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Commission Memorandum
REPORT TO: Honorable Mayor and City Commission
FROM: Brian Heaston, Project Engineer Craig Woolard, Public Works Director
SUBJECT: Authorize the City Manager to sign a Memorandum of Agreement with the Gallatin Local Water Quality District and a Memorandum of Agreement with the Greater Gallatin Watershed Council to
perform water quality sampling and analysis for the East Gallatin River.
MEETING DATE: August 11, 2014
AGENDA ITEM TYPE: Consent
RECOMMENDATION: Authorize the City Manager to sign a Memorandum of Agreement with the Gallatin Local Water Quality District and a Memorandum of Agreement with the Greater Gallatin
Watershed Council to perform water quality sampling and analysis for the East Gallatin River.
BACKGROUND: The city endeavors to obtain water quality data to develop a water quality model for
the East Gallatin River to understand the nature of phosphorous and nitrogen nutrient impairments in the
stream. The Gallatin Local Water Quality District (GLWQD) and the Greater Gallatin Watershed Council (GGWC) will partner with the city to complete the water quality sampling and analysis effort.
Separate Memoranda of Agreement (MOA) are attached to this memo outlining roles and responsibilities
of the parties. The GWLQD Board of Directors will meet on August 7, 2014 to approve the MOA; GGWC has already executed the MOA provided herein. The city has a prior history of collaborating with
GLWQD and GGWC to perform water quality sampling and desires to continue the collaborative relationship as these organizations area uniquely positioned to assist with the effort.
The sampling effort will be accomplished in general accordance with a sampling plan previously developed by the state Department of Environmental Quality to support water quality modeling on the East Gallatin River. Three years of water quality data are necessary to support model development. The
city intends to utilize the model to derive specific numeric nutrient limits for the East Gallatin River. The model will serve as an important tool that will inform future wastewater discharge permit compliance
discussions with the DEQ.
UNRESOLVED ISSUES: None.
ALTERNATIVES: As suggested by the City Commission.
FISCAL EFFECTS: The adopted FY 2015 Wastewater Fund CIP budget includes $60,000 for project
‘WW27’ to fund water quality sampling and analysis. Payment provisions are specified in the MOAs.
Attachments: (1) Memorandum of Agreement with Gallatin Local Water Quality District (1) Memorandum of Agreement with Greater Gallatin Watershed Council
Report compiled on: July 31, 2014
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MOA for East Gallatin River Water Quality Sampling Page | 1
MEMORANDUM OF AGREEMENT
Between
CITY OF BOZEMAN
And
GALLATIN LOCAL WATER QUALITY DISTRICT
For
2014 EAST GALLATIN RIVER WATER QUALITY SAMPLING
This Memorandum of Agreement (this ‘Agreement’) made this day of , 2014,
between the CITY OF BOZEMAN, a municipal corporation of the State of Montana (COB) and
the GALLATIN LOCAL WATER QUALITY DISTRICT (GLWQD), describes the duties, agreements
and obligations of the COB and GLWQD in connection with water quality sampling and analysis
on the East Gallatin River.
A) GLWQD agrees to perform water quality sampling activities on the East Gallatin River in
general accordance with ‘Recommendations for Sampling and Modeling the East
Gallatin River to Accomplish Multiple Objectives’ (hereafter ‘Sampling Effort’) developed
by the Montana Department of Environmental Quality hereby incorporated by
referenced and attached to this Agreement. More specifically, the following tasks will
be performed by GLWQD to support developing a mechanistic water quality model (to
be completed by others) for the East Gallatin River between Bridger Creek and West
Gallatin River confluences to be utilized in deriving reach-specific nitrogen and
phosphorous criteria:
Article 1 – Roles and Responsibilities
1) A biological characterization to acquire minimum data necessary to complete
‘Objective 1’ of the Sampling Effort. Due to resource constraints and time
available to complete Objective 1, GLWQD will complete a scaled-down
biological characterization. Sampling at sites B, D, F, G, H, I, and J will be
performed in August 2014, September 2014, and October 2014, and monitored
for the following:
a) Benthic Algae (Chlorophyll-a)
b) Benthic Algae (Ash-Free Dry Mass)
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MOA for East Gallatin River Water Quality Sampling Page | 2
c) Macroinvertebrates
d) Diatoms (Periphyton)
e) Water Quality (TSS, TN, TP, SRP, nitrate + nitrite, and total ammonia)
f) Herbicides (N, P, and S containing pesticides [Method E507 modified])
g) Stream discharge
2) Water quality data collections to complete ‘Objective 2’ sufficient to calibrate
and confirm a mechanistic model of the study reach. Sampling at sites B, D, G, H,
I, and J, will be performed in August 2014 and September 2014 and monitored
for the following:
a) Benthic Algae (Chlorophyll-a)
b) Benthic Algae (Ash-Free Dry Mass)
c) Phytoplankton (Chlorophyll-a)
d) Nutrients (TN, TP, SRP, nitrate + nitrite, total ammonia)
e) Water Chemistry (TSS, ISS, alkalinity, hardness, TOC)
f) CBOD20
g) Stream discharge
Note: Objective 1 and Objective 2 overlapping monitoring constituents may be
acquired in conjunction (ie additional samples unnecessary so long as minimum
sample frequencies are met)
3) Water quality data collections to acquire data necessary to determine water
quality effects of the Riverside Water/Sewer District wastewater system.
Sampling at site C will be performed in August 2014 and September 2014 and
monitored for the following:
a) Nutrients (TN, TP, SRP, nitrate + nitrite, total ammonia)
b) Water Chemistry (TSS, ISS, alkalinity, hardness, TOC)
c) Stream discharge
B) GLWQD agrees to use laboratories and equipment recognized by DEQ to produce data
of sufficient quality for the intended purpose of the Sampling Effort and to input data as
appropriate into the state’s official water quality database.
C) The COB agrees to fund laboratory costs, supplies costs, mileage costs and equipment
costs, as well as personnel costs of the GLWQD necessary to complete the monitoring
tasks outlined within this Agreement at an amount not to exceed $52,000.
A) Laboratory and equipment invoices will be paid by the COB directly.
Article 2 – Payment Schedule
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MOA for East Gallatin River Water Quality Sampling Page | 3
B) The COB will reimburse GLWQD for personnel costs not to exceed $15,000 for personnel
completing field and administrative duties.
C) The COB will reimburse GLWQD for supplies and motor pool mileage necessary to
complete the monitoring tasks outlined within this Agreement at an amount not to
exceed $2,000.
A) The term of this agreement shall expire on June 30, 2015 unless separately extended or
amended as agreed by the parties hereto.
Article 3 – Duration of the Agreement
The parties agree that GLWQD is an independent contractor for purposes of this
Agreement and is not to be considered an employee of the COB for any purpose. Neither
GLWQD or any of its employees, officials, or agents, are subject to the terms and provisions of
the COB’s personnel policies handbook and may not be considered a COB employee for
workers’ compensation or any other purpose. GLWQD is not authorized to represent the COB
or otherwise bind the COB in any dealings between GLWQD and any third parties.
Article 4 – Independent Contractor
GLWQD will not refuse employment to a person, bar a person from employment, or
discriminate against a person in compensation or in a term, condition, or privilege of
employment because of race, color, religion, creed, political ideas, sex, age, marital status,
national origin, actual or perceived sexual orientation, gender identity, physical or mental
disability.
Article 5 – Non-Discrimination
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MOA for East Gallatin River Water Quality Sampling Page | 4
Article 6 – Execution
IN WITNESS WHEREOF, the parties have caused this Agreement to be executed by their
authorized representatives, on the day and year first written above.
CITY OF BOZEMAN
(Signature)
City Manager
(Title)
Chris Kukulski
(Printed Name)
APPROVED AS TO FORM:
GREG SULLIVAN, CITY ATTORNEY
GALLATIN LOCAL WATER QUALITY DISTRICT
(Signature)
Board Chair
(Title)
Gretchen Rupp
(Printed Name)
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WQPBWQSTR-002
DRAFT 7.3
Carrying Out a Substantial and Widespread
Economic Analysis for Individual Nutrient
Standards Variances
AND
Guidelines for Determining if a Waste
Water Treatment Facility Can Remain at a
Previous General Variance
Concentrationan Individual Variance Based
on Water Quality Modeling
February 2013
Prepared by:
20
WQPBWQSTR-002
Water Quality Planning Bureau, Water Quality Standards Section
Montana Department of Environmental Quality
1520 E. Sixth Avenue
P.O. Box 200901
Helena, MT 59620-0901
21
Suggested citation: Montana Department of Environmental Quality, 2013. Carrying out a Substantial and
Widespread Economic Analysis for Individual Nutrient Standards Variances AND Guidelines for
Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration. DRAFT, version 7.7. Helena, MT: Montana Dept. of Environmental Quality
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration – Table of Contents
5/15/12 Draft i
TABLE OF CONTENTS
Table of Contents ........................................................................................................................................... i
List of Figures ................................................................................................................................................. i
Acronyms ..................................................................................................................................................... iii
1.0 Introduction ............................................................................................................................................ 5
2.0 The Evaluation Process for Individual Variances: Public-sector Permittees ........................................... 5
2.1 Substantial and Widespread Economic Impacts: Process Overview .................................................. 5
2.2 Completing the Substantial and Widespread Assessment Spreadsheet ............................................ 7
2.3 Determining the Target Cost of the Pollution Control Project ........................................................... 8
3.0 The Evaluation Process for Individual Variances: Private-sector Permittees ......................................... 9
3.1 Substantial and Widespread Economic Impacts: Process Overview ................................................ 10
3.2 Completing the Substantial and Widespread Assessment Spreadsheet .......................................... 10
3.3 Cost-cap (or other solution) for Private Entities ............................................................................... 11
4.0 Guidelines for Determining if a Wastewater Treatment Facility Can Remain at the Previous General
Variance Concentration(s) .......................................................................................................................... 12
4.1 Methods for Demonstrating Insignificant Environmental Improvement/Progress Towards Attaining
the Standard ........................................................................................................................................... 13
4.2. Unwarranted Cost and Economic Impact ........................................................................................ 14
5.0 References ............................................................................................................................................ 15
LIST OF FIGURES
Figure 2-1. Sliding scale for determining cost cap based on a community’s secondary score. .................... 9
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration – Table of Contents
5/15/12 Draft ii
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration– Acronyms
5/15/12 Draft iii
ACRONYMS
Acronym Definition
DEQ Department of Environmental Quality (Montana)
EPA Environmental Protection Agency (US)
LMI Low to Moderate Income
MCA Montana Code Annotated
MHI Median Household Income
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration– Acronyms
5/15/12 Draft iv
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1.0 INTRODUCTION
Montana law allows for the granting of nutrient standards variances based on the particular economic
and financial conditions of a permittee (§75-5-313 [1], MCA). These variances, referred to as individual
nutrient standards variances (“individual variances”), may be granted on a case-by-case basis because
the attainment of the base numeric nutrient standards is precluded due to economic impacts, limits of
technology, or both. Individual variances may only be granted to a permittee after the permittee has
made a demonstration to the Department that adverse, significant economic impacts would occur, the
limits of technology have been reached, or both, and that there are no reasonable alternatives to
discharging into state waters. The Department documents this assessment process here. It was
developed in conjunction with the Nutrient Work Group and an earlier, informal working group (the
Nutrient Criteria Affordability Advisory Group, which met between September 2008 and April 2009). It is
modeled after a U.S. Environmental Protection Agency’s (EPA) process (U.S. Environmental Protection
Agency, 1995); however, Montana’s process departs from EPA’s in several substantive ways. This
document outlines the specific data requirements, tests, and procedures by which the Department will
determine if an individual variance is to be granted (or not) due to the potential for significant and
widespread economic impacts.
