post- construction requirements and BMP
selection in accordance with existing design standards, zoning requirements and master plans,
a post- construction BMP inventory, BMP inspections and maintenance, enforcement
procedures, and staff training and education. Permittees must also require the implementation
of low impact development practices that infiltrate, evapotranspire, or capture the first 0.5-
inches of rainfall from a 24 -hour storm preceded by 48 -hours of no measurable precipitation.
Post Construction Storm Water Management Summary:
Storm Water Ordinance 1763 adopted by the City of Bozeman in 2010 establishes legal
authority to require post- construction Best Management Practices (BMPS) for all new
development and redevelopment projects within the MS4. The Ordinance includes
requirements for a comprehensive drainage plan, submittal and review process, maintenance
requirements, and multiple enforcement mechanisms. Ordinance 1763 also incorporates by
reference storm water development requirements in the City's Storm Water Master Plan,
Unified Development Ordinance (UDO), and Design Standards.
Currently as -built inspections are performed on post- construction BMP's but regular
inspections are not conducted unless there is a complaint. Inspections are not currently
tracked in a database. The engineering department conducts storm water drainage plan and
BMP plan reviews. A Pre - Construction Criteria Checklist and a Municipal Checklist are used to
document plan reviews. Standard conditions of approval include requirements for the
submittal of a Storm Water Drainage /Treatment Grading Plan and Maintenance Plan and Storm
Water Management Permit. Pre - project meetings are held with the developer. Training and
outreach activities specific to post- construction are not conducted.
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MDT has completed a Transportation Plan that guides development. MDT conducts design
review on all projects and requires BMPs with detailed design review at all projects regardless
of size. All construction projects are tracked in a database. A library of technical guidance
materials including operation and maintenance is available on the MDT website. MDT has
significant information available on post- construction BMP's in its Permanent Erosion and
Sediment Control (PESC) Manual. Plan reviews are conducted routinely during construction.
Post - construction BMP inspections are conducted regularly by MDT maintenance personnel
and are tracked in its Maintenance Management System (MMS) database. Post - construction
BMP training is conducted annually.
MSU conducts design review of new developments through the State Architect and Engineering
(A &E) department. MSU typically assumes maintenance requirements on post- construction
BMPs as defined by the contractor; as a result, enforcement mechanisms (other than
contractual requirements during the construction phase) are not in place. Regular inspections
are not conducted unless prompted by a citizen complaint or weather event. The status of
construction projects of all sizes are tracked using a campus wide database, which is updated
monthly. Sites with close proximity to surface water are given priority.
Permit Violations: None
Program Deficiencies:
• The City of Bozeman should perform regular inspections of post- construction BMPs for
all new development and redevelopment projects greater than 1 -acre. A checklist
should be used to document these inspections.
• Although the City maintains file copies of subdivision and SID drawings, storm water
post construction infrastructure is not available in a single usable database or mapping
program such as GIS. Other city infrastructure is available on %- section grid maps. The
city should transfer all hard copy file drawings and grid maps into an electronic format
that can be easily distributed to City staff and the public.
The General Permit requires that permittees identify how the success of this minimum
control measure will be evaluated, including how the measurable goals for each of the
BMPs were selected. All permittees need to improve their measurability and evaluation
techniques to determine the effectiveness of BMPs.
Recommendations for Improvement:
The City commissioned a Bozeman Storm Water Facilities Plan (HDR & M -M, 2008) that
included several goals related to storm water: existing system inventory, planning for
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future growth, evaluation of problem areas, storm water system analysis, MPDES permit
implementation, financial plan, and a recommended plan. This plan identifies several
significant potential improvements to how the City of Bozeman manages its storm
water, and should be used as a basis for updating the current SWMP.
All permittees should include more frequent and specific training related to post -
construction storm water BMPs, and training attendance should be mandatory with
attendance and topics documented. Increasing the awareness of all permittee staff
allows for broader participation and an increased level of compliance regarding storm
water issues.
Training should include engineering, planning, maintenance, and inspection staff.
Commendable Elements:
• Permittees have incorporated Low Impact Development (LID) practices into their storm
water regulations and BMP selection guidance, and have encouraged their use on
recent development projects. LID BMP's include permeable pavement, rain gardens,
grass swales, and bioswales. MSU has a sustainability committee that encourages LID
practices, such as artificial turf on the new Stadium Expansion Project.
• The Bozeman Storm Water Facilities Plan represents a significant commitment by the
City to improve storm water management and water quality. The City should move
forward with recommendations outlined in the plan.
Participants: Dustin Johnson (COB), Dave Hill (MDT), Moriah Thunstrom (MDT), and EJ Hook
(MSU).
3.6 MS4 MAINTENANCE - POLLUTION PREVENTION /GOOD HOUSEKEEPING
Permittees must develop and implement an operation and maintenance program to inspect,
clean, and repair infrastructure, with an ultimate goal of preventing or reducing pollutant
runoff from the MS4 into receiving waters. This control measure should include: storm water
system infrastructure; public streets; flood management; pesticide, herbicide and fertilizer
application; public facility maintenance; and training. The Pollution Prevention /Good
Housekeeping program must meet all requirements listed in Section II.B.6 of the Montana
General Permit.
