MONTANA DEPARTMENT OF
ENVIRONMENTAL QUALITY
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
COOPERATIVE AGREEMENT
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022^
Approved:
The undersigned hereby execute this cooperative agreement
between the Montana Department of Environmental Quality and the
Environmental Protection Agency for the period October 199 6 - June
1997.
Marl?'A. Simonicfi,Director Date
Department of Environmental 7
Quality
u
Hi/ jl,il L/h^/
Jack W. McGr^to
Acting Regional Administrator
DฃC 13 1986
Date
John F. WardeH, Director
Montana Office
ill flfoh
Date
U.S EPA REGION 8
999 1 M?ql"ibra,y 80C"L
n Street, Suite 500
Denver, CO 80202
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TABLE OF CONTENTS Page
Introduction 1
Performance Partnership Grant 1
Core Programs 2
Implementation of Goals and Measures . 3
Quality Assurance Program 3
Reporting 3
Community Based Environmental Protection 3
Environmental Justice 4
Pollution Prevention 4
Future Cooperative Agreements 4
Enforcement Agreement 4
Enforcement and Compliance Assurance Sector Initiative... 5
Program Description and Workplans
Monitoring, Assessment and Planning Program 12
Technical Studies and Support Program 23
Wastewater Discharge Permit Program 31
Ground Water Program 38
Public Water Supply Program 45
Municipal Wastewater Assistance Program 69
Air Program 87
Hazardous Waste Program 110
Underground Storage Tank Program 129
Leaking Underground Storage Tank Program 132
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INTRODUCTION
The previous fiscal year has been a transition year for both
the Montana Department of Environmental Quality (DEQ) and the
Environmental Protection Agency. Beginning in October 19 95, EPA
underwent a major reorganization that resulted in new
administrative divisions based upon functional programs rather
than the traditional media programs. In July 1995, DEQ was
created through the combining of the former environmental
programs of the Department of Health and Environmental Sciences
(DHES) and certain programs from the Department of State Lands
and the Department of Natural Resources and Conservation.
Personnel from the three agencies made physical changes and were
combined into two buildings during the early spring of 1996. New
administrative divisions based upon functional programs became
effective in July 1996. The functional divisions are completing
their internal reorganizations.
As a result of these reorganizations of both EPA and DEQ and
in order to form a better partnership among the two agencies,
this cooperative agreement will be a transitional one. Because
it is still too early in DEQ's functional reorganization to do
anything else meaningful, the cooperative agreement is still
based upon media activities rather than upon the various
division's functional activities. The cooperative agreement is
for a 9 month period (October 1996 - June 1997) rather than for
the traditional 12 month federal fiscal year. Future cooperative
agreements will be based upon the state fiscal year and will be
for the 12 month period beginning July 1 and ending the following
June 3 0.
Beginning this year, grants for a number of the traditional
media programs have been combined into one single performance
partnership grant. The current status and future plans for this
grant will be discussed in a separate section.
The goal of Montana's environmental protection programs is
to protect public health while sustaining a spirit of cooperation
between environmental protection and resource development.
Through agreements, research, monitoring, technical expertise and
other areas of cooperation, the DEQ and EPA are helping Montanans
maintain a high quality lifestyle. The cooperative agreement
contributes to this process by consolidating all narratives and
work plans, thus producing a concise document and reducing
paperwork and duplication of effort.
PERFORMANCE PARTNERSHIP GRANT
Language in EPA's 1996 budget authorized the combining of
certain grants to States into one grant. Beginning in October
1996, Clean Water Act 106 grants for both surface and ground
water, the Public Water Supply Supervision grant, the Underground
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Storage Tank Program grant, the Hazardous Waste Program grant,
the Clean Air Act 105 grant and the radon program grant have all
been combined into one performance partnership grant (PPG).
Future grants to be added during the course of the cooperative
agreement, as they become available to Region VIII to award to
DEQ, include Clean Water Act Section 319 non-point source grants
and Clean Water Act Section 104(b)(3) grants for wetlands, MPDES
activities and total maximum daily load development. Because of
the transition to the state fiscal year period, the performance
partnership grants being awarded are, for the most part, for
three-fourths of the available grant. The remaining one-fourth
of the grant will be awarded during the period of the next
cooperative agreement.
Any grant additions to the PPG will require the submittal of
additional workplans to account for. the activities that are being
funded by the grant addition. This includes the use of carryover
money from the previous fiscal year.
During this cooperative agreement period, DEQ has not
requested the use of any flexibility in the PPG process that
would allow the Department to move funds between media
categories. It is planned to negotiate this flexibility in future
PPA's.
DEQ and EPA will jointly evaluate the success of the
Performance Partnership Grant, to the extent it is being
utilized, using the following measures. Does the PPG allow DEQ
to:
o improve environmental performance
o achieve administrative savings; and
o strengthen the partnership between DEQ and EPA.
The evaluation will occur at mid-year and end-of-year.
CORE PROGRAMS
DEQ certifies that it has, maintains, and implements
adequate programs in conformance with federal and state laws and
regulations ana conditions set forth in program
authorization/delegation documents for the programs contained in
this, cooperative agreement. The cooperative agreement is not
intended to and does not supersede authorization/delegation
documents or enforcement agreements.
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IMPLEMENTATION OF GOALS AND MEASURES
By entering into this cooperative agreement, DEQ and EPA,
agree to implementation of the goals and measures contained
herein. EPA commits to fund DEQ in the amounts specified in the
Performance Partnership Grant application. Should final
appropriations be considerably less than these amounts, both
parties may renegotiate the goals and measured outlined in this
agreement.
QUALITY ASSURANCE PROGRAM
DEQ will maintain an EPA approved Quality Assurance Program
that meets or exceeds federal requirements which cover any data
collection activities for which DEQ receives financial
assistance. DEQ will also continue to provide input into
regional/national data bases.
REPORTING
Except where otherwise specified differently in the program
workplans, DEQ will provide midyear and end-of-year performance
reports for each program workplan. The midyear report will be an
exceptions type report in that the report will only identify
areas that are not meeting the expectations of the workplans. It
may be used to negotiate modifications, if needed, to the
workplans. The end-of-year performance report will address both
accomplishments and shortcomings.
Financial reporting by DEQ will be done in accordance with
40 CFR 31.41.
COMMUNITY BASED ENVIRONMENTAL PROTECTION
Community based environmental protection is an approach to
delivering environmental programs that emphasizes environmental
goals and outcomes, relies upon a collaborative and inclusive
process for developing environmental solutions and seeks to
consider all environmental concerns comprehensively within an
identified geographic area.
DEQ and EPA both recognize that community based, cross media
approaches to addressing environmental issues can be effective
and provide for a comprehensive, localized, tailored approach to
resolving those issues. During the period of this cooperative
agreement, EPA and DEQ will continue to work together in
addressing the on-going activities in the Clark Fork and Flathead
watersheds. Community based environmental protection activities
in other watersheds will be identified, and DEQ and EPA will work
together to identify mutual roles in those activities as well as
future needs in watersheds without any on-going activities.
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EPA will provide community based environmental protection
related training as needed and requested by DEQ or other entities
in Montana, as well as technical, project development or
financial assistance for community based environmental protection
activities as resources allow.
ENVIRONMENTAL JUSTICE
With the issuance of Executive Order 12898, "Federal Actions
to Address Environmental Justice in Minority Populations and Low
Income Populations" in February 1994, environmental justice
became a priority for EPA. A national work plan for
environmental justice has been developed and Region VIII has made
commitments to fulfill various elements of the national work plan
in regional work plans.
During the period of this cooperative agreement, DEQ and EPA
will begin discussions to discuss the environmental justice
strategy, its applicability to Montana, and the appropriate roles
of both DEQ and EPA. EPA commits to provide support and
technical assistance to DEQ in the form of training, consultation
and collaboration on identified environmental justice projects.
POLLUTION PREVENTION
DEQ recently created a pollution prevention bureau to
coordinate pollution prevention activities, both within the
Agency and with other agencies. During the period of this
cooperative agreement, DEQ will continue to maintain these
activities and will seek out new opportunities for additional
pollution prevention activities. EPA will provide financial and
technical assistance to DEQ for the current and future
activities, to the extent that resources allow.
FUTURE COOPERATIVE AGREEMENTS
DEQ will form a "study team" to develop the process for
moving DEQ gradually over a period of time into a performance
partnership agreement. The study team will consist, at a
minimum, of at least one person from each division including the
Fiscal Division, a person from the Director's office, a person
from the Planning Division and a person from EPA.
ENFORCEMENT AGREEMENT
DEQ and EPA will work together towards developing a
comprehensive enforcement agreement for all programs that will
replace the individual enforcement agreements from past SEAs.
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SECTOR ENFORCEMENT AND COMPLIANCE INITIATIVE
EPA has identified six industrial/commercial sectors for implementation of an enforcement
and compliance assurance initiative. DEQ will participate with EPA in this initiative.
The intent of addressing these sectors is to define baseline sector compliance and increase
sector compliance through special emphasis and focused application of the appropriate compliance
and enforcement tools.
EPA intends to comprehensively evaluate the compliance issues, compliance needs and
compliance rate of these sectors in Region Vm. ("Comprehensive Evaluation" is defined in EPA's
Enforcement and Compliance Assurance Work Plan for the State of Montana, which has been
provided to DEQ.)
The purpose of the evaluations, is to: (1) defme the compliance status and compliance
problems associated with the selected facilities and operations within these sectors; and (2) develop,
implement and evaluate approaches which may be able to increase the compliance rate within these
sectors.
It is the intent of both the State and EPA to define the specific facilities and media of interest
for each sector as quickly as possible. Compliance inspections conducted during either Federal FY
96 or FY 97 may be relied upon to provide the information necessary for the comprehensive
evaluations, provided that the inspections assessed all aspects of the facility's or source's compliance
requirements. It should be noted that much of the inspection work for this initiative may have either
already been done in FY 96, or already be planned for FY 97. For example, DEQ's hazardous
waste program already focuses on dry cleaners as solvent users which are inspected as part of its
solvent registration program; the hazardous waste, air, and MPDES programs normally inspect all
refineries and power plants each year; and auto service facilities are part of the universe of facilities
normally inspected by the UST program.
For this sector initiative, the Montana Department of Agriculture (MDA) and DEQ will
conduct the media inspections for which they have delegated programs, and EPA will conduct those
for non-delegated media programs and those inspections which may be conducted in Indian Country.
EPA, MDA and DEQ recognize that there will be a need to coordinate the inspections among
themselves. (Should the Montana Oil and Gas Board be delegated the UIC Class II program during
FY 97, coordination with the Board may also be necessary).
The media programs which retain an interest in these sectors are noted in the Table of Media
Sector Participation - those which will participate will have an entry in the appropriate row for the
sector of interest.
Agricultural Practices Sector;
Based on criteria contained in EPA's Enforcement and Compliance Assurance Work Plan for
the State of Montana and information in EPA's files, EPA will select an ag pesticide producer in
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Montana as a candidate for a comprehensive evaluation. Using these same criteria applied to
information in DEQ files, DEQ (in coordination with MDA) will select one fertilizer producer or
one feedlot operation for the same evaluation. These criteria include size, geographic clustering,
environmental justice concerns, compliance history, and others.
EPA will provide to DEQ and MDA an itemized list of information (such as current and
historical non-compliance, environmental justice and community concerns, environmental problems
at the site, pollution prevention potential) needed from State files for these facilities in order to
conduct the comprehensive evaluations, including parameters regarding what is considered current
and relevant information. DEQ and MDA will use this list to extract information from their files.
If inspections of these facilities have not been done during FY 96, DEQ, MDA, and EPA will
inspect these facilities to gather the needed information.
Auto Services Sector;
EPA and DEQ will collaborate in selecting a list of representative facilities from the universe
of this sector for comprehensive evaluation (one percent of the universe = 34 facilities). The list of
facilities will be selected based on information obtained from Dun and Bradstreet, FINDS and
RCRIS databases, and other sources. EPA and DEQ will select facilities which were inspected by
DEQ during FY 96 to the maximum extent possible, provided that the facilities so selected are
representative of the sector. Because the universe is so large, and includes many forms of vehicle
service, the inspections/evaluations will focus on those service facility types using Standard
industrial Codes (SIC) that have the greatest potential for environmental impact: new and used car
dealers with service (SIC 5511 and 5521), paint and body shops (SIC 7532), general automotive
repair (SIC 7538), public transportation maintenance facilities (if any), and government motor pool
facilities.
EPA will provide DEQ an itemized list of information (such as current and historical non-
compliance, environmental justice and community concerns, environmental problems at the site,
pollution prevention potential) needed from State files for these facilities in order to conduct the
comprehensive evaluations, including parameters regarding what is considered current and relevant
information. DEQ will use the lists to extract information from its files, and to conduct inspections
during FY 97 where selected facilities have not been inspected during FY 96.
Dry Cleaner Sector:
(NOTE: In the Dry Cleaner sector, outreach will be done first, followed by compliance
audits/inspections and comprehensive evaluations second. This is opposite the order for the other
five sectors.)
EPA and DEQ will determine the level and type of outreach and other small business
compliance assistance activities which are currently available to the dry cleaner industry. This may
include outreach conducted by DEQ and other state or federal agencies. If additional activities are
necessary to adequately inform the dry cleaner industry of the environmental requirements which
apply to them, EPA and DEQ will collaborate in the design and implementation of those additional
activities, and will carry them out.
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After outreach activities are complete, EPA and DEQ will collaborate on the selection of dry
cleaners for a comprehensive evaluation. A representative list of 15 facilities (approximately 10%
of the universe in MT) will be randomly selected. The list will include to the extent possible those
dry cleaners already visited during FY 96, provided no criteria were used to select the FY 96 dry
cleaners which would adversely bias the random nature of this sector initiative. EPA will provide
DEQ with a list of information (such as current and historical non-compliance, environmental justice
and community concerns, environmental problems at the site, pollution prevention potential)
necessary to conduct a comprehensive evaluation and determine compliance status. For small
businesses (100 or fewer employees company-wide), the visits will be compliance assistance audits.
For large businesses, the visits will be compliance inspections. The compliance audits will be
followed by a letter describing the non-compliance, with assistance in returning to compliance.
Violations at large businesses will be followed with whatever action is called for in the applicable
Enforcement Agreement. From this information, EPA will determine the compliance status of this
sector.
Petroleum Refining. Coal Fired Power Plant, and Primary Non-Ferrous Metals and Mining
Sectors:
EPA will provide to DEQ (1) the list of facilities for each sector, and (2) an itemized list of
information (such as current and historical non-compliance, environmental justice and community
concerns, environmental problems at the site, pollution prevention potential) needed from State files
for these facilities in order to conduct the comprehensive evaluations, including parameters
regarding what is considered current and relevant information. The list of facilities will be selected
based on information obtained from EPA files, databases, and other sources. DEQ will use these
lists to extract information from its files, and to conduct inspections where necessary to obtain the
information.
Post-Inspection/Evaluation Activities
(NOTE: In the Dry Cleaner sector, outreach will be done first, followed by compliance
audits and comprehensive evaluations second. This is opposite the order for the other five sectors.)
Reports will be written for all inspections. If violations are found during any inspections
conducted, EPA and DEQ will adhere to the provisions of the cooperative enforcement agreements
for follow up.
EPA and DEQ will share the results of all media inspections. EPA will define the
compliance status of these sectors using the information collected as a result of these inspections and
file reviews, and any other valid data available to it. EPA will attempt to identify compliance
strategies and outreach activities that will improve compliance within each sector. By utilizing
information collected from sectors across the Region, patterns of non-compliance and successful
compliance activities may emerge.
EPA and DEQ agree to collaborate in the design and implementation of compliance
strategies and outreach approaches to these sectors in order to improve future compliance. EPA and
DEQ will utilize existing outreach and compliance assistance mechanisms to the maximum extent
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possible. EPA and DEQ will evaluate the effectiveness of these approaches through continued
compliance monitoring activity in future fiscal years. Additionally, EPA and DEQ will provide
compliance assistance as necessary to support these approaches.
For Fiscal Year 1997
The following Table of Milestones for the FY 97 Sector Enforcement card Compliance
Initiative details the schedule under which these sector activities will be completed.
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Table of Milestones for the FY 97 Sector Enforcement and Compliance Initiative
Activity
Completion
Date
Responsible
Agency
Comment
AG PRACTICES SECTOR
AUTO SERVICES SECTOR
PETROLEUM REFINING
SECTOR
COAL-FIRED POWER PLANT
SECTOR
PRIMARY NON-FERROUS
METALS AND MINING SECTOR
1. Finalize lists of facilities and
sources.
11/30/96
EPA, MDA,
DEQ
2. Provide list of file information
needed for candidates selected in
step 1 to DEQ and MDA.
12/30/96
EPA
3. Provide file information on
candidates to EPA.
5/30/97
DEQ, MDA
4. Conduct inspections and prepare
reports.
6/30/97
DEQ, MDA,
EPA
5. Perform comprehensive
evaluations, and establish
compliance status.
7/30/97
EPA
6. Design compliance outreach
approach.
8/30/97
EPA, DEQ,
MDA
7. Implement compliance outreach
approach.
9/30/97
EPA, DEQ,
MDA
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Activity
Completion
Date
Responsible
Agency
Comment
DRY CLEANING SECTOR
1. Determine sufficiency of current
outreach and compliance assistance
activities.
12/30/96
EPA, DEQ
2. If necessary, design additional
outreach and assistance activities.
1/30/97
EPA, DEQ
3. If necessary, implement
additional outreach and assistance
activities.
3/30/97
DEQ, EPA
4. Finalize list of candidate dry
cleaners to be audited/inspected.
12/30/96
DEQ, EPA
5. Provide list of information
needed to evaluate sector
compliance status.
1/30/97
EPA
6. Conduct inspections/audits, and
prepare reports.
8/30/97
EPA, DEQ
7. Determine sector compliance
status.
9/30/97
EPA, DEQ
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Table of Media Sector Participation *
Sector
(delegation status)
CAA
(1)
CERCLA
(2)
EPCRA
(2)
FFFRA
(3)
NPDES
(4)
OPA
(2)
PWSS
(4)
RCRA
(5)
TSCA
(2)
UIC
(2)
UST
(5)
404
(2)
Asbestos
AHERA
(2)
Asbestos
NESHAPS
(5)
Agriculture
X
X
X
X
X
Auto Service
X
X
X
X
Dry Cleaner
X
X
X
X
X
Petroleum Refining
X
X
X
X
X
X
X
Coal-Fired Power
Plants
X
X
X
X
X
X
Primary Non-
Ferrous Metals and
Mining
X
X
X
X
X
X
X
* "x" indicates an active interest by the media program noted. Other media programs are "on call" should the need for their involvement arise. Active interest does not
necessarily mean that a site visit by that media program is a certainty for all sites within the sector; there may be no reason to visit a particular eite within the Bector, or the
need for a site visit may be satisfied by the presence of a multi-media inspector.
Delegation status codes:
1 - Partially delegated to DEQ (CFC and some MACT standards are not delegated to DEQ).
2 - Not delegated
3 - Delegated to MDA
4 - Partially delegated to DEQ (sludge and pre-treatment standards are not delegated to DEQ).
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MONITORING, ASSESSMENT AND PLANNING
FISCAL YEAR 1997 PROGRAM PLAN
Fiscal Year 1997 will be a year of transition for the
Monitoring, Assessment and Planning (MAP) Program as the new DEQ
completes its organizational efforts. DEQ is organizing along
functional lines and former MAP program elements will be separated
into two or more new bureaus within the new Planning, Prevention
and Assistance Division. It is anticipated that monitoring and
assessment functions will fall within the new Monitoring and Data
Management Bureau, while watershed planning responsibilities will
go to the new Resource Protection Planning Bureau.
Again in FY 1997, former MAP program staff will address lakes,
streams and wetlands. Highlights include a continuation of
statewide lakes monitoring by volunteer monitors, implementation of
a voluntary nutrient TMDL plan for the Clark Fork River, continued
implementation of the tri-state Clark Fork-Pend Oreille Basin
management plan, completing a wetlands assessment/biocriteria
development project, and continued development of TMDLs for
Flathead Lake, Swan Lake and Ten Mile Creek.
DEQ will initiate a thorough review and continue to fund, as
deemed appropriate, monitoring of Flathead Lake and tributaries by
the University of Montana's Biological Station as part of the
Flathead Basin Commission's master plan for monitoring surface
water quality in the Flathead Basin. Using carryover funds from
the statewide lake water quality assessment grant, the Department
will again contract with the Canyon Ferry Limnological Institute to
provide training and equipment for lake monitoring to citizen
volunteers. The volunteer monitoring project of the Flathead Basin
Commission will continue as a component of the Flathead TMDL
project. A special lakes nonpoint source education project will be
initiated in FY 1997.
Ambient monitoring of the Clark Fork River will continue at 26
sites, to the degree that staff resources allow. Nutrients and
other parameters will be sampled quarterly. Through a continuing
cooperative funding agreement with ARCO, macroinvertebrates and
periphyton will be collected once in August and interpretive
reports prepared. A tri-state Clark Fork-Pend Oreille Basin water
quality monitoring strategy focusing on nutrients will be completed
and joint funding discussions begun with business, industry, and
local, state and tribal governments. A special study of nonpoint
source pollution problems, sources and geographic trends will be
initiated in the Bitterroot River drainage and a monitoring plan
developed. Stream reach assessments or intensive surveys will be
conducted by program staff on approximately 25 threatened or
impaired streams statewide. Approximately 10 lakes and wetlands
will be sampled for chemical and biological variables. All new
water quality information will be used to update assessments in the
EPA Waterbody System.