This document also outlines guidelines for determining when a wastewater treatment facility can, based
on water quality modeling, remain at the previous general-variance concentration requirements when
even though the Department has updated those requirements per §75-5-313 [7][b], MCA. These
guidelines are presented in Section 4.0 of this document.
2.0 THE EVALUATION PROCESS FOR INDIVIDUAL VARIANCES: PUBLIC-
SECTOR PERMITTEES
Methods outlined below are Montana’s modifications to methods presented in U.S. Environmental
Protection Agency (1995). If adverse substantial and widespread economic impacts to a community
trying to comply with base numeric nutrient standards are demonstrated, the facility upgrade cost-cap
will be determined via a sliding scale as proposed by EPA in its September 10, 2010 memo “EPA
Guidance on Variances”, reference No. 8EPR-EP.
In taking this approach, the Department has assumed that most permittees who cannot comply with the
base numeric nutrient standards (DEQ-12, Part A) would pursue a general variance (DEQ-12, Part B).
Therefore, it is only permittees for whom significant economic impacts would occur even at the general
variance treatment levels that would likely request individual variances. As such, for communities with
secondary scores (discussed further below) of 1.5 or lower, the cost cap for the upgrade would be set at
1.0% of median household income (MHI), including existing wastewater fees. The Nutrient Work Group
has indicated that 1.0% of MHI is an acceptable cost cap for a community to expend on wastewater
treatment where economic hardship due to meeting base numeric nutrient standards has been
demonstrated. Higher Secondary scores would lead to a higher MHI cost cap.
2.1 SUBSTANTIAL AND WIDESPREAD ECONOMIC IMPACTS: PROCESS OVERVIEW
The following is an overview of the steps required to carry out a substantial and widespread economic
analysis for a public-sector permittee. The evaluation can be undertaken directly in an Excel spreadsheet
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template which contains instructions (see Section 2.2). The template is called
“PublicEntity_Worksheet_EPACostModel_2012.xlsx” and is available from the Department.
Step 1: Verify project costs and calculate the annual cost of the new pollution control project.
Step 2: Calculate total annualized pollution control cost per household (manifested as an increase in the
household wastewater bill).
Steps 3-5: The Substantial Test
Step 3: Calculate and evaluate the Municipal Preliminary Screener score based on the town’s Median
Household Income. This step identifies communities that can readily pay for the pollution control
project.
Note: If the public entity passes a significant portion of the pollution control costs along to private
facilities or firms, then the review procedures outlined in Chapter 3 of EPA (1995) for 'Private Entities'
should also be consulted to determine the impact on the private entities.
Step 4: Apply the Secondary Test. This measurement incorporates a characterization of the socio-
economic and financial well-being of households in the community. It comprises five evaluation
parameters which are then averaged to give the secondary test score for a given community. A
secondary score can range from 1.0 to 3.0.
Note: The ability of a community to finance a project may be dependent upon existing household
financial conditions within that community.
Step 5: Assess where the community falls in the substantial impacts matrix. This matrix evaluates
whether or not a given community is expected to incur substantial economic impacts due to the
implementation of the pollution control costs. If the applicant can demonstrate substantial impacts,
then the applicant moves on to the widespread test. If the applicant cannot demonstrate substantial
impacts, then they will not perform the widespread test; they will be required to meet the base numeric
nutrient standards, or may request a general variance if they can discharge at the general variance
concentrations defined in Department Circular DEQ-12, Part B.
Note: The evaluation of substantial impacts resulting from compliance with base numeric nutrient
standards includes two elements; (1) financial impacts to the public entity as measured in Step 3
(reflected in increased household wastewater fees), and (2) current socio-economic conditions of the
community as measured in Step 4. Governments have the authority to levy taxes and distribute
pollution control costs among households and businesses according to the tax base. Similarly, sewage
authorities charge for services, and thus can recover pollution control costs through user’s fees. In both
cases, a substantial impact will usually affect the wider community. Whether or not the community
faces substantial impacts depends on both the cost of the pollution control and the general financial and
economic health of the community.
Step 6: The Widespread Test
Step 6: If impacts are expected to be substantial, then the applicant goes on to demonstrate whether or
not the impacts are expected to be widespread.
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Note: Estimated changes in socio-economic indicators as a result of pollution control costs will be used
to determine whether widespread impacts would occur.
Step 7: Final Determination of Substantial and Widespread Economic Impacts
Step 7: If widespread impacts are also demonstrated, then a permittee is eligible for an individual
variance after having demonstrated to the Department that they considered alternatives to discharging
(including but not limited to trading, land application, and permit compliance schedules). If widespread
impacts have not been demonstrated, then the permittee is not eligible for an individual variance
(however, the permittee may still receive a general variance if they can comply with the end-of-pipe
treatment requirements thereof).
2.2 COMPLETING THE SUBSTANTIAL AND WIDESPREAD ASSESSMENT SPREADSHEET
Detailed steps for completing the substantial and widespread cost assessment are found in the
spreadsheet template “PublicEntity_Worksheet_EPACostModel_2012.xlsx” available from the
Department. Readers should refer to that spreadsheet, as it is self explanatory and instructions are
found throughout. Below are a few additional details which may help clarify some of the steps:
1. Start at the far left tab of the spreadsheet (“Instructions [Steps to be Taken]”) and review the
instructions. They are the same steps outlined in Section 2.1 above, but in more detail. Proceed
to subsequent tabs to the right, making sure not to skip any of worksheets A through F.
2. Summarize the project on Worksheet A.
3. Detail the costs of the project on Worksheet B.
4. Calculated the annual cost per household of existing and expected new water treatment costs
on Worksheet C.
5. On Worksheet D, carefully read the text in blue and compare it to the results from the MHI test
and the community’s Low to Moderate Income (LMI) level. Based on this screener, the
evaluation will either terminate (i.e., it has been shown that the water pollution control is
clearly affordable), or will continue to the secondary tests on the next tab which is Worksheet
E1.
6. On Worksheet E, note the linkages to websites and phone numbers where the information
requested can be obtained. Then use this information to fill in Worksheet F where a secondary
score is calculated.
7. The next tab, ‘Substantial Impacts Matrix’, shows if the community has demonstrated
substantial impacts (or not). Those that have clearly demonstrated substantial impacts as well as
those that are ‘borderline’ move on to the widespread tests.
8. On the ‘DEQ Widespread Criteria’ tab, complete the four descriptive questions. Then, complete
the six primary questions and determine the outcome as to whether impacts are widespread. If
still unclear, complete the additional secondary questions and again evaluate.
9. In order to be eligible for an individual variance, both substantial and widespread tests must be
satisfied.
1 The Department appended the LMI test to EPA’s Municipal Preliminary Screener at this step in the process. This
was done in order to address communities in which the income distribution is skewed such that there is a large
proportion of high- and low-income individuals, but less in the middle near the median household income. As
modified, the test should assure that such communities will move on to the more detailed secondary tests.
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10. If substantial and widespread impacts are demonstrated, refer to Section 2.3 below to
determine the percentage of median household income that the community is expected to pay
towards the pollution control project.
2.3 DETERMINING THE TARGET COST OF THE POLLUTION CONTROL PROJECT
If a permittee has demonstrated that substantial and widespread economic impacts would occur if they
were to comply with the base numeric nutrient standards, and there are no reasonable alternatives to
discharging, then the cost the permittee will need to expend towards the pollution control project will
be based on a sliding scale (Figure 2-1). The cost cap is determined as a percentage of the community’s
MHI, and the key driver of the cost cap is the secondary test (secondary score) calculated in step 4 of
Section 2.1.
For example, a community has demonstrated that substantial and widespread economic impacts would
occur from trying to comply with the base numeric nutrient standards, and there were no reasonable
alternative to discharging. If the permittee’s average secondary score from the secondary tests was 1.5,
then the annual cost cap for the pollution control project (including current wastewater fees) would be
the dollar value equal to 1.0% of the community’s MHI at the time that the analysis was undertaken (see
blue line, Figure 2-1). This 1.0% would include existing wastewater costs plus new upgrades. If this
community was already paying 1.0% or greater MHI for its wastewater bill, then no additional monies
would be spent (and no additional upgrades would occur) under the individual variance.
The percentage of a community’s MHI—as determined by the ‘sliding scale’ in Figure 2-1—would
translate to the final wastewater bill that the community would pay after the upgrade. For example, a
community with 10,000 households has a MHI of $40,000/year, and the sliding scale table indicates that
1.0% MHI needs to be expended on the pollution control project. To receive the individual variance, the
per-household wastewater bill for the community would need to become, on average, $400 per year
($33.33 per month), because $400 is 1% of MHI in that community. If the average household in this
community currently has a wastewater bill that is $300 per year ($25.00 per month), then a bill increase
of $100 per year per household on average would be warranted to reach $400 per year or 1% MHI.
Multiplying $100/year in an increased wastewater bill by the number of households on the system
(10,000) provides the total annual dollar value available to be expended towards construction,
operations, and maintenance of the wastewater upgrade. In this hypothetical case, that amounts to $1
million (10,000 X $100) that could be spent per year on an upgrade project. The upgrade itself may be
significantly more than $1 million in initial capital costs, but the annualized payback of capital costs plus
O&M costs of the upgrade could not be more than $1 million per year. If the current wastewater bill of
this town was already $400 or higher, then no additional change would be expected (i.e., no further
system upgrade would be required).
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1
1.5
2
2.5
3
0.5 1 1.5 2 2.5Secondary ScoreCost Cap (Percent MHI)
Cost Cap versus Secondary Score
Cost Cap
Figure 2-1. Sliding scale for determining cost cap based on a community’s secondary score.
The horizontal axis represents percentages of a community’s median household income (MHI) that the
community would be expected to expend towards the pollution control project as a function of the
secondary score shown on the vertical axis.
It should be noted that the final cost of the engineering project may not exactly match the dollar value
associated with the percent MHI determined via Figure 2-1 (i.e., the actual project cost could be
somewhat lower or somewhat higher than the dollar value equivalent for the percent MHI of the
community in question). Engineers should view the dollar value equivalent of the MHI derived from
Figure 2-1 as a target, to help select the most appropriate water pollution control solution for the
community. In order to accommodate actual engineering costs for the project, the Department will
provide flexibility around the dollar value arrived at via Figure 2-1, subject to final Department approval.
When the level of treatment required has been established and accepted by the Department, it will be
adopted by the Department following the Department’s formal rule making process and documented in
Circular DEQ-12, Part B.
3.0 THE EVALUATION PROCESS FOR INDIVIDUAL VARIANCES: PRIVATE-
SECTOR PERMITTEES
Methods outlined below are almost identical to those presented in U.S. Environmental Protection
Agency (1995). If adverse substantial and widespread economic impacts to a private entity trying to
comply with nutrient standards are demonstrated, the facility upgrade will be determined via
approaches discussed in Section 3.3.
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3.1 SUBSTANTIAL AND WIDESPREAD ECONOMIC IMPACTS: PROCESS OVERVIEW
The following is an overview of the steps required to carry out a substantial and widespread economic
analysis for a private-sector permittee. The evaluation can be undertaken directly in an Excel
spreadsheet template which contains instructions (see Section 3.2). The template is called
“PrivateEntity_Worksheet_EPACostModel_2012.xlsx” and is available from the Department.
Step 1: Verify Project Costs and Calculate the Annual Cost of the Pollution control project to the private
entity.