MS4 Maintenance Summary:
The City of Bozeman conducts regular cleaning of its roads and catch basins. Roads are typically
swept once per week for arterials, three times per year for residential areas, and once per
month for bike paths. Catch basins are typically cleaned at least once per year and again as
necessary. Pipes are not inspected unless a problem is identified. Spoils from street sweeping
and catch basin cleaning are disposed of at the Logan landfill. Maintenance activities are
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tracked in a work order database. Public facilities are inspected regularly by department
personnel, and as required by other existing permits (SPCC, MPDES, etc). BMPs are used during
road maintenance activities. Road sand and salt is used on public streets and is swept up as
soon as practicable based on weather conditions. Department superintendents are responsible
for storm water operation and maintenance of public facilities. Certified applicators and
integrated pest management practices are used for pesticide, herbicide and fertilizer
application.
The City does not have a complete mapping system of outfalls, receiving waters, ditches, and
storm water infrastructure. Some information is available on the city'/- section grid maps and
via as -built maps. MDT and MSU have partial maps that need to be completed, and also rely on
as -built drawings.
MDT conducts regular inspections of its MS4, typically during spring /high water conditions, and
in the fall. Maintenance staff conduct regular street sweeping, with one sweeper dedicated
completely to the MS4 area. The MDT Bozeman Maintenance Facility conducts bi- annual yard
inspections and monthly SPCC inspections. MDT has established maintenance procedures and
BMP guidance materials that are available to staff and the public. Maintenance activities are
tracked through MDT's Maintenance Management System (MMS) database. Internal
compliance and enforcement is conducted by the Environmental Services division of MDT.
Certified applicators and integrated pest management practices are used for pesticide,
herbicide and fertilizer application.
MSU regularly inspects and cleans storm water infrastructure and roads, typically in the spring
and fall. The MSU maintenance facility is inspected annually by maintenance staff. MSU uses a
private contractor as well as maintenance staff to perform street sweeping activities.
Enforcement is conducted by construction project managers in the event of a problem with
storm water compliance. MSU relies on the City of Bozeman to inspect and clean pipes and for
outreach materials on storm water impacts to the MS4. Certified .applicators and integrated
pest management practices are used for pesticide, herbicide and fertilizer application.
Permit Violations: None
Program Deficiencies:
Permittees must develop site - specific storm water plans for major permittee -owned
facilities, including maintenance shops, industrial facilities, parks, gravel /sand pits, etc.
These plans would be similar to SWPPPs and would include site characteristics, drainage
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patterns, facility activities, potential pollutant sources, storm water BMPs, spill
control /response,, and other pollution prevention activities.
Permittees should perform and document regular storm water inspections of all public
facilities, not just those sites that have inspection requirements under other permits.
Checklists should be used to track results.
The General Permit requires that permittees identify how the success.of this minimum
control measure will be evaluated, including how the measurable goals for each of the
BMPs were selected. All permittees need to improve their measurability and evaluation
techniques to determine the effectiveness of selected BMPs.
Recommendations for Improvement:
Permittees have the ability to track maintenance activities, but don't seem to use the
data to evaluate its SWMP. Documentation and evaluation of maintenance data will
provide permittees a better picture of MS4 maintenance activities and needs, and these
data can be used to develop measurable goals in this area.
Commendable Elements:
The City has an aggressive street sweeping program that minimizes the amount of
sediment that is washed into the MS4. Any street flushing activities are coordinated
with street sweeping to avoid sediment delivery to the MS4.
Participants: Dustin Johnson (COB), John VanDelinder (COB), Dave Hill (MDT), Moriah
Thunstrom (MDT), C. Ray Stock (MDT), Mark Peterson (MDT), and EJ Hook (MSU).
3.7 INDUSTRIAL /COMMERCIAL FACILITIES
An Industrial /Commercial Facility component is typically only applicable to Phase 1 permittees;
as a result, this control measure is not included in the Montana General Permit. Phase II
permittees should address storm water discharges from industrial and commercial businesses
in their public education program. The EPA MS4 Program Evaluation Guidance and Worksheets
included a section on Industrial /Commercial facilities and the topic was covered in the audit. As
a result, recommendations were made related to this topic.
Industrial /Commercial Facility Summary:
The City has the ability to track commercial and industrial sites through its business license
system and zoning information. These data are available on a GIS layer. The City requires oil -
water separators on all floor drains, and shop drains are required to be connected to the
sanitary system. The Unified Development Ordinance will trigger site plan review of these
facilities. A pretreatment survey is conducted if necessary.
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This program component is not applicable to MDT and MSU, as they do not have any industrial
or commercial facilities within their MS4 boundaries.
Permit Violations: Not applicable
Recommendations for Improvement:
• The City of Bozeman should have an inventory of industrial and heavy commercial
facilities, particularly those with other MPDES permits. Information on various area
MPDES permits can be researched on the EPA "ECHO" website, which can be accessed
at: http://www.epa-echo.gov/echo/compliance report water icp.html.