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DEQ will continue its contract with the Natural Resource
Information System of the Montana State Library to index stream
segments in Reach File 3 in order to develop Arclnfo coverage of
state waters. The Department will complete and distribute the 1996
Montana 305(b) report. The 1996 305(b) report will include a
refined 303(d) list of water quality-limited waterbodies.
Statewide public meetings will be held to discuss the 303(d) list
and its implications.
A contract coordinator will continue to facilitate
implementation of the Clark Fork River-Lake Pend Oreille nutrient
management plan. In addition, program staff will participate in
planning efforts underway in the Upper Clark Fork River (SB 434),
and in the Blackfoot and Kootenai river basins (Blackfoot Challenge
and the Kootenai River Network). DEQ will complete an interpretive
report on recommendations for voluntary clean-up of abandoned mine
sites in the Blackfoot watershed and assist in implementing
remedial projects.
Development of biological water quality criteria will continue
in FY 1997. Reference streams will be revisited to establish
annual variability in biological metrics. The DEQ biological data
bases will be updated as needed. A statewide wetlands assessment
report will be published and distributed, together with
recommendations for adopting statewide wetlands biocriteria.
Lastly, DEQ staff will work with stakeholders to pursue
development of a strategy including possible sponsorship of
legislation for statewide implementation of the TMDL process.
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Program Mnnitnring; A^c^mcnl anrl Planning
Planning Matrix
Fiscal Year 1997 By jGaryJngman.
Page 1
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL #1: Administer the MAP Program
OBJECTIVE #1: Administer Current-Level Program
Activities:
1. Plan, organize, coordinate and lead program activities;
develop, defend and track budgets; prepare and monitor
contracts; and perform other administrative functions as
needed.
2. Fill, train and supervise program positions; assign duties
and monitor and evaluate staff performance.
3. Monitor changes in federal and state law, rules and
policy affecting program and personnel.
4. Attend weekly managers meetings and monthly section
meetings.
Ongoing
Bahls (vacant)
Ingman
0.50
0
RIT
A
SUBTOTALS
0.50
0
RIT
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Program Monitoring, Assessment anrl Planning
Jam [atr
Fiscal Year 1997 By jGaryJngmaii
F
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FIE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL #2: Monitor Water Quality and Assess Sources and
Causes of Pollution
OBJECTIVE #1: Implement Clean Lakes Program
Activities:
1. Monitor Flathead Lake and tributaries (7 stations 15
times per year) per agreement with the Flathead Lake
Biological Station, University of Montana (FLBS).
2. Continue lake volunteer monitoring project per
agreements with the Flathead Basin Commission and the
Canyon Ferry Limnological Institute; assist with training of
volunteers.
3. Assist the Flathead Basin Commission with the Flathead
Lake TMDL project.
4. Serve on Flathead Basin Commission and FBC
Monitoring and Lake Management Committees; administer
Clean Lakes program contracts; pursue additional support and
funding for the Clean Lakes Program in Montana.
5. Initiate lakes nonpoint source education program.
Ongoing
Apfelbeck
Bahls (vacant)
Levine
0.60
50,000
RIT
20,000 314
30,000 106
A
OBJECTIVE #2: Complete Wetlands Assessment and
Biocriteria Project
Activities:
1. Develop wetlands biocriteria and complete final report.
06/97
Apfelbeck
0.30
RIT
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Program Monitoring, Assessment and Planning
Planning Matrix
Fiscal Year 1997 By Gary Ingman
Page 3
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE #3: Conduct Intensive Waterbody Surveys
Activities:
1. Prioritize intensive surveys on page 4 of the Montana
Water Quality Monitoring Strategy (04/28/94) according to
the criteria listed on page 2 of the Strategy.
2. Design and conduct intensive surveys in order of priority,
as staff and resources allow.
3. Prepare a report on each intensive survey in a timely
manner.
Ongoing
Apfelbeck
Levine
Ingman
0.80
RIT
604b
A
OBJECTIVE #4: Conduct Clark Fork Monitoring
Activities:
1. Conduct quarterly chemical/physical monitoring at 26
stations.
2. Conduct annual biological monitoring at 25 stations.
3. Manage project budget, contracts, and MOUs.
4. Participate in meetings of the monitoring subcommittee of
the Clark Fork Coordinating Forum.
5. Prepare or coordinate the preparation of Clark Fork
River water quality reports.
6. Negotiate joint funding agreement with business, industry
and local and state government.
Ongoing
Ingman
0.10
48,000
RIT
37,000 ARCO
20,000 Fees
A
SUBTOTALS
1.80
98,000
RIT
604b
20,000 314
30,000 106
37,000 ARCO
20,000 Fees
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Program Monitoring, Assessment and Planning
r laniung iriatriA
Fiscal Year 1997 By JGary Ingman
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL #3: Prepare and Implement Water Quality
Management Plans
OBJECTIVE #1: Prepare and Implement Statewide Plan
for Basin Management and Ambient
Water Quality Monitoring
Activities:
1. Design and implement a monitoring network for the
purpose of writing discharge permits and tracking the
performance of permitted discharges, and for collecting
baseline information for nondegradation reviews.
2. Participate in development of national nutrient assessment
strategy for rivers and streams with states and EPA HQ.
3. Work with Project WET, NRIS and NPS Program staff
to develop and fund a statewide citizen volunteer water quality
monitoring project.
4. Secure assistance from The Cadmus Group for
integrating SRF and NPS program planning under a statewide
basin management approach.
06/97
Bahls (vacant)
Ingman
Levine
0.30
10,000
RIT
604b
50,000 Fees
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Program Monitoring; Assessment and Planning
Planning Matrix
Fiscal Year 1W7 By .Gary Ingman
Page 5
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE #2: Implement Section 525 Nutrient
Management Plan for the Clark Fork
River Basin
Activities:
1. Serve on project steering committee.
2. Administer grant for and provide guidance to project
coordinator.
3. Participate in Tri-State Council meetings; chair and
participate in subcommittee meetings.
4. Coordinate implementation of Clark Fork nutrient
TMDL.
5. Coordinate implementation of project to land-apply Deer"
Lodge wastewater.
6. Work with NPS staff, NPS subcommittee, SB434
committee, and others to develop a NPS pollution control
strategy for the basin.
7. Continue to work with Butte-Silver Bow, Superfund,
ARCO and others to explore alternatives to Butte's direct
wastewater discharge to Silver Bow Creek.
Ongoing
Ingman
0.20
35,000
RIT
35,000 104b
A
OBJECTIVE #3: Implement Upper Clark Fork River
Basin (SB 434) Management Plan
Activities:
1. Participate in meetings of the Steering Committee and
Watershed Subcommittee.
2. Develop recommendations and legislation for 1997
legislature.
Ongoing
Ingman
0.10
0
RIT
-------
Program
Harming niatrix
Fiscal Year 1997 By _GarjiIngmaii
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE #4: Participate in Watershed Planning in the
Blackfoot, Bitterroot and Kootenai
Basins
Ongoing
Ingman
0.10
33,000
RIT
58,000 104b
A
Activities:
1. Participate in quarterly meetings of the Kootenai River
Network.
2. Assist in finalizing the Kootenai River Network workplan
and implementing the plan's recommendations.
3. Administer grants for Kootenai River Network facilitator
and Network activities.
4. Participate in meetings and activities of the Blackfoot
Challenge and its subcommittees.
5. Conduct Bitterroot watershed NPS pollution assessment
and develop long-term monitoring strategy.
OBJECTIVE #5: Participate in Other Planning Activities
as Needed
Ongoing
Ingman
Levine
0.20
0
RIT
A
SUBTOTALS
0.90
78,000
RIT
604b
50,000 Fees
93,000 104b
-------
Program Monitoring, Assessmpnf and Planning
Planning Matrix
Fiscal Year 1997 By fiaiy Ingman
Page 7
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL #4: Provide Water Quality Information and Other
Assistance to Resource Managers and the
Public.
OBJECTIVE #1: Edit, Print and Distribute 1996 305(b)
Report and 1996 303(d) List
December 1996
Contractors
Levine
Williams
0.10
10,000
RIT
604b
A
OBJECTIVE #2: Maintain DHES/EPA Waterbody
System
Ongoing
Levine
0.30
50,000
604b
50,000 104b
A
Activities:
1. Assemble and evaluate new water quality information as
it becomes available.
2. Prepare or update waterbody assessments as necessary.
3. Enter waterbody assessments into the DHES/EPA
Waterbody System.
4. Administer contract with Montana State Library for reach
file indexing and Arclnfo coverage of state waters.
OBJECTIVE #3: Provide Water Quality Information,
Technical Assistance and Expert
Witness Testimony as Needed
Ongoing
Staff
Williams
0.60
0
RIT
604b
A
Activities:
1. Provide copies of the latest 305(b) report, 303(d)
list, waterbody assessments, water quality data, and other
information, to resource managers and the public.
2. Provide technical assistance and general consultation
services to resource managers and the public.
3. Help teachers and citizens to design and implement
volunteer water quality monitoring projects.
4. Provide expert witness testimony as requested for local
water quality districts and the state's natural resource damage
claim against ARCO.
-------
Program Monitoring, Assexsmpnt anH Planning
Fiscal Year 1997
By Cary Ingnian
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE M: Develop Biological Water Quality
Criteria
Activities:
1. Resample reference streams to establish annual variation
in biological metrics.
2. Refine bioassessment techniques and biological criteria.
3. Develop periphyton biocriteria and bioassessment
protocols.
Ongoing
Bahls (vacant)
0.10
10,000
RIT
A
OBJECTIVE #5: Provide QA/QC Services
Activities:
1. Develop Quality Assurance Program Plans as needed.
2. Finalize updated and expanded Field Procedures Manual.
3. Provide other QA/QC assistance as needed.
4. Provide training on QA/QC.
Ongoing
Apfelbeck
0.10
0
604b
A
OBJECTIVE #6: Coordinate TMDL Activities
Activities:
1. Coordinate TMDL development for the Upper Clark
Fork River, Flathead Lake, Swan Lake and Ten Mile Creek.
2. Provide assistance to other programs (e.g., mining
compliance) for future TMDL development.
3. Participate in a work group to develop a strategy for
completion of necessary TMDLs in a timely manner,
including legislation and rules for statewide TMDL process.
4. Conduct statewide meetings to discuss the draft 303(d)
list.
Ongoing
Bahls (vacant)
Levine
Ingman
0.60
30,000
30,000 104b
A
SUBTOTALS
1.80
100,000
RIT
604b
50,000 104b
-------
Program
Planning Matrix
Fiscal Year J 997 By JGary Ingman
Page 9
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
TOTALS
5.00
RIT
604b
314
104b
106
Fees
ARCO
ro
-------
TECHNICAL STUDIES AND SUPPORT SECTION (SURFACE WATER 106)
The mission of the Technical Studies and Support Section is to protect, sustain, and improve the
quality of State Waters to benefit present and future generations.
This section provides scientific support to the Planning, Prevention and Assistance Division
(PPAD) in the area of standards development and interpretation, including the development of
permit limits, provides technical support for computer and data management systems for all
division sections, and provides technical support for reviewing and tracking developments (such
as mining) which may effect surface or ground water quality whether or not the development
activity requires a permit from the DEQ.
The section also provides scientific analysis concerning toxicity, permit limits, standards
interpretations, determination of nondegradation standards, and the implementation of
nondegradation standards.
The State surface water quality standards and the nondegradation rules must be reviewed and
revised at intervals not to exceed three years. In fact, the review and revision process requires
a constant level of effort with concentrated effort every three years. The nondegradation rules
were completely revised in 1994 and are increasingly being utilized as public awareness grows.
Legislative changes to the Montana Water Quality Act have necessitated continued changes to the
rules.
At the present time hard-rock mines are the most visible and contentious developments which
could potentially degrade water quality throughout the State of Montana. The Technical Studies
and Support Section is responsible for ensuring these hard-rock mining activities are in compliance
with the water quality standards of Montana. The section reviews all mining plans submitted for
potential violations of the water quality standards. Follow-up includes inspections and monitoring,
after construction, to ensure compliance with nondegradation requirements surface and ground
water quality standards. In the past these developments were not processed in a timely manner
and there was virtually no follow up in terms of monitoring and review. Modifications in
organization or changes in staff/section responsibilities are needed to adequately preform this
function.
Additionally, through the; Montana Environmental Policy Act (MEPA) process, all other
significant developments, such as subdivisions or shopping malls, which may affect water quality,
are reviewed by section personnel for potential impacts and compliance requirements.
The Section contributes one FTE for general personal computer (PC) hardware and software
support to the staff of the PPAD. These support functions include:
Provide data-base program(s) integration, development, and support for all Sections
of the PPAD which will ensure that the Division is able to meet all present and
future needs for data storage, manipulation, retrieval, and utilization;
-------
Research concerning computer system hardware and software changes, modifications,
and upgrades needed to accommodate future needs and developments required by
Section, Department, State and Federal legislation and programs;
Development, implementation, and planning activities for the PPAD computer
system;
Computer system inventory control methods which meet all Division, Department and
Federal requirements;
Conduct maintenance, repair, troubleshooting, and upgrading of the PPAD's
computer system hardware and software;
Provide computer system expertise to the Division staff;
Provide computer system interface-support with Federal computer systems;
Provide support for PPAD access and utilization of data manipulation including
uploading and downloading for the EPA data bases including FRDS, STORET, IRIS
and others.
-------
Technical Studies and Support/EPA-106
rianning ivlatrix
Fiscal Year 1997
By: Abe Horpestad
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES J
TOTAL
$'
FUNDING
SOURCE2
OBJECTIVE #1: ADMINISTER THE TECHNICAL STUDIES AND SUPPORT GROUP.
Activities required for the accomplishment of Objective ff\:
A. Plan section activities, develop budgets, and write
reports;
Ongoing
Bureau Chief
Admin Support
0.20
A
B. Assign duties, supervise, and evaluate staff;
Ongoing
Bureau Chief
0.06
A
C. Conduct research, prepare and submit requests for
EPA grants related to computer systems; submission of
Section budget amendments;
Ongoing
Abe H
0.02
A
Ongoing
Alan H
0.01
A
Ongoing
Don M
0.02
A
D. Conduct research, prepare and submit special
computer system projects concerning outside vendors;
Ongoing
Don M
0.16
A
E. Inter-agency/Department contract development,
Development of external, private vendor contracts,
Supervision of vendor contracts;
Ongoing
Abe H
0.02
A
Ongoing
Don M
0.25
A
Ongoing
Contracts
A
SUBTOTAL FOR OBJECTIVE #1:
0.740
45,478
CONTRACTS FOR OBJECTIVE #1:
1 COST PER TASK CAN BE CALCULTED BY MULTIPLYING FTE TIMES THE AVERAGE COST PER EMPLOYEE OF 54,493 (84% EPA-106, AND
16% NON-FEDERAL)
2 86% EPA-106, AND 14% NON-FEDERAL
-------
Planning Matrix
Technical Studies and Support/EPA-106 Fiscal Year 1997 By: Abe Horpestad
OBJECTIVE #2: DETERMINE THE EFFECTS OF ONGOING MINING ACTIVITIES AND PROVIDE INTUT TO THE PERMIT DIVISION ON THE WATER
QUALITY EFFECTS OF PROPOSED MINING ACTIVITIES.
Activities required for the accomplishment of Objective #2:
A. Coordinate review and oversight of hard rock mines;
Ongoing
Bureau Chief
0.01
A
Ongoing
Tom R
0.15
A
B Review operating plans of hard rock mines upon
submittal for potential violations of water quality
statutes;
Ongoing
Abe H
0.02
A
Tom R
0.20
A
Ongoing
Ken K
0.30
A
C. Assist Reclamation division and the Forest Service in
the development of EA's and EIS's for mining and
milling projects;
Ongoing
Bureau Chief
0.02
A
Ongoing
Tom R
0.14
A
Ongoing
Ken K
0.30
A
D. Follow through on nondegradation decisions and
petitions, monitor existing operations;
Ongoing
Abe H
0.10
A
Ongoing
Tom R
0.13
A
Ongoing
Ken K
0.10
A
Ongoing
Contracts
B
SUBTOTAL FOR OBJECTIVE #2:
1.47
CONTRACTS FOR OBJECTIVE #2:
0
OBJECTIVE #3: KEEP THE SURFACE WATER AND NONDEGRADATION RULES IN COMPLIANCE WITH STATE AND FEDERAL REQUIREMENTS,
Activities required to accomplish Objective #3:
A. Review the rules and make necessary changes;
Ongoing
Abe H
0.22
A
Ongoing
Don M
0.22
A
Ongoing
Contracts
B
it, r
-------
Planning Matrix
Technical Studies and Support/EPA-106 Fiscal Year 1997 By: Abe Horpestad
SUBTOTAL FOR OBJECTIVE #3:
0.440
CONTRACTS FOR OBJECTIVE #3:
OBJECTIVE #4: PROVIDE COMPUTER SUPPORT TO THE DIVISION STAFF.
Activities required to accomplish Objective H:
A. Supplement local area-network in areas not
adequately supported by the department;
Ongoing
Alan H
0.15
A
B. Research new hardware and software systems that
will improve the ability of the division to fulfill its
mission;
Ongoing
Alan H
0.06
A
C. Assist division staff in the use of department, state
and federal computer systems;
Ongoing
Don M
0.11
A
Ongoing
Alan H
0.10
A
D. Develop personal computer programs to support
Division responsibilities; includes specification
development for contracted services;
Ongoing
Don M
0.11
A
Ongoing
Alan H
0.02
A
Ongoing
Contracts
A
E. Maintain, repair, upgrade, and order new
equipment;
Ongoing
Alan H
0.13
A
F. Retrieve data, including global position sensing
reference data;
Ongoing
Alan H
0.02
A
Ongoing
Don M
0.04
A
G. Provide training and support for staff use of the
Department, State and Federal mainframe computer
systems;
Ongoing
Don M
0.04
11. Staff meetings and planning sessions;
Ongoing
Don M
0.01
A
Ongoing
AlanH
0.05
A
SUBTOTAL FOR OBJECTIVE #4:
0.84
November 18,1996
-------
Planning Matrix
Technical Studies and Support/EPA-106 Fiscal Year 1997 By: Abe Horpestad
CONTRACTS FOR OBJECTIVE #4:
OBJECTIVE #5: PROFESSIONAL DEVELOPMENT.
Activities required for the accomplishment of Objective #5:
A. Attend EPA conferences and seminars; attend
specialized training courses;
Ongoing
Abe H
0.02
A
Ongoing
Tom R
0.02
A
Ongoing
Don M
0.03
A
Ongoing
Ken K
0.02
A
Ongoing
AlanH
0.03
A
B. Read professional literature/Self training;
Ongoing
Abe H
0.02
A
Ongoing
Tom R
0.02
A
Ongoing
Don M
0.01
A
Ongoing
Ken K
0.02
A
Ongoing
AlanH
0.12
A
SUBTOTAL FOR OBJECTIVE #5:
0.310
I, IV
-------
Planning Matrix
Technical Studies and Support/EPA-106 Fiscal Year 1997 By: Abe Horpestad
OBJECTIVE #6: COMPUTER SUPPORT FOR PLANNING, PREVENTION AND ASSISTANCE DIVISION.
Activities required for the accomplishment of Objective #6:
A. Retrieve information from the WATERBODY
SYSTEM in the format required by the latest 305(b)
guidance;
Ongoing
AlanH
0.02
A
B. Establish and maintain a computerized system to
manage NPS demonstration project monitoring data and
enter data as it becomes available;
Ongoing
AlanH
0.02
A
C. Establish, maintain, operate and update the wetlands
data base;
Ongoing
AlanH
0.03
A
D. Establish, maintain, operate, and update the
Biological Data System (BIOD);
Ongoing
AlanH
0.02
A
A
A
E. Establish, maintain, operate, and update the
Enforcement computer Information system (EOS);
Ongoing
AlanH
0.20
E. Establish, maintain, operate, and update the NPS
stream Reach Tracking System (RTS);
Ongoing
AlanH
0.02
SUBTOTAL FOR OBJECTIVE #6:
0.310
OBJECTIVE #7: PROVIDE TECHNICAL SUPPORT IN THE AREAS OF TOXICITY, STANDARDS INTERPRETATION, PERMIT LIMITS, AND EVALUATION OF
THE ENVIRONMENTAL EFFECTS OF ACTIVITIES REGULATED BY STATE LAW.