Step 2: Substantial Test. Run a financial impact analysis on the private entity to assess the extent to
which existing or planned activities and/or employment will be reduced as a result of meeting the water
quality standards. The primary measure of whether substantial impact will occur to the private entity is
profitability. The secondary measures include indicators of liquidity, solvency, and leverage.
Step 3: Widespread Test. If impacts on the private entity are expected to be substantial, then the
applicant goes on to demonstrate whether they are also expected to be widespread to the defined
study area.
Note: Estimated changes in socio-economic indicators in a defined area as a result of the additional
pollution costs will be used to determine whether widespread impacts would occur.
Step 4: Final Determination of Substantial and Widespread Economic Impacts. If both substantial and
widespread impacts are demonstrated, then a permittee is eligible for an individual variance after
having demonstrated to the Department that they considered alternatives to discharging (including but
not limited to trading, land application, and permit compliance schedules). If widespread impacts have
not been demonstrated, then the permittee is not eligible for an individual variance (however, the
permittee may still receive a general variance if they can comply with the end-of-pipe treatment
requirements thereof).
3.2 COMPLETING THE SUBSTANTIAL AND WIDESPREAD ASSESSMENT SPREADSHEET
Detailed steps for completing the substantial and widespread cost assessment are found in the
spreadsheet template “PrivateEntity_Worksheet_EPACostModel_2012.xlsx” (available from the
Department). Readers should refer to that spreadsheet, as it is self explanatory and instructions are
found throughout. Detailed steps for private sector entities are also found in Chapter 3 of U.S.
Environmental Protection Agency (1995). Below are a few additional details which may help clarify
some of the steps:
1. Start at the far left tab of the spreadsheet (“Instructions [Steps to Take]”) and review the
instructions. They are the same steps outlined in Section 3.1 above. Proceed to subsequent tabs
to the right, making sure not to skip any of the worksheets.
2. Summarize the project on Worksheet A.
3. There are no worksheets B through F on the private test.
4. The next worksheet is G where one details the costs of the project.
5. In the next tab, carefully read the ‘Substantial Impact Instructions’.
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6. In worksheets H through L, the four main substantial tests are presented. For these tests, profit
and solvency ratios are calculated with and without the additional compliance costs (taking into
consideration the entity's ability to increase its prices to cover part or all of the costs).
Comparing these ratios to each other and to industry benchmarks provides a measure of the
impact on the entity of additional wastewater costs. For profit and solvency, the main question
is how these will be affected by additional pollution control costs. The Liquidity and leverage
measures look at how a firm is doing right now financially, and how much additional financial
burden they could take on.
7. In the Tab entitled “Substan.Impacts_Determined”, instruction is given as to how to interpret
the results from the ‘Substantial’ tests in worksheets H through L.
8. If a ‘Substantial ‘ finding is made, then proceed on to the next tab. If it is not made, then a
variance will not be given.
9. On the ‘DEQ Widespread Criteria’ tab, complete the descriptive questions. Then, complete the
primary questions and determine the outcome as to whether impacts are widespread. If still
unclear, complete the secondary questions and again evaluate.
10. In order to be eligible for an individual variance, both substantial and widespread tests must be
satisfied.
11. If both substantial and widespread impacts are demonstrated from additional pollution control
costs, see Section 3.3 below.
3.3 COST-CAP (OR OTHER SOLUTION) FOR PRIVATE ENTITIES
U.S. Environmental Protection Agency (1995) provides very little guidance as to what financial
expenditure should be made towards water pollution control when a private firm has demonstrated
substantial and widespread impacts would occur if they complied with the standards. U.S.
Environmental Protection Agency (1995) only states that “…if substantial and widespread economic and
social impacts have been demonstrated, then the discharger will not have to meet the water quality
standards. The discharger will, however, be expected to undertake some additional pollution control.”
In cases where substantial and widespread economic impact has been demonstrated per methods
outlined here in Section 3.0, the Department expects that in most cases the discharger (and their
engineers) will propose to the Department some level of effluent improvement beyond that which they
are currently doing, but less stringent that the general variances concentrations (which are now in
statute at §75-5-313, MCA, and which will later be adopted as Department rules in 2016). A likely
scenario would be that the discharger could implement a treatment technology one level less
sophisticated than that required to meet the general variance concentrations. Basic definitions for
different treatment levels are found in Falk et al. (2011); through 2016 the general variance requirement
for dischargers > 1 MGD corresponds to level 2. When the discharger and the Department have come to
agreement on the level of treatment required, the treatment levels will be adopted by the Department
following the Department’s formal rule making process, and documented in Circular DEQ-12, Part B.
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4.0 GUIDELINES FOR DETERMINING IF A WASTEWATER TREATMENT
FACILITY CAN REMAIN AT THE PREVIOUS GENERAL VARIANCE
CONCENTRATIONAN INDIVIDUAL VARIANCE BASED ON WATER QUALITY
MODELING (S)
The Department is required to review, and update as needed, the effluent treatment requirements
associated with the three general variance categories found at §75-5-313(5)(b), MCA. The main principle
that the Department must uses to update (i.e., make more stringent) the statute-defined concentrations
is that more cost effective and efficient treatment technologies have become available (§75-5-313
[7][b], MCA). The Department will carry out the determinations every 3 years as part of the water
quality standards triennial review, and will update the category concentrations and requirements if
more cost effective and efficient treatment technologies, relative to 2011, are available. However,
circumstances may arise where, for a specific discharger, it may not make sense to move to the new,
lower general variance concentration(s) at the time they are updated by the Department.
In some cases a permittee may be able to demonstrate, using water quality modeling and reach-specific
data, that greater emphasis on reducing one nutrient (the target nutrient) will achieve the same desired
water-quality conditions as can be achieved by emphasizing reduction of both nutrients. Requiring a
point source discharger to immediately install sophisticated nutrient-removal technologies to reduce the
non-target nutrient to levels more stringent than what is in statute at §75-5-313(5)(b), MCA may not be
the most prudent nutrient control expenditure, and would cause the discharger to incur unnecessary
economic expense. Since this is a form of economic impact, as described at §75-5-313(1), MCA, these
situations are appropriately addressed by individual variances.
If such a case can be demonstrated to the satisfaction of the Department, then a permittee can apply
for an individual variance which will include discharger-specific limits reflecting the highest attainable
condition for the receiving water rather than limits based on any new general variance concentration.
The demonstration must consider effects on the downstream waterbody including effects from the non-
target nutrient; if the downstream waterbody will be impacted, some level of reduction on the target
and/or non-target nutrient will be necessary or the individual variance may not be granted. In addition,
the permittee is required to provide monitoring water-quality data that can be used to determine if the
justifications for less stringent effluent limits continue to hold true (i.e., status monitoring). Because
status can change, for example due to substantive nonpoint source cleanups upstream of the
discharger, status monitoring by the discharger is required.
In order to remain at a previous general variance concentration, a permittee will need to demonstrate
to the Department that (1) moving to the updated general variance concentration would not result in a
net environmental improvement or material progress towards attaining the standards and water-quality
endpoints, and (2) that these additional, unwarranted costs would cause an economic impact or have a
negative economic effect on the community. The purpose of this sSection 4.0 is to provide guidelines
for the types of information the Department would need to evaluate in order to permit a discharger to
remain at the previous general-variance treatment treatment levels less stringent than any updated
(compared to 75-5-313(5)(b), MCA) general variance requirements.; topic (1) above is covered in Section
4.1, and topic (2) above is covered in Section 4.2.
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4.1 METHODS FOR DEMONSTRATING INSIGNIFICANT ENVIRONMENTAL
IMPROVEMENT/PROGRESS TOWARDS ATTAINING THE STANDARDMECHANISTIC
AND EMPIRICAL MODELING APPROACHES FOR ESTABLISHING INDIVIDUAL
VARIANCES AND (POTENTIALLY) REACH-SPECIFIC NUTRIENT STANDARDS
Two major approaches may be used to establish that upgrading a wastewater facility to an updated
general variance levels would not result in significant environmental improvement or material progress
towards attaining the standard and defined water-quality endpoints and beneficial use support:
1. Simulations based on mechanistic computer models
2. Demonstration of use support based on empirical data
Whichever approach is selected—and in fact both approaches can be pursued simultaneously—the
Department will require a 2-year biological characterization of the reach in question. A solid
understanding of the biological status existing under the current level of water quality is required.
Factors (both natural and human-caused) independent of nutrient concentrations can influence
biological integrity and need to be understood. The biological characterization will change from case to
case, but will normally involve collection of diatoms, macroinvertebrates, benthic and phytoplankton
algae density, and critical physical and chemical parameters that influence these. See Section 2.0
Appendix A for an example of the types of biological data and the rationale for each.
The following provides further detail on the two modeling approaches bulleted above.
Simulation Based on Mechanistic Computer Models. The Department will consider mechanistic model
results that demonstrate that the lowering of one nutrient (e.g., TP) without the lowering (or with less
lowering) of the other would achieve essentially the same water quality endpoint (i.e., equivalent
movement towards the water quality goal), subject to Department approval of the model and the
model’s parameterization. Modeled endpoints may include changes in water quality (pH, dissolved
oxygen, etc.), and benthic and phytoplankton algae density. . Mechanistic models must be supported by
data from a Department-approved study design that includes characterization of the chemical,
biological, and hydrological conditions of the study reach during a lower-than-average baseflow
condition. Data collection willshould follow Department SOPs.
The Department encourages the use of the QUAL2K model (Chapra et al., 2010) but may consider results
from other water quality models as well. Modeled nutrient reduction scenarios can vary in each case,
but scenarios based on the five treatment levels described in Falk et al. (2011)—which represent steps in
biological nutrient removal technologies—are encouraged by the Department. The Department can will
consider nitrogen and phosphorus independently in this analysis. and it is possible that a general
variance level would be adjusted for one nutrient, but not the other
The state of the art in computer water quality/algal growth modeling is such that nutrient co-limitation
and community interaction of river flora is poorly simulated (or is not simulated at all). Models often
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treat algal growth dynamics in streams and rivers as though the algae were a monoculture (which is not
the case). Because of the uncertainties in model simulations, the Department will require monitoring
(per NEW RULE I [3][a]) for dischargers that are permitted to remain at a the previous general variance
concentration based on a mechanistic computer model output. The intent of the monitoring is to
corroborate (or refute) the computer simulated results. At a minimum, growing season benthic-algae
sampling will be required for a reach of the river downstream of the permittee’s mixing zone, to be
established in coordination with the Department. If the base numeric nutrient standard for the river in
question was developed based on another water quality endpoint (for example, pH), then data
collection must also include that parameter. Data collection will follow Department SOPs. If the
collected data and the computer modeling results corroborate one another, then a reach-specific base
numeric nutrient standard may be in order. Any reach-specific nutrient standard so determined may be
adopted by the Board of Environmental Review under its rulemaking authority in §75-5-301(2), MCA.
Demonstration of Use Support Based on Empirical Data. Permittees may begin at any time to collect
nutrient concentration, benthic and phytoplankton algae, and other biological and water quality data in
the receiving waterbody downstream of their mixing zone. In cases where the base numeric nutrient
standards for the waterbody were developed using a specific water quality endpoint (for example, pH),
data collection must include that parameter. Data collection shall follow Department SOPs. Permittees
are strongly encouraged to coordinate with the Department on study design and data collection
protocols upfront, to assure that the data will be acceptable to the Department when the time comes
for evaluating the outcomes. For example, it has been shown that chlorination of effluent can, in some
cases, mute the effects of nutrients for some distance downstream (Gammons et al., 2010); this would
need to be accounted for in any study design. Subject to Department approval, these data may be used
to demonstrate that remaining at the previous general-variance treatment level (assumed here to have
been achieved by the permittee) was adequate to support beneficial uses of the waterbody. If the
collected data conclusively indicate that beneficial uses of the waterbody are fully supported, then a
reach-specific base numeric nutrient standards may be in order. Any reach-specific nutrient standards so
determined may be adopted by the Board of Environmental Review under its rulemaking authority in
§75-5-301(2), MCA. An example of an empirical approach to developing reach-specific nutrient criteria is
provided in Section 2.0 of Appendix A.