• The City should ensure that its Public Education Program includes outreach and
education materials specifically for industrial and commercial business target audiences.
Storm water inspections could be conducted on these facilities in conjunction with other
inspections or site visits.
3.8 SITE INSPECTIONS
Four field site - inspections were conducted and documented; two construction projects; one
MS4 maintenance facility, and one industrial /commercial site. In addition, two outfall
inspections were conducted on the designated sampling outfalls for the City of Bozeman (001A
and 002A). The location of each inspection site is shown on Figure 2. Site visit forms and notes
were completed and are included in Attachment D.
3.8.1 Construction Site Field Inspections
MSU Stadium Expansion
WET personnel inspected the Montana State University (MSU) Football Stadium Expansion
Project; located south of the MSU campus, south of West Kagy Blvd on August 4th, 2011.
Martel Construction was the general contractor for the project. Two employees were
interviewed for Martel: Jacob Ehresmann, Project Engineer, and Frank Harriman,
Safety /Human Resource Director.
The inspection started with a review of the NOI /SWPPP submittal package for the project. All
paperwork was present and current per MPDES requirements. A facility map was provided by
Martel Construction personnel and a tour of the site was conducted. Construction BMPs were
inspected and found to be in good condition, and BMPs appeared to be adequately managing
the potential for storm water runoff at the site. A field inspection worksheet consistent with
Appendix C in EPA - 833 -R -07 -003 is included in Attachment D.
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Participants: Dan Stevenson (MSU) and EJ Hook (MSU).
City of Bozeman Wastewater Treatment Plant
WET personnel inspected the expansion project at the City of Bozeman's Wastewater
Treatment Plant (WWTP) located at 7022 Sourdough Canyon Road on August 4th, 2011.
Williams Brothers Construction (WBC) was the general contractor on the project. Clay Pipinich,
the General Superintendent for the project was present for the records inspections portion of
the visit.
The NO1 /SWPPP submittal package was reviewed prior to touring the facility. The review
revealed that storm water inspections were not being conducted or documented according to
MPDES requirements. A facility map from the SWPPP was used to guide a tour of the site. The
audit team noted several areas where improvements were needed: concrete washout was
noted in several locations and did not appear to be managed properly; silt fence was not
installed according to the SWPPP plan and in some areas needed repair; straw wattles were not
present or installed properly in some areas along the construction site boundary adjacent to
the East Gallatin River; and construction - related trash was noted across the project site. Dustin
Johnson, Engineer with the City, requested that these issues be addressed with the Contractor
as soon as possible. The inspection team did not receive any follow -up paperwork or evidence
that issues had been corrected at the facility, which may indicate that inspections are not being
conducted according to its ordinance.
A field inspection worksheet is included in Attachment D.
Participants: Dustin Johnson (COB)
3.8.2 MS4 Maintenance Facility
WET personnel inspected the Montana Department of Transportation (MDT) Bozeman Division
Field Maintenance shop located at 907 N. Rouse Avenue on August 3rd, 2011.
A facility map was provided by Bozeman's MDT personnel and a tour of the grounds was
conducted. The facility was generally well maintained. The following issues were identified in
the inspection and communicated to MDT personnel: the sand storage area is not covered and
drainage patterns result in the potential for sand to wash directly into storm inlets on the north
boundary of the property; liquid de -icer did not have secondary containment and could
discharge directly into the MS4; and some fuel /oil drums did not have secondary containment
in place.
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Outfaf1002A- Residential
WET personnel inspected the City of Bozeman's Residential outfall 002A at the Middle Creek
Ditch and the sampling site at the intersection of Langhor Avenue and Westridge Drive on
August 4th, 2011. The outfall drains a residential development and discharges into a small
channel and then a pond, which discharges into the Middle Creek Ditch. The outfall is 15 -inch
concrete pipe. Sampling is conducted in a manhole approximately upstream of the outfall
location. Significant baseflow was noted at the time of inspection. The source of this flow was
unknown.
A field inspection worksheet is included in Attachment D.
3.9 ADDITIONAL PERMIT CONDITIONS
The Montana General Permit (MTR040000) contains additional requirements outside of the
SWMP requirements detailed in Part II of the permit:
Part I of the permit defines Effluent Limitations and defines conditions placed on small
MS4 permittees.
Part III of the permit requires the permittee to control discharges and prevent
exceedances of water quality standards, and to address TMDL load allocations for any
waterbody and incorporate into is SWMP.
Part IV of the permit defines self- monitoring requirements for permittees. Information
includes specific monitoring parameters, locations, frequency, evaluation, procedures,
and recordkeeping. It also includes the requirement to submit an annual permit to the
Department for each calendar year within the General Permit term.
Part V of the permit contains the Department's Standard MPDES Permit Conditions.
. Part VI of the permit contains definitions.
Additional Permit Conditions Summary:
Permittees are currently meeting all additional conditions of the Montana General Permit. The
City of Bozeman conducts semi - annual monitoring and reporting activities as required. MDT
and MSU are not currently required to conduct monitoring.
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