Activities required for the accomplishment of Objective #7:
A. Consult with staff, other agencies and the public on
questions of toxicity, nondegradation, water quality
standards, permit limits, prepare public information,
and hold public training sessions;
Ongoing
Abe H
0.25
A
Ongoing
Tom R
0.13
A
Ongoing
Ken K
0.13
A
B. Review EA's and EIS's from Reclamation and
Energy divisions, US Forest Service, etc.;
Ongoing
Abe H
0.04
A
Ongoing
Tom R
0.21
A
Ongoing
Ken K
0.13
November II, 1996
-------
Planning Matrix
Technical Studies and Support/EPA-106 Fiscal Year 1997 By: Abe Horpestad
Ongoing Contracts
A
SUBTOTAL FOR OBJECTIVE #7:
0.89
CONTRACTS FOR OBJECTIVE #7:
TOTAL FTE FOR THE SECTION
5
CONTRACTS
GRAND TOTAL FOR THE SECTION
ASSUMPTIONS USED FOR THIS MATRIX:
- SALARY FOR STAFF ARE BASED ON AN AVERAGE ANNUAL COST PER EMPLOYEE OF 52,493 (84% EPA-106, AND 16% NON-
FEDERAL.
OJ
COSTS SHOWN WERE DERIVED BY DIVIDING PROGRAM COSTS LESS CONTRACTS COSTS BY THE NUMBER OF EMPLOYEES
EPA-106 (AND "106) MEANS FUNDS FROM EPA UNDER SECTION 106 OF THE FEDERAL CLEAN WATER ACT
AMOUNTS SHOWN ARE APPROXIMATE DUE TO ROUNDING ERRORS
1 FTE = 2,080 WORK HOURS THUS .02 FTE = ABOUT ONE WEEK
-------
WASTEWATER DISCHARGE PERMIT PROGRAM FY 19 97
Montana's Wastewater Surface Discharge Permit Program began in
1968. With passage of Public Law (PL) 92-500 (Water Pollution
Control Amendments of 1972), the federal NPDES Wastewater Discharge
Permit Program was also created. In 1974 Montana applied for and
received authority from the EPA to administer this program, thus
minimizing a duplication of effort. The pretreatment and sludge
programs have not been delegated to the state by EPA.
There are approximately 56 minor industrial, 18 major
industrial, 82 minor municipal and 26 major municipal facilities
that have individual MPDES permits. The state has also issued 12
general permits to date. Table #1 lists the breakdown of
facilities that presently have general wastewater discharge
permits. The general permits have been quite successful in
minimizing permit issuance time for repetitive classes of permits.
Major, minor and most general permit facilities are tracked
for compliance utilizing the PCS Database System. Permit fee
regulations have been adopted and the program is now funded 100% by
permit fees. Nondegradation and mixing zone regulations have been
passed and result in new requirements being placed in MPDES
permits. EPA provides the pretreatment and sludge requirements
language to be inserted in the MPDES permits.
Table 1 GENERAL PERMIT SURVEY
General Permit Authorizations
Category Currently Active
Suction Dredge 4
Fish Farm 12
Construction Dewatering
and well pumping 10
Disinfected Water Discharge 1
Facultative Sewage Lagoon 3 0
Concentrated Animal
Feeding Operation 60
Produced Water 19
Petroleum Cleanup 2
Sand & Gravel 3
Storm Water Industrial 183
Storm Water Construction 174
Storm Water Mining and Oil 75
573
Permits are issued for up to five years and reflect
technology-based controls, Best Available Technology (BAT), and
Best Practicable Technology (BPT); and where appropriate, water
quality based controls using wasteload analyses and current water
quality standards. Water quality variables for which effluent
-------
limitations have been developed to protect the waters of the State
include ammonia, total dissolved solids, DO, residual chlorine,
fecal coliforms, turbidity, total suspended ' solids, BOD,
temperature, various nutrients and toxics. Most of the major
permits also contain whole effluent toxicity testing requirements
to insure the effluent remain non-toxic to state waters.
All permits, new or renewals, must go through wasteload
allocation analysis and review before they are issued. Based upon
the results of the wasteload allocation analysis, stricter effluent
limitations may be placed on the permittee to insure that State
water quality standards are not exceeded.
Table 2 MAJOR PERMITS TO BE
Major Industrial
Decker Coal West
Holly Sugar
Western Sugar
Stimson/Libby
Zortman Mining Inc.
ISSUED, FY 199 7
Manor Municipal
Billings
Kalispell
Bozeman
Livingston
Missoula
Helena
Specific priorities for FY 1997 include:
* Implement new department organization and relocation,
* Reduce backlog of expired major permits ensuring that
water quality standards are met; toxic criteria
limitations, effluent toxicity testing, pretreatment
requirements, nondegradation requirements, mixing zone
requirements and sludge handling requirements are
imposed, and appropriate effluent limitations and
selfmonitoring are provided,
* reissue minor permits and issue new minor permits as
required,
* Provide timely complaint follow-up,
* Provide compliance monitoring for all permittees as per
workplan agreement, completing Form EPA-3560-3 for each
and entering data into the Permits Compliance System
(PCS),
* Compliance monitoring dischargers where self-monitoring
data is suspect,
* Continue the QA program to assure accurate self-
monitoring data for MPDES program,
* Provide appropriate enforcement and report to the EPA,
giving priority to major dischargers and federally-funded
minor municipalities,
* Provide timely review and appropriate notification on
self-monitoring information. Enter Discharge Monitoring
Report (DMR) data into PCS on a timely basis.
* Review program goals and work priorities, in light of the
new reorganization.
-------
Surface Water Program
_ .jnn.. ./lai.
Fiscal year 1997
F
By Fred Shewman
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACT
SERVICES
FUNDS
FUNDING
SOURCE(S)
GOAL ft\\ Implement Surface Water Program
OBJECTIVE #1: Administration including planning, budgeting, public relations and staff supervision
ACTIVITIES:
A. Conduct administrative duties necessary for program
maintenance and development; public relations; supply
program information; develop policy; coordinate w/DEQ
sections; answer public inquiries; develop budgets and
contracts; write reports, grant applications; and plan.
Develop 1998 program work plan.
Ongoing
1998 plan
due 9-97
Fred Shewman
0.50
A
B. Supervise, assign duties, train, monitor and evaluate
staff.
Ongoing
FS
0.20
A
C. Shared adm & overhead
)
)
Ongoing
Jan S, JK, JB,
DH, Support
Services Bureau
1.05
A
SUBTOTALS for Objective #\
1.75
Fees
OBJECTIVE #2: Maintain the MPDES Program
ACTIVITIES:
A. Issue approximately 15 new and 40 renewal MPDES
permits. Include WET, sludge, pretreatment and
nondegradation requirements when necessary.
Ongoing
Sam Martinez
Greg Wermers
Joe Strasko
Mike Pasichnyk
2.00
A
B. Pre-permit visits for quality control for MPDES
Ongoing as
resources allow
SM, GW, JS, MP
0.20
B
C. Issue approximately 90 general permit authorizations per
year.
Ongoing
SM, GW, JS, MP
0.15
A
-------
Surface Water Program
Planning Matrix
Fiscal year 1997
Page 2
By Fred Shewman
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACT
SERVICES
FUNDS
FUNDING
SOURCE(S)
D. Pre-authorization visit for quality control
Implementing
as resources
allow
SM, GW, JS
0.05
B
E. Revise fee regulations
9-97
FS
0.10
A
F. Compliance inspection of 25 majors.
Ongoing
GW, SM, JS
0.20
A
G. Compliance inspection of minors and general permit
authorizations 50 per year plus 24 complaints per year
Approx. 75
visits
SM, GW, JS
0.40
B
H. Maintain PCS system, conduct monthly DMR meetings
and followup initial enforcement
Ongoing
MP
0.60
A
I. Fees management - task order, compute billing, tracking
payments, update tracking system.
Ongoing
Karen Anthony
0.40
A
J. Provide quarterly list of permits issued with WQS, WET,
sludge, or pretreatment requirements
Quarterly
MP
0.00
A
K. Followup on yearly DMR/QA program (lab deficiencies)
Yearly
MP
0.02
B
L. Receive and give training
Ongoing
FS, SM, GW, JS,
MP
0.13
B
M. Administrative support services
Ongoing
KA
0.60
A
SUBTOTALS for Objective #2
4.85
Fees
OBJECTIVE #3: Spill Tracking and Response
ACTIVITIES:
A. Receive and record into database approximately 300 spill
reports per year, follow up as per spill protocol. Decide
organizational placement of spill response in new
department.
Ongoing
All personnel
Mike Pasichnyk-
lead
0.15
A
B. Extended followup on 3-4 major spills per year
Occasional
Mike Pasichnyk
0.05
A
-------
Surface Water Program
__.jnn & lat___
Fiscal year 1997
P
By Fred Shewman
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACT
SERVICES
FUNDS
FUNDING
SOURCE(S)
C. Extra spill visits required to satisfy protocol
Occasional
Need 0.26 FTE
0
C
SUBTOTALS for Objective #3
0.20
Fees
-------
Surface Water Program
Planning Matrix
Fiscal year 1997
Page 4
By Fred Shewman
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACT
SERVICES
FUNDS
FUNDING
SOURCE(S)
OBJECTIVE #4: Review Reclamation Dirision Operating Permit Applications
ACTIVITIES:
A. Review 5-8 mine applications per year for MPDES
Occasional
FS, GW, SM, JS
0.25
B
SUBTOTALS for Objective #4
0.25
Fees
OBJECTIVE #5: Maintain the MPDES Storm Water Program
ACTIVITIES:
A. Issue authorizations under general permits
Ongoing
Roxann Lincoln
Nicholas Bugosh
0.30
A
B. Administer contracts for compliance inspections, ECP
and SWPPP Review, local educational programs, public
service announcement.
7-96 to 6-97
RL
0.20
A
C. Public Information, Program updates,
workshops/training, guidance document.
Ongoing
Quarterly -
Prog. Updates
RL
0.25
B
D. Review Storm Water Pollution Prevention Plans and
Erosion Control Plans.
Ongoing
RL, NB
0.55
A
E. Compliance inspect sites.
Ongoing
RL, NB
0.30
B
F. Track/follow up noncompliance, complaints,
enforcement.
Ongoing
RL, NB
0.20
A
G. Administrative Support services
Ongoing
Darla Hassler
0.50
A
SUBTOTALS for Objective #5
2.50
104(b)(3)
Fees
GRAND TOTALS
9.55
550,000
104 (b)(3)
Fees
-------
_ .jiui.0 . lal.
Surface Water Program Fiscal year 1997 By Fred Shewman
ASSUMPTIONS: 1.00 FTE = 1880 hours per year (at work)
1.00 FTE = $60,733
CO
-------
FY97 DEQ Ground Water Program
Reorganization of the DEQ placed the FTEs that implement the Ground
Water Program into the Planning, Prevention and Assistance Division
(1.5 FTE), Remediation Division (1 FTE), Permitting/Compliance
Division (4.1 FTE), and Enforcement Division (1 FTE). The
individuals coordinate implementation of the Ground Water Program
by maintaining informal communications throughout the year and
formally meeting four times a year. The Montana Interagency
Coordinating Group will be asked to facilitate coordination between
DEQ and other agencies involved in implementing comprehensive
ground water protection by forming a Ground Water Coordination
Subcommittee.
Montana's Wellhead Protection Program is working cooperatively with
Montana Bureau of Mines, Montana Rural Water System, Midwest
Assistance Program and Montana University Water Resource Center to
provide wellhead delineations for public water supplies prioritized
in the approved program, schools and small public water systems.
A fourth local water quality district was formed in Gallatin County
and the Board of Environmental Review will be approving their water
quality program. Program staff continue to work with the Montana
Department of Agriculture to implement the Agricultural Chemical
Ground Water Protection Act.
The 4.1 FTE assigned to the Permitting/Compliance Divsion will
continue to implement the MGWPCS permit program and also will
assist in reviews of projects potentially affecting state ground
water quality standards, assuring compliance with those standards.
With the advent of more hydrologically-connected discharges, the
ground water personnel are becoming more involved in MPDES
discharge permits involving discharges to surface waters that enter
through the ground water. General discharge permits are also under
consideration for ground water discharges from domestic sewage
lagoons and from septage disposal sites.
-------
Ground Water Program
_ .. mi: _ ปtri
Fiscal Year 1997
age
By Fred Shew man
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE I: Administer program including budgeting, stal
f supervision, plai
ining and address
ng regulatory and legislative issues.
A. Conduct administrative duties necessary for program
maintenance and support. Review monthly SBAS, monitor
expenditures, develop FY97 work plan and SEA, monitor
progress with plan, and develop FY98-99 budgets.
Ongoing
FY97 Plan
Sept 96
SP
.55
A
B. Provide support services to program including permit and
public notice processing, tracking system data entry and
maintenance, mailing, copying, filing, phone answering, etc.
Fund portion of division administrator and division support staff.
Ongoing
DM (.5)
JS/JK @.1
Need .5 FTE
.7
A
C. Supervise staff, assign duties, review work, conduct
evaluations. Develop individual performance appraisals and
conduct annual personnel evaluations. Hire new or replacement
FTEs as needed.
Ongoing
Appraisals
SP
.1
A
D. Update ground water regulations to address 1995
amendments. Develop strategy to implement regulation of
municipal sewage lagoons and educate community
representative. Respond to information requests and interpret
statutes and regs for regulated community and public.
Strategy
July 97
Info response
ongoing
SP (.2)
TW/TB
JM/CD
@ .05
.4
B
E. Develop UIC Class V program and submit application to
EPA for authorization and funding.
Draft Program
Ap. July 98
Need .5 FTE
C
F. Provide hydrogeologic expertise to the public, other division
programs and agencies. Contract to fund graduate research
projects related to ground water quality or pollution prevention .
As requested if
funding
available
SP
.05
B
SUBTOTAL
Need 1 FTE
1.8
State GW
EPA
-------
Ground Water Program
Planning Matrix
Fiscal Year 1997
Page 2
By Fred Shewman
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE II: Implement Wellhead Protection Program to protect ground water used by public water supply systems.
A. Implement wellhead protection program in accordance with
approved program description. Review applications for
certification within 30 days, work with applicants to address
deficiencies and certify approved programs.
Certification
Review within
30 days
JM
Need .5 FTE
.5
A
B. Develop and distribute wellhead educational materials such
as program summaries and guidance, information displays, fact
sheets, etc. and publish articles in statewide publications.
4 printings
per year
JM
.05
A
C. Encourage development of local wellhead programs and
provide training by speaking at city council meetings and
Montana Rural Water Systems workshops, operator certification
training, and other meetings or conferences.
8 talks pier year
JM
.1
.05
B
D. Coordinate state-wide Water Education Calendar Poster
Contest.
July 97
JM
Need .05 FTE
.02
B
E. Assist MBMG and MT Rural Water Assoc. in their
delineation of wellhead protection regions and help select
communities and ensure delineations meet criteria. Attend
meetings to educate and solicit participation in WHP. Distribute
WHP guide developed by MBMG.
Bimonthly
meetings
JM
.23
B
F. Coordinate with PWS and NRIS to develop WHP data base,
and to produce maps.
July 97
JM
.05
C
SUBTOTAL
Need .85 FTE
.95
EPA
-------
Ground Water Program
ini o itri..
Fiscal Year 1997
- age .
By Fred Shewman
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE III: Implement Montana Ground Water Pollutio
n Control System
permit program t
o contro
1 sources of pollution.
A. Process MGWPCS permits: Review permit applications and
renewals for nonsignificance and completeness, construction and
design of containment and monitoring systems, draft permits and
EAs, hold public meetings.
6 major
15 general
permits/yr
20 permits/yr
TW/TB
@ .4
CD .1
Need 1 FTE
.9
A
B. Conduct pre-permit, permit compliance and sampling
inspections, write GW inspection reports, review self-monitoring
data, monitor permit expiration, and notify permittees of
compliance issues. Make recommendations to bring operations
into compliance.
25 insp/yr
TB/TW
@ .2
CD .25
.65
A
C. Respond to complaints related to ground water and conduct
site investigations. Evaluate contaminated sites unregulated by
other programs, review/recommend remedial actions, oversee
cleanup and coordinate between all DEQ Divisions. Support 1.0
FTE WQ Specialist (complaint investigator) in Enforcement
Program.
40 ongoing
10 new/yr
20 additional
sites/yr
TW/TB
ฎ -22
CD (.25)
Vac 1
Need 1 FTE
1.69
B
D. Provide support for enforcement activities related to permit
and ground water quality standards violations. Write notice of
violations and informal enforcement letters. Make
recommendations for formal enforcement actions, assist in order
development, and monitor compliance with department or court
orders. Support 0.4 FTE Attorney in Enforcement Program.
3 formal 10
informal
cases/yr
20 informal
SP
TW/TB
@ .05
CD .4
Need .5 FTE
.55
B
E. Assist in review of hard rock operating permit applications,
Haz waste, Superfiind, UST and Solid waste sites as requested.
5 sites/yr
5 sites/yr
TB/TW
@ .03
Need .5 FTE
.06
B
-------
Ground Water Program
Planning Matrix
Fiscal Year 1997
Page 4
By Fred Shewman
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
F. Develop general permits for categories of sources
discharging to ground water (1) municipal lagoons, infiltration
ponds and land application sites, (2) septage disposal sites, (3)
industrial Class V UIC wells, and others as needed.
(1) July 97
(2) Oct 97
(3) Dec 98
TW/TB/CD
@ .05
Need .1 FTE
.15
B
SUBTOTAL
Need 3.1 FTE
4
State GW
EPA
Fees
OBJECTIVE IV: Pesticides in Ground Water and Nonpoint Initiatives.
A. Fulfill responsibilities under MACGWPA. Follow MDA-
DEQ MOU, coordinate with MDA on oversight and
investigation of agrichemical releases and assist in review of
pesticide management plan submitted to EPA.
5 sites/yr
CD
.25
A
B. Represent Ground Water Program on and participate in NPS
Watershed/Ground Water committee in review and ranking of
NPS Watershed Ground Water preproposals.
Quarterly
meetings
CD
.05
B
C. Develop, submit and review and implement 319 proposals to
address short or long-term goals of the ground water components
of the Montana Nonpoint Source Management Plan.
July 97
CD
JM
Need .1 FTE
in m
ฉ ฉ
SUBTOTAL
Need .1 FTE
.35
AG-GW
EPA
-------
Ground Water Program
jini o atrL.
Fiscal Year 1997
'age
By Fred Shewman
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
OBJECTIVE IV: Develop and implement the Local Water Quality Districts program to assist local governments in ground water pollution prevention.
A. Consult with counties on development of LWQDs including,
Flathead, Gallatin, Silver Bow and others that propose to form
districts. Review program plans when submitted and write
completeness reviews.
Biannual
meetings
1 new plan per
year
CM
Need . 1 FTE
.15
A
B. Assist in the board review and approval of WQD programs.
Review annual WQD reports, process requests for enforcement
authority, track compliance with program plans and enforcement
authorizations, and maintain status data base.
3 reviews per
yr
3 enf auth/yr
CM
.1
A
C. Coordinate with other division programs to enhance
implementation of district programs and to encourage formation
of districts to support wellhead programs.
Ongoing
CM
.05
B
SUBTOTAL
Need .1 FTE
.3
LWQD
OBJECTIVE V: Develop and implement a Comprehensive Groundwater Protection Program. Assist in statewide coordination efforts to optimize use of state
resources, exchange data and to identify and fill gaps.
A. Review EPA comments CSGWPP, update and resubmit
plan.
Final Plan
Jan 97
CM
.1
A
B. Participate in other groups to enhance and coordinate ground
water quality protection: (Ground Water Assessment Steering
Committee, Montana Watershed Council).
Bimonthly and
Quarterly
meetings
CM
.05
B
C. Inform public and agencies of plan recommendations and
assist agencies in implementation of recommendations specified
in plan.
May 97
CM
Need .2 FTE
.05
B
SUBTOTALS
Need .2 FTE
.2
EPA
LWQD
-------
Ground Water Program
Planning Matrix
Fiscal Year 1997
Page 6
By Fred Shewman
ACTIVITY (OUTPUT)
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
TOTAL - Activities described in this matrix are implemented
by the Department of Environmental Quality:
Permitting/Compliance Division, Planning, Prevention and
Assistance Division, and Remediation Division
Need 7.25 FTE
7.6
see summary
FUNDING/FTE SUMMARY SOURCE
SOURCES POSITION FTE
State GW Division Adm. 0.1
EPA Division Adm. Support 0.1
Permit Fees Env. Program Manager 1.0
AG-GW Water Quality Specialist IV 2.0
LWQD Water Quality Specialist III 3.5
Attorney 0.4
^ Administrative Asst. 0.5
^ Total FTE 7.6
-------
PUBLIC WATER SUPPLY
The first Montana Public Water Supply law was enacted in 1907. This law was revised in 1977, 1979,
1991, and 1995, to enable Montana to receive and retain delegation for the administration of the Federal Safe
Drinking Water Act (SDWA) (PL 93-523). The Public Water Supply Program (PWSP) has adopted and received
primacy for the Total Coliform Rule (TCR), the Surface Water Treatment Rule (SWTR), the Public Notification
Rule (PNR), the Phase I rule, the lead and copper rule (LCR) and the Phase n/V Rule. In FY 1995, the PWSP
also adopted rules for administrative order procedures and penalties.
The 1991 changes in the law allowed DHES to develop a fee schedule to assess service connection fees
and plan review fees to recover costs of administering the law. In November of 1991, the Board of Health and
Environmental Sciences (BHES) adopted the rules that established the assessment and collection of service
connection fees. In July of 1992, the BHES adopted rules that established the fees for plan review. A total of
approximately $557,000 was collected in FY 1996 in service connection fees and plan review fees.