4.2 PROTECTION OF DOWNSTREAM BENEFICIAL USES
Any reach-specific criteria developed for a receiving stream using a mechanistic or empirical model will
also need to protect downstream beneficial uses. “How far downstream” is a consideration which will
vary from case-to-case; an example is provided in Sections 2.7 and 4.0 of Appendix A. Mechanistic
models have very clear advantages over empirical models for running hypothetical scenarios and
assessing potential downstream impacts, however a mechanistic model will normally be more expensive
to complete. A budget estimate for a mechanistic and an empirical model is provided in Section 6.0 of
Appendix A. If it results that modeling (of either type) has shown that beneficial uses of the assessed
reach can be protected with site-specific criteria, but a downstream reach will be negatively impacted by
the higher concentrations of one (or both) nutrients, then the Department will require treatment levels
which will support the uses in the downstream waterbody or it may not grant the individual variance.
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4.23. UNWARRANTED COST AND ECONOMIC IMPACT
NEW RULE I (3) requires that, in order for a permittee to remain at a previous general variance
treatment level, a demonstration must be made that (1) an upgrade to an updated general variance
concentration would not results in net environmental improvement and (2) that there would be
additional cost and economic impact to the community. Per (2), the Department does not want to see
communities invest in wastewater upgrades unnecessarily and, in turn, make substantive contributions
to one form of pollution (air, noise, greenhouse gases, etc.) resulting from actions to address water
pollution if those actions may only minimally reduce the water pollution problem in question. This
section addresses the requirements associated with the later requirement.
In order to satisfy the economic impact component of an individual variance (§75-5-313[2], MCA)
Permittees permittees must provide the Department approximate estimates of the capital costs, and
operations and maintenance costs, which would have been expended in order to upgrade the facility to
the new general variance concentrations. The intent is to demonstrate that there were substantial
savings in capital costs, materials, fuel, and energy by opting not to upgrade the facility. The permittee
can compare the cost saved to the MHI of the community, similar to what is done for determining
substantial and widespread economic impacts (see steps 1 through 5, Section 2.2); however, the
Department wants to make clear here that no specific percent of MHI needs to be realized in order for
this aspect of the two-part analysis to be satisfied. Capital costs saved would not include design-related
work and overhead. Operations and maintenance cost saved should be estimates of fuel and/or
electrical consumption, and other materials (e.g., chemicals). Permittees are not required to carry out a
complex analysis comparing the relative economic or social value of one resource (the stream or river)
vs. another (e.g., air quality) and then trying to quantify the relative savings. Rather, the Department
wants a straight-forward quantification of cost savings associated with the key factors of concern
(capitol costs, fuel and electrical consumption, and routine materials such as chemical additions).
4.3 DEPARTMENT ADOPTION AND PERIODIC REVIEW OF THE INDIVIDUAL VARIANCE
Nutrient concentrations in the draft individual variance would be based on the results of modeling and
the assessment of downstream use protection as described above. Individual variances approved by the
Department become effective and may be incorporated into a permit only after a public hearing and
adoption by the Department (§75-5-313[4], MCA).
Status monitoring of the receiving stream and the affected downstream waterbody will be used to
evaluate the individual variance justification going forward. For example: model results have shown
that a large reduction of phosphorus by the permittee would render the receiving stream P-limited and
in full support of beneficial uses, without a reduction in nitrogen. At the same time, nonpoint
contributions of nitrogen to the downstream waterbody of concern are presently large enough that a
substantial reduction of nitrogen load by the permittee would have had little or no beneficial effect. As
a result, the permittee’s individual variance reflects a low TP concentration and a TN concentration of 10
mg/L. If in the next ten years (of the twenty year variance period) nonpoint sources cleanup sufficiently
that the 10 mg TN/L concentration has become a sizeable proportion of the downstream nitrogen load
and reduction of that load would benefit the stream, then the justification for the 10 mg TN/L will have
changed. Any updated individual variance would reflect a lower TN concentration. As before, modeling
could be used to help derive the updated TN concentration.
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5.0 REFERENCES
Chapra, S.C., Pelletier, G.J., and Tao, H. 2010. QUAL2K: A Modeling Framework for Simulating River and
Stream Water Quality, Version 2.11: Documentation and Users Manual.
Falk, M.W., J.B. Neethling, and D.J. Reardon, 2011. Striking a Balance between Wastewater Treatment
Nutrient Removal and Sustainability. Water Environment Research Foundation, document NUTR1R06n,
IWA Publishing, London, UK.
Gammons, C.H., J.N. Babcock, S.R. Parker, and S.R. Poulson, 2010. Diel Cycling and Stable Isotopes of
Dissolved Oxygen, Dissolved Inorganic Carbon, and Nitrogenous Species in a Stream Receiving Treated
Municipal Sewage. Chemical Geology, doi 10.1016/j.chemgeo.2010.07.006.
U.S. Environmental Protection Agency. 1995. Interim Economics Guidance for Water Quality Standards -
Workbook. U.S. Environmental Protection Agency. Report EPA-823-B-95-002.
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APPENDIX A
Recommendations for Sampling and Modeling the East
Gallatin River to Accomplish Multiple Objectives
1.0 Background
The Department indicated in its draft numeric nutrient standards rule package that a person may collect
and analyze water quality and biological data along a reach of stream or river to determine if reach-
specific numeric nutrient criteria different from those of the Department are warranted. A draft
proposal of this type was provided to the Department in July 2012 for the East Gallatin River (HDR
Engineering, 2012)2. The Sampling and Analysis Plan (SAP) provided to the Department in July 2012
(HDR Engineering, 2012) is based on sites that were sampled in 2009-2010 for the purpose of
determining flow-stage relationships in the East Gallatin River. Building on those sites, the following are
recommendations for an optimized study design which can be used to develop reach-specific nitrogen
and phosphorus criteria for the East Gallatin River. It is hoped that this document may also serve as a
blueprint for similar work that may be carried out on other Montana rivers or streams.
The Department already has a public-reviewed and finalized assessment methodology for determining
when a stream reach is impaired by excess nitrogen and phosphorus (Suplee and Sada de Suplee, 2011).
However, that assessment methodology was designed to be a minimum data method and was not
intended to be sufficient for deriving reach-specific criteria. Therefore, the reader will find that methods
recommended below are more data intensive than those needed to complete an assessment via the
assessment methodology.
1.1 Design and Possible Outcomes of the Investigation
The East Gallatin River is an excellent case study in which to explore several variations on the
development of reach-specific criteria. These variations include:
1. The case where a stream reach may have natural factors (e.g. high turbidity, cold temperature, etc.)
that suppress benthic algae growth, and therefore reach-specific criteria are appropriate;
2. The case where benthic algae is found to be above nuisance levels, but modeling shows the algae
problem can be addressed by focusing on the reduction of one nutrient more than the other; or
3. The case where reach-specific numeric nutrient criteria for a reach of the East Gallatin River are
appropriate, but consideration of downstream beneficial uses precludes their application.
Figure 1-1 below forms the basis for the recommendations in the rest of this document.
2 It should be noted that the Department has developed reach-specific criteria for the East Gallatin River using
approaches somewhat different than those provided here. See Section 4.0 in Suplee and Watson (2012).
Formatted: Heading 1
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1. Based on the analysis of data collected along the East
Gallatin River between the Bridger and Hyalite creek
confluences, from July to September, is benthic algae
density above or below benchmarks?
BELOW ABOVE
6. Done. Study and/or
modeling does not indicate
reach specific criteria are
appropriate. TP and TN
criteria developed by the
Department in 2012 should
be retained for reach
8. River ecological status complex.
Consultation between the Department
and city need to determine course of
action/how much additional work
should be done. Further/different
sampling may be required.
2. Do other biological and/or other water
quality indicators along the reach exceed
standards or benchmarks?
YES NO
5. Develop reach-specific criteria. Will downstream
beneficial uses be protected by the criteria?
NO YES
3. Does modeling show that benthic algae benchmarks
can be met in the reach by reducing one nutrient
substantially more than the other (e.g., reduce end-of
pipe TP to 0.1 mg/L, but only reduce TN to 8 mg/L)?
NO YES
4. Will downstream beneficial uses be
protected, especially in regards to the
nutrient which is not being substantially
reduced?
NO YES
7. Reach Specific
Criteria Appropriate.
Develop reach-
specific criteria and
monitor biological
status of the receiving
stream
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Figure 1-1. Flowchart outlining various outcomes from the analysis of reach-specific data and
the development of reach-specific criteria.
Figure 1-1 provides for an empirical approach to developing reach-specific criteria and assessing
downstream effects of these criteria. It provides a mechanistic model approach (starting in Box 3), as
well as an approach where either option can be pursued (starting in Box 5). Regardless of which
approach is taken, as shown in Figure 1-1, proper biological characterization of the mainstem East
Gallatin River needs to be undertaken. Both criteria derivation approaches require robust field data and
an understanding of the impairment status of the river in relation to nuisance algae and/or other
aquatic life.
Please note that “other water quality indicators” (Box 2) in Figure 1-1 does not include a comparison of
measured nutrient concentrations to currently recommended criteria for the reach. (That would be
circular.) It does, however, include things such as pH, DO, and DO delta; i.e., effect variables. It is a
foregone conclusion (based on existing data) that much or all of the reach below the Bozeman water
reclamation facility (WRF) outfall will manifest nutrient concentrations in excess of the Department’s
recommended criteria.
Figure 1-1 does not provide closure in all circumstances. There is a pathway by which one can arrive to
Box 8 “River ecological status complex”. If the study findings lead to this outcome, it is not clear at this
point what the path forward would be. It may require substantially more sampling and analysis. The
assumption here is that the Department and the city would want to discuss what (if any) further work
would be carried out, and what the endpoints might look like.
1.2 Summary of the Basic Approaches to Reach-specific Criteria
Two broadly defined modeling approaches to developing criteria (empirical and mechanistic) are
detailed in the following sections. Briefly, the basic characteristics and strengths and weaknesses of each
are given below.
Empirical Approach. Fewer overall sites to sample compared to mechanistic modeling and, as a result,
lower overall cost. Samples can be collected most years during baseflow. Samples need to be collected
for at least three years, however two of those three years are already needed for the basic biological
characterization of the reach and the same sites can be used for both. Robustness of the empirical
statistical relationships are difficult to know in advance and could require additional data beyond three
years. The ability to run “what if” scenarios or extrapolate predictions outside of the range of data from
which the relationship is developed is much more limited compared to that of the mechanistic model.
Mechanistic Approach. This method requires more overall sites and more complex data collection
compared to the empirical approach, with concomitantly higher cost. The mechanistic model still
requires a two-year biological characterization, only some sites of which will overlap with the sampling
sites for the model. The model will also require collection of DO, pH, etc. with deployed water-quality
sondes. As you can imagine, these factors increase the cost and complexity of this approach. Data for
calibration and validation of the model can be collected during one field season, provided that both
collections are done near to peak growth and approximately a month apart. Perhaps two separate low-
flow years of data is a better corroboration of the model. Preferably, data collection should occur during
a low baseflow (i.e., near the seasonal 14Q5 or, optionally, when baseflow is below the long-term
seasonal average). This ensures that physical and biogeochemical conditions are consistent with that of
the targeted low-flow period. Once the model is corroborated (i.e., validated) it can readily be used to
run “what if” scenarios which can assess downstream uses, different nutrient reduction strategies at the
Bozeman WRF and their effects, etc.
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2.0 Biological Characterization of the East Gallatin River, and
the Empirical Model Approach to Deriving Reach-specific
Criteria
Objective 1: Determine the current biological condition of the reach of the East Gallatin River
between the Bridger Creek and West Gallatin River confluences during the growing season
(summer and early fall) and compare the results to standards and benchmarks used to assess
stream eutrophication.
2.1 Detailed Consideration of the Objective 1
The following questions are designed to address objective 1 given above:
In the wadeable regions of the East Gallatin River between the Bridger Creek and West Gallatin River
confluences, during the July 20 to September 30 period, what:
(a) are the average benthic algae densities (quantified as chlorophyll a and ash free dry mass, per m2)?
(b) is the areal coverage and thickness of benthic algae and macrophytes (based on standardized visual
assessment methods)?
(c) is the range and central tendency of specified macroinvertebrate metric scores (MT Hilsenhoff Biotic Index, O/E, and EPT taxa richness)?
(d) is the range and central tendency of specified diatom metric scores (WEMAP MVI and WEMAP WA
TN)?
(e) are the dissolved oxygen concentrations and pH compared to state standards, and what is the
dissolved oxygen delta (daily maximum minus the daily minimum)?
(f) are the concentrations of nitrogen and phosphorus (total and soluble) and total suspended solids?
(g) is the stream temperature, and incoming light intensity( in PAR units, e.g., µmol quanta/m2∙s)?
(h) are the concentrations of herbicides which are frequently used in the watershed?
Note in the question at the start of Section 2.1 the dates during which data collection should occur (July
20 to the end of September). These dates were based on the Middle Rockies growing season (Suplee et
al., 2007), and the fact that in the East Gallatin River the first three weeks of July have considerably
higher flows compared to August and September (shown in dark gray, Table 2-1). Commencing July
sampling after July 20th will generally exclude the higher flows and lead to data collection during base
flow conditions more consistent with August and September. Sampling could extend into the first two
weeks of October, if temperatures remain moderate and base flow conditions remain reasonably stable
(Suplee and Sada de Suplee, 2011).
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To further address the questions posed at the start of Section 2.1, it will be necessary to measure a
number of physico-chemical parameters; the rationale for measuring each of these is described below.
Biological parameters specified in the questions above were selected because they are known to be
directly influenced by or significantly correlate with lotic nutrient concentrations. The Department has
established benchmarks for most of the physic-chemical and biological variables, and East Gallatin River
data can be compared against these (DEQ-7, 2012; Suplee and Sada de Suplee, 2010).
Benthic algae densities (chlorophyll a [Chla] and ash free dry mass [AFDM] per m2). Based on work in
the Clark Fork River, statewide public opinion surveys, and a whole-stream dose-response study, the
Department is using average Chla levels of 125 to 150 mg/m2 and 35 g AFDM/m2 as harm-to-use
thresholds for western Montana rivers and streams (Dodds et al., 1997; Suplee et al., 2009; Suplee and
Sada de Suplee, 2011). Algae densities above these levels impact the recreation and aquatic life uses.
The Department also has standard visual assessment methods to asses algal and macrophyte density at
a coarser scale (WQPBWQM-011, 2011). The general composition, amount, color, and condition of
aquatic plants are visually assessed in the field using the Aquatic Plant Visual Assessment Form. This
information helps describe the health and productivity of the aquatic ecosystem, records nuisance
aquatic plant problems, documents changes in the plant community over time, and can be used to help
corroborate the quantitative Chla results.
Macroinvertebrate metrics. The Hilsenhoff Biotic Index (HBI) is included as part of the Department’s
current eutrophication assessment methodology (see Suplee and Sada de Suplee, 2011). The HBI index
Day of
month Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
1 42 47 45 118 283 433 164 52 43 40 55 47
2 44 43 44 128 267 441 155 51 42 41 55 47
3 44 42 46 124 268 453 147 53 39 42 57 47
4 41 43 48 112 297 433 142 53 37 44 56 47
5 43 44 47 121 295 418 141 51 39 48 55 47
6 43 47 46 148 328 425 130 52 42 50 53 47
7 41 44 46 139 364 479 124 51 43 51 55 46
8 46 44 52 140 379 461 118 52 41 51 62 43
9 44 42 54 149 376 440 108 54 43 52 60 43
10 42 42 56 157 380 443 102 52 50 52 56 44
11 41 42 58 155 373 513 101 49 45 52 56 46
12 42 42 70 164 373 501 97 46 41 53 56 46
13 43 42 88 182 377 465 94 45 42 52 57 45
14 44 42 88 218 404 436 90 45 42 52 56 45
15 43 41 80 232 439 420 84 47 43 55 52 45
16 42 41 80 212 442 404 81 44 42 59 55 43
17 44 41 81 229 464 390 78 44 44 61 54 42
18 46 41 86 239 484 359 75 47 45 59 53 41
19 51 42 89 235 509 335 73 46 44 59 53 43
20 48 40 88 231 528 310 68 42 44 66 52 44
21 47 41 93 254 523 299 66 41 46 63 49 45
22 44 41 94 279 505 277 66 41 47 58 47 44
23 44 41 94 324 495 264 67 45 48 56 48 46
24 44 41 90 315 500 247 62 43 49 56 46 44
25 43 41 89 290 615 237 63 41 46 57 48 45
26 43 42 95 293 540 228 64 41 43 55 50 46
27 47 43 93 270 502 209 63 39 42 55 48 44
28 46 43 95 266 475 195 61 39 42 55 47 44
29 44 41 91 274 490 183 55 41 42 57 46 46
30 45 97 295 466 175 51 41 44 57 47 44
31 43 104 444 50 43 56 43
Table 2-1. Discharge, ft3/sec for USGS Station 06048700 "East Gallatin River at Bozeman, Mont.". Mean of daily values for 10 years of record (calculation period 2001-10-01 to 2011-09-30).
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was designed to assess biological impacts caused by organic enrichment and eutrophication (Hilsenhoff,
1987). The Department considers HBI scores in the Middle Rockies > 4.0 to indicate an impact to aquatic
life (Suplee and Sada de Suplee, 2011). Two other metrics, O/E and EPT richness, were considered
during the development of the eutrophication assessment methodology since both metrics correlated
significantly to nutrient concentrations (Tetra Tech, 2010); however, for simplicity, only the HBI was
retained in that methodology. Nevertheless, it would be of value to include these metrics in this study.
The O/E metric evaluates the taxa diversity that was actually Observed compared to an Expected taxa
diversity for the location where the sample was collected. The Department uses an O/E ratio of 1.0 to
0.9 as un-impacted; ≤ 0.9 is the harm threshold (i.e., loss of 10% of species). Modest stream nutrient
enrichment can actually cause the metric to be > 1.0. A Bray-Curtis Index should be calculated to
accompany the O/E to help interpret counterintuitive O/E scores (WQPBWQM-009, 2012). The EPT
richness metric was part of older DEQ protocols and has application to intermountain valley and foothill
streams. EPT richness values > 14 are considered healthy and this value will decline with water quality
impacts (Bukantis, 1998).
Diatom metrics. The Department currently addresses nutrient impacts using increaser diatom taxa
metrics which were developed using discriminant function analysis (Bahls et al., 2008, Teply, 2010a and
2010b; Suplee and Sada de Suplee, 2011). Currently there is no calibrated and validated model for the
ecoregion in which the East Gallatin River resides (the Department hopes to have such a metric in a year
or so). Therefore, two diatom metrics are recommended (one for TN, one for TP) which were developed
by others and which correlate closely with stream nutrient concentrations in Montana (Tetra Tech,
2010). The metrics are WEMAP WA TN (for TN) and WMAP MVI (for TP); each was developed from work
in the Western Environmental Monitoring and Assessment Program (EMAP) of the early 2000s. Results
that differ largely from the regression line shown in Tetra Tech (2010) might suggest a stream with
characteristics different from the Middle Rockies norm; for example, a WEMAP MVI diatom score of 1.5
associated with a TP concentration of 0.25 mg/L would be well outside the expected pattern (one would
expect a score closer to 3)(Tetra Tech, 2010).
Dissolved oxygen, pH. Standards for dissolved oxygen (DO) and pH for a B-1 waterbody are established
in state law (DEQ-7 October, 2012). DO and pH have been linked to elevated nutrient concentrations
(Stevenson et al., 2012), making them good parameters to measure. But the Department has frequently
observed that DO minima are not found to be out of compliance in heavily eutrophied streams, at least
during summer, due to stream re-aeration. However, punctuated DO problems can occur in fall when
the built-up algae senesce en masse (Suplee and Sada de Suplee, 2011). Therefore, in addition to state-
adopted DO standards, the Department uses DO delta (daily maximum minus the daily minimum) of 5.3
as a benchmark for excessive plant productivity and respiration in streams (see Appendix C.2, Suplee
and Sada de Suplee, 2011). Others have found DO delta to be valuable in assessing eutrophication in
northern rivers, and recommend a benchmark of 5.0 (Minnesota Pollution Control Agency, 2010).
Concentration of nitrogen and phosphorus (total and soluble), total suspended solids, temperature,
incoming light intensity, and herbicide concentrations. These water quality parameters are critical for
the development of empirical relationships between algae density and nutrient concentrations.
Variables that influence light levels are particularly important for algal growth rates. Light
measurements can include PAR near the stream bottom, or (as a possible surrogate) measurements of
canopy density above the water’s surface. Temperature alters the growth rates of stream algae. In
addition, stream samples for herbicides which have historically been used in the basin should be
collected as these, if present in sufficient concentration, could suppress algal growth. Previous work has
shown herbicides to be present in Montana rivers and streams, with atrazine, metolachlor, and triallate
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being among the most commonly detected (USGS, 2004). Algae (as well as macrophytes) are sensitive
to these herbicides and growth can be suppressed at fairly low concentrations (see work by the USGS
and EPA at: http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm#benchmarks,
and http://www.cerc.usgs.gov/clearinghouse/data/usgs_brd_cerc_d_cerc008.html . The Department
would not consider suppression of algal growth in the East Gallatin River due to herbicides as a viable
rationale for reach-specific nutrient criteria because (a) it is not a naturally occurring environmental
variable and (b) future application of BMPs might reduce the amount of herbicides reaching the river
and this change could remove the algae-suppressing effect.
2.2 Data Collection Methods
The Department has Standard Operating Procedures (SOPs) for the collection of benthic and
phytoplankton algae (both quantitative and qualitative methods)(WQPBWQM-011, 2011), diatoms
(WQPBWQM-010, 2011), macroinvertebrates (WQPBWQM-009, 2012), and water quality (WQBWQM-
020, 2012), and recommended methods for measuring DO, pH, and DO delta when assessing
eutrophication (Suplee and Sada de Suplee, 2011). The Department’s 3rd iteration of the Field
Procedures Manual (WQBWQM-020, 2012) also summarizes parts of the SOPs most pertinent to field
sampling. I recommend these methods be adhered to for all sampling in the East Gallatin River. These
documents can be found at: http://deq.mt.gov/wqinfo/qaprogram/sops.mcpx.