Service connection fee funds were used to hire additional employees, bringing the total to 20.45 FTEs in
the program.
The PWSP regulates all public water supplies (PWSs). PWSs are those supplies which have at least 15
service connections or serve 25 people per day for 60 or more days per year. The 1995 legislature changed the
definition from 10 to 15 service connections, effective October 1, 1995. The inventory of Montana's PWSs varies
in number but currently includes about 700 community systems, 1050 transient noncommunity systems and 225 non-
transient non-community systems.
The chemical quality of drinking water in western Montana is generally considered good. Many PWSs in
eastern Montana have high levels of dissolved solids, sulfates, sodium, iron and manganese. These problems are
generally not a public health threat. Some PWSs in western Montana still use surface water without filtration and
occasionally have turbidity problems. Many groundwater supplies in western Montana obtain water from shallow
groundwater sources. These supplies are relatively susceptible to microbiological contamination and to contamination
from man-made chemicals.
Several systems have exceeded the maximum contaminant level (MCL) for nitrate in the past. The PWSP
requires these systems to provide bottled water from an approved source for infants and pregnant mothers and is
working with these supplies to achieve long-term solutions. Nitrate problems have been resolved through treatment
or blending with low-nitrate water. Recent Phase n/V sampling has shown some additional systems have nitrate
and/or nitrate exceedances. The PWSP continues to work with these systems also to resolve this problem.
Montana has about nine community supplies that exceed 4.0 mg/1 in fluoride. These systems are required
to give public notice and provide bottled water for those who prefer it. The department has been working with these
systems in order to find an affordable solution to the fluoride problem.
Unfiltered surface water has been one of the state's major concerns for the past several years. The PWSP
issued 8 administrative orders in FYs 1994 and 1995, and plans to issue additional administrative orders in 1996
and 1997 to the PWSs that cannot meet the requirements of the surface water treatment rule. Other orders may be
issued to significant non-compliers (SNCs) of the TCR, the Phase 2/5 Rule, and the LCR. Several new treatment
plants have been constructed in the past several years that have eliminated some of the most serious problems.
Several outbreaks of giardiasis have occurred before in Montana. The public water supply program has taken action
to see that the risk from Giardia and other waterborae pathogens is minimized until filtration is installed, or until
existing filtration plants are upgraded to meet the requirements of SWTR. The program has personnel on staff who
specialize in the area of Giardia filtration and control. A procedure known as the microscopic particulate analysis
(MPA) has been used to evaluate surface water source quality and filtration efficiency. The MPA analyzes the
microscopic content of the water. Program staff and contracted consultants will also investigate shallow wells and
springs in 1997 to determine whether they are influenced by surface water.
-------
Over the past several years, the program has developed a detailed method of evaluating all aspects of the
performance of water filtration plants. The method is patterned after the wastewater industry's Comprehensive
Performance Evaluation (CPE) process. CPEs have been performed on 17 of Montana's surface water treatment
plants. Composite Correction Programs (CCPs) are a follow-up technical assistance effort directed at plants that
have problems that were identified during a CPE. CCPs have been completed at Miles City, Conrad, Loma and
Harlem. Unfortunately, no additional CPEs or CCPs were performed in 1996 due to legislative, enforcement and
regulatory compliance issues, and department reorganization. The CPE/CCP program is relatively new to the
drinking water industry and there has been a great deal of interest shown by other states, the American Water Works
Association (AWWA), the AWWA Research Foundation, the Association of State Drinking Water Administrators
(ASDWA) and the Environmental Protection Agency (EPA). The work completed in Montana and more recently
in a few other states has been used by EPA's Center for Environmental Research Information to develop a
"Summary Report" titled Optimizing Water Treatment Plant Performance With The Composite Correction Program
(EPA/625/8-90/017). An EPA handbook has also been distributed nationwide.
The Division's local area network system of IBM computers (PCs) provides easy access for all staff
members to the PWSP's Advanced Revelation database. Programs have been written to compute monthly compliance
using the new total coliform regulations. Turbidity and most chemical analysis data can also be entered into the
database. Compliance determinations cannot yet be made for all parameters. Programming efforts are nearly
complete for the Phase II and Phase V Rules. Programming for the Lead and Copper Rule is essentially complete.
On July 1, 1995, the PWSP became part of the new DEQ. The PWSP relocated to the Metcalf Building
at 1520 East Sixth Avenue in March of 1996.
Refer to the matrix for the priority objectives for FY 1997.
-------
Program DRINKING WATER
.'Ian _ latr_._
Fiscal Year 1997
By MELSTAD. SMITH & GOLZ
P
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL I: Develop legislation, new rules and rule changes
to allow effective program growth and
implementation.
Objective 1: Prepare proposed viability rule
06/30/97
Mark, Jim,
.06
$
B
Objective 2: Prepare rule revisions
12/31/96
PWS Staff
.11
B
Objective 3: Final proposed cross-connection control program
rule
12/31/96
Marc
.05
B
SUBTOTAL
.22
$
RC 59612
$
$ EPA
Fees
RIT
ASSUMPTIONS: 0.02 PTE = 40 hours = 1 week
-------
Planning Matrix
Page
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL II: Prepare for hiring of additional staff; revise PDs
as necessary
Objective 1: Replacement of staff in vacant positions
as needed
Jim, Mark,
Marc
0.10
A
Objective 2: Submit revised engineering position descriptions
to Personnel Unit
06/30/97
Mark, Gary,
Marc, new
engineers
.06
B
SUBTOTAL
.16
0
$
$ EPA
Fees
RIT
ASSUMPTIONS: 0.02 FTE
* ~TE
40 hours =
-------
'Ian' latr
P
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL HI: Effectively administer day-to-day PWSP duties
and coordinate activities between work units.
Objective 1: Develop draft of Program Plan for FY 1998.
08/01/97
Jim, Mark,
Marc
.04
A
Objective 2: Develop Annual Work Plans for Engineering and
Field Services Programs.
10/15/97
.05 FTE
Needed
C
Objective 3: Project and track expenditures closely to insure
grant and fee income is adequate for program
operations; make projections for upcoming fiscal
years.
Ongoing
Jim, Mark,
Marc
.04
A
Objective 4: Hold weekly program meetings
Ongoing
PWS Staff
.30
B
Objective 5: Implement optimistic, but realistic performance
standards; perform annual performance
evaluations.
Ongoing
Jim, Mark,
Marc
.23
A
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
Program DRINKING WATER
Planning Matrix
Fiscal Year 1997
By MELSTAD. SMITH & GOLZ
Page 6
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 6: Weekly managers meetings.
Ongoing
Mark, Marc,
Div. Adm.,
Jim
.15
A
Objective 7a: Miscellaneous manager responsibilities.
Objective 7b: Misc. other responsibilities; e.g. more
completely monitor individual activities and
accomplishments, communication/coordination
with other agencies, continue regular PWS task
force activities and meetings etc.
Ongoing
Mark, Marc,
Steve, Jim
Need 0.5 FTE
.75
A
C
Objective 8: Develop 5-year program plan
Need 0.04 FTE
C
Objective 9: Budget preparation, EPP misc. tasks
Ongoing
Div. Adm.,
Jim, Marc,
Mark
.10
0
0
A
SUBTOTAL
Need 0.59 FTE
1.61
0
$
$ EPA
$ Fees
$ RIT
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
Program DRINKING WATER
'Ian ^ latr
Fiscal Year 1997
Bv MELSTAD. SMITH & GOLZ
P
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
RITY
GOAL IV: Conduct Sanitary Surveys of Public Water
Systems and Small Wastewater System
Inspections.
Objective la: Helena and Poison Offices to conduct
approximately 50 water system sanitary
surveys and 10 wastewater inspections.
ongoing
PWS Staff
.45
0.00
A
Objective lb: Helena and Poison Offices to conduct
approximately 30 water system sanitary survey
and 15 wastewater system inspections.
Need 0.2 FTE
B
Objective lc: Complete reports in a timely fashion, act to
correct deficiencies found during inspections.
Need 0.5 FTE
B
Objective Id: Conduct regular field visits at water and
wastewater facilities not scheduled for sanitary
surveys.
Need 0.5 FTE
C
Objective 2a: Provide for regular sanitary surveys and water
sampling of small public systems through
administration of county contracts.
Ongoing
PWS Staff
.20
$
A
Objective 2b: Evaluate county survey reports closely &
follow up on reported deficiencies in a timely
fashion; prepare instructions and answer
questions in a timely fashion, prepare & revise
contracts in a timely fashion.
Need 0.9 FTE
C
ASSUMPTIONS: 0.02 FTE =
1.00 FTE =
40 hours =
$49,086
-------
Planning Matrix
Page 8
Program DRINKING WATER Fiscal Year 1997 By MELSTAD, SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 3a: Provide for regular sanitary surveys and water
sampling of small community water systems
through the administration of contracts with
private consultants.
Objective 3b: Evaluate contracted survey reports closely and
follow up on reported deficiencies in a timely
fashion.
Ongoing
Terry, Marc
Need 0.45 FTE
0.47
$
A
B
Objective 4: Provide sanitary survey training for county
sanitarians and new staff through contracts with
private consultants and PWS staff.
3/31/97
Marc, PWS
Staff
0.04
$
B
SUBTOTAL
Need 2.55
FTE
1.16
$
RC 59611
$ RC 59612
$
$ EPA
$ Fees
$ RIT
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
nlan latr-
P "
Program DRINKING WATER
Fiscal Year 1997
By MELSTAD. SMITH & GQLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL V: Provide training services to water and wastewater operators and
managers and to the general public to facilitate better operation
and maintenance of public water and wastewater facilities and
better understanding of the public health aspects of public water
supplies.
Objective 1: Conduct 2 annual water and wastewater
operator schools in Billings and Bozeman.
Mar 12-14,
1997
&
Sept. 22-26,
1997
Rick
et.al
0.4
0.00
Objective 2a: Conduct 21 days of training activities, not
including water school, sponsored by the
WQB, METC or MRWS.
Objective 2b: Conduct an additional 10 days of specialized
training sponsored by WQB and/or METC,
additional prep, for training
Ongoing
Rick, et.al
Need 1.3 FTE
0.45
0.00
Objective 3a: Review and write 2 versions of the new water
operator exams including a new exam for
water bottlers. Review new study materials
for bottlers.
Objective 3b: Develop water treatment exams and study
materials for systems served by wells and
surface sources
12/31/96
Shirley, Jim,
Marc
et.al
0.04
Objective 4: Prepare 1996 METC annual training calendar
for water and wastewater operators
11/01/96
Rick
0.04
0.00
Objective 5: Serve as advisory and voting members of
METC Steering Committee
Ongoing
Rick, Marc
0.08
0.00
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
Program DRINKING WATER
Planning Matrix
Fiscal Year 1997
By MELSTAD. SMITH & GOLZ
Page 10
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 6: Continue development of training materials on
the purpose and public health implications of
the SDWA and operator certification programs
Ongoing
Field Serv.
0.03
0.00
A
Objective 7: Develop audio/visual training materials for
GWUI, SDWA amendments, and public
notification, and other water operator training
and public education topics
Ongoing
Rick, Eric
et.al.
0.06
$
A
Objective 8: Provide contracted training for conducting
CPE, for assistance with CPEs, administrator
training, general water treatment plant operator
training
Ongoing
Marc
0.10
$
B
Objective 9: Fund technical trainer and half time support
staff for Montana Environmental Training
Center
Ongoing
Marc, Rick
0.02
$
A
Objective 10: Maintain operation guide books for public
water suppliers that compile monitoring and
reporting requirements
Ongoing
Sara
0.05
B
Objective 11: Assist water suppliers in wellhead protection
efforts.
Ongoing
0.04
$
0
SUBTOTAL
Need 1.30 FTE
1.31
$
RC 59611
$
RC 59612
$
$ EPA
$ Fees
$ RIT
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
"lanj " " latri"
Pajse 1 1
Program DRINKING WATER Fiscal Year 1997 By MEI^TAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL VI: Provide technical assistance to operators and
managers of water and wastewater facilities to
solve specific problems.
Objective la: Conduct 2 CPEs at surface water treatment
plants
Objective lb: Conduct an additional 2 CPEs and 1 CCP at
surface water treatment plants
Objective lc: Additional tech. asst. for follow-up to CCPs
Ongoing
Marc, John,
Terry, PWS
staff
Need 0.4 FTE
Need 0.3 FTE
0.40
0.00
B
C
C
Objective 2: Implement contracted services to provide
technical assistance to small systems and
follow-up to boil orders and health advisories
Ongoing
Rick
0.33
$
A
Objective 3a: Implement boil order policy
Objective 3b: Additional assistance for 3a
Ongoing
PWS Staff
Need 0.5
0.40
0.00
A
Objective 4a: Provide emergency response to contamination
events in addition to boil orders
Objective 4b: Additional assistance for 4a
As Needed
PWS Staff
Need 0.50
0.10
0.00
A
Objective 5: Finalize and implement emergency response
plan
01/31/97
Rick
0.06
0.00
B
ASSUMPTIONS: 0.02 PTE = 40 hours = 1 week
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Planning Matrix
Page 12
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIO
RITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 6: Draft groundwater CPE approach objectives
and factors
06/30/97
Need 0.25 FTE
0.00
C
Objective 7a: Provide general assistance and education to
the general public and operators
Objective 7b: Provide for additional general assistance to
operators and the public
Ongoing
PWS Staff
Need 2.0 FTE
0.60
0.00
A
C
Objective 8: Provide funds for special water sampling for
VOCs, SOCs, IOCs
Ongoing
$
A
TOTAL
Need 3.95 FTE
1.89
$
RC 59611
$
RC 59612
$
$ EPA
$ Fees
$ RIT
ASSUMPTIONS: 0.02 FTE = 40 hours = 1 week
-------
'Ian latr
P
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL VII: Provide for effective, efficient review of plans
and specifications.
Objective la: Conduct 65 reviews in the Helena Office, 50
in the Billings Office. Coordinate review with
Groundwater Program and Municipal
Wastewater Assistance Section. (More
reviews are possible as a result of the LCR.)
Ongoing
PWS Engineers
0.82
$
A
n
Objective lb: Provide for timely review of plans, conduct
field investigations during and after
construction to ensure compliance with
approved plans and specifications, check as-
builts for accuracy, assist support staff with
better filing system for plans and
specifications.
Need 3.0 FTE
Objective 2a: General maintenance of design standards;
Implementation of deviation process.
Ongoing
PWS Engineers
.20
B
Objective 2b: Regular & timely development, documentation
and revision of review policies and procedures,
assistance to consultants and general public
with design and construction questions and
policies.
Need 0.50 FTE
C
Objective 3a: Provide oversight of delegated plan and
specification review to local governments
Ongoing
PWS
Engineers
.15
$
A
Objective 3b: Provide regular training and new information
to contracted local governments as procedures,
standards and personnel change, and provide
for regular review of work performance.
Need 0.45 FTE
C
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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Planning Matrix
Page 14
Program DRINKING WATER Fiscal Year 1997 By MELSTAD, SMITH & GOL2
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORITY
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 4a: Provide oversight of contracted consulting
services for assistance with review of
approximaately 200 sets of plans and
specifications.
Objective 4b: Provide for regular review of consultant's
work, provide regular training updates and
policies and procedures change.
Ongoing
Mark
Need 0.10 FTE
0.27
$
A
B
TOTALS
Need 4.05 FTE
1.44
$
RC 59612
$
$ EPA
$ Fees
$ RIT
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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'lani latr.'
Pa
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
Y
FTE
CONTRACTED
SERVICES
TOTAL $
FUNDING
SOURCE(S)
GOAL VIII: Develop and maintain data management
system and provide clerical support for PWSP
Objective 1: Develop software for PWSP
1. Enhance Phase II/V software.
12/31/96
Bruce, Chris
.57
A
2. Enhance/Modify other software.
On-going
Bruce, Chris
.45
A
3. Provide support for field offices
On-going
Bruce
.10
B
4. Enhance long-term coliform MCL software.
01/31/97
Bruce
.10
B
5. Develop sanitary survey tracking software
Need 0.10 FTE
C
6. Develop Rad compliance software.
Need 0.10 FTE
C
SUBTOTAL
Need 0.20 FTE
1.22
RC 59612
EPA
Fees
RIT
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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Planning Matrix
Page 14
Program PRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
GOAL VIII: (continued) . . Develop and maintain data
management system and provide clerical support for PWSP
Objective 2: Maintain electronic database for PWSP
1. Develop capability to import LIMS data
06/30/97
Bruce, Chris
.10
A
2. Develop method to archive AREV data
Need .08 FTE
C
3. Develop plan for labs to report electronically
Need 0.10 FTE
C
SUBTOTAL
Need 0.18 FTE
.10
RC 59612
EPA
Fees
RIT
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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'Ian lati P<
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
GOAL VIII: (Continued) . . Develop and maintain data
management system and provide clerical support for PWSP
Objective 3:
1. Continue electronic SDWIS reporting
On-going
Bruce, Chris
.34
A
2. Generate chemical and inventory printouts for counties
02/01/97
Bruce, Chris
.04
A
3. Review submitted LCR data & prepare for data entry.
On-going
Chris
.05
A
4. Develop data verification/validation plan
Need 0.10 FTE
C
5. Write data flow manual for PWSP
Need 0.10 FTE
C
SUBTOTAL
Need 0.2 FTE
0.43
0
EPA
Fees
RIT
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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Program DRINKING WATER
Planning Matrix
Fiscal Year 1997
Bv MELSTAD. SMITH & GOLZ
Page 16
GOAL VIII: (Continued) . . Develop and maintain data
management system and provide clerical support for PWSP
Objective 4: Provide other technical and clerical support
la. Provide data base technical support, generate reports for
A and B priority activities.
lb. Provide above support for C activities
On-going
Chris
Need 0.25 FTE
.25
A
C
2. Provide timely mailing, filing and AREV data entry of
coliform, inorganic, LCR and chemical data, including
LIMS data
On-going
Position 5501
.40
A
Sandi
.40
Paula
.45
temporary
3. Update AREV PWS inventory
On-going
Sara
.20
A
temporary
4. Plan & Spec Review-related services
On-going
Sara
.15
A
4
4
4
4
4
4
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1 on FTP. = $49 (IRfi
-------
lani latri
Pa
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
GOAL VIII: (Continued) . . Develop and maintain data
management system and provide clerical support for PWSP
Objective 4: (Continued). . Provide other technical and
clerical support
5. General office support services
On-going
Sara
.10
A
Sandi
.30
Paula
.30
Erin
.10
Cookie, Janet
K.
1.2
C
Temporary
Need 0.5 FTE
6. Fee-related support services
On-going
Chris
.03
A
Sara
.55
SUBTOTAL
Need 0.75 FTE
4.33
EPA
Fees
RIT
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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Planning Matrix
Page 18
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Y
GOAL IX: Provide for effective formal enforcement
procedures for PWSP
Objective la: Assist Enforcement Section to finalize and
monitor AOs for unfiltered surface water
supplies that must filter
12/31/96
Marc, Betsy
John, Jim
.20
A
Objective lb: Review and comment on documents and
reports submitted in response to AOs for
unfiltered surface water systems.
Ongoing
Betsy, PWS
Staff
.20
A
Objective 2: Assist Enforcement Section to finalize and
monitor AOs for filtered water supplies that
are not in compliance.
03/1/97
Betsy, Marc,
John, Jim
.15
B
Objective 3a: Participate in other formal enforcement
actvities, including planning, negotiation, Div.
enf. mtgs., preparation of other formal orders
orders or judicial actions.
On-going
PWSP staff,
Betsy, Bob,
Claudia
1.23
A
Objective 3b: Provide adequate FTEs incl. lawyers and
paralegals for participation in BCA, AO and
civil actions with non-complying PWSs, and
for consultation with staff regarding
enforcement issues.
Need 1.7 FTE
C
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
i nn ppp _ *49086
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lani atri
Pa;
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
Y
FTE
CONTRACTE
D SERVICES
TOTAL $
FUNDING
SOURCE(S)
Objective 4: Investigate complaints, other misc. Enf.
Section and Legal Unit responsibilities.
On-going
PWSP Staff,
Rob, Besty,
Claudia, other
Enf. Section
Staff
1.50
A
TOTAL
Need 1.7 FTE
3.28
EPA
Fees
RIT
cn
i/i
ASSUMPTIONS: .02 PTE = 40 hours = 1 week
1.00 FTE = $49,086
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Program DRINKING WATER
Planning Matrix
Fiscal Year 1997
By MELSTAD, SMITH & GOLZ
Page 20
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
FTE
CONTRA
CTED
SERVICE
S
TOTAL $
FUNDING
SOURCE(S)
Y
GOAL X: Provide effective oversight and monitoring for
PWSP rules in accordance with EPA PWSS
Priority Guidance.
Objective la: Implement TCR & PN rules, monitor sample
results, reporting and public notification for
compliance with PWSP rules and provide
informal enforcement follow-up other than as
provided in Goal VI, Objective 3.
On-going
PWS staff
1.0
A
Objective lb: Complete implementation of tasks in la,
including assistance to PWSs with resolution
of positive non-acute coliform sample results.
Need 3.0 FTE
C
Objective 2a: Monitor self-monitoring results submitted by
PWS's, do follow-up as needed. (Does not
include compliance monitoring data for
surface water systems. This is covered in 3
below.)
On-going
PWS Staff
.10
A
Objective 2b: Complete implementation of tasks in 2.
Need 1.5 FTE
C
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1 0(1 FTP = *49,08(5
-------
Iaru atri
Pa;
Program DRINKING WATER Fiscal Year 1997 By MELSTAD. SMITH & GOLZ
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
FTE
CONTRA
CTED
SERVICE
S
TOTAL $
FUNDING
SOURCE(S)
Y
Objective 3a:
Implement SWTR for unfiltered systems, and
as many filtered systems as possible.
On-going
PWS Staff
0.70
A
Objective 3b:
Complete implementation of tasks in 3a.
Need 3.0 FTE
C
Objective 3c:
Implement GWUI policy and make GWUI
determinations.
Ongoing
Marc, Terry,
Eric
.10
A
Objective 3d:
Complete implementation of tasks in 3c.
Need 2.0 FTE
C
Objective 4a:
Continue implementation of LCR for all
systems > 3300 and for all systems that
exceed lead action levels.
On-going
Richard, PWS
Staff
.60
A
Objective 4b:
Complete implementation of LCR for all
systems.
Need 3.0 FTE
C
ASSUMPTIONS: .02 PTE 40 hours = 1 week
1.00 FTE = $49,086
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Program DRINKING WATER
Planning Matrix
Fiscal Year 1997
\ By MELSTAD. SMITH & GOLZ
Page 22
ACTIVITY/OUTPUT
MILESTONE
PERSONNEL
RESOURCES
PRIORIT
FTE
CONTRA
CTED
SERVICE
S
TOTAL $
FUNDING
SOURCE(S)
Y
Objective 5a:
Implement Phase II & V rules for acute
contaminants for community systems.
On-going
Gary, Chris,
Craig
.20
A
Objective 5b:
Implement vulnerability assessment program
and enforce initial monitoring requirements
for community systems serving >150 service
connections.
Ongoing
Craig, Chris,
Gary
.25
A
Objective 5c:
Follow up on MCL violations for all systems.
Craig, Chris,
Gary
.25
A
Objective 5d:
Complete implementation of Phase II and V
Rules, including technical assistance for
vulnerability assessments for all systems and
follow up for monitoring violations and
detects < MCL.
Ongoing
Need 3.0 FTE
C
Objective 6a:
Preparation for implementation and misc.
tasks associated with EPA rules that are yet to
be promulgated.
On-going
PWS Staff
.10
B
Objective 6b:
Complete implementation and misc. tasks
associated item 6b, including providing
review and comments of proposed EPA rules.
Need 1.5 FTE
C
SUB-TOTAL
17.0 FTE
Needed
3.30
RC 59611
RC 59612
EPA
Fees
RJT
TOTAL
20.45
0
0
ASSUMPTIONS: .02 FTE = 40 hours = 1 week
1.00 FTE = $49,086
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MUNICIPAL WASTEWATER ASSISTANCE SECTION
This section's primary activities are to provide financial, technical, and training assistance to
Montana communities to build and operate wastewater treatment and collection facilities. The
section provides financial assistance through the administration of the EPA Construction Grants
program and the Montana State Revolving Fund (SRF) loan program. The passage of the
Federal Clean Water Act in 1972 created the Construction Grants program which has provided
over 200 million dollars in Montana to build needed water pollution control facilities. The 1987
Amendments to the Act sunset the Grants program and concurrently created the State Revolving
Fund. The administration of the Grants program has been fully delegated to the state since the
late 1970's. The section has 4 active grant projects which will be closed out over the next
several years. Workplan tasks associated with these projects include reviewing the design and
construction of grant-funded facilities. Administratively closing out grant projects which have
completed construction is another major task of the section. The level of effort required to
administer this program will continue to decline in fiscal year 1997 with some shifting of staff
responsibilities to the SRF program.
The State Revolving Fund (SRF) loan program provides low interest loans to communities to
build wastewater projects in a manner similar to the Construction Grants program. The loan
program will allow funding of some projects (i.e., storm sewers) which were not eligible under
the Construction Grants program. All funds loaned out must return to the SRF in the form of
loan repayments to provide a self-perpetuating form of financial assistance. Loans are made up
of 83.33% federal funds and 16.67% state match. While certain federal requirements are
imposed on first-round loans, many will no longer apply after the funds revolve.
The loan program made its first four loans in 1991 totaling 8.9 million dollars and has since
closed a total of 33 loans for over 41 million dollars in project funds. The SRF program
adopted many of the technical requirements of the Construction Grants program and added
financial requirements inherent to any loan program. The Montana Department of Natural
Resources and Conservation and specialized financial consultants are used, under contract, for
financial expertise in this program. As new loans are funded, administrative requirements will
increase. The loan program must be managed to protect the state and federal interests in the
program yet still provide an affordable source of funding for Montana communities.
Needs in Montana for wastewater facilities will continue to grow. Projects selected for
assistance must be placed on the annual Project Priority List which determines order of need
according to severity of public health hazards or environmental problems. Currently, the
greatest needs in Montana are for small unsewered communities which have failing septic
systems and need a centralized sewer system. High growth rates in western Montana have
resulted in the overloading of existing treatment systems. Another significant need in this state
relates to decaying infrastructure which requires updating or replacement. Water quality
standards in high priority watersheds may require additional community investment in water
pollution control systems. Increased user costs and affordability will be an issue that financial
assistance programs and local governments must contend with in the future.
-------
The proper operation and maintenance of existing facilities is necessary to preserve the
investment of public funds in wastewater facilities as well as maintain compliance with water
quality standards.
The Municipal Wastewater Assistance Section, in conjunction with MSU-Northern, directs the
Montana Environmental Training Center (METC) which is partially funded with federal
construction grants assistance (109 (b) funds). The Training Center's primary mission is to
provide operators and managers with training and technical assistance in all aspects of facility
operations. Section staff participate in the development of the annual training program which
is facilitated by METC. Staff also frequently provide training for operators and administrators
at workshops and schools sponsored by METC. Specific training subjects to be covered in fiscal
year 1997 include compliance with the new Federal Part 503 sludge regulations, compliance with
the state's recently implemented nondegradation rules, as well as safety and health issues. The
section also provides on-site training to wastewater operators when it appears that this method
of training is most effective. Often new operators benefit most from on-site assistance. Also,
the section supports the Department's Operator Certification program by providing resources for
a variety of needs within that program.
A restructured wastewater treatment plant inspection program is being implemented through the
section's technical assistance program with the goal of identifying existing and potential
performance-limiting factors at wastewater facilities. Pollution prevention methods will be
stressed during the plant evaluation process. Inspectors will try to visit all municipal treatment
facilities every three-to-five years. An effort began in 1994 and continuing into 1997 is to
evaluate nondischarging lagoons to determine their potential impacts on water quality.
A former employee developed and implemented a Municipal Water Pollution Prevention program
utilizing grant funds made available through a special grant received from EPA. A new
employee, hired in 1996, will continue implementing the Pollution Prevention program goals and
objectives. The purpose of the grant was to allow states to develop and implement pilot
programs to: a) assist in maintaining a high rate of MPDES permit compliance; b) maximize
the useful life of municipal wastewater facilities through effective operation and maintenance,
and control of pollutant flow and loads; and, c) ensure effective and timely planning for future
needs before problems occur. Pollution prevention activities planned by the section include
continued implementation of the self-assessment process which has been developed for
wastewater plants, modification of the inspection program to more proactively consider
problems, continuation of our public education efforts through brochures and public service
announcements and a youth education program. A water conservation pilot program is being
sponsored by the agency to evaluate effectiveness of certain conservation measures as they relate
to needed upgrades of water and wastewater systems.
Contact for this program is Thomas J. Slovaip, Environmental Engineer Manager, telephone
(406) 444-5323.
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MUNICIPAL WASTEWATER ASSISTANCE PROGRAM
Fiscal Year 1997 Plan
MISSION STATEMENT:
TO PROTECT, ENHANCE, AND RESTORE MONTANA'S WATERS THROUGH
THE PROVISION OF TECHNICAL, FINANCIAL, AND TRAINING ASSISTANCE
TO MUNICIPAL WATER POLLUTION CONTROL FACILITIES.
FINANCIAL ASSISTANCE PROGRAM OBJECTIVES:
I. Provide effective program administration.
II. Close out the Construction Grants Program as per the 1997 Closeout Strategy and annual
state workplan.
m. Manage the State Revolving Fund Loan Program as per the Operating Agreement
between EPA and the DEQ.
IV. Assist small communities in obtaining affordable financing.
ACTIVITIES:
I. Administration
A. Conduct administrative duties necessary for program maintenance and
development, develop and track budgets and contracts, write reports, and conduct
program planning.
B. Supervise, assign duties, fill positions, train, monitor and evaluate staff.
C. Provide administrative support services to program including managerial,
wordprocessing, data entry, report generation, mailings, etc.
D. Promote consistent work methods among section staff.
II. Construction Grants Program Management
A. Provide projections for outlays and obligations to EPA on an annual basis.
B. Review facility plans for twenty-seven (27) active projects (Belgrade, Bozeman,
Box Elder, Columbus, Deer Lodge, Drummond, East Missoula, Eureka,
Fairfield, Hamilton, Harlowton, Havre, Hot Springs, Judith Gap, Lewis & Clark
County/Helena Valley, Lincoln/Lewis & Clark County, Poison, Rae, Red Lodge,
Roundup, Superior, Sweetgrass, Troy, Valier, Westshore/Lake County,
Whitefish, Wisdom). Provide Advance of Allowance grants for sixteen (16) new
planning projects (Alder, Alberton, Augusta/Lewis & Clark County, Choteau,
-------
Culbertson, Eureka, Gallatin Gateway/Gallatin County, Geraldine, Harrison,
Hilger, Joplin, Judith Gap, Lambert, Libby, Nashua, Richey).
C. Review designs for five (5) grant-funded projects (Box Elder, Deer Lodge,
Hobson, Ronan, Superior). Coordinate nondegradation policy issues concerning
these projects with Permits Section.
D. Manage projects which are currently in construction. Initiate operations at four
(4) projects (Box Elder, Deer Lodge, Hobson, Ronan).
E. Administratively complete three (3) projects (Somers, Flathead/Evergreen,
Whitefish County).
F. Obtain positive performance certification from two (2) projects (Whitefish
County, Reedpoint).
G. Complete biannual U.S. EPA Needs Survey.
H. Perform periodic MBE/WBE activities.
I. Implement Closeout Strategy for the program.
State Revolving Fund Loan Program
A. Provide projections for outlays and obligations to EPA on an annual basis.
B. Close up to nine (9) loans prior to the end of the planning period. Likely
borrowers include: Cascade, Glasgow, Harlowton, Lincoln/Lewis & Clark
County, Ronan (Ph. II), St. Marie, Townsend, Valier, Vaughn.
Manage all projects in accordance with the operating agreement and program
documents developed under the capitalization grants awarded through October
1996.
C. Provide input to our congressional delegation on adjustments to the SRF program
during the reauthorization process currently underway for the Clean Water Act.
D. Develop a SRF program marketing strategy and actively market the SRF program
to communities throughout the state. Meet with ten (10) communities to discuss
the program. Obtain feedback from existing borrowers to improve the SRF
program and expand utilization. We will also apply for a Marketing Grant.
E. Revise the SRF application to make the document more informational and user
friendly.
-------
F. Consider a small community program to operate in conjunction with the Montana
Board of Investments, including assistance for planning.
G. Develop and implement the SRF database which is being prepared for program
management.
H. Using EPA's model specification inserts, develop these documents to incorporate
all federal and state program requirements into one useful package.
I. Make adjustments to the SRF Handbook of Procedures to improve its usefulness
and consistency.
J. Work with DNRC to develop SRF Handbook of Financial Procedures which
includes loan underwriting criteria.
K. Complete biannual U.S. EPA Needs Survey.
L. Perform periodic MBE/WBE activities.
M. Continue to enhance staff knowledge of public finance.
N. Implement nontraditional uses of SRF funds, in particular, the funding of landfills
and storm sewers. Develop administrative rules as needed.
O. Develop and implement a new revolving loan program for drinking water
projects.
Small Community Outreach Program
A. Help communities initiate the planning process including the use of EPA-funded
Advance of Allowance grants.
B. In conjunction with the reauthorization of the Clean Water Act, work with our
congressional delegation and other agencies to promote a financial assistance
program designed for small, needy communities.
C. Identify small communities with known needs. Contact these towns and offer
outreach help which consists of technical and financial assistance. Hold
workshops to assist these communities in planning and financing wastewater
facilities. Educate administrators in the process of hiring technical consultants.
D. Consider application of program for small projects and streamline the
requirements wherever possible.
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TECHNICAL ASSISTANCE PROGRAM OBJECTIVES:
I. Provide effective program administration.
n. Proceed with the Pollution Prevention Program based on the current process used to
evaluate wastewater treatment facilities.
HI. Train wastewater facility operators and administrators in plant operations.
IV. Through education and on-site assistance, assist communities in complying with Federal
Part 503 sludge regulations, new State nondegradation regulations and water quality
standards established to protect priority watersheds.
V. Plan, specification and project review.
VI. Develop a public education program to improve the understanding of the need for
wastewater treatment.
VII. Integrate nonpoint source (NPS) pollution control activities into the SRF funding
framework.
ACTIVITIES:
I. Administration
A. Conduct administrative duties necessary for program maintenance and
development, develop and track budgets and contracts, write reports, and conduct
program planning.
B. Supervise, assign duties, fill positions, train, monitor and evaluate staff.
C. Provide administrative support services to program including managerial,
wordprocessing, data entry, report generation, mailings, etc.
D. Through strategic planning, evaluate the technical assistance program to redefine
purpose and needs.
n. Municipal Water Pollution Prevention Program (MWPP)
A. Proceed with the MWPP program consistent with the and May 1995 grant
proposal submitted to EPA. Key elements of the proposal include:
i. Evaluate 5-10 systems annually looking at plant operations, design,
administration and pollution prevention opportunities.
-------
ii. Identify existing and potential performance-limiting factors. Provide
report to community.
iii. Work with facility administrators to address performance-limiting factors
through O&M training and/or capital improvements. Direct municipalities
in obtaining needed technical or financial assistance. Follow-up on these
activities to see that important concerns raised during the evaluation are
being addressed.
iv. Evaluate user charge systems in conjunction with plant evaluations to
determine the financial condition of the wastewater utility.
B. Perform periodic O&M inspections of approximately 25 systems annually.
Employ practices to support pollution prevention as part of these inspections.
C. Direct MSU-Northem 104(g) trainer to communities requiring operational
assistance following a CPE or inspection, where section staff cannot provide these
services.
D. Promote water conservation through education, facilities planning, and mandates
to reduce flows to wastewater facilities. Implement a water conservation pilot
program in one (1) community.
E. Continue implementation of the plant self-assessment process which has been
developed for mechanical plants and lagoons. Hold workshops to assist operators
in performing self-assessments and to promote pollution prevention concepts.
F. Educate the public on the subject of pollution prevention through the use of
informational materials, public service announcements and conferences.
G. Implement Upper Missouri River Basin watershed technical studies required under
the EPA 104(b)(3) grant, primarily through use of contracted services and other
agency resources.
WW TP Operator Training
A. Provide statewide training at regional sites (15-20 speaking engagements) to
wastewater professionals on plant operations, management, regulatory
requirements, and pollution prevention. Prepare training materials regarding the
history and rationale behind water pollution control laws.
B. Jointly manage the Montana Environmental Training Center (METC) in
conjunction with MSU-Northern. Provide direction and support to training
coordinator hired for METC activities.
-------
C. Jointly sponsor the annual water/wastewater operators school with Montana State
University including logistical support and speaking at the school. Assist the
METC coordinator in the sponsoring of a spring water school designed for small
communities.
D. Support the DEQ's Operator Certification program through writing examinations,
grading tests, conducting operator help sessions, evaluating training sessions for
certification requirements, and attending advisory board meetings.
E. Assist operators on-site in response to specific requests for assistance or as
follow-up to identified permit compliance problems. Estimate 10 visits annually.
F. Provide in-house training to staff on plant operations and other technical
wastewater topics. Utilize a video camera for this purpose.
G. In conjunction with the Public Water Supply Program, assist in preparation and
distribution of the Big Sky Clearwater.
H. Obtain training in public speaking and making presentations. Utilize appropriate
audio/visual aids. When preparing for presentations, assemble slides and
narrative into training modules suitable for use by all staff in making
presentations.
IV. Community Education and Assistance
A. Continue to gain knowledge of the new federal standards and become more
familiar with their requirements. Work with communities to help them
understand Federal sludge disposal requirements, new State nondegradation
regulations and water quality initiatives intended to protect priority watersheds.
B. Design a generic sludge management plan for communities to follow for
beneficial reuse of sewage sludge. Distribute the plan to consultants and
communities.
C. Inventory existing sludge handling methods in Montana communities. Working
with the Permits Section, determine which facilities are not in compliance with
the regulations. Provide technical assistance to these communities to help achieve
compliance with the regulations.
V. Plan, Specification and Project Review
A. Participate in the DEQ's Deviation Review Committee which considers variances
from Circular WQB-2.
-------
B. Evaluate facilities for compliance with DEQ Nondegradation Rules. Establish
1993 baseline loads and coordinate activities with the Permits Section.
C. Review project plans and specifications for facilities not funded with construction
grants or SRF loan assistance.
D. Maintain and expand knowledge of current and new technologies through training,
references and contact with professionals in the field. In particular, gain insight
in the utilization of natural systems for treatment of domestic wastewater.
E. Assist other governmental agencies in performing a technical review and
verification of need of projects seeking financial assistance.
VI. Public Education Program
A. Prepare a training module on wastewater treatment and present this publicly (i.e.,
local schools).
B. Present workshops to educate the public on environmental issues.
C. Develop or obtain materials to distribute to the public to promote understanding
of wastewater treatment.
D. Interface with MWEA/MSAWWA Public Information Committee regarding their
activities.
VII. Integrate Nonpoint Source (NPS) Pollution Control Activities into the SRF Funding
Framework
A. Modify current priority ranking procedures to incorporate statewide water quality
improvement goals and include nonpoint source pollution control activities in the
ranking procedures. Write narrative of the procedures and circulate to general
public and EPA for comments. Modify Intended Use Plan accordingly.
B. Administer contracted services to establish a framework for prioritizing water
pollution control activities associated with watershed-based management. Develop
an integration scheme to combine statewide and watershed priorities. Write
narrative of the procedures and circulate to general public and EPA for
comments. Modify Intended Use Plan accordingly. Develop an enhanced public
participation program to obtain more feedback in establishing funding priorities.
gr\budgets\progplan.97
September 30, 1996
-------
Planning Matrix - FFY 97
DEPARTMENT OF ENVIRONMENTAL QUALITY
Planning, Prevention and Assistance Division
Technical and Financial Assistance Bureau (Municipal Wastewater Assistance)
doc: gr\123\matrix97.wkl
FTE CONTRACT FUNDING
ACTIVITY/OUTPUT MILESTONE PERSONNEL NEEDED FTE SERVICES FUNDS SOURCE PRIORITY
**************************************** *******************************
GOAL #1:
OBJECTIVE #1:
ACTIVITIES s
Administer the Financial Assistance Program.
Provide effective program administration.
oo
A. Conduct admin, duties necessary Ongoing Slovarp
for prog, maintenance and develop- Div. Admin,
ment, develop and track budgets
and contracts, write reports and
conduct program planning.
B. Supervise, assign duties, fill Ongoing Slovarp 0.30
positions, train, monitor Env.Engr.
and evaluate staff.
C. Provide admin, support services Ongoing Reeves
to program including managerial, Quirino
woraprocessing, data entry, report
generation, mailings, etc.
D. Promote consistent work methods Ongoing Slovarp
among section staff. Env.Engr.
SUBTOTAL 0.30
0.25
15
07
1.22
0 . 05
0.05
1.79
$0 $16,544
$0
$0
>9,927
>4 ,632
$80,736
$0
0.00 $118,457
3,309
3,309
205
or
20 5j gj
or
205(g)
or SRF
205(g)
or SRF
OBJECTIVE #2: Construction Grants program management.
ACTIVITIES:
A. Provide projections for outlays 06/97 Reeves 0.01 $0 $662 205(g) A
and obligations to EPA annually.
B. Review facility plans for 27 Ongoing Staff 1.00 0.90 $0 $59,559 205(g) A
active projects: Belgrade, Box
Elder, Bozeman, Columbus, Deer Lodge,
Drummond, East Missoula, Eureka,
Fairfield, Hamilton, Harlowton, Havre
Hot Springs, Judith Gap, L&C Co./
Helena Valley, Lincoln/L&C Co.,
Poison, Rae, Red Lodge, Roundup,
Superior, Sweetgrass, Troyf Valier,
Westshore/Lake Co., Whitefish, Wisdom.
Provide Advance of Allowance grants
for 16 new planning projects:
Alberton, Alder, Augusta/L&C Co.,
Choteau, Culbertson, Eureka,
Gallatin Gateway/Gallatin Co.,
Geraldine, Harrison, Hilger,
Joplin, Judith Gap, Lambert,
Libby, Nashua, Richey.
C. Review designs for 5 grant-funded Ongoing Staff 0.10 $0 $6,618 205(g) A
-------
Hobson, Box Elder, Superior.