A common trait of all the biological sampling methods is the necessity of laying out a short sampling
reach, which the Department usually refers to as a ‘site’. These short reaches are typically 150 to 300 m
in length in wadeable streams, and are delineated at the time of sampling as 40X the wetted width of
the stream or a minimum of 150 m. Sample collection at locations where there is a large proportion of
the river that is unwadeable requires special consideration and these situations are also addressed in
the SOPs.
Collection of DO, temperature, pH, and DO delta are best measured with deployed data sondes (e.g., YSI
6600s). Continuous collection of data via sondes is not needed at all stations but 1 or 2 along the East
Gallatin River study reach is recommended for biological characterization. These instruments can be
rented seasonally from commercial suppliers.
Details on data collection will need to be elaborated upon in the final Sampling and Analysis Plan (SAP)
developed to implement this general study design.
2.3 Recommended Sampling Sites along the East Gallatin River
To address objective 1 and its associated questions, ten sampling sites have been identified along the
East Gallatin River between the Bridger Creek and West Gallatin River confluences (Figure 2-1). These
ten sites are key to the implementation of the empirical approach outlined in Section 1.2. Seven sites (A
to G; Figure 2-2) are intended for more intense chemical and biological sampling, while three (H to J)
may be less intensively sampled and are the foundation of the downstream use assessment.
Site A (~0.7 miles downstream of the Bridger Creek confluence, at 45.71516, -111.0358): Establishes
water quality and biological conditions near the head of the study reach. Suplee and Watson (2012)
indicate that the East Gallatin River upstream of the Bridger Creek confluence should have a higher TP
criterion (to account for the natural influence of the Absaroka-Gallatin Volcanic Mountains ecoregion).
However, the elevated TP has been diluted out once Bridger Creek joins the river, and the
recommended criteria are then the same as for the Middle Rockies as a whole. The site is the natural
starting point for the work. This site also corresponds to site 1 of the mechanistic model (i.e., the
QUAL2K model).
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Site B (~0.3 stream miles upstream of Bozeman WRF outfall, at 45.72568, -111.06469): Provides a
second site to characterize the upper extent of the study reach. It is also not far upstream from the
major point source on the river and so can provide a nearby point of reference for any changes
occurring downstream of the facility. See also, Figure 2-3.
Site C (~0.9 stream mile downstream of the Bozeman WRF outfall, at 45.7284, -111.072): First site
downstream of the city of Bozeman WRF discharge. A study shows that the facility’s effluent is
completely mixed within about 400 ft (0.08 miles) of the discharge (USGS, 1999), although flows at the
time of the study were nearly double that of average conditions and nearly 3X the 7Q10. This site—
located about 0.9 miles downstream of the discharge— should capture changes in the river due to the
effluent, post-mixing. See also, Figure 2-3.
Site D (~0.3 stream miles downstream of the Riverside Water & Sewer District ponds, at 45.7363,
-111.07105): Conversations with Department staff indicate that the Riverside Water & Sewer District
ponds are a likely source of nutrients to the East Gallatin River. By establishing this site (and the one
upstream, site C) it should be possible to discern differences in river biology and water quality due to the
Bozeman WWTP effluent vs. any subsequent changes due to the ponds. See also, Figure 2-3. This site
also corresponds to QUAL2K model site 2.
Site E (~0.6 stream miles downstream of the Buster Gulch irrigation diversion, at 45.74765, -
111.08195): Site is established below a major water withdrawal to Buster Gulch. The site is established
in order to determine if lower water volume is having a measureable effect on water quality or biology
of the reach below the withdrawal.
Site F (Lower third of reach at 45.76698, -111.0968): Site will provide data representative of the reach
between site E upstream and site G downstream. There are few notable characteristics in this reach of
the river (e.g., point sources, tributaries, etc.) and this site will help ascertain the degree to which
upstream loads extend their influence downstream.
Site G (upstream of confluence with Hyalite Creek, at 45.7888, -111.1195 [same as site EGRF2]):
Establishes water quality and biological conditions near the end of the reach prior to the Hyalite Creek
confluence. This site corresponds to a site established in an earlier study on the river (PBS&J, 2011). Any
earlier data can be compared to that collected for this study. This site also corresponds to QUAL2K
model site 3.
Site H (just upstream of the Dry Creek Irrigation withdrawal, at 45.83059, -111.14617): Nutrient
criteria recommended for Hyalite Creek are higher for TP (due to natural geologic sources) and slightly
lower for TN (to maintain N limitation) than the reach of the East Gallatin River into which Hyalite flows
(Suplee and Watson, 2012). As such, Hyalite Creek is an important water quality change point. This site
is intended to discern changes resulting from Hyalite Creek and to characterize the East Gallatin just
prior to the Dry Creek irrigation withdrawal. This location is the first site intended for the assessment of
downstream uses. This site also corresponds to QUAL2K model site 4.
Site I (just upstream of the Dry Creek Irrigation System return flow, at 45.88921, -111.26408): The Dry
Creek Irrigation system is one of, if not the largest, irrigation withdrawals on the East Gallatin River.
Irrigation return flows can be a significant source of nutrients and turbidity. The intent of this site is to
characterize the East Gallatin River just prior to the addition of irrigation return flow to the river. The
site is part of the assessment of downstream uses, and also corresponds to QUAL2K model site 5.
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Site J (just upstream of the confluence with the West Gallatin River, at 45.8923, -111.3286 [same as
site EGRF1]): This site is located just upstream of the confluence with the West Gallatin River, and
should reflect effects from the Dry Creek irrigation return. The site corresponds to an earlier study site
(EGRF1; PBS&J, 2011) and so flow-stage relationships established there can be used; it also is the end of
the study reach. The site is part of the assessment of downstream uses, and also corresponds to QUAL2K
model site 6.
If resources are a constraint, objective 1 can be addressed with a scaled-down version of this plan. At
a very minimum, the Department recommends that sites B, C (or as alternate to C, D), F, G, H, I and J
be sampled.
2.4 Sampling Frequency and Duration of Study
Each site should be sampled synoptically at least once during the months of July, August, and
September. This will provide good characterization of the sites during baseflow. Two years of data
should be collected for the basic biological characterization. This will provide enough information to
have some confidence in the biological status of the river during baseflow. If it is intended that the
empirical criteria-derivation approach is taken, at least one more year (three total) of baseflow data
should be collected at the sites. (Requirements associated with the mechanistic model approach are
addressed in Section 3.0.) However, if a particular year has unusual high flows ≥ 165% of the long-term
average August and September flows, data should not be collected until flows have declined to below
this volume. At the USGS gage station at Bozeman on the East Gallatin River (gage No. 06048700), the
long-term average flow in August and September is 45 ft3/sec; thus, until summer and fall flows fall
below 74 ft3/sec, sampling should not occur.
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Figure 2-1. Ten biological and water quality sampling sites along the East Gallatin River. Sites A to G are for biological characterization of the
East Gallatin River in the reach below the WRF. Sites H to J are for biological characterization and for assessing downstream use protection.
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Figure 2-2. Sampling sites A to G along the East Gallatin River between the Bridger and Hyalite creek confluences.
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Figure 2-3. Close-up of the three sampling sites around the city of Bozeman WRF discharge. Green dot is USGS gage 06048700.
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2.5 Data Analysis and Interpretation
Due to the number of variables measured (e.g. benthic algae density, macroinvertebrates, diatoms),
many different data combinations and outcomes are possible. The Department does not believe that
establishing a rigid analysis structure upfront—that is, laying out the exact statistical tests, data
aggregation methods, etc.—would be beneficial at this point. There are still a number of unknowns
going forward and we must allow ourselves some flexibility in how the data will be interpreted. When
statistical tests are, ultimately, carried out, a balance should be sought between type I and II error rates,
as has been instituted in other Department stream-assessment procedures (Suplee and Sada de Suplee,
2011). This will seek a balance between error that imposes unneeded cost on the regulated community,
and error that leads to degradation of (or lack of improvement to) the river environment (Mapstone,
1995).
2.6 Reach Specific Criteria—Empirical Approach
If it appears that natural environmental factors are keeping benthic algae density below nuisance levels
in spite of elevated nutrient concentrations, then it may be possible to develop a reach-specific multiple
regression equation involving nitrogen, phosphorus, and the additional environmental variable(s) of
relevance, as has been done by others (e.g., Dodds et al., 1997; Biggs, 2000). Whether there will be
enough data to develop significant relationships is hard to predict in advance, especially if the reduced-
sites approach is selected; but it is safe to say the dataset will be relatively small and will require the
assumption that all (or most) sites are independent from one another and samples collected a month
apart are temporally independent. The Department has been able to substantiate similar assumptions in
other cases (see Appendix A.3, Suplee and Sada de Suplee, 2011).
The multiple regression might take on the following form (Neter et al., 1989):
Y = βo + β1X1 + β2X2 + β3X3 + βnXn
where Y is the dependent (or response) variable, what is being predicted or explained; βo is a constant
or Y-intercept; β1 is the slope (beta coefficient) for X1; X1 is the first independent variable that is
explaining the variance in Y; β2 is the slope for X2; X2 is the second independent variable that is
explaining the variance in Y; β3 is the slope for X3 and X3 is the third independent variable that is
explaining the variance in Y, and on so on for the total number of slope∙variables used (βnXn). For
purposes of this work, Y equals benthic algae density (mg Chla/m2, g AFDM/m2). Likely explanatory
variables (βs) would be TN concentration, TP concentrations, TSS concentration, and stream-bottom
PAR. This same approach could be used to explain relationships between other response and causal
variables (e.g., macroinvertebrate HBI score as the response [Y], TN, TP, and TSS as causal variables [βs]).
2.7 Protection of Downstream Uses
The next step in the process is to determine if downstream uses will be protected by the reach-specific
criteria (Box 5, Figure 1-1). Nutrients are assimilated longitudinally in streams and elevated
concentrations will eventually decline due to biological uptake and adsorption to the sediments. Thus,
assessing protection of downstream uses amounts to an evaluation of whether or not the higher
nutrient concentrations being allowed upstream will have a deleterious effect downstream.
It is unlikely that any reach-specific criteria in the East Gallatin River would affect the Missouri River. The
confluence of the three forks of the Missouri River results in orders-of-magnitude greater summer flows
than the East Gallatin River. For example, mean August flow in the Missouri River ~24 miles downstream
of the three forks is around 2,747 ft3/sec, whereas in the Gallatin River at Logan it is 490 ft3/sec, and
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near the mouth of the East Gallatin River it is about 250 ft3/sec (USGS, 2002; PBS&J, 2011). The most
likely impacts from reach-specific nutrient criteria would be in the reach of the East Gallatin River
downstream of the Hyalite Creek confluence. The nitrogen criterion recommended for the East Gallatin
River between Hyalite Creek and the confluence with the West Gallatin River is 290 µg TN/L, lower than
the 300 µg TN/L for the Middle Rockies (Suplee and Watson, 2012). Data suggest that the stream is
nitrogen limited (since TP is naturally elevated) and is the reason why a lower TN criterion has been
recommended there. A relaxation of the nitrogen criterion upstream of Hyalite Creek could very well
lead to use impacts if the nitrogen limitation is, consequently, alleviated. Two approaches (which tie to
Box 5 in Figure 1-1) can be taken to address downstream effects:
An empirical approach. If the sites along the East Gallatin River downstream from Hyalite Creek (sites H,
I, and J) show a general immunity to elevated nutrients (and the reach upstream of Hyalite Creek does
as well) due to some natural factor like elevated turbidity, then reach specific criteria in the East Gallatin
River could be extended all the way from the Bridger Creek confluence to the confluence with the West
Gallatin River, or even beyond, to the confluence with the Missouri River. However if the reach of the
East Gallatin River downstream of the Hyalite Creek confluence shows biological impacts/nuisance algae
above targets, then reach specific criteria that may be appropriate for the East Gallatin River further
upstream will not protect downstream uses, and should not be put in place.