Coordinate Nondegradation policy
issues concerning these projects
with Permits Section.
D. Manage projects currently in con-
struction. Initiate operations at
4 projects: Deer Lodge, Hobson,
Box Elder and Ronan.
E. Administratively complete 3
projects: Somers, Wnitefish Co.,
and Flathead/Evergreen.
F. Obtain positive performance
certification from 2 projects:
Whitefish Co. and Reeapoint.
G. Complete biannual U.S. EPA
Needs Survey.
H. Perform periodic M/WBE activities.
I. Implement closeout strategy
for the program.
Ongoing
Ongoing
Ongoing
12/96
Quarter
Ongoing
Staff
Staff
Staff
Reeves
Reeves
Staff
SUBTOTAL
OBJECTIVE #3:
ACTIVITIES:
Manage State Revolving Fund loan program.
A. Provide projections for outlays
and obligations to EPA annually.
B. Close up to 9 loans prior to the
end of the planning period.
Likely borrowers include: Vaughn,
Harlowton, Lincoln/L&C Co., St.
Marie, Ronan (Ph. II), Cascade,
Valier, Townsend, Glasgow.
Manage all projects in accord-
ance with operating agreement
and program documents developed
under the capitalization grants
awarded through 10/96.
C. Provide input to our congressional
delegation on adjustments to the
SRF program during the reauthori-
zation process currently underway
for the Clean Water Act.
06/97
Ongoing
Neuwerth
Staff
DNRC
Dorsey &
Whitney
1st Trust
DAD & PJ
As needed Slovarp
Develop SRF program marketing Ongoing
strategy and actively market the
SRF program to communities through-
out the state. Meet with 10 communi-
ties to discuss the program. Obtain
feedback from existing borrowers to
improve the program and expand utili-
zation. Apply for marketing grant.
Neuwerth
Staff
Revise SRF application to make
06/97
Neuwerth
0.25
$0 $16,544 205(g)
0 . 30
$0 $19,853 205(g) B
0.01
$0
$662 205(g)
1. 00
0.07
0.02
0.01
1.67
$0 $4,632
$0 $1,324
$0 $662
$0 $110,516
205 (g
205^1
or SRF
205(g)
B
B
0.01
1.87
$0
$662
$0 $123,751
118,000
135,000
SRF
SRF
A
A
0.05
$0
$3,309
SRF
0.10
0. 10
$30,000 $6,618
SRF
0.05
$0
$3,309
-------
I.
J.
L.
M.
00
o
O.
the document more informational
and user friendly.
Consider a small community program 03/9 7
to operate in conjunction with the
Montana Board of Investments,
including assistance for planning.
Develop and implement the SRF 03/9 7
database which is being prepared
for program management.
Using EPA's model specification 03/97
inserts, develop these documents
to incorporate all federal and
state program requirements into
one useful package.
Make adjustments to the SRF Ongoing
Handbook of Procedures to improve
its usefulness and consistency.
Work with DNRC to develop SRF 06/97
Handbook of Financial Procedures
which includes loan underwriting
criteria.
Complete biannual U.S. EPA 12/9 6
Needs Survey
Perform periodic M/WBE activities. Quarter
Continue to enhance staff Ongoing
knowledge of public finance.
Implement nontraditional uses of Ongoing
SRF funds, in particular, the
funding of landfills and storm
sewers. Develop administrative
rules as needed.
Develop and implement a new
revolving loan program for
drinking water projects.
Slovarp
Env.Engr.
Neuwerth
Quirino
Little
Slovarp
Staff
Neuwerth
Reeves
Reeves
Staff
Teegarden
Staff
SUBTOTAL
OBJECTIVE #4: Administer small community outreach program.
ACTIVITIES:
A. Help communities initiate the Ongoing Staff
planning process including use
of EPA-funded Advance of
Allowance grants.
B. In conjunction with reauthori- Ongoing Slovarp
zation of the Clean Water Act,
work with our congressional
delegation and other agencies to
promote a financial assistance
program designed for small,
needy communities.
0.30 0.05 $0 S3 ,309 SRF A
0.05 ง3,309
0.20 0.10 $6,618 SRF A
0.05 $0 $3,309 SRF A
0.10 0.05 $0 $3,309 SRF B
0.15 $0 $9,927 SRF B
0.07 $0 $4,632 SRF B
0.02 $0 $1,324 SRF B
0.05 $0 $3,309 SRF B
0.20 0.05 $0 $3,309 SRF B
0.08 $5,294
3.00 t. 4 . 00 0 . 00 $0 $0
3.90 t. 4.90 2.80 $83,000 $185,296
0.05 $0 $3,309 SRF or A
205(g)
0.01 $0 $662 SRF or A
-------
C. Identify small communities with Ongoing Staff
known needs. Contact these towns
and offer outreach help which
consists of technical and financial
assistance. Hold workshops to
assist these communities in
?lanning and financing wastewater
acilities. Educate administrators
in the process of hiring
technical consultants.
D. Consider application of program Ongoing Staff
small projects and streamline the
requirements wherever possible.
SUBTOTAL
***************************************-.*********************
FINANCIAL ASSISTANCE PROGRAM TOTAL
GOAL #2:
OBJECTIVE #1:
ACTIVITIES:
Administer the Technical Assistance Program.
Provide effective program administration.
A. Conduct administrative duties Ongoing
necessary for program maintenance
and development, develop and track
budgets ana contracts, write reports,
and conduct program planning.
B. Supervise, assign duties, fill
positions, train, monitor and
evaluate staff.
Ongoing
C. Provide admin, support services Ongoing
to program including managerial,
woraprocessingr data entry, report
generation, mailings, etc.
D. Through strategic planning, Annual
evaluate the technical assis-
tance program to redefine
purpose and needs.
Slovarp
Div. Admin.
Reeves
Slovarp
Env.Engr.
Reeves
Quirino
Staff
SUBTOTAL
OBJECTIVE #2: Administer pollution prevention program.
ACTIVITIES:
A. Proceed with the MWPP Program Ongoing Abrahamson
consistent with 05/95 grant Env.Engr.
proposal submitted to EPA. Key
elements of the proposal includes:
1) evaluate 5-10 systems annually
looking at plant operations, design,
administration, ana pollution pre-
vention opportunities; 2) identify
existing and potential performance-
limiting factors, provide report to
0.30 0.05 $0 $3,309 SRF or
205(g)
0.20
0.05
$0
$3,309
SRF
0.50
0.16
$0 $10,588
* * * * * *******************************************
5.70 t. 6.70 6.42 $83,000 $424,856
* * * * * ********************************* 1*********
0.20
$0 $13,235 205(g)
0.30
0.10
0.05
$0 $6,618
$3,309
205(g)
0.35
$0 $23,162 205(g)
0.02
$0 $1,324 205(g)
0.30
0.72
$0 $47,647
0.10 $5,000 $6,618 205(g)
-------
community; 3) work, with facility
administrators to address performance-
limiting factors through O&M training
and/or capital improvements; direct
municipalities in obtaining needed
technical or financial assistance;
follow-up on these activities to see
that important concerns raised during
the evaluation are addressed; 4)
evaluate user charge systems in
conjunction with plant evaluations
to determine the financial condition
of the wastewater utility.
B. Perform periodic O&M inspections Ongoing
of approx. 2 5 systems annually.
Employ practices to support pollution
prevention as part of these inspections.
C. Direct MSU-Northern 104(g) trainer Ongoing
to communities requiring operational
assistance following a CPE or inspec-
tion where section staff cannot
provide these services.
D. Promote water conservation through Ongoing
education, facilities planning and
mandates to reduce flows to waste-
water facilities. Implement a water
conservation pilot program in one (1)
community.
E. Continue implementation of the Ongoing
plant self-assessment process which
has been developed for mechanical
plants and lagoons. Hold workshops
to assist operators in performing
self-assessments and to promote
pollution prevention concepts.
F. Educate the public on the subject Ongoing
of pollution prevention through the
use of informational materials, public
service announcements and conferences.
G. Implement Upper Missouri River
Basin watershed technical studies
required under the EPA 104(b)(3) grant
primarily through use of contracted
services and other agency resources.
SUBTOTAL
OBJECTIVE 3: Provide WVJTP operator training.
ACTIVITIES:
A. Provide statewide training at Ongoing
regional sites (15-20 speaking
engagements) to wastewater profes-
sionals on plant operations, manage-
ment, regulatory requirements and
pollution prevention. Prepare
training materials regarding the
Bahr 0. 10
Abrahamson 0.10
Env.Engr. 0.10
Bahr 0.05
Staff Engrs. 0.02
LaVigne 0.02
Abrahamson 0.10
Bahr 0.05
Abrahamson 0.02
Env.Engr. 0.30
0.00 1.26
Staff 0.30 t. 0.50 0.40
$0 $6,618 205(g)
$6,618
$6,618
$0 $3,309 205(g)
$0 $1,324 205(g)
$1,32 4 MWPP
$0 $6,618 205(g)
$3,309
$0 $1,324 MWPP
$90,000 $19,853 104(b)(3)
$95,000 $83,383
-------
B.
C.
D.
oo
ijj
F.
G.
H.
history and rationale behind water
pollution control laws.
Jointly manage the Montana
Environmental Training Center
(METC) in conjunction with MSU-
Northern. Provide direction and
support to training coordinator
hired for METC activities.
Jointly sponsor the annual water/
wastewater operators school with
MSU-Bozeman including logistical
support and speaking at the school.
Assist METC coordinator in sponsor-
ing a spring water school
designed for small communities.
Ongoing
04/97
09/97
Boyle
Slovarp
Bahr
Bahr
Support the DEQ's Operator
Certification program through
writing examinations, grading tests,
conducting operator help sessions,
evaluating training sessions for
certification requirements, attending
advisory board meetings.
Ongoing Bahr
Assist operators on-site in
response to specific requests
for assistance or as follow-up
to identified permit compliance
problems. Estimate 10 visits
annually.
Provide in-house training to
staff on plant operations and
other technical wastewater
topics. Utilize a video camera
for this purpose.
In conjunction with the Public
Water Supply program, assist in
preparation and distribution of
the "Big Sky Clearwater."
Obtain training in public speak-
ing and making presentations.
Utilize appropriate audio/visual
aids. When preparing for pre-
sentations, assemble slides and
narrative into training modules
suitable for use by all staff
in making presentations.
SUBTOTAL
Ongoing
Bahr
Ongoing Staff
02/97
and
08/97
Ongoing
Bahr
Reeves
Quirino
Staff
OBJECTIVE #4:
ACTIVITIES s
Community education and assistance.
A. Continue to gain knowledge of the
new federal standards and become
more familiar with their require-
ments. Work with communities to
help them understand federal
Ongoing
Staff
Env.Engr.
0. 50
0.05
0.09
$0 $33,089
$3,309
$5,956
205(g) A
0. 10
0.05
$0 $3,309 205(g)
0.02
$1,324 A
ME1
0.30 t. 0 .50 0. 10
$0 $6,618 205(g) B
0.10
0.01
$0 $662 205(g) B
0.01
0.01
0.02
$0 $662 205(g) B
$662
$1,324
0 .10
0.00
$0
$0 205(g) C
0.90 t. 1.30 1.26
$0 $83,383
0.05 $0 $3,309 205(g) A
-------
sludge disposal requirements, new
State nondegradation regulations
and water quality initiatives
intended to protect priority
watersheds.
B. Design a generic sludge manage- 08/97 LaVigne
ment plan for communities to Env.Engr
follow for beneficial reuse of
sewage sludge. Distribute the
plan to consultants and communities.
C. Inventory existing sludge handling Ongoing Env.Engr
methods in Montana communities.
Working with Permits Section,
determine which facilities are not
in compliance with the regulations.
Provide technical assistance to
these communities to help achieve
compliance with the regulations.
SUBTOTAL
OBJECTIVE #5:
ACTIVITIES:
Review plans, specifications and projects.
A.
co b.
D.
E.
Participate on DEQ's Deviation Ongoing LaVigne
Review Committee which considers
variances from Circular WQB-2.
Evaluate facilities for compliance Ongoing Staff
with DEQ nondegradation rules.
Establish 1993 baseline loads and
coordinate activities with the
Permits Section.
Review project plans and speci- Ongoing Staff
fications for facilites not funded Engrs.
with construction grants or SRF
loan assistance.
Maintain and expand knowledge of
current and new technologies
through training, references and
contact with professionals in the
field. In particular, gain insight
in the utilization of natural systems
for treatment of domestic wastewatej
Assist other governmental agencies
in performing a technical review
and verification of need of projects
seeking financial assistance.
Ongoing LaVigne
Staff
Engrs.
SUBTOTAL
OBJECTIVE #6: Administer public education program.
ACTIVITIES s
0. 05
0. 05
$0 $3,309 205(g) B
$3,309
0.02
$0 $1,324 205(g) B
0.00
0.22
$0 $14,559
0.03
0.20
$0 $1,985 205(g) A
or
P&S Fees
$0 $13,235 205(g) A
Permit Fees
0.15
$0 $9,927 P&S Fees B
0 . 05
$0 $3,309 SRF B
0.04
$0 $2,647 205(g) B
0.00
0.47
-------
A. Prepare a training module on METC
wastewater treatment and present
this publicly (i.e., local schools).
B. Present workshops to educate the
public on environmental issues.
C. Develop or obtain materials to
distribute to the public to promote
understanding of wastewater treatment.
D. Interface with MWEA/MSAWWA Public
Information Committee regarding
their activities.
SUBTOTAL
OBJECTIVE #7: Integrate nonp
-------
FY97 Program Revenue:
EPA Constr. Grants $400,000
WW Treatment - SRF $2 51,6 54
104(b)(3) grant - SRF Implemen. $21,633
104(b)(3) grant - Watersned-NPDES $14,428
Poll. Prev. grant $27,000
TOTAL $714,715
Funding for contracted services: SRF, 205(g), PP grant, 106 grant, METC 109(b) grant (costs included
in average staff cost per FTE).
Priorities are defined as follows:
A. Absolutely essential to accomplish within the time indicated in order to accomplish mission.
B. Important, but not essential to mission; could be delayed if necessary.
C. High priority objectives or activities for which resources are currently not available.
00
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996. @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
ENFORCEMENT AND COMPLIANCE
8.5
These FTE'6 are partially funded
by operating permit fees.
oo
Conduct Level II inspections at all sources targeted
for inspection under the State's FY97 CMS plan, at
the frequency indicated in the CMS plan.
State
2. Submit to EPA a CMS plan for FY98, pursuant to
EPA national guidance on CMS. Source ranking
method used for source inspections will be by U6e
of ITM. CMS plan will also address any State-
enforceable requirements relevant to Title IV (acid
rain) provisions of CAA.
State
EPA will perform overview inspections at selected
sources listed for inspection in the State's FY97
CMS plan.
EPA
B.
B! Where appropriate conduct
cross-program, multimedia inspections and, as
necessary, conduct appropriate cross-program,
multimedia enforcement. Where these inspections
involve facilities not initially targeted for inspection
in the State's FY97 CMS plan, EPA will agree to
adjust the CMS inspection list accordingly, such
that this cross-program, multimedia initiative will
not require additional State resources.
Ongoing
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
C.
00
00
D.
Identify to EPA all violators subject to the current
State/EPA Enforcement Agreement (S/EPA EA),
upon determination of Violation.
Take appropriate action to resolve violations, in
accordance with the S/EPA EA, including tracking
of sources subject to compliance schedules.
FiftlH Citations: Provide information to EPA on
minor violations that might be subject to federal
field citations. State and EPA will coordinate on
issuance of any field citations. EPA will provide the
State with a copy of any EPA-issued field citations,
upon issuance.
Ongoing
Ongoing
As required
State
State
State/EPA
Submit inspection reports to EPA within 60 days of
inspection date.
Submit copies to EPA, upon issuance, of all
enforcement actions (NOV's, Orders, proposed and
final penalty settlements, referrals to State AG) for
all sources subject to CMS, and for all NSPS and
NESHAP sources.
Ongoing
Ongoing
State
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
Management:
1. Provide timely data to AFS on CMS Group I and II
Ongoing
State
sources and any other sources that are major
according to 1990 CAAA definition, including
general description of each source, compliance and
operating 6tatus, compliance/enforcement activities
(including inspections and enforcement actions),
types of criteria pollutants emitted, and
identification of federally enforceable continuous
emission monitors.
2. Coordinate with EPA to ensure that FY97 CMS Ongoing State
sources are flagged in AFS for inspection, and to
ensure that significant violators are correctly
identified in AFS.
3. Perform periodic reviews of AFS data, to ensure Ongoing State
required data has been entered correctly.
4. Perform evaluations of source-submitted summary Ongoing State
data reports by reviewing on-site records on a
random basis during Level II inspections required by
the revised CMS.
1.
Develop and implement Statewide CEM quality
assurance (QA) program, which includes the
following activities:
Ongoing
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18. 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
ID
O
a. Review any required CEM QA project plans and
program plans submitted by sources. Provide
written summary to EPA of findings and
recommendations made on any plans reviewed.
b. Conduct on-site observations and review a
representative portion of Performance Specification
Test6 for CEMs, including test protocols and any
concurrent stack tests. Provide written summary to
EPA of PST results. Review test protocols.
c. Review any required annual Relative Accuracy Test
Audits or CEM recertification. Provide written
summary to EPA of audit results and findings on
tests.
Quarterly
Quarterly
Quarterly
State
State
State
Review a random and representative portion of the
source self-audits, whether voluntary or required by
State-enforceable source QA plan, permit or SIP
regulation. Provide written summary to EPA of
findings and the State's impressions of the sources'
audits.
Quarterly
State
Review Data Assessment Reports, as may be
required by 40 CPR 60 Appendix F, source QA plan,
permit or SIP regulation, from significant sources.
Review a random and representative portion of the
QA information in the source self-monitoring reports
(which include EERs and FSA [fuel sampling and
analysis] reports) with emphasis on significant
Quarterly
Quarterly
State
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
2. Revie\AP60urce self-monitoring compliance reports
and excess emission reports (EERs) from CEM
sources and take appropriate enforcement action for
non-compliers, in accordance with the S/EPA EA.
Quarterly
State
The state will input EER summary data for all
federally enforceable CEMs into PCCEMS on a
timely basis and provide EPA with the PCCEMS
data. As long as AFS provides current plant
information, EPA will upload PCCEMS data to AFS
and maintain up-to-date data listings of CEMs in
AFS.
Ongoing
State
Maintain qualified CEM enforcement staff, by
providing for attendance at EPA-6ponsored CEM
training courses and workshops, if State travel
budget allows.
Ongoing
State
5. In support of EPA development and implementation
of the "Compliance Assurance Monitoring Rule"
being promulgated under Section 702(b) of the
1990 CAA Amendments, ensure that source self-
monitoring programs are effective and consistent
with the rule and EPA guidance, upon federal
promulgation.
Ongoing
State
6. Assist EPA in the enforcement of any new CEM
requirements pursuant to CAA Title IV (acid rain).
Monitor process of installation of any new CEMs
and CEM QA activities.
Ongoing
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18. 1996, @ 2:42pm
FILENAME = = => MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
(O
Maintain a qualified inspector force by allowing air
inspector' attendance at EPA-sponsored training
courses and workshops conducted in Region VIII.
As part of the FY97 CMS plan, submit to EPA a
written stack test oversight program, to include
criteria for prioritizing a list of sources at which the
following activities will be conducted: State review
of stack test protocols, on-site stack test
observations by qualified State staff, and State
review of stack test reports for completeness,
representativeness and compliance. Include
description of State's methodology/protocol/SOP for
planning, witnessing and reviewing stack tests.
Provide quarterly listing of test results.
J.
Perform asbestos NESHAP inspections targeting a
majority of the jobs done by major contractors and
at least one job for a majority of the small
contractors. Special emphasis will be given to
contractors that have not been inspected before and
to complaint response. This commitment includes
inspections of regulated asbestos NESHAP projects
and landfills which accept asbestos material.
Ongoing
State
6/97
State
Quarterly
State
6/97
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
2. Conduct 30 inspections, following the above stated
priorities.
3. Report information to the National Asbestos
Registry System though ACTS, within 30 days of
the end of each quarter. Perform appropriate
QA/QC on all ACTS data submitted.
Quarterly
State
State
4. Submit to EPA, within 30 days of the end of the
inspection month, copies of all inspection reports/
checklists), waste shipment discrepancies and
exception reports. Identify violators.
5. Take appropriate enforcement action for all
asbestos violators in accordance with the S/EPA
EA. Submit copies of enforcement actions to EPA
upon issuance. Update EPA on enforcement status
of violators monthly. Implement asbestos T&A
guidelines.
6. Respond to citizen complaints and log any requiring
inspection or enforcement action into ACTS.
7. Perform public outreach activities as necessary for
regulation revisions and enforcement actions.
Monthly
Ongoing
State
State
Ongoing
Ongoing
State
State
2.
Provide P2 training to key compliance staff,
pursuant to EPA guidance, focusing on identification
of P2 opportunities as part of on-site inspections.
Continue to develop outreach programs to advise
industry of P2 opportunities.
Ongoing
Ongoing
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = => MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
Provide P2 information to EPA for input into EPA's
P2 database.
As required
State
L.
M.
Participate in
field investigation, case development and
enforcement initiatives with the Regional Office.
Prepare for implementation and
enforcement of standards as they are finalized.
As required
As required
State/EPA
State
Implement a Federal
Facilities Compliance Program, pursuant to the EPA
Federal Facilities Compliance Strategy.
Ongoing
State
O.
P.
Contingent upon EPA funding, negotiate and
implement delegation of State enforcement
activities to reduce or phase out ozone-depleting
compounds, upon federal promulgation. Until State
assumes program, forward all CFC complaints and
possible violations to EPA.
FY96/FY97 MOA Guidance identified National
Priority Sectors: petroleum refining, primary
nonferrous metals and dry cleaners. In addition, the
Guidance recommends that the Regions and States
give increased attention to other significant sectors.
Of the four significant sectors selected by Region
VIII staff (agricultural practices, mining, auto
Ongoing
State
6/97
State/EPA
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18. 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
service/repair shops and coal-fired power plants),
the one with significant air emissions is coal-fired
power plants. Therefore, we are requesting that
you develop and implement a strategy for each of
these industry sectors that identifies environmental
and/or noncompliance problems which need to be
addressed, the enforcement and compliance tools
(e.g., compliance assistance, compliance
monitoring, incentive and recognition programs, civil
and criminal enforcement) that will be applied to the
sector, and the outcomes or results which will be
measured to assess the effectiveness of the
strategy.
NEW SOURCE REVIEW
6.5
Operate an NSR Permit
Program in accordance with PSD and nonattainment
area permitting requirements.
copy of the public notice, the technical review and
analysis, and the proposed permit or permit
conditions, at the start of the public comment
period, for the following categories of permit
actions:
Ongoing
Ongoing
State
State
1. PSD permits for new and modified sources
2. Permits for Clas6 A1 new sources
3. Permits for Class A1 modified sources (if permitting
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
COMMENTS
4. Permits for sources avoiding major source NSR, by
permit restrictions to reduce their potential
emissions (synthetic minor)
5. Permits for major new and major modified sources
in nonattainment areas, as well as any permits
issued to implement source-specific provisions of
nonattainment area SIPs.
The technical review and analysis must include an
emission inventory, emission calculations, and a
description of the source. A BACT analysis and
modeling analysis must be included for the PSD
permits. For nonattainment area permits, a LAER
analysis and modeling analysis must be included. A
RACT analysis mu6t be included for nonattainment
area SIP requirements.
Department Determinations: Submit to EPA copies Ongoing State
of Department determinations, including the
technical review and analysis, for those categories
of permit actions listed in item B. above.
Submit to EPA a copy of any draft Department
determinations (including the technical review and
analysis) in which pollutant emissions limitations,
testing requirements, or operational reporting
requirements have been revised from the proposed
permit, prior to issuance of the Department
determination. The DEQ will respond to all EPA
comments.
Final Permits: Copies of the final permits, for those Ongoing State
categories of permit actions listed in item B. above,
shall be submitted to EPA, when issued. The DEQ
DUE STATE STATE EPA
MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = => MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
will respond to all EPA comments.
-j
Submit to EPA a
copy of the PSD permit application for those
sources located at or within 100 kilometers of the
U.S./Canada border per the U.S./Canada Air Quality
Agreement. Submit each application within 30
days of receipt.
F.
Submit to the
Federal Land Managers, a copy of all PSD permit
applications and supplemental information, when
received, for sources located within 100 kilometers
of any Class I areas or causing a significant impact
on any Class I areas.
NSR Training: Evaluate the need for additional
training regarding permitting under the PSD/NSR
process to improve permitting activities. EPA will
schedule and provide training, as needed.
H.
jsfli Submit RACT,
BACT, and LAER determinations to the EPA
Clearinghouse, Pursuant to CAA Amendments of
1990, Section 108(h).
Review the SIP to
determine that no applicable increments are being
violated. If an applicable increment is being
violated, notify EPA and work with them to revise
the plan to correct the violation. [40 CFR
51.166(a)(4)]
J.
State-required
Ongoing
State
Ongoing
State
Ongoing
State
Ongoing
State
Ongoing
State
Ongoing
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
permitting (non-PSD, attainment area), open burning
permits and Montana Environmental Policy Act
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
COMMENTS
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
2.
SIP DEVELOPMENT
EM,.
Submit redesignation of nonattainment and
unclassifiable areas to attainment, as necessary.
Columbia Falls PM10
Provide guidance on PM)0 NSR, redesignation,
maintenance, BACM.
Provide technical assistance on all aspects of PM10
SIP development.
Implement and track PM10 nonattainment area SIPs.
Submit PM10 SIP for Thompson Falls (including
provisions for contingency measure and
nonattainment NSR).
Submit PM,0 SIP for Whitefish (including provisions
for contingency measures and nonattainment NSR).
Lead:
Implement and track the nonattainment lead SIP for
East Helena.
Evaluate the lead SIP for East Helena and determine
approvability.
5.5
These FTE's are partially funded
by operating permit fees.
Ongoing
12/96
Ongoing
Ongoing
Ongoing
3/97
6/97
Ongoing
6/97
State
State
EPA
EPA
State
State
State
State
EPA
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = => MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
SG2
1. Submit East Helena Secondary S02 SIP
2. Implement and track the S02 SIP for Billings and
Laurel.
3. Evaluate the S02 SIP for Billings/Laurel and
determine approvability.
4. Implement East Helena primary and secondary S02
SIPs.
6/97
Ongoing
mz
Ongoing
State
State
EPA
State
1. Request authority from the Board of Environmental
Review to revise NSR and PSD regulations to add
new EPA promulgations and/or correct deficiencies
noted in existing regulations. Propose revisions
according to schedule specified in the
promulgations and/or EPA's letter noting
deficiencies.
Ongoing
State
Develop and propose regulation revisions to address
new and modified NESHAPs and NSPS regulations
which have been promulgated through 6/30/96.
Request authority from the Board of Environmental
Review to adopt rules incorporating existing
municipal solid waste landfill and municipal waste
combuster NSPS and emission guideline plans.
Ongoing
12/96
State
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
COMMENTS
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
1. Continue implementation and enforcement of
oxygenated fuels program.
2. Submit public hearing documentation for the Great
Falls 1990 Base Year Emission Inventory.
3. Submit final 1993 periodic inventory for Missoula.
4. Submit redesignation of nonattainment and
unclassifiable areas to attainment, as necessary.
- Billings CO
- Great Falls CO
Ongoing
12/96
6/97
6/97
6/97
State
State
State
State
State
5. Complete the Kalispell carbon monoxide emission
inventory.
3/97
State
6. Install and begin operation of a second carbon
monoxide monitoring site in Kalispell.
10/96
State
Assess conformity of projects, TIPs and RTPs for all
nonattainment area pollutants.
Ongoing
State
2. Develop and submit a general conformity SIP.
6/97
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @1 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
MONITORING
4.0
Prepare and submit annual
updated Network Review per EPA guidance.
State EPA will respond within 60
days after receipt of the
Network Review.
o
to
OA Plnri- Review and revise Quality Assurance
Project Plan and SOPs and submit report.
Submit updated three
year ambient air monitoring equipment plan for
FY97, highlighting equipment to be purchased in
FY97. Submit report on FY96 equipment
purchases.
6/97
fi/97
State EPA will respond within 90
days after receipt of QAPP and
SOPs.
State HP-Monitor Replacement (Funds
to be determined by Region
VIII). Part of Network Review.
Operate embient air
monitoring network consistent with Network
Review, QAPP and 40 CFR Part 58.
Ongoing
State
E.
F.
Submit ambient air quality data (including null data
codes) monthly within 60 days after the end of the
month (SLAMS and SPM).
Precision and Accurany: Submit precision and
accuracy data to AIRS-AQS within 90 days after
the end of the quarter.
Monthly
Quarterly
State Although we generally meet the
monthly schedule, the Federal
Register requires quarterly.
State Due to analysis time, lead
precision data will be submitted
within 120 days after the end
of the quarter.
Submit annual (1996) SLAMS
report to AIRS-AQS.
aaz
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = => MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
I.
J.
O
w
a; Apply for advanced approval
of any proposed monitoring network modifications.
Training: Attend EPA monitoring workshop.
NAAQS Exnftflriannfts: Notify EPA in writing of any
NAAQS exceedances within 45 days of
exceedance.
Ongoing
As scheduled
As needed
State
State
EPA will respond to a
modification request within 30
days.
PM10SIP requires notification of
all PM10 exceedances
Participate in National Performance
Audit Program by auditing all category 1 sites as
defined by EPA National Exposure Research
Laboratory (NERL).
Ongoing
State
Send participants to annual AIRS conference.
As scheduled
State
M.
N.
Review precision and accuracy data and NPAP
reports for completeness and compliance with
regulations.
Provide State with guidance on S02 and fine
particulate network design in support of NAAQS
reassessment.
Ongoing
As required
EPA
EPA
O.
Submit a sampling and analysis
plan for all special studies for review and EPA
approval. The studies planned for FY 97 include:
As needed
60 days
before imple-
mentation of
the study
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996. @ 2:42pm
FILENAME = = => MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
1. Missoula County will design and conduct an air
toxics screening study for Missoula.
As needed
6/97
State
2. Lewis and Clark County will design and conduct a
PM,0 saturation study in the Helena Valley.
6/97
State
o
Conduct performance audits at
least once per year on 50% of the industrial
monitoring 6ites which are required by permit or
stipulation, and conduct system audits as resources
allow.
State
Funded by operating permit
fees.
ACID RAIN
0.5
Funded with Title V permit
fees.
Incorporate guidance from EPA on Acid Rain
Program Development into State's OPP (Title V)
Wnte acid rain permits for affected sources as part
of State's OPP (Title V).
1. Participate in EPA's team review of certification
applications from affected sources. State to
provide opinion on approval or disapproval of
monitoring system.
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE
MILESTONES DATES
STATE
FTE
STATE
DOLLARS
EPA
DOLLARS
AGENCY
COMMENTS
2.
Observe recertification tests and audits - a minimum
of 50% of the scheduled tests are to be observed.
ANNUAL POINT SOURCE EMISSION INVENTORY
3.0
A.
Submit 1996 annual
statewide point source emission inventory into AFS
to comply with requirements of 40 CFR, Parts
51.325 and 51.326, including pa6t due annual
inventories, if any.
6/37
State
SEE NOTE
B. Summary Reports: EPA will provide emission Ongoing
inventory summary report within 30 days after the
notification that inventory is completed.
NOTE: States are required to submit emission inventories into AIRS within a prescribed deadline. To ensure emission inventories are submitted in a timely manner, the 6tate should identify the resources
required to complete this activity in 105 grant dollars that will be allocated with each State's emission inventory development and preparation program. The required emission inventories include annual
emissions inventories for point sources and area mobile sources as well as SIP 03 and CO nonattainment area inventory data, whoro applicable, ae ctotod in tho CAA ond itc Amondmontc. A otato
could use the grant money to have a contractor prepare the data in order to meet the required deadline. Partially funded with operating permit fees.
VISIBILITY
0.0
No resources allocated.
Evaluate and prepare any
necessary revisions to long term strategy review.
EPA
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @1 2:42pm
FILENAME = = = > MTSEA1.97
ACTIVITY/OUTPUT
DUE STATE STATE EPA
MILESTONES DATES FTE DOLLARS DOLLARS
AGENCY
COMMENTS
AIR TOXICS
2.0
Partially funded with Title V
permit fee6.
O
tn
Environmental Indicator:
The total tons of toxics emitted per year.
Objective: Reduce the total tons of toxic emissions
statewide from 1990 base levels.
Assist EPA Region VIII
in the review of applications for the Early Reduction
Program (ERP) pursuant to Title III Section 112(i)(5)
of the CAA and the final rule.
As needed
State
Regulation Dsvfilnpmfinf Request authority from the
Board of Environmental Review to promulgated
MACT rules and standards (at least for Title V
sources) in a timely manner and notify EPA of the
adoption.
As needed
Date of
promulgation
plus 1 2
months
State
Identify major sources subject to As needed
section 112(g).
MACT Delegation: Request delegation for all As needed
promulgated rules and MACT standards (at least for
Title V sources) unless no sources exist in state.
Date of state
adoption plus
30 days
State
State
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
E. Sfintinn 1 17(11: Make requests for section 112(1) As needed State
approval as appropriate. Communicate with Region
VIII to indicate whether section 1 1 2(1) applications
will be submitted, when, and the nature of the
application.
Identify sources in the State subject to MACT As needed
Date
of
State
standards as promulgated.
proposal
plus
60 days
Notify sources subject to a promulgated MACT. As needed
Date
of
State
proposal
plus
60 days
G. Collect data for case-by-case data base. Assume As needed State
responsibility for data entry and adhere to QA/QC
protocol and timely updates to data base.
MACT Interim FnfnrnnmHnf Implement and enforce
promulgated MACT standards to the extent state
authority will allow until delegation and adoption
have occurred.
As needed
Upon MACT
promulgation
State
J.
Maintain data base.
Receive and track initial notification forms for
MACT standards which have been promulgated by
the State.
As needed
As needed
Upon MACT
promulgation
State
State
POLLUTION PREVENTION
2.0
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
Develop and submit a strategy to integrate P2 into
State air regulatory and non-regulatory activities,
including:
1. Train staff in P2 applicability to CAA programs and
legal guidelines for encouraging P2 implementation
at air pollution sources as available.
2. Relocate the Small Business Technical and
Environmental Compliance Assistance Program
(SBAP) to the Planning, Prevention and Assistance
Division's Pollution Prevention Bureau.
Ongoing
Ongoing
State
State
3. Conduct outreach to industry on available P2
techniques and options.
4. Incorporate P2 into regulatory activities such as
state MACT standards, VOC BACT, enforcement
activities as identified above. Supplemental
Environmental Projects (SEPs), permitting, SIPs as
identified above, and others.
Ongoing
Ongoing
State/EPA
State
PROGRAM ADMINISTRATION
-------
MONTANA FY97 SEA
AIR PROGRAM
(October 1, 1996 through June 30, 1997)
Prepared November 18, 1996, @ 2:42pm
FILENAME = = = > MTSEA1.97
DUE STATE STATE EPA
ACTIVITY/OUTPUT MILESTONES DATES FTE DOLLARS DOLLARS AGENCY
COMMENTS
A. Personnel Management EPA
B. Program Administration State/EPA
C. Legislative Liaison State
D. EPA Liaison EPA
E. County Program Oversight State
F. Training State/EPA
G. Program Resource Improvement Strategy State/EPA
H. Legal Support
g TOTALS $812,212
* Carried over from last year's SEA
Total dollars are best estimates
based upon legislative
authorizations and estimated
105 Grant. State dollars are
subject to change through
executive and legislative
actions and federal dollars may
also fluctuate.
-------
MONTANA RCRA HAZARDOUS WASTE PROGRAM
NARRATIVE FOR FISCAL YEAR 1997
INTRODUCTION
This narrative and the attached tables make up the RCRA Subtitle C Hazardous Waste
Program portion of the Annual State-EPA Agreement (SEA) for the DEQ. The SEA addresses
all major elements of the state program.
FY 97 will continue to be a transition year for DEQ moving the RCRA-C Program from an
emphasis on performing and measuring activities (e.g., number of permits processed, number
of enforcement actions taken) to an emphasis on environmental results (e.g., number of
corrective action sites with environmental pathways controlled).
The FY 97 SEA is composed of two parts as in the past: a narrative and a work plan. The
narrative describes DEQ activities in areas that EPA has identified as a high priority for all
programs which EPA supports through grants. These priority areas are: 1) environmental
indicators and measures; 2) Common Sense Initiative; 3) community based programs and; 4)
small businesses/community initiatives. The narrative is specific to RCRA and describes
DEQ's plans for each of these subjects. In addition, the narrative addresses what DEQ is
doing to maintain a strong core program in accord with the Authorization Agreements with
EPA.
PART 1: NARRATIVE FOR INITIATIVES AND CORE PROGRAM
A. EPA/State Initiatives
1. Environmental Indicators/Measures
To address the Environmental Indicators Initiative, DEQ will continue to use the corrective
action measures which are a part of the SEA work plan table. The mechanism used to measure
this program activity is RCRIS data. DEQ will also continue to develop and define additional
environmental indicators so that baseline data for future comparison can be developed. In
addition, DEQ will continue to evaluate and where appropriate define other environmental
measures for the non-permitted universe of handlers.
During FY 96, DEQ defined certain quantitative measurements which may be useful in
evaluating overall environmental quality and the relative success of maintaining the quality of
the environment. The indicators defined are: total hazardous waste generated; recurring versus
one time hazardous waste generated; hazardous waste generated by generator classification;
recurring hazardous waste by waste code; and hazardous waste diverted from land disposal.
During FY 97, these potential indicators will be evaluated to determine their usefulness in
measuring environmental quality.
-------
2. EPA's Enforcement and Compliance Initiative
The U.S. EPA Office of Enforcement and Compliance Assurance (OECA) has identified the
following industrial sectors for implementation of an enforcement and compliance initiative:
metal mining and nonferrous metals; coal fired power plants; agricultural practices; automotive
services; petroleum refining; and dry cleaning. The goal of the initiative is to identify areas of
noncompliance within each sector, and promote a high compliance rate through traditional
enforcement and an aggressive outreach program. The DEQ will implement the
comprehensive evaluation component of this initiative. Specific activities for this initiative
may be found in the attached "EPA's Enforcement and Compliance Assurance Work Plan."
In FY96, DEQ selected certain industrial sectors and focus areas which were applied to the
state's hazardous waste "common sense" initiative. The four areas selected were: petroleum
refining waste; wastes sent to combustion; waste solvents and non-ferrous smelting waste.
DEQ intends to maintain these sectors/focus areas for scheduling compliance monitoring
activities for two main reasons. First, these sectors/areas appear to be amenable for expanded
pollution prevention activities; and secondly, these sectors/areas overlap the sectors identified
in EPA's Enforcement and Compliance Initiative.
3. Community Based Efforts
In FY 97, DEQ will develop and implement the Billings Metropolitan Geographic Initiative.
This community based intiative will focus on identifying the level of compliance with
hazardous waste management regulations in the Billings area. The initiative will consist
principally of increased inspections of non-notifiers to determine if there is a disproportionate
level of non- compliance in this geographical region. If determined appropriate, the DEQ will
initiate
community outreach activities with an emphasis on the use of mass media to provide
compliance assistance.
4. Small Business/Community Initiatives
DEQ will continue to employ traditional outreach activities to enhance compliance by the
regulated community. These activities include:
~Ongoing response to requests for clarification of regulatory requirements;
~Participation in seminars and workshops sponsored by such organizations as the DEQ
Small Business Assistance Program, trade associations, and the Montana Pollution
Prevention program;
~Revision of the manual titled "The Small Business Handbook for Managing
Hazardous Waste" and offering the publication to interested parties on an ongoing
basis.
During FY96, DEQ initiated formal contact with the three largest chemical distributors in the
state and two major hazardous waste service firms. It was found that all of these private firms
-------
are proactive in providing technical and general compliance assistance to their customers. The
firms distribute program publications and refer clients to the DEQ for compliance assistance on
a routine basis. For FY 97, DEQ will continue to maintain lines of communication with these
private firms. In addition, publications produced or acquired will be offered to these firms who
then may distribute the material to their customers.
A bibliography of publications pertaining to waste minimization and pollution prevention has
been developed. That bibliography has been provided to all large generators and facilities.
During FY 97, as new publications dealing with waste minimization and pollution prevention
are placed in DEQ's library, the bibliography will be updated. If significant addition are made
to the library, the regulated community will be advised of the additions.
B. Core Program
1. RIPFLEX
In FY 97, DEQ expects to continue to shift some of its resources to corrective action
activities. This shift will coincide with state authorization for this program element and the
final issuance of pending post-closure permits.
2. Program Management
The total resources for implementation of hazardous waste waste management provisions are
distributed over nine program element areas. As illustrated in the attached budget summary
table, 13 percent of total resources (in terms of both FTE and budget) are allocated for
program management. Approximately 15 percent of resources are allotted for data
management. Post-closure and operating permit activities will expend about 17 percent of
resources and corrective action activities will use an additional 17 percent. About 17 percent
of resources are budgeted for compliance monitoring. About 11 percent of resources have
been apportioned for enforcement activities. Approximately 2 percent of resources have been
designated for waste minimization. State authorization has been allotted 7 percent of the
budget.
DEQ and EPA will revise the Enforcement Agreement (EA) and Memorandum of Agreement
(MO A), if necessary. Proposed MO A revisions in FY 97 will include a transition strategy for
the transfer of the lead in corrective action activities.
DEQ and EPA agree to submit, at a minimum, those management reports included in the
program SEA table (i.e., mid and end of year written reports, with conference calls and status
checks as needed or appropriate).
3. Data Management (RCRIS)
-------
DEQ is committed to the use and maintenance of RCRIS as the hazardous waste management
planning and reporting mechanism. DEQ prefers to address the upcoming RCRIS upgrades
with direct assistance from Region VIII personnel. DEQ will continue to develop and
implement procedures to ensure timely and consistent entry of data to the national data base.
Recent changes in the RCRIS program have led to some difficulties in both data input and
extraction. DEQ personnel have relied primarily on telephone support for the resolution of
RCRIS problems, but require more opportunities to work in person with Region Vm on more
specialized report generation and technical understanding of the entered data.