A mechanistic modeling approach using QUAL2K. This approach links to Section 3.0. The model would
extend the full length of the East Gallatin River, between the Bridger Creek and West Gallatin River
confluences to ascertain whether nutrients at a certain concentration, moving downstream from the
point where Hyalite Creek confluences with the East Gallatin, would impact the beneficial uses further
downstream. Beneficial uses addressed by the model include DO delta, pH delta, and benthic algae
density. Please note that the mechanistic model requires additional types of sampling and sampling
sites (tributaries, irrigation withdrawals and returns) than the empirical approach; see Section 3.0.
The next section discusses approaches that can be used to develop a mechanistic model.
3.0 Developing Reach Specific Criteria via the Mechanistic
Modeling Approach
Objective: Collect enough data along the East Gallatin River between the Bridger Creek confluence and
the West Gallatin River confluence during a low-flow condition to be able to calibrate and confirm a
mechanistic QUAL2K model of the study reach.
This objective still requires adequate biological characterization of the reach, as outlined in Sections 2.1
through 2.5. Many sites described in Section 2.0 overlap with model sites described below; this was
done in order to optimize sampling. To assure the reach is long enough to be able to judge the validity of
the rate coefficients used in the model, the longitudinal distance must be sufficient to observe during
calibration the decline in soluble nutrients, conversions to organic from algal death and recycling, etc. It
is the Department’s judgment that the East Gallatin River can be effectively modeled if the reach from
above the Bozeman WRF to the West Gallatin River confluence (Figure 3-1) is considered, a distance of
approximately 25 stream miles.
Mechanistic models for criteria derivation require a robust set of field observations including
streamflow and water-quality data, measurements from continuously deployed sondes (including, at a
minimum, dissolved oxygen, pH, temperature, conductivity, and turbidity), and biogeochemical kinetic
observations (if possible). The Department has a detailed Quality Assurance Project Plan (Suplee et al.,
2006) and a technical report (Flynn and Suplee, 2011) on the use of the QUAL2K model for developing
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reach-specific nutrient criteria; the reader is referred to those documents for greater detail. Selected
sites are best sampled during one low-flow summer and fall (i.e., a year with flows near the seasonal
14Q5 of the East Gallatin River [McCarthy, 2005] or, alternatively, sequential low-flow summers during
the peak of the growing period. Consecutive years with base flows that are below average is preferred
but may not always be possible. If, during the initial biological and water-quality characterization
(Sections 2.1 through 2.5), it is found that herbicides are high enough to suppress algal growth, the
model will be severely compromised. Therefore, herbicide data are best collected and then assessed
in advance of the decision to complete the mechanistic model detailed below.
3.1 Sites Requiring Water Quality Sonde Deployment
For the QUAL2K model, six sites are recommended (Figure 3-1). Sondes could be deployed
continuously, or for a week to ten days in middle to late August and then again for another week to ten
days in middle to late September, during period of relatively stable flow (or in two sequential Augusts if
each has lower-than-average baseflow).
Water quality samples for key model drivers (nutrient concentrations—which include total nitrogen,
nitrate+nitrite, ammonia, total phosphorus, and soluble reactive phosphorus; TSS and ISS; alkalinity;
hardness; CBOD20; Total Organic Carbon [TOC]; and benthic and phytoplankton algae) need to be
collected at the six sites, at least once in August and once in September (or in sequential low flow years).
These data collections could potentially be synchronized with the data collection in Section 2.1.
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Figure 3-1. Map showing the six main sites along the East Gallatin River needed for the development of the QUAL2K model. Twelve other
sampling sites (tributaries, irrigation canal withdrawals, etc.) are needed to develop the model but are not shown on this map.
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The sites are:
Model Site 1 (~0.7 miles downstream of the Bridger Creek confluence, at 45.71516, -111.0358; same
as Site A): Establishes water quality boundary conditions near the upper-most point of interest on the
East Gallatin River based on reasons provided previously (page 9).
Model Site 2 (~0.3 stream miles downstream of the Riverside Water & Sewer District ponds, at
45.7363, -111.07105; same as Site D): For the purposes of the model, this site is intended to represent
conditions in the East Gallatin River after the full mixing of Bozeman’s WRF effluent discharge and any
effects that may be coming from the Riverside Water & Sewer District ponds (see Figure 2-3).
Model Site 3 (upstream of confluence with Hyalite Creek, at 45.7888, -111.1195 [same as site G and
site EGRF2]): Establishes water quality conditions in the East Gallatin River just before the confluence of
Hyalite Creek, which naturally has differing nutrient concentrations (Suplee and Watson, 2012). This site
corresponds to a site established in an earlier study (PBS&J, 2011). Any earlier data and flow-stage
relationships can be compared to that collected for this study.
Model Site 4 (just upstream of the Dry Creek Irrigation withdrawal, at 45.83059, -111.14617, same as
site H): Nutrient criteria recommended for Hyalite Creek are higher for TP (due to natural geologic
sources) and slightly lower for TN (to maintain N limitation) than the reach of the East Gallatin River into
which Hyalite flows (Suplee and Watson, 2012). As such, Hyalite Creek is an important water quality
change point. Model Site 4 is intended to discern changes resulting from Hyalite Creek, and characterize
the East Gallatin just prior to the Dry Creek irrigation withdrawal.
Model Site5 (just upstream of the Dry Creek Irrigation System return flow, at 45.88921, -111.26408,
same as site I): The Dry Creek Irrigation system is one of if not the largest irrigation withdrawals on the
East Gallatin River. Irrigation return flows can be a significant source of nutrients and turbidity. The
intent of this site is to characterize the East Gallatin River just prior to the addition of irrigation return
flow to the river. Changes in water quality as a result of this inflow will be captured by the next site
downstream, model site 6.
Model Site 6 (just upstream of the confluence with the West Gallatin River, at 45.8923, -111.3286
[same as site J and site EGRF1]): This site is located just upstream of the confluence with the West
Gallatin River, and should reflect any effects from the Dry Creek irrigation return. The site corresponds
to an earlier study site (EGRF1; PBS&J, 2011) and flow-stage relationships established there can be used;
it also is the end of the modeled reach.
3.2 Additional Sites Requiring Flow and Water Quality Data
Proper quantification of the water balance, associated mass fluxes, and water quality changes resulting
from inputs and outputs to the East Gallatin River are key to a successful modeling strategy. As a result,
there are a number of large and small tributaries inflows, irrigation withdrawals and return flows, and
point source contributions that need to be quantified. These should be sampled for concentrations of
nutrients (total nitrogen, nitrate+nitrite, ammonia, total phosphorus, and soluble reactive phosphorus),
TOC, alkalinity, TSS and ISS, hardness, and CBOD20 along with instantaneous measurement of
temperature, DO, conductivity, pH, and flow.
A list of important hydrologic features that the Department believes should be characterized is shown
below. Other tributaries and canals may be included if greater model detail is desired:
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1. Bozeman WRF effluent
2. Withdrawal to Buster Gulch irrigation diversion, located ~0.6 upstream of Site E (see Figure 2-1); flow
only
3. Mouth of Hyalite Creek
4. Withdrawal to Dry Creek irrigation diversion, just downstream of model site 4 (flow only)
5. Mouth of Smith Creek
6. Mouth of Dry Creek
7. Mouth of Ben Hart Creek
8. Mouth of Story Creek
9. Mouth of Cowen Creek
10 Mouth of Gibson Creek
11. Return flow from Dry Creek irrigation diversion (just downstream of model site 5)
12. Mouth of Thompson Creek
13. Mouth of Bull Run Creek
It should be noted that prior to the field assessment, diurnal variation of the discharge of the
wastewater from the Bozeman WRF should be considered. If flows from the WRF are significantly
variable such that they alter the diurnal flow characteristics of the East Gallatin River itself, further
discussions with the Department should be commenced about using a time-variable flow model
necessary to represent these changes and their associated effect on water quality.
3.3 Other Data
In addition to the boundary conditions identified previously, forcing functions of air temperature,
dewpoint, windspeed, and cloud cover are required to develop incoming PAR estimates and associated
heat balances with QUAL2K. The Department has not taken the time to investigate whether suitable
information is available from Gallatin Field (or other stations), but it is recommended that such
information be assessed to determine availability as well as whether it is appropriate for the East
Gallatin River corridor. If suitable information is not available, it is recommended that a meteorological
station be placed nearby to measure these inputs for the model.
3.4 Numeric Nutrient Criteria Derivation Process via QUAL2K
A properly calibrated and validated QUAL2K model is necessary for nutrient criteria derivation. Basic
criteria for determining when the model is calibrated and validated can be found in Suplee et al. (2006)
and are further elaborated upon in Flynn and Suplee (2011). Numeric nutrient criteria can be
ascertained by simulating incremental nutrient additions, or more likely in this case nutrient reductions,
to the point where water quality standards (e.g., DO, pH), benchmarks (benthic algae density), or other
ecological indicators are in compliance /achieved. Detailed discussions of this process are found in
Section 13 of Flynn and Suplee (2011).
4.0 Can Beneficial Uses be Supported by Applying Greater
Emphasis on Reducing One Nutrient?
The model described in Section 3.0 can be used to answer certain questions regardless of whether or
not the East Gallatin River is found to have nuisance algae levels or other undesirable water quality
characteristics. If it is established that algae density is above benchmarks, the model can be used to
explore “what if” scenarios, including “what if the city of Bozeman greatly reduced its TP load to the East
Gallatin but only reduced its TN load somewhat?”
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Figure 4-1 helps illustrates the concept. Taken from Flynn and Suplee (2011), Figure 4-1 shows growth
limitation factors (0-1 scaling factor) from nitrogen, phosphorus, or light at any given point along the
river. The horizontal line nearest to the X-axis is the most-limiting factor.
Figure 4-1. QUAL2K model results for nitrogen, phosphorus, and light limitation of benthic algae in the
Yellowstone River. From Flynn and Suplee (2011).
What can be ascertained from Figure 4-1 is that in the case of point-source inputs, the nutrient
limitation term can greatly change. In this example, nitrogen limitation is strong downstream of the city
of Billings for some distance due to phosphorus load additions from the Billings WWTP (note: the
nitrogen load is also large, but the phosphorus load evidently has a much stronger effect because it
leads to river phosphorus concentrations far above saturation levels for benthic algae). But the
nitrogen-limitation status then changes due to external conditions. So within a model, questions can be
posed such as: (1) “What if the Billings TP load were to be greatly reduced such that phosphorus could
be made limiting (or co-limiting) with nitrogen?”, (2) “What effect would this have on benthic algae
levels in the immediate vicinity of the wastewater discharge?”, and (3) “What would be the effect
further downstream?”.
0.0
0.2
0.4
0.6
0.8
1.0
0.00100.00200.00300.00400.00500.00600.00 Growth Limitation Factor (dimensionless)River Station (km)
Nitrogen Limitation
Phosphorus Limitation
Light Limitation
Miles CityTerryGlendiveForsythBillingsSidneyHuntley DamCartersville DamIntake DamWaco-Custer DamYellowstone DamRancher's DamBighorn RiverCusterPowder RiverFlow direction
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In the case the East Gallatin River, such an exercise would greatly help us understand if a greater
reduction in WRF phosphorus (the less expensive nutrient to eliminate) would achieve benthic algae
targets by pushing the East Gallatin to P limitation. The model could also be used to see the
downstream effects. We know that Hyalite Creek introduces naturally-elevated TP concentrations; in all
probability, any TP limitation achieved further upstream would there be lost. The model could also
show how changes to WRF treatment systems affect benthic algae. Model results may possibly indicate
that a substantial reduction in TN from the WRF is necessary so that nitrogen limitation (and beneficial
uses) can be maintained below the Hyalite Creek confluence. Again, the main point is that with the
QUAL2K model “what if” scenarios can be evaluated.