4. Closure, Post-Closure
DEQ will participate in a joint State-EPA long-term strategy on Closure and Post-Closure,
with a focus on priority activities. DEQ has identified no new or remaining hazardous waste
management units that require closure. Closure plans for units already in the hazardous waste
management system have been called in and approved.
Post-closure permit authority will most likely be used to address the remaining management
units requiring post-closure care (all other units in post-closure care have received permits).
DEQ considers all post-closure facilities to be high priority and will continue to address the
remaining post-closure facilities. Issuance of these post-closure permits would allow the
allocation of resources to operating permits, compliance monitoring and corrective action.
Historically, many permit modifications for operating and post-closure permits have been
requested within a fiscal year. Such modification requests have required considerable effort to
process and may detract considerable amounts of resources from post-closure permit issuance.
DEQ will issue two major permit modification to two post closure permits in FY 97.
5. Operating Permits
DEQ will participate in joint State-EPA long-term strategy for operating permits, with a focus
on high priority activities. There are no remaining Part B applications that have yet to be
called in. There are no pending operating permit appeals or modification requests. DEQ has
begun preparations and discussions with Montana State University, Exxon, Conoco and
Burlington Northern-Paradise about re-issuance of their permits in 1998.
6. Corrective Action
DEQ is presently not authorized for the lead in facility wide corrective action. Authorization
is anticipated in the first quarter of FY 97. To help demonstrate capability, DEQ continues to
assist the EPA Montana Office in the review of documents associated with corrective action.
The Montana corrective action universe of facilities actively engaged in site investigation or
cleanup is comprised of four petroleum refineries, an air force base, a pesticide formulator and
a former wood preserving site. A fourth petroleum refinery permit is currently under appeal.
-------
Prioritization of corrective action is through the use of NCAPS and the annotated facility
management plan. All high priority sites are being addressed by EPA or State authority.
If DEQ is authorized for corrective action in FY 97, it is anticipated that considerable work
sharing with EPA on corrective action sites will occur. As clarified in the MOA, it is
expected that the EPA Montana Office will retain the lead for those facilities already issued
HSWA permits or 3008(h) order and DEQ will assume the lead for these facilities after
significant milestones (i.e., after interim measures are implemented or RFI investigations are
completed). DEQ will have the lead on any new facilities issued permits under HSWA
authority after corrective action authorization.
EPA approaches corrective action oversight in a tiered fashion in Montana. Facilities receive
intensive oversight during the development of work plans, reports, selection of risk assessment
assumptions and the selection of interim measures or corrective measures. Less intensive
oversight is used during data collection and analysis due to limited EPA resources. DEQ will
approach corrective action oversight in the same fashion.
All sites requiring stabilization have been evaluated and the interim ground water control
mechanism for the Cenex refinery will be selected by the end of FY 97. The Conoco Refinery
interim measure has been in operation for over a year. EPA has required facilities with off-
site releases to evaluate the need for interim measures upon initiation of RFI activities.
7. Compliance Monitoring
Because compliance with permit conditions is considered to be essential in protecting public
health and environmental resources, DEQ will conduct at least one compliance evaluation
inspection at each permitted TSDF. The results of those inspections will used to determine if
additional inspections are warranted.
Other handlers will be selected for compliance evaluation inspections based upon a handler's
compliance history, knowledge of the waste streams generated, an evaluation of a handler's
environmental setting, and the length of time that has transpired from the last inspection.
For handlers who have notified of their waste management activities, an evaluation of annual
reports, past inspection reports, RCRIS data, and information from notification forms will
assist in selecting inspection candidates. Generators who have a history of serious violations
or a large number of violations are candidates for inspection. Generators who produce large
quantities of waste or who produce a waste that offers a high risk of environmental or public
health damage if mismanaged are also inspection candidates. Generators who are not served
by public utilities or who are otherwise located in environmentally sensitive areas may be
considered for inspection. Handlers who have not been inspected in the last three years are
also inspection candidates, especially if they meet any of the aforementioned criteria.
Non-notifier candidates are selected by the applying knowledge of hazardous waste generation
that is typical for the industry, by evaluating a handler's physical setting as it relates to
-------
sensitive environmental resources and waste management challenges, considering the size of
the business, and considering any allegations of improper waste management received by the
program.
DEQ is committed to providing compliance assistance to the regulated community at every
possible opportunity. Compliance assistance will be provided during inspections, during
workshops or other outreach efforts, and during daily communication with affected handlers.
Development, maintenance and distribution of compliance assistance materials will continue
to be a priority for the program.
The implementation of an established inspection plan could be affected by a reallocation or
reduction in staff resources. In such a case, priority will be placed in selecting inspection
candidates that offer the greatest potential to adversely affect public health or the environment.
8. Enforcement
DEQ uses RCRIS to project and track enforcement actions.
A revised Cooperative Enforcement Agreement has been drafted which incorporates the
provisions of Enforcement Response Policy. DEQ will consider the provisions of the revised
Supplemental Environmental Projects Policy, the Small Business Policy and the Small
Community Policy in enforcement actions where applicable and appropriate.
9. State Authorization
DEQ will submit the draft RCRA 4 and 5 authorization revision applications during FY 97.
Alternatively, DEQ may submit a draft comprehensive authorization package consisting of the
HSWA 2 through RCRA 6 clusters in FY 97. No format or substantive changes in the MO A
or other instruments, other than the aforementioned corrective action transition strategy, have
been identified. Should such changes be identified, they will be addressed.
Authorization for Non HSWA 5 and HSWA 1 clusters is anticipated in the first quarter of FY
97.
10. EPA's Role/State Oversight
DEQ will accommodate EPA's evaluation of the state's closure/post-closure, permit and
corrective action programs by sharing the program's work products with the EPA prior to final
decision. DEQ will take comments received from these evaluations under advisement. DEQ
will provide copies of all formal enforcement actions to EPA at the time when the action is
taken against the owner/operator.
-------
DEQ has continued to identify training and technical assistance as areas where assistance from
EPA is needed. Training is needed in vital areas such as RCRIS management, risk assessment
and remediation technology selection.
PART 2: WORK PLAN AND BUDGET TABLES
Attached are the tables which summarize DEQ's work plan and budget.
-------
Attachment 1
FY 1997 HAZARDOUS WASTE PROGRAM
WORK PLAN FOR MONTANA DEQ
Lead Agency/
Project Manager
Quarter
Activity
Facility, ID#
(if applicable)
sched
Actual
Comment
I.
PROGRAM MANAGEMENT
A. Revise State-EPA Enforcement Agreement, if necessary
(list changes which will be made)
S/Vidrine
4
n.
AUTHORIZATION OF STATE PROGRAMS
A. List of planned authorization submittals (cluster and quarter)
Draft RCRA 4
Draft RCRA 5
Draft RCRA 6
S/Hall
S/Hall
S/Hall
1
1
4
B. Publish Federal Register Notice of Decision(s) list notices and
quarter targeted for publication
Non HSWA 5
HSWA 1
C. Revise MOA as necessary - HSWA 1 cluster
E/Finke
E/Finke
S/Hall
1
3
1
-------
Lead Agency/
Project Manager
Quarter
Activity
Facility, ED#
(if applicable)
sched
Actual
Comment
HI. OVERSIGHT OF STATE PROGRAMS (EPA lead)
A. Monitor State Performance (identify only those options that apply)
1. Conduct FY 96 End-of-Year Review E/Finke
2. Conduct FY 97 Mid-Year Review E/Finke
3. State Submittals (status reports, etc.)
4. Indicate if the RCRIS reports should be substituted for U\, #2, or #3 above (circle one)
1
3
-------
Lead Agency/
Project Manager
Quarter
Activity
Facility, n)#
(if applicable)
sched
Actual
Comment
IV. CLOSURE AND POST CLOSURE
A.
Closure Plan Approvals (list
facility name, ID#, and
units)
CL360
None pending
B.
Closure Certifications (facilities
certifying that closure
activities were completed
under approved closure plan -
list facility name and ID#)
CL370
None pending
c.
Closure Verifications
(determinations by the
authorized agency that the
approved closure plan has
been completed - list
facility name and ID#)
CL380
None pending
D.
Final Post-Closure Permit
Determination/Issuance
(list facility name, ID#, and
units)
Conoco Refinery
MTD006229405
Flying J
Refinery
MTD002076370
Montana
Refining Co.
MTD000475194
S/Holmes
S/Heckengerger
S/Heckenberger
1
2
1
PC200
Extension of FY
96 Commitment.
PC200
-------
Activity
Facifityf IDH
(if applicable)
Lead Agency/
Project Manager
Quarter
Comment
sched Actual
OPERATING PERMITS
A. Permit Final Determination
(issuance/denials list
facility name, ID#, and
units, if applicable)
OP200
None pending
B. Permit Modification Activities
(list/report majors mods
only)
BN Paradise
MTD000716787
BN Somers
MTD053038386
S/Phillips
S/Holmes
2
3
OP240
Approve CAMU
OP240
Shorten PC
period
C. Five-Year, Ten-Year Permit Reviews and
Renewal Determinations (list high
priority sites only)
OP200
-------
Activity
Facility, ID#
(if applicable)
Lead Agency/
Project Manager
Quarter
Comment
sched Actual
D. Miscellaneous Activities (e.g., combustion,
no migration petitions, emergency permits,
waivers, etc.)
None pending
VI. CORRECTIVE ACTION
A. Assessments - RFAs, PA+s
(list facility name, ID#, and
activity)
CA050
None pending
B. NCAPS Rankings Completed (list all
sites that have not been ranked
and indicate quarter and year
that ranking will be done)
CA075
-------
Activity
Facility, ID#
(if applicable)
Lead Agency/
Project Manager
Quarter
Comment
sched
Actual
C. Stage I (RFI) activities (list facility
Flying J
E/Zazzall
4
name, ID#, and activity)
Refinery
(Heckenberger)
MTD002076370
RFI WP Approval
4
MRC schedule
Montana Refining
E/Wallace
subject to change
Co. MTD000475194
(Heckenberger)
if permit
RFI WP Approval
3
appealed
Transbas
MTD079711198
S/Phillips
CA200
RFI Rpt Approval
(Zazzali)
2
Malmstrom AFB
E/Zazzall
CA200
MT8571924556
(Heckenberger)
RFI Phase II Rpt
4
Approval
CA200
Exxon Billings
E/Wallace
Refinery
(Holmes)
MTD010380574
2
RFI Phase II
Report Approval
CA200
E/Wallace
Conoco Billings
(Holmes)
3
Refinery
MTD006229405
CA200
RFI Rpt Approval
E/Zazzali
(Holmes)
Cenex Laurel
Refinery
MTD006238083
RFI Phase II Rpt
Annroval
-------
Activity
Facility, ED#
(if applicable)
Lead Agency/
Project Manager
Quarter
Comment
sched
Actual
D. Stage II (CMS) activities (list
facility name, ID#, activity)
BN Paradise
MTD000716787
CMS WP Approval
Malmstrom Air
Force Base
MT8571924556
CMS Report
Approval
Conoco Billings
Refinery
MTD006229405
CMS Workplan
Approval
BN Paradise
MTD000716787
CMS Report
Approval
E/Wallace
(Phillips)
E/Zazzali
(Heckenberger)
E/Wallace
(Holmes)
E/Wallace
(Phillips)
2
3
4
4
E. Stage HI (CMI) activities (list
Malmstrom AFB
E/Zazzali
1
CA550
facility name, ID#,
MT8S71924556
(Heckenberger)
PCB and Wherry
activity)
CMI
Housing SWMUs
Implemented,
initial
E/Zazzali
4
CA550
(Heckenberger)
(subsequent)
Malmstrom AFB
Remaining SWMUs
MT8571924556
CMI
Implemented,
subsequent
-------
Activity
Facility, ID#
(if applicable)
Lead Agency/
Project Manager
Quarter
Comment
sched Actual
F. TSDFs evaluated for Stabilization (list
only sites still needing an
evaluation and indicate when
they will be evaluated)
CA225
None
G. TSDFs with stabilization/interim measures
implemented (list facility name,
ID#, measures, and
mechanism)
CA650
-------
fO
in
Lead Agency/
Project Manager
Quarter
Activity
Facility, ID#
(if applicable)
scbed
Actual
Comment
H. Environmental Indicators of Corrective
Action Results
1. Determinations of
Current Human Exposures
Under Control (list
facility name, and ID#)
CA725
None pending
2. Determinations of
Ground Water Releases
Under Control (list
facility name and ID#)
Conoco Billings
Refinery
MTD006229405 IM
Implementation
Wallace /
Holmes
1
-------
VII. COMPLIANCE MONITORING
A. Inspections of Treatment, Storag
e and Disposal Facilities:
Priority
Incinerators
BIFS
L.DFS
TSFs
Gen
FF
Trans.
Non-Notifier
Total
T
A
T
A
T
A
T
A
T
A
T
A
T
A
T
A
T
A
Community-Based: Billings
Metro Geographic Initiative
12
Sectors Gist sectors)
Petroleum Refineries
Combustibles (Mines, Heavy
Equipment Repair)
Waste Solvents (Dry
Cleaners, Auto Repair)
Non-Ferrous Smelters
2
2
1
1
1
1
5
Other Priorities
2
1
B. EPA Oversight Inspections - list facility name and ID#
-------
Activity
Facility, ID#
Action Taken
Quarter
VIII. ENFORCEMENT
A.
Formal Administrative Enforcement Actions
(report only) Gist each facility and action taken)
As needed.
B.
Formal Judicial Enforcement Actions - referrals
to State Attorney General (report only) (list
facility and action taken)
As needed.
C.
Compliance Assistance/Outreach specify
projects, sectors, programs
Leverage the Role of the Private Sector
See narrative
on-
going
Integrate Pollution Prevention into all
Program Activities
See narrative
on-
-------
Activity
Facility, ID#
Action Taken
Quarter
IX. Building State Capability, Technical
Assistance, Training (list specific
activities, projects, etc. below)
Risk Assessment
RFI/CMS Training
Remedial Technology Selection
RCRJS Training
Subpart CC Training
LDR Training
Community Involvement Training for
corrective action
-------
FISCAL YEAR 1997 (10/1/96-6/30/971
UNDERGROUND STORAGE TANK PROGRAM WORK PLAN
Note: This workplan covers 3 quarters to accommodate a switch from the Federal to the State fiscal year. The first quarter activities in the workplan below were completed under the
4th quarter of Federal fiscal year 1996.
Activity/Output
Underground Storage Tanks
Quarterly
Milestones
Work years
Dollars
Responsible
Agency
1
2
3
4
State
EPA
State
EPA
I. UST Program Development and Implementation
A. Implement UST operation and management rules.
Ongoing
.1
DEQ
B. Implement program for UST installer permits.
Permits are required whenever an UST is installed,
modified, repaired, or closed.
Ongoing
.1
DEQ
C. Implement UST installer/inspector licensing
program.
Ongoing
.07
DEQ
D. Maintain State funding mechanism.
1. Evaluate self-funding options; brief report.
Ongoing
Draft
Final
.05
DEQ
E. Apply for FY 98 UST assistance.
Negotiate FY 98 UST SEA workplan.
6/97
.05
.03
DEQ
F. Update UST notification data base.
Ongoing
.2
DEQ
G. Provide timely compliance assistance (pamphlets
and other information) to 0/0 for release detection,
financial responsibility, and 1998 upgrade
requirements.
1. Outline 1998 deadline strategy/approach; brief
report.
Ongoing or as needed and requested
Draft Final
.2
DEQ
H. Obtain technical assistance/training for LGUs,
Tribal, and state staff.
As required
.05
.01
DEQ/EPA
I. Provide technical assistance/training to local and
Tribal program implementation staff.
Ongoing
.1
.01
-------
Activi ty/Output
Quarterly
Milestones
Work years
Dollars
Responsible
Agency
Underground Storage Tanks
1
2
3
4
State
EPA
State
EPA
J.
Exchange RCRA regulated UST facility information
for Indian Reservations in an effort to keep DEQ and
EPA data bases current.
Ongoing
.08
.02
DEQ/EPA
K.
Report quarterly (STARS) on 10th day following
mid-year and end-of-year.
Ongoing
.1
DEQ
L.
Work with EPA on transfer of data from UST/DMS
to replacement data base.
1. Work with EPA to develop communications link
to share database information.
As needed
.25
.03
DEQ/EPA
II. Compliance, Monitoring and Enforcement
A.
Identify, document, investigate and attempt to
resolve violations of state and federal rules with
emphasis on leak detection violations.
As required
.25
DEQ
B.
Develop and maintain an enforcement tracking
system that incorporates a prioritization of
enforcement cases, and tracks all violations from
discovery to resolution.
1
1
1
.2
DEQ
C.
Meet monthly to discuss enforcement cases with
EPA, assess progress, consider enforcement
alternatives, and refer cases to EPA as appropriate.
.05
.02
DEQ/EPA
D.
Notify EPA of all violations of federal regulations
involving USTs on Indian Reservations within 10
days of discovery by MDHES.
.05
DEQ/EPA
E.
Advise and educate regulated community regarding
compliance alternatives.
2
2
2
.15
-------
Activity/Output
Quarterly
Milestones
Work years
Dollars
Responsible
Agency
Underground Storage Tanks
1
2
3
4
State
EPA
State
EPA
F. Conduct UST compliance inspections
1. Develop and implement an inspection and self-
certification plan designed to assure that each
operating UST facility has been assessed for
compliance at least once every 5 years.
2. Issue press releases of inspection results to
assure regulated community is aware of
enforcement presence.
3. Emphasize 1998 upgrade requirements during
each inspection. Provide outreach materials on
1998 upgrade requirements.
15
2
15
2
15
2
.4
DEQ
G. Conduct joint UST compliance inspections with EPA
emphasizing leak detection enforcement.
10
.1
.02
DEQ/EPA
H. Develop and implement administrative penalties
program (field citations).
.4
DEQ
I. Encourage State/EPA coordinated planning and
decision making regarding potential and actual
multimedia enforcement cases (Focus on Federal
facilities).
As appropriate
.05
DEQ/EPA
III. Oversight
A. Advise/assist with UST Program Development.
Ongoing
.01
EPA
B. Refer inquiries, complaints to State.
As needed
.01
EPA
C. Assist State with implementation of State Program.
As needed
.01
EPA
D. Assist State with leak detection compliance
monitoring enforcement efforts, and 1998 upgrade
requirements.
As needed
.01
EPA
E. Provide training/secure training opportunities for
State staff.
As needed
.01
EPA
Total
3.00
0.19
$40,625
$121,875
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FISCAL YEAR 1997 (10/1/96-6/30/97)
LEAKING UNDERGROUND STORAGE TANK PROGRAM WORK PLAN
Note: This workplan covers 3 quarters to accommodate a switch from the Federal to the State fiscal year. The first quarter activities in the workplan below were completed under the
4th quarter of Federal fiscal year 1996.
Activity/Output
Quarterly
Milestones
Work
years
Dollars
Responsible
Agency
LEAKING UNDERGROUND STORAGE TANKS
TRUST FUND
1
2
3
4
State
EPA
State
EPA
I. LUST Trust Fund Implementation
A.
Submit FY 98 LUST Cooperative Agreement
application.
Negotiate FY 98 LUST Cooperative Agreement
workplan.
9/96
.1
.02
MDEQ/EPA
B.
Provide training/technical assistance for regulated
community, affected industry, LGU's, and Tribes in
corrective action procedures.
.1
.02
MDEQ/EPA
C.
Maintain corrective action status tracking system in
UST/DMS, and in UST Access.
Ongoing
.6
MDEQ
D.
Implement the following core elements of corrective
actions:
1. Conduct site investigations.
As appriopriate
.25
MDEQ
2. Direct and manage LUST Trust contractors.
Ongoing
.75
3. Conduct corrective action plan review.
Ongoing
.75
.02
MDEQ
4. Initiate cost recovery actions.
As appropriate
.75
MDEQ
E.
Report quarterly (STARS) on 10th day following
mid-year and end-of-year.
1
1
.1
MDEQ
F.
Conduct corrective action streamlining efforts.
Ongoing
.1
MDEQ
G.
Promote alternative remediation technologies.
Ongoing
.1
.02
MDEQ/EPA
H.
Exchange RCRA regulated LUST facility information
as requested in an effort to keep MDEQ and EPA
data bases current.
Ongoing
.1
.02
-------
Activity/Output
LEAKING UNDERGROUND STORAGE TANKS
TRUST FUND
Quarterly
Milestones
Work years
Dollars
Responsible
Agency
1
2
3
4
State
EPA
State
EPA
1. Notify MDEQ/EPA of all RCRA regulated
LUSTs on Indian Reservations within 10
days of discovery. Provide corrective action
status of LUST facilities upon request.
Ongoing
.05
.02
MDEQ/EPA
I. Work with EPA on transfer of data from UST/DMS
to UST Access.
As
needed
.05
.02
MDEQ/EPA
J. Develop a RBCA or RBCA alternative approach for
setting site-specific cleanup goals.
1. Establish workgroup to meet on a regular
basis.
2. Draft plan with workgroup assistance.
.2
II. Oversight
A. Conduct joint LUST Trust site investigations.
.02
EPA
B. Provide technical assistance.
.02
EPA
C. Provide training.
.01
EPA
Total
4.00
0.19
$26,498
5688,482
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