5.0 Status Monitoring
If reach specific criteria are developed and it appears that downstream uses will be protected, and those
criteria are moving towards adoption by the Board of Environmental Review, the last step in the process
is status monitoring. The state-of-the-art in both mechanistic and empirical models is such that they
inherently have noise, and confirmation of use-support of the reach-specific criteria is needed to assure
stream protection. It is recommended that model sites 1 through 6 be used for this purpose regardless
of the method used (mechanistic model or empirical model) to develop the criteria. Data collection
should focus on the endpoints of concern (benthic algae density, macroinverebrate metrics, diatom
metrics), and (if QUAL2K modeling was used) other endpoints (like pH) that were used in developing the
criteria. Presuming that the criteria can be met by changes to the WRF alone, then, after upgrades
occur, five years continuous monitoring is recommended at a minimum, to be carried out by the city or
its consultants. Five years will also allow enough time to apply robust non-parametric trend statistics to
the dataset (Helsel and Hirsch, 2002). Models developed via the methods outlined in Sections 2.6 and
3.0 may show that, due to nonpoint source contributions, an upgrade to the WRF cannot in and of itself
achieve the reach-specific criteria. In this case, the Department and the city should discuss how to
proceed with status monitoring. TMDLs for nonpoint source cleanups or application of BMPs generally
recognize that implementation will take years (5+), and this should play an important role in
determining the monitoring status timeline.
6.0 Budget Estimates
An estimate was made for the cost to complete the data collection and analysis for each of the three
major aspects discussed: (1) the biological characterization, followed by either (2) empirical statistical
modeling or (3) QUAL2K modeling. Estimates shown are total, that is, the grand total to complete each
task including development, calibration, and validation of the models, and any criteria developed
thereof. Status monitoring, which would occur afterwards, is not included. Cost estimates were based
on 2012 analytical laboratory price sheets, costs for purchasing small equipment or rental of large
equipment, etc. They should be viewed as estimates only, as best professional judgment was needed to
estimate hours of labor for field data collection, professional data analysis and modeling, etc. See
Appendix A for details.
1. Biological characterization: $75,220
The following are additional costs to be added to that above in order to complete the task:
A. Empirical Model Approach: $30,900
B. QUAL2K Model Approach: $113,635
If the empirical approach is taken, the grand total (biological characterization plus the empirical
statistical model) is $106,120. If the minimized study (sites B, D, F, G, H, I and J only) is selected for the
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empirical approach, which again includes the biological characterization, the grand total drops to
$75,853. If the mechanistic model approach using QUAL2K is taken, the grand total (biological
characterization plus the calibrated and validated model) is $188,855. If the minimized study (sites B, D,
F, G, H, I and J only) is selected for the biological characterization, the grand total for the QUAL2K model
approach drops to $168,500.
7.0 Next Steps
This document has outlined the basic conceptual framework for (a) characterizing the biological and
water-quality status of the East Gallatin River (Section 2.0), (b) using empirical methods to derive the
criteria (Sections 2.6), (c) using mechanistic modeling approaches to derive the criteria (Section 3.0), (d)
consideration of downstream effects (Sections 2.7 and Section 4.0), and (e) biological status monitoring
(Section 5.0). This document provides several pathways and options to study and model the East
Gallatin River.
If work outlined in this document is to be undertaken, the next logical step would be to develop a
detailed SAP. Potentially, a Quality Assurance Project Plan (QAPP) may need to be developed, but that
document may be optional so long as Department SOPs are closely adhered to and the SAP provides
sufficient detail on topics that are not specifically covered in DEQ SOPs. Further discussion with the
Departments Quality Control Officer (Mindy McCarthy; MMcCarthy3@mt.gov ) should clarify if a QAPP
is needed to further support field sampling. If reach-specific criteria are found to be needed and the
QUAL2K model is going to be used, it would be worth further consultation with the Department on a
QAPP specific to the model as well as discussions with Department staff during model development.
8.0 References
Bahls, Loren L., M. Tepley, R. Sada de Suplee, and M. W. Suplee, 2008. Diatom Biocriteria Development
and Water Quality Assessment in Montana: A Brief History and Status Report. Diatom Research
23: 533-540.
Biggs, B.J.f. 2000. Eutrophication of Streams and Rivers: Dissolved Nutrient-Chlorophyll Relationships for
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http://deq.mt.gov/wqinfo/Standards/default.mcpx
Dodds, W.K., V.H. Smith, and B. Zander, 1997. Developing Nutrient Targets to Control Benthic
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1750.
Flynn, K., and M.W. Suplee, 2011. Using a Computer Water Quality Model to Derive Numeric Nutrient
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Environmental Quality. Available at
http://deq.mt.gov/wqinfo/standards/NumericNutrientCriteria.mcpx
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HDR Engineering, 2012. East Gallatin Algae, Nitrogen, and Phosphorous Sampling 2012: Sampling and
Analysis Plan.
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McCarthy, P.M., 2005. Statistical Summaries of Streamflow in Montana and Adjacent Areas, Water
years 1900 through 2002. U.S. Geological Survey Scientific Investigations Report 2004-5266, 317
p.
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http://www.pca/state.mn.us/index.php/water/water-permits-and-rules/water-
rulemaking/proposed-water-quality-standards-rule-revision.html.
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Greater Gallatin Watershed Council and the Montana Department of Environmental Quality, pp
11 and two appendices.
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration
5/15/12 Draft 1
Appendix A
1. Biological Characterization (2-year study, up to three months per summer). This work is undertaken regardless of preferred modeling approach.
Benthic Algae (Chla)Benthic Algae (AFDM) Macroinvertebrates Diatoms WQ (nutrients, TSS)* Herbicides**
SITE Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample
A 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
B 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
C 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
D 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
E 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
F 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
G 6 $1,170 6 $300 4 $980 2 $500 6 $960.00 5 $750
H 6 $1,170 6 $300 2 $490 1 $250 6 $960.00 5 $750
I 6 $1,170 6 $300 2 $490 1 $250 6 $960.00 5 $750
J 6 $1,170 6 $300 2 $490 1 $250 6 $960.00 5 $750
Totals:$11,700 $3,000 $8,330 $4,250 $9,600 $7,500
Subtotals, analytical
costs:$44,380
YSI 6600 Sonde Rental:$2,240 Assume 2 sondes, deployed for 1 week each summer for two summers ($560 X 2 X 2).* TSS $20.00
Purchase YSI 85 $1,350 For instantaneous DO, temperature, and conductivity. Separate low-cost pH meter can be purchased.TN $40.00
Labor in field:$14,250 Assume a field team of 2 people, 10 sites, 3 hrs/site, average of 4.75 trips per site (for both years), assume $50/hr.TP $30.00
Data analysi:s $10,000 Assume 1 person, contracted, professional environmental consulting firm SRP $30.00
Misc. supplies:$3,000 macroinvertebrate nets, filters, filter apperatus, vehicle gasoline, etc. nitrate + nitrite $25.00
GRAND TOTAL,
Biological
Characterization:
$75,220 total ammonia $15.00
Analytical (min sites)Field labor (min sites)$160.00
$28,300 $9,975 GRAND TOTAL, min. sites (B, C, F, G, H, I, J):$54,865
**N, P, and S containing pesticides (Method E507 modified).
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration
5/15/12 Draft 2
2. Statistical Empirical Model (One additional year of data in additional to the biological characterization).
Benthic Algae (Chla) Benthic Algae (AFDM) Macroinvertebrates Diatoms WQ (nutrients, TSS)* Herbicides
SITE Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample
A 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
B 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
C 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
D 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
E 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
F 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
G 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
H 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
I 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
J 3 $585 3 $150 2 $490 1 $250 3 $480.00 2 $300
Totals:$5,850 $1,500 $4,900 $2,500 $4,800 $3,000
Subtotals, analytical
costs:$22,550
YSI 6600 Sonde Rental:$560 Assume 1sondes, deployed for 1 week for 1 summers ($560 X 1 X 1).
Labor in field:$6,990 Assume a field team of 2 people, 10 sites, 3 hrs/site, average of 2.333 trips per site, assume $50/hr.
Data analysi:s $15,000 Assume 1 person, contracted, professional environmental consulting firm. This would be final report and emperical model development
Misc. supplies:$800 macroinvertebrate nets, filters, filter apperatus, vehicle gasoline, etc.
Year 3 Total:$30,900
Emperical Model,
TOTAL‡:$106,120 Analytical (min sites)Field labor (min sites)
$14,735 $4,893 Year 3 Total, min. sites (B, C, F, G H, I, J):$20,988
Emperical Model, TOTAL, min sites (B, C, F, G, H, I, J)‡:$75,853
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Carrying out a Substantial and Widespread Economic Analysis for Individual Nutrient Standards Variances AND
Guidelines for Determining if a Waste Water Treatment Facility Can Remain at a Previous General Variance
Concentration
5/15/12 Draft 3
3A. QUAL2K Model main sites (data in addition to data from the biological characterization). Assumes a single year sampling in Aug and Sept.
Benthic Algae (Chla) Benthic Algae (AFDM) Phytoplankton Chla Nutrients* CBOD20SITEFrequencyCost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample
1 (same as A)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
2 (same as D)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
3 (same as G)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
4 (same as H)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
5 (same as I)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
6 (same as J)2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Totals:$2,340 $600 $780 $1,260 $720 $720
*TN $40.00 †TSS $20
TP $30.00 ISS $20
SRP $30.00 alkalinity $10
nitrate + nitrite $25.00 hardness $20
total ammonia $15.00 TOC $35total nutrients:$140.00 total WQ:$105.00
3B. QUAL2K Model, Additional Sites. Assumes a single year sampling in Aug and Sept.
Benthic Algae (Chla) Benthic Algae (AFDM) Phytoplankton Chla Nutrients* CBOD20Additional Sites Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample Frequency Cost/sample
(two flow sites)
Bozeman WRF 0 $0 0 $0 0 $0 3 $420.00 3 $315 3 $180
Hyalite Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Smith Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Dry Creek mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Ben Hart Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Story Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Cowen Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Gibson Cr moutn 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Dry Creek Irrig. return 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Thompson Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Bull Run Cr mouth 2 $390 2 $100 2 $130 2 $280.00 2 $210 2 $120
Totals:$3,900 $1,000 $1,300 $3,220 $2,415 $1,380
Subtotals, analytical
costs:$19,635
YSI 6600 Sonde Rental:$10,800 Assume 6 sondes, deployed for 2 weeks in Aug and 2 weeks in Sept ($1800/month X 6).
Labor in field:$12,000 Assume a field team of 2 people, 16 sites, 3 hrs/site, average of 2.5 trips per site (for both months), assume $50/hr. Assume flow meter provided by consultant.
Hobo Weather
Station:$1,200
Data analysi:s $65,000 To build calibrated and validated model, professional environmental consulting firm with expertise in QUAL2K modeling
Misc. supplies:$5,000 vehicle gasoline, filters, syringes, Aquarods, etc., contingencies
QUAL2K Model,
TOTAL:$113,635
TSS, ISS, Alk, Hardness, TOC†
TSS, ISS, Alk, Hardness, TOC†